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b/marker2/ds9/EFTA00083270/EFTA00083270.md @@ -0,0 +1,946 @@ +Edited on June 21, 2018 + +This was sent to all investigative offices in Massachusetts many times about a cocaine trafficker and child predator the police do dose business with. I am editing this document on July 3, 2020 to remove some information as I would like to solely confine it to Mr. O'Connell. I had questioned why LE and this group of police rarely investigates or arrests the wealthy white drug dealers, including O'Connell and his male family members, and why these troopers and politicians do business with him. + +A man with a sordid past who seems to have mimicked the actions of predator Jeffrey Epstein, actions such as having females bring his child victims to him for sex. + +DEVAL L PATRICK + +ooventroR + +MARY ELIZABETH HEFFERNAN SECRETARY + +COLONEL MARIAN J. McGOVERN SUOERWIENDINT + +> TO: Captain FROM: Trooper #2791 SUBJECT: Summary of Facts CASE NUMBER: 2011-112-0112/ Relative to aSexual Assault - Quincy + +Canton, MA 02021 + +I. The following is a preliminary report and does not contain all information relative to this criminal investigation. + +2. After making an initial disclosure of asexual relationship with an older man to a friend, a female juvenile known to the commonwealth went to the Norfolk Advocates for Children in Foxboro on Wednesday, March 30, 2011 and had aSAIN (Sexual Assault Intervention Network) interview. During the interview, this female juvenile provided astatement alleging that she had been having asexual relationship with a72 year old white male. During her interview, the juvenile stated that she was introduced to the man in the spring or summer of 2009 when she was 14years old through awoman friend of hers by the name of Phyllis Capuano, a.k.a. "Kookie". Prior to the juvenile's arrival at the man's Quincy, MA residence, it was explained to the juvenile by Capuano that the male would provide payment for sex. The juvenile described in detail how she and Capuano in front of the man to include + +You see, Bill O'Connell was arrested and convicted of cocaine trafficking, but this arrest came only because a fourteen year old girl accused him of raping her for one year. They had to arrest him and he had many grams of cocaine on him when arrested. + +Can anyone tell me when one of these top wealthy dealers was arrested in MA ? They aren't and in some cases they are even protected ! It also appears to me that one cop tied to him hacked this document to delete information on it. I also found some of the below Ebay accounts appear to have been canceled and reissued by a random person. This hides who the original owner of that account was and hides the cops ties to O'Connell. + +Ebay accounts are used to pass money via Paypal and these cops have transactions with O'Connell. Below is one woman who pimped the child out for money and gifts. + +Everett woman as his co-conspirator in one of the incidents. + +![](_page_2_Picture_2.jpeg) + +Phyllis Capuano. 21, has been indicted on charges that stem from several alleged statutory rapes of a now 15-yearold girl over a two-year period — SitterCity corn + +A grand jury returned a total of 17 indictments Monday against William S. O'Connell, 71, and Phyllis Capuano, 21, on charges that stem from several alleged statutory rapes of a now 1S-year-old girl over a two-year period. + +O'Connell faces four counts of statutory rape, each of which stem from separate incidents. Capuano's charges stem from one of those incidents, which are alleged to have taken place between June and September of 2009. + +O'Connell was indicted on 12 charges; Capuano on five. + +Both are charged with committing statutory rape in the 2009 incident, as well as conspiring with and aiding the other + +Guess what happened to this young victim of this wealthy and influential man who is closely tied to politicians and these MA troopers? + +She just happened to be killed in a "fiery crash" one week before his trial was to begin sp he got off many child rape charges, and she is one reason I created this document. + +www.heraldnews.com artrcle NEWS • + +Alleged victim in O'Connell case 'haunted' to the end - News - The -.- + +Rebecca Resendez, the alleged victim in the statutory rape case against Quincy developer + +William O'Connell, was killed in a fiery car crash early Tuesday . . + +His name is Wm O'Connell and he is a part of this donor 'Enterprise'. He's another who wants me silenced. Me and many others feel this influential pedophile needs to be investigated, including the child's sudden death. + +Has O'Connell ever communicated with Jeff Epstein? I cannot confirm whether he did or not, but you will find some eerie similarities within these documents. I know he drove his yacht to the Carribean, but I don't know if that was to visit Epstein's island, and I know this group has ties to the wealthy in Manhattan who were arrested for paying bribes to NYPD. But today I found they have accounts using the name of Ghislaine and appear they may be tied to the Granite Reality-Realty Group who claim to own her home. Below you can see a few tied to Bill O'Connell, but there are many more than that, and the BNEG nightclub owners have over one hundred realty companies they silently control and own. (Many tied to Seaport where Granite is located) + +In September, William was arraigned in Norfolk Superior Court on charges including four counts of statutory rape, one count of cocaine trafficking, and two counts of committing an unnatural and lascivious act with a child under i6. Statutory rape convictions carry a minimum sentence of to years per charge. (William pleaded not guilty to all charges.) He retains a prominent role in three other development corporations — O'Connell Denver Properties Inc., Seaport Aviation Inc., and Seaview Real Estate Inc. — and, pending trial, is allowed to travel to Florida, Colorado, and New York for business, though he must submit to regular drug screenings and cannot + +As soon as I heard the name Granite Reality and McClellen & Fish, I began checking into them. I did this because for many years I've sent in their extensive billion dollar hidden real estate, the many real estate companies and investment companies owned by these police and nightclub owners, and their online mortgage and loan companies. (They have many straw buyers but they silently own and control them). + +Aside from that, I've found almost one billion in nonprofits they own using fictitious names and tied to these law firms, so I may have found a connection. If they are connected to Epstein and Ghislaine, it would be this underground group who placed her in that home. (see below) + +I found more information on the above than I thought I would, and my new document titled Epstein, Ghislaine, and O'Connell ties is below. Harboring a fugitive? This document was added on 7-5-2o2o. + +Ghislaine Maxwell and her MA-NH ties... + +https://docs.google.com/document/d/1DILdQv9FMJFM -qe-SyJsvr4Yp8006sDgliOZ3 zDwhc/edit?usp=sharing + +If you send this document back to Massachusetts nothing will happen to him. I've tried and I received nothing but more abuse from the corrupt police who support him. They all protect one another and you will see why if you view my other documents. + +This group chose to surveil and chase me around state to state and year after year all in a bid to silence this information, yet hidden under the guise of a legitimate investigation. Over ten years straight and still no charges. Why? Because they are really doing this to watch me with hopes of protecting the wealthy I've been reporting, and I've sent ample proof showing this over the last eight years. + +A crime is investigated and not a person. You don't investigate a person to wait for them to commit a crime, so what crime did I commit twenty years ago when this began and just after I divorced a trooper who has always stalked me? There can't be a different interpretation of law for the wealthy and the common man. From day one, MA law enforcement has been trying to bail out the corrupted troopers and wealthy committing crimes, as well as the police's heinous and blatant corruption, but chasing me around with hopes of silencing me. Aside from that, how come they're not investigating the troopers stolen overtime ten years back? Why only one year ago when most people know all of them didn't begin this one year ago. + +It's to let them off easy, because they're probably stealing \$15,000 yearly. For those of you who don't know, one hundred MA State Troopers have been arrested since 2010, forty six of them arrested or implicated for stealing overtime while forging tickets. The Feds also just arrested the head of the MSP union, Dana Pullman. + +The MSP hired Leigha Genduso years ago, an admitted drug dealer, perjurer, and money launderer, with her past criminal actions and acceptance on the force tying into all I've reported since 2010! Below is a story on the MSP hiring Leigha Genduso who had a long term relationship with a LT Colonel! That's okay with them providing she doesn't report their corruption as I do. + +http://www.bostonherald.com/news/columnists/howie can/2018/02/carr life of cri me you can be a trooper + +So think about it, over 20 years chasing me around, but just as many years working for and with the below wealthy man (Wm. O'Connell) who was arrested for child rape and cocaine trafficking. This child was killed one week before her trial was to begin so he got off, but the MSP swamp isn't looking his way because I'm much more important to them. + +O'Connell is tied to the BNEG Nightclub and restaurant group which Joe and Ed Kane own. He's also closely tied to the MA politicians who still do business with him. BNEG has a brother who is a SGT on the MA State Police named Charlie Kane who I personally know and socialised with. + +This wealthy and influential group, including rapist and cocaine trafficker O'Connell, appear to have their own private police force protecting them and the same force after me. O'Connell is one of the Kanes top guys and below you'll see how they do business together. He's bad news and so is this group of rogue troopers. The only folks who don't believe he was involved in the child's death are his friends and these troopers. + +Below, you'll also read about the corrupt attorneys who work with the troopers. + +This document is about the little girl and the wealthy man whose family seems to avoid jail time, avoids thorough investigations, and scrutiny of his crimes due to his political affiliations and wealth. + +On April 15th, 2018 this document was sent to FBI offices outside Massachusetts, Washington DC, and several other people I felt would stand for this child and look into O'Connell and the child's death. I've sent it to Boston as well. (They have now retired) + +This document is to show who the members of this 'enterprise' of police are, including those MSP are loyal to, a wealthy child rapist and cocaine trafficker, while they harass me year after year and make up excuses why they are doing so. They've done this since I divorced their co-worker. + +O'Connell, is a man tied to a few 'untimely deaths', as well as rape and drug charges, including the death of his friend under his boat propellers, murders by others in his family, a woman killed and buried, his son shot a US Marine and only got seven months, and O'Connell is one who the MA authorities refuse to investigate or surveil. + +O'Connell was raping a child and arrested for cocaine trafficking, yet he's Trooper Charlie Kanes buddy who apparently knew about O'Connell and his child victims. (this is explained below). + +The question is why does L.E. refuse to do their jobs and investigate the many horrific crimes against women and children, MSP crimes against humanity, or the massive government fraud driven by greed taking place by MA police and attorneys? I've already done all the footwork, and have submitted their paper trail, so the rest should be simple. + +I've quoted this good male police officer in the past and I will quote him again today, because he can say in a few words what takes me thirty pages to say. He is one who knows what they've done to me since I separated. + +"THERE have long been whispers of prevalent sexual harassment in the law enforcement industry, but none have dared come forward with public disclosures. Given the exhaustive debates since the #MeToo campaign began, one would expect considered responses. Instead, it is dispiriting to witness many within the industry peddle the same tired tropes of shaming and blaming victims, and assumptions that sexual predators can be easily discerned. + +It is ignorant to pretend that conditioning and social pressures have no effect on victims' ability to speak out, that sexual harassment cannot intersect with other disputes, or that 'hard working family men' are precluded from scrutiny. Abuse of power in law enforcement is particularly insidious given that informal work conditions are taken by some as a licence to exploit. For better or worse, the public looks up to police who, as such, have a civic responsibility to send the right signals. Being called out is not enough. + +Sorely needed is an elected body of representatives and outsider experts to draw up a code of conduct and audit productions. Amending harassment legislation to grant the federal ombudsperson suo motu powers to investigate and arbitrate such claims would also show that harassment in any quarter will not be tolerated and will be followed by serious sanctions. For too long, in the absence of accountability and + +restorative justice, women's experiences of abusive men have either been hushed up or relegated to 'whisper networks'. The industry must make it clear that, when women do speak up, their voices will be heard." + +#### BILL O'CONNELL Both Protecting and Protected by the CORRUPT + +#### SOUTH SHORE SEX and DRUG KINGPIN + +My name is Lisa Kenney and for almost nine years I've been reporting abuses and corruption by several MA troopers who are seemingly involved with bank, grant, and healthcare fraud, connected to pharmaceutical companies, doing business with unethical attorneys, nightclub owners, and construction companies, and their obvious money laundering. + +I had been married to a trooper who I lived with for twenty years, and I dated one of the most corrupt and vindictive troopers mentioned below. I ended that 'friendship' due to his odd, vindictive, and egotistical behavior. His name is Troope + +It seems no one in Massachusetts wants to investigate this group and excuses are made up as to why they are not. "There isn't enough evidence" is said, although I've sent almost their entire paper trail on their laundering, federal grant fraud, real estate, and bank fraud which O'Connell is a part of. + +In order to get more evidence someone has to investigate and it's been proven MSP never investigated their own! I'm asking that this young rape victims sudden death be investigated because her sudden death is highly suspect, and the only folks who don't believe O'Connell was behind her death are the LE and politicians connected to him, those who accept his donations, and who are friends with him. + +O'Connell would pay multi millions of dollars for others to look the other way and he is one of the civilians funding the troopers on the side to try to silence me. I've received numerous death threats, rape threats, threat to be "shot in the face and head", and two separate men have tried to force me into a guard rail on the highway. I have submitted these plates in the past. (See my Denise Robert doc, a FBI unsolved murder) + +L.E. frequently asks the public for tips or help when crimes are committed and I've supplied a lot more than tips. These are excuses for an unwillingness to do their jobs or + +investigate their friends, either that or it's due to reelection issues. (As it turns out, it just may be and that document has recently been sent) + +People are being abused and there's hard evidence children and women have been raped and exploited, along with government grant money stolen. Today, I am focusing on the top wealthy civilians who the corrupt police and attorneys are loyal to and all are protecting one another. + +I've sent thirty or more letters on this to former Director James Comey of the FBI and the FBI in Massachusetts. No response from them, but I've received more abuses from the corrupt I've been reporting. + +Over the years I had been searching for a specific civilian who is tied to and heading this group with the nightclub owners Kanes of Big Night Entertainment (BNEG), and I believe I've now found him. + +Based on what I've found over the years, I allege this 'enterprise' is laundering millions of dollars offshore, including stolen federal grant money, and bringing it back in via real estate and mortgage/financial companies. The attorneys deal with the legal loopholes of this while the wealthy nightclub and business owners launder the money through their many companies. This information can be found on my BNEG and Donor Racket document. + +https://docs.google.com/document/d/1VYOZS37PeliAQOkbP75iivcxwg UOCDlytuMks Neh8/edit?usp=sharing + +Seven years ago, one of these police officers was online writing to the other police and he told them; + +"The person you REALLY work for drives his yacht to the Caribbean during the Winter, has an indoor swimming pool," and he gave a couple more hints as to who he was without giving his name. I believe they said he also owns a bakery but I'm not positive. + +Someone in their group deleted this statement just after I found it on a website where they frequently communicate with one another. This is the same site Trooper Charlie Kane was posting his own writings about me which I have sent in the past. Since they have been hacked into my pc for years (per Computer Forensics Associates of Boston), they see all of the information I am obtaining to send to you and delete any evidence I find. + +For those new to my documents, I've previously reported their use of online servers to conduct their business and Kane's distribute laptops to members of the enterprise. I've sent this information in the past and I've sent proof they're distributing laptops. In fact, during 2007, and once Trooper Manning was off probation from MSP, he kept sending me emails asking me to tell Trooper Kane he needs a laptop. Manning later hacked my emails and deleted that conversation so I couldn't submit it. The laptop info is shown on my lawyers and courts document. + +Based on their comments and other information, I've tried figuring out who this single wealthy person was for years, the "person they really work for" and I believe it is Quincy Developer Wm. O'Connell, the man mentioned above who was arrested for child rape and cocaine trafficking. + +O'Connell is good friends with Norfolk DA Mike Morrissey, Rep Bruce Ayers, the Kanes who own BNEG nightclubs, Senators Keenan, Keating, and Senator Brian Joyce, FX Messina, and several politicians including Delahunt. + +He's also described as one of the most powerful Massachusetts developers with strong political influence. Most of these politicians' names have already been mentioned in my many letters to show their ties to the corrupt police and unscrupulous attorneys. One being Braintree Attorney Kathleen Morrissey who you will read about below. + +Kathleen is tied to the Messina boys who violently drugged and raped my friend, they are more big donors to the DA's office who never charged them with the rape either. All of these wealthy 'donors' seem to get away with their many violent crimes. At the same time of her rape I found these troopers had pay transactions with the Messina boys who raped SK. (I was invited out with her and them that night but declined). The Messina's also want me silenced, and the last time I was in their section of MA, a couple of them followed me around. They're easy to spot because their license plates begin with FX. + +Due to his friendship, DA Mike Morrissey had to hire a special prosecutor for Wm. O'Connell for the rape and drug charges. I'd be curious to know if the fire which was in his office destroyed any information on the Messina rape. There was some backdoor settlement with my friend who probably thought it was normal court procedure, and it was probably Attorney Morrissey who scammed her to settle and protect the Messina boys. The Messina's are also connected to Wm. O'Connell. + +The two of them are also found entangled in the same drug treatment centers which troopers, lawyers, and some judges are silently running, including Judge Bibaud of the latest MA State Police scandal shown in the link below. + +http://www.wbur.orginews/ww/n/antrooper-lawsuit-edit-police-report + +MA keeps screaming for more "drug epidemic money", yet the major wealthy white drug dealers, one whom I believe to be Wm. O'Connell, his son, or his nephew, are NOT being watched or investigated! + +A little background on O'Connell is below and includes his arrest for child rape of He had nineteen grams of cocaine on him at the time of arrest. This is who the rogue MSP and politicians are loyal to. + +A couple of nights ago I found information tying him to these troopers and I found plenty of information which shows they were aware of his yearly rape relationship with this fourteen year old girl who he lavished with money and gifts for sex. + +They have registered plenty of shell corps and accounts using the fourteen year old girl's name, as well as the adult female named Capuano who pimped her out to O'Connell, a man who is in his seventies. They also used to run online `Sugar Daddy' websites which they were members of. It's possible he met Capuano through the troopers website? + +He's probably on the list of names of those who visited Jeff Epstein when he "drove his yacht to the Carribean". They do have Ghislaine Ebay accounts. Check them quickly, or they'll certainly contact their friends in the law enforcement section of Ebay to delete, alter , or have them reissued to a random person not tied to them! + +# rofile + +ghislaine55 (276 ) + +Positive Feedback (last 12 months): 100% 0 + +Member since: Dec-01-03 in United States + +I believe Capuano who pimped the child out has since run off to Brazil and they would give plenty of money to get rid of her. + +Don't think she's the only victim either, but she is the only one who had the courage to file charges against him, and yet, the police refuse to keep an eye on him. + +There is a child rapist running free and let's not fool ourselves to believe she will be his last victim. If MA doesn't care about protecting children I will find someone who does. Grave crimes are being committed against women and children with law enforcement not only looking the other way, but defending and protecting them. + +O'Connell has many million dollar homes in several locations with a few being Quincy, Marina Bay, Chappaquiddick, Florida, and I'm sure one of his many homes has an indoor swimming pool as the police had mentioned online. + +He does have a yacht and a forty-seven foot cigarette boat named `Thunder-Enlightening,' and I've provided a matching Ebay account with this same name which I believe is owned by a trooper and part of this enterprise. + +If he is paying them for services, women, children, court outcomes, or business favors, they'll pass money via Paypal & Ebay. This is also a way kickbacks and political donations are distributed between these cops and attorneys. I've collected twenty million of their transactions since 2010 SO I can identify them easily. + +As you can see below, the account using his boat name holds 226 transactions and these will be transactions connected to O'Connell and the police ties to him. The transactions could be tied to his construction co, his nightclubs, or the little girls he raped. + +KEEP IN MIND, I sent this information in a few years ago, so they've had plenty of time to get their Ebay friends to alter or cancel and reissue the below account name. They do this ALL the time to protect the original owner of the accounts they don't want connected to them! I've seen it happen with all the important accounts which expose them. + +thundernlightening ( 226) 17 years 3 months PA,United States + +I'm going to deviate from O'Connell for a moment, because I want to show you one of their connections to a judge and a drug treatment center tied to the courts. + +You may have read about MSP Colonel trying to protect Judge Bibaud and his daughter from embarrassing facts regarding her arrest, there is also Judge Estes who appears to be a part of this group of police, wealthy, and unethical attorneys. Both of them are also tied to drug treatment and healthcare networks, the same treatment and healthcare this corrupt enterprise, including Attorney Morrissey, and the DA are a part of. + +The link to the story is below. + +http://www.gazettenet.com/Former-Eastern-Hampshire-District-Court-judge-engagedin-willful-judicial-misconduct-that-brings-the-judicial-office-into-disrepute-th4o63o9 + +Now I will show you the connections between them (Judge Estes, the rogue cops, and attorney Kathleen Morrissey), as well as their ties to the healthcare network which they are running using fictitious names. + +This is yet another treatment center facility this group is connected to which is receiving federal grant monies. I've sent plenty others to the FBI in the past and showed they've received multi-millions in awards while using fictitious names. + +In this case, Judge Estes was having sex with a court social worker from the Behavioral Healthcare Network the cops and lawyers run. Attorney Kathleen Morrissey is using another one of her aliases on this healthcare network, this time she's using Katherine Wilson and has signed the documents as such. I've provided one of her Wilson signatures and screenshot from the healthcare network below, as well as her legal signature for you to compare. + +To break it all down for you, I've provided the link to their fictitious names shown on Behavioral Healthcare . + +SAMHSA and BHTCC have to do with federal grant awards as explained on their website. + +I've also supplied the cops and lawyers Ebay accounts for both these grant names of Samhsa and Bhtcc, and I've supplied the cops Ebay accounts they've created using the same fake names found under the center's leadership. + +The Healthcare Network Website and leaders who are really this group. + +https://bhninc.org/aboutileadership/president-and-ceo/ + +Below are a couple of the troopers Ebay account names using this same healthcare network where they hide behind fictitious names. + +#### BHTCC -grants + +bhtc ( 182) 17 years 0 months Germany + +#### SAMHSA -Funded Grants + +samhsa ( 31) 13 years 8 months MD,United States + +Below is Attorney Morrissey using an alias of Katherine Wilson, the screenshot shows her signature from the Behavioral Health Network and it doesn't take an expert to see they are identical to her legal signature taken from court documents. + +Her alias of Wilson is displayed first. + +Morrissey is also connected to Wm O'Connell and all of the above engage in these activities together and have for over twenty years. She is also tied to the Messina's who raped my friend. This is shown on the sexual assault document. + +![]()Below is the Kathleen Morrissey legal signature from my court documents when she represented my ex husband. The signature is a little messier than how she usually writes but it's hers. + +![](_page_16_Figure_17.jpeg) + +BHN is for Behavioral Healthcare Network and the next three Ebay accounts represent the listed leadership of this center, but they are all police officers using fake names. Swittenberg is a name taken from BHN. + +[bhn](#) ( 70 ) + +19 years 10 months TX,United States + +[swittenberg](#) ( 6 ) + +6 years 6 months NJ,United States + +Back to O'Connell.. + +A special prosecutor or investigative agency from another state is needed to investigate MA, O'Connell and the rot of society posing as police officers. Law enforcement ignored all of the rape and death threats which were sent to me via email and also directed at my minor daughter. + +Since they're hacked into my pc, they can see the information I've been compiling and typing on this document. Rest assured, they will run to O'Connell and tell him what I am reporting which they've already done in the past with others. + +The reason they do this is because the dirty cops make money off me. O'Connell and the other wealthy I've been reporting pay the rogue law enforcement big money to chase me around on the side with hopes they'll be able to silence me or stop or block my complaints. + +In order to silence me, you have to follow me around to see where I am, where I'm mailing or faxing from, or if I'm at a public location sending emails. + +This has already been proven, both their hacking and their intercepting my letters. I have signed signatures from the AG and DOJ my letters were received, but when I call to inquire they have "no record" of them. + +Bill O'Connell is shown below. Does anyone find the below " accident" suspect? His rape victim returns to MA to prepare for trial and is suddenly killed in a "fiery car accident". If it didn't sound suspicious to you before, perhaps it will after you read this? + +![](_page_18_Picture_0.jpeg) + +SOURCE: Greg Derr/Patriot Ledger + +QUINCY, Man. — Less than two years after William O'Connell was charged with having a sexual relationship with a 14-year-old girl, and three months after the girl was killed in a fiery car crash, the wealthy Quincy developer is likely to walk out of court friday a free man, our news partners at the Patriot Ledger reported. + +A prosecutor and lawyer for O'Connell will present a plea agreement to a Norfolk County Superior Court judge that drops all charges against O'Connell, including four statutory rape counts and a cocaine-trafficking charge. + +"http://www.wickedlocal.com/x767231206/Wealthy-Quincv-developer-Wilham-O-Con nell-charged-with-child-rape-cocaine-trafficking + +A little more on O'Connell and his sons is below.. + +Keep one thing in mind while reading all of this, they know I've been collecting this information for years so they've had plenty of time to discard their hard drives, get new cell phones, close places they've held illegal `stings', and destroy evidence. This is one reason they are still hacked into me, it's to protect, destroy, and prepare to discredit my findings and reports. They also have many attorneys coaching them behind the scenes. + +O'Connell, a man who was convicted of multiple felonies, but a man who has money and ties to politicians and law enforcement, coupled with LE's priorities tied to elections, their political party, and a group blinded by greed, makes for a failed government and sham democracy. + +I'm going to be showing more of O'Connells ties to the rogue troopers, the ICanes, and their ties to the escort business. What better way to protect the wealthy men, the wealthy married men, married police, politicians, and the paid escorts than to have police run the show?! They are able to protect both the john' and the escorts since they're usually the ones responsible to arrest them. + +There's one trooper I consider to be a sexual predator who has boasted about women deserving to be raped, lives at strip clubs when he's off, supports rapist Messina who raped my friend 'S', and he films unsuspecting women undressing, in the bathroom, and having sex. He's also posted numerous photos of naked women in their bathrooms on Craigslist and titled the photos 'Peeping Tom'. His name is Trooper David M. Manning whom I dated a few times and ditched. + +In fact, he tried forcing me to have sex with him by holding me down, until I got angry and threw him off me so nothing else happened. He is the one currently sending ex-cons and criminal informants to harass and commit crimes against me in NH. + +Years ago, one of the troopers told the others online "If I go down I'm taking everyone with me" and I'm pretty sure it was Manning who wrote that. This is the reason I feel they haven't held him accountable or even responded to my hundreds of letters about his crimes against me and my child. Manning was a part of their group long before he got on the state police because he probably worked for one of their nightclubs. PI Bob Long is one who is a part of this 'enterprise' because Long works for these same wealthy folks. + +#### Facts on the O'Connell Family + +William O'Connell was charged with raping a fourteen year old girl for years and was charged with cocaine trafficking. He gave her cash and allowed her to use his credit card to purchase thousands of dollars of goods in return for sex. Child was killed one week prior to the onset of his trial. + +William O'Connell was given six months probation after being charged with negligent motorboat homicide in 2002. O'Connell's best friend, William Sanderson, 62, of Quincy, was killed when he was struck by the propellers of a boat with O'Connell at the helm off Chappaquiddick Island. A charge of drunken operation of a boat was dismissed." + +O'Connell was charged with assault with intent to murder, assault and battery with a dangerous weapon and unlawful discharge of a firearm. + +O'Connell listed his occupation as a real estate developer with Marina Bay Development in a report filed earlier this year with the state Office of Campaign and Political Finance. There may be ties between him, Epstein, and Granite Reality. + +He and his extended family have given thousands of dollars to local Democrats, politicians, and candidates over the years, including to U.S. Rep. William Delahunt, who lives at Marina Bay, and Treasurer Tim Cahill, also of Quincy. + +This is not the first time that the extended O'Connell clan has run into trouble with police. Robert O'Connell's cousin, Matthew "Ky" O'Connell, was convicted of second-degree murder in the 1987 stabbing death of Julie Hamilton, 22, who grew up in Randolph. Hamilton's body was found in a shallow grave in a wooded area about 100 feet from the house where Matthew O'Connell was living with his mother. Matthew O'Connell, William O'Connell's son, was sentenced to life in prison with the possibility of parole after 15 years. + +The articles on his arrest and long term rape of a fourteen year old child is below. + +http://www.patriotledger.com/article/2012122o/NEWS/312209226 + +https://www.bostonmagazine.com/2on/o9/27/fast-times-at-marina-bay/ + +http://www.patriotledger.com/x1444028051/High-profile-Quincy-family-at-center-ofattempted-murder-case + +O'Connell 74, crashed his helicopter while entertaining two women in their twenties. The troopers even created Ebay accounts under the womens names. + +https://vineyardgazette.com/news/20o8/06/23/helicopter-crashes-lake-tashmoo-no-i njuries-investigation-continuing + +O'Connells son was arrested for shooting a US Marine and firefighter during a road rage incident. O'Connell got off as the firefighter 'decided' to not press charges. + +BNEG and O'Connell own nightclubs and restaurants next door to each other and have worked together for years. There seems to be lots of deaths surrounding O'Connell and his family and they always seem to get no real punishment or prison time. + +Due to the sudden death of his young victim, O'Connell got off. + +When arrested O'Connell had nineteen grams of cocaine on him. + +Where did he get the large amount of cocaine? His sons? Do police watch them ? No, they do not. All law enforcement should know major dealers have 'safe houses'. Did anyone do any checking on the abandoned Quincy apartment where they found millions of dollars worth of cocaine and cash? + +Guess who's a part of that complex? Bill O'Connell is! + +A man named David Max Aaronson grew up near him and was arrested in 2008 for cocaine trafficking. I later noticed he was online with the troopers when he posted a photo of his stomach tattoo while communicating with them. He could be one of O'Connells Quincy drug dealers as well. + +Most of their business is done online to avoid a footprint of their communications and dealings. This is how I'm able to find them. + +I'd like to add that I believe there is more to the sudden death of the child rape victim which I'll explain below. There are many people who feel her death ou e proper y investigated, especially since we know O'Connell will continue preying on young girls due to his protection. + +This group will lead you to one of the major drug dealers in MA which for some reason law enforcement doesn't seem to be in a rush to find them. + +Perhaps the dealer IS O'Connell or his sons? + +This group was well aware of O'Connell's relationships with these girls, minors, and escorts, and yet they still referred to him as their 'real boss'. + +I can also provide many of their Ebay accounts and shell corporations which were created under the woman involved with the Resendez girl, including the Malden officer who investigated her death and the fiery crash. + +There was an Ebay account they created under the investigating officers name at the same time Rebecca returned to MA to prepare for trial. According to online news networks, the officer who investigated her death is Captain Gatcomb of Malden PD who was a detective at the time. When I contacted the PD involved they wouldn't respond to me because the MA troopers told them to ignore me. + +I've provided the Gatcomb Ebay below. Again, he is the one who investigated the girls 'accident'. Someone placed a 'B' in front of his last name and I don't know if that is for Bill (O'Connell) or the troopers who use 'B' a lot online as a reference to their group. (I have monitored their online dealings for twenty years) + +If this is the investigating officers Ebay account below, then it should raise suspicion of both her death and the investigation of the accident. If it's a troopers account, it's also highly suspect due to their business and friendship ties with O'Connell. I'd be willing to bet O'Connell would pay millions to make his statutory rape case go away. + +Why was the rape victim driving a car she wasn't supposed to be driving, and is the owner of this car affiliated with the Phyllis Capuano girl who pimped her out to O'Connell? + +Were accelerants found in the vehicle? I'd be willing to bet no one searched for them, and I'd be willing to bet the car can no longer be found. + +Did anyone find any connections between the vehicle owner and Capuano, O'Connell, or any of his many construction businesses tied to the area where she lived or crashed ? + +I'm sure one of O'Connells employees had ties to either the rape victim, Capuano, the car owner, or some of their family/friends. O'Connells reach is far and wide but I'm sure the ties can be found. Did anyone look for them? + +My auto smelt of gas for a few days during the time two separate men were sent to try and force me into a guardrail on 93. I've since sent in their license plates. + +Was there really a passenger in the vehicle with her and how did she escape slightly injured if the car went airborne and burst into flames? O'Connell would also pay a lot to say someone was in the car with her as a 'witness'. + +One of them threatened me during 2O11, they said " we pay a lot to get what we want" and I still have this on email. + +Did this passenger see anyone try to force to crash, or when she lost control of her vehicle before the crash ? NO, because it happened at 330 AM when most are asleep. + +I find it highly odd that during 2012 arrived back in MA, finds a car she wasn't supposed to drive, is immediately killed, and at the same time, these troopers connected to O'Connell created an Ebay account using the investigating officers name! + +All of the above happened one week before the trial, the child was suddenly killed, and O'Connell got off and avoided the rest of his short life in jail. + +I've checked all Ebay accounts including bgatcomb, billoconnell, and thundemlighting, and all three of them appeared to have been altered. So, someone is covering something up. + +An easy way to cover who owns the accounts is to have their friends at Ebay cancel the original account and have a random person recreate another using the same name. + +This way the original owner is hidden and protected. + +Below is the Martin Luther King Health Center where you can see the name `Dare Johnson' and Bill O'Connell. I submit these few shells simply to show the police are connected to him, and the Dare Johnson will belong to a cop. + +These cops have created over 250,000 shell corporations for these wealthy and nightclub owners, many of which are tied to the corrupt attorneys close to them. I believe they've also altered the below account. + +darejohnson (12) 4 years 6 months LA,United States + +![](_page_24_Picture_3.jpeg) + +As I've done in the past, I can match all the above names on the shell with the MA cops Ebay accounts.. + +Bill O'Connell referred to the little girl who he raped for months as 'Kookie' which is also a name his friend Trooper Charlie Kane texted to me during 2008. + +For Charlie, this was a reference to his friend 'Mathias' who accompanies the troopers on illegal stings where they have sex with women and secretly film them. + +This is the reason Trooper Kane texted the name 'Kookie' to me, because he's friends with O'Connell who probably calls all of his paid child rape victims 'Kookie' so he doesn't have to remember their names. + +After I fought with them is when Charlie sent me the text. + +Trooper Kane and O'Connell are very dose, and during 2008 (and years prior) Manning was spreading rumors about me that I was a prostitute. The Kookie text from Kane wasi a reference to that rumor. But, the fact of the matter is that Trooper Kane knew about O'Connells many child victims he called Kookie, and that's why Kane texted me the same name. + +A person named Jane Debo also tried luring me to Wm O'Connell's golf club but I declined. Jane was recruited by these troopers who told her to do so, but I have no idea what their plan was at the time. + +A man driving a BMW once approached me on a Quincy beach and made sexual comments to me. He also knew things about me he shouldn't have known unless the troopers sent him. Looking back today, after seeing his photo, I believe that man was Wm. O'Connell. + +O'Connell and his sons used their various construction company license numbers for their Ebay accounts as well, with all transactions between cops and the Kane Enterprise. I haven't provided these today but have provided them in the past. Below may be one of them, and when there is only one transaction on an Ebay account, it means a large amount of money has been passed. + +One O'Connell Ebay account is shown below and originated around the time of the girl's death.. Since this document was typed a few years ago, that means the below account is actually over ten years old. + +billoconnell ( 1 ) 4 years 11 months Germany + +The first account shown below, O'Connell has transactions with all the troublemakers including bdubia, which 'may' be Internal Affairs Dave Debuccia who is a part of this corrupt enterprise. DUB IA + +oconnel ( 286) + +bdubia ( L3t4) + +dubia ( 20Q) + +18 years 11 months NJ,United States + +18 years 7 months + +15 years 11 months + +PA,United States + +Germany + +Thunder n-lightening is O'Connell's cigarette boat name. The Ebay account is below and the pay transactions can be for anything.... women, drugs, fuel, jobs, cover-ups, or court outcomes, etc. The point is the transactions are with troopers using O'Connells boat name and dates back almost twenty years. They have been doing business with him for over twenty years. + +thundernlightening ( 226) 17 years 3 months PA,United States + +Kookie is the child rape victims nickname O'Connell called her. + +ckookie ( a ) 16 years 3 months United States + +Mussaw was the last name of one of the women with O'Connell when he crashed his helicopter. + +mussaw( 43) 17 years 1 month MD,United States + +Malden Police Detective Gatcomb investigated her accident and claimed "no foul play", but if this is his account, he has transactions with the biased troopers who are friends with Bill O'Connell, thus another conflict of interest, or cover up. + +I was also told MSP took over the investigation of her death, but they'd never tell me because they know I will find his Ebay accounts and ties to them. MSP usually uses their names and four digit MSP ID numbers, and many times place a MA, S, or SP before their ID numbers when creating their accounts. + +Trooper Charlie Kane uses Maine on his accounts as he has close family living there, so this Gatcomb account could belong to him as he is a close associate of O'Connells. + +The name Gatcomb is the name of the officer who investigated the little girl's death. I find it suspect this account was created at the same time she returned to MA and at the same time was killed. + +If Trooper Kane owns it, he is close to O'Connell and texted me to call me Kookie, just as they called Capuano. He's also at the top of the rogue donor group and one who moves the big money around. + +As I stated above, to cover up their connections and crimes, they've been duplicating Ebay accounts to hide the original owner, and they have friends working at Ebay to assist with this. + +So, I'm wondering why the account below no longer shows it's location in ME? It's usually because it was tampered with. So, let's say Bill O'Connell didn't want the child's death appropriately investigated, and he wanted to pay Gatcomb off to cover it up. Since he trusts the head of this rogue group Trooper Charlie Kane, he would pay him the large sum of money and Kane would open an Ebay account under Gatcomb's name. The payoff would then be passed. + +They would go to great lengths to cover something this big (if they did). I've provided the screenshot to the account I just found. The original account shows Maine and is older than it appears below. + +If the ME account was connected to the troopers and the cop who investigated the little girl's death, that would be why it was changed.. The account was created once the child victim arrived back in MA. + +The one I just found is below and no longer shows ME as the location which I find suspect. To alter an account to hide the original owner, they will ensure the member name, member date, and number of transactions match the original account. This seems to be happening with all the accounts they don't want to be connected to. + +.mmunity > Feedback forum > Feedback profile + +# )ack profile + +bgatcomb ( 21 \* ) Positive Feedback (last 12 months): 0% [How is Feedback percentage calculated?) Member since: May-02-12 in United States + +I'd be willing to bet O'Connells trooper friends were illegally listening in on the girls conversations while she was in California, just as they did to me for years, and heard she was coming back to Malden. + +They also do this to get first hand knowledge of private meetings between attorneys and their clients if they are involved. + +Listening in on her private conversations would give hints as to how he may beat the case, the specific evidence they have, and sensitive case information about him the child shared with the attorney. + +Most importantly, he would find out exactly when she was coming back to Massachusetts. She came back and was killed. + +They engage in fishing expeditions and illegally gather evidence to protect their illegal organization and members. They also knew the contents of my conversations with my attorneys after they had me falsely arrested in order to silence me. (I was found not guilty). + +The below corporation is from his Marina Bay management Co. They also have accounts under its address. I believe Peter O'Connell is his son and the one who shot a firefighter during a road rage incident. He also got off attempted murder charges. + +#### ARTICLE WI + +The effective date of organization of the corporation dull be the date approved and filed by the Secretary of the Conunonweaki. If a later dtecove date is desired. specify such date which dull not be more than retry days after the date of filing. + +#### ARTICLE VIII + +The Information contained In Ankle VW S not a permanent part of the Ankles of Organizadion. + +a. The street address (post office bare are nor acceptable) of the principal office of the corporation In Massachusetts it + +Quincy, MA 02171 b. The name. residential address and pOSI office address of each director and Officer of the corporation is as follows. + +NAME President. Williaa S. O'Connell Trasanal Willian S. O'Connell aerk Richard C. Pierce Directors. William S. O'Connell Richard C. Pierce Walter J. Hannon, III IISIDENTLU. ADDRESS POST OFFICE ADDRESS Miramar, FL 33023 Mira ,i 1.3302 Randolph, MA 02368 Quincy, MA 02170 + +Vita + +I + +As you can see, Hannon is another name on O'connells business but these accounts are all owned by cops. + +hannon ( 8'7) 19 years 11 months MD,United States + +FEDERAL I.D. NUMBER + +04-2517835 + +CERTIFICATE OF CORRECTION +(GENERAL LAWS, CHAPTER 156B, SECTION 6A) + +CORPORATE NAME: O'Connell Management Company, Inc. + +DOCUMENT TO BE CORRECTED: Massachusetts Corporation Annual Report for year ending December +IT IS HEREBY CERTIFIED THAT THE ABOVE MENTIONED DOCUMENT WAS FIELD WITH THE OFFICE 31, 1987 +OF THE SECRETARY OF STATE ON 11/01/98. + +PLEASE STATE THE INACCURACY OR DEFECT TO BE CORRECTED IN SAID DOCUMENT, AND THE +CORRECTED VERSION OF THE DOCUMENT: + +The correct names and addresses of all officers and directors of the corporation +are as follows: + +President - Gary S. Grimes, [REDACTED] Scituate, MA 02066 +Treasurer - Linda R. Golden, [REDACTED] Quincy, MA 02101 +Clerk - John W. Sharry - [REDACTED] Quincy, MA 02171 +Directors - Peter F. O'Connell, [REDACTED] Quincy, MA 02170 +William S. O'Connell - [REDACTED], N. Quincy, MA 02171 +All shall serve until successors are duly elected and qualified. + +IN WITNESS WHEREOF AND UNDER THE PENALTIES OR PERJURY, WE SIGN OUR NAMES THIS 10L +DAY OF January IN THE YEAR 1989. + +X Gary S. Grimes PRESIDENT/VICE PRES. +John W. Sharry CLERK/PRESE - CLERK + +NOTE: IF THE INACCURACY OR DEFECT TO BE CORRECTED IS NOT APPEARED ON THE FACE OF +THE DOCUMENT, MINUTES OF THE MEETING SUBSTANTIATING THE ERROR MUST BE FILED WITH + +Their president is listed as Gary Grimes but transactions on all of these accounts are +with troopers and this corrupt group. + +garysgrimes ( 19 ) 15 years 3 months OH, United +States + +johnsharry ( 111 ) 9 years 6 months OH, United States + +golden ( 140 ) 14 years 6 months Germany + +After going through many of O'Connells business names, locations, folks he's connected to, employees, and all of the false real estate listings created for him by police, I know he is the one they were referring to as the "person they really work for". + +I could list all of this for you but you're looking at another fifty or more pages. I've done it plenty of times in the past so you know I can obtain it easily. + +Two days ago I found one of the troopers bogus Facebook accounts. The name of it was Kane-O'Connell and all of his FB friends were these police officers using their known aliases. Overnight, someone remotely hacked my pc and deleted the screenshots I took of this account, so I'm sure they also deleted the Facebook account. This is what they do to hide the truth. + +I'm going to show some of the erotic women information I've found over the years which is tied to them and which I've reported to all MA investigative offices and James Comey. + +Think about it though, had you investigated all I've told you since 2010, their escort ties and the Mathias incident, my friends rape, this little girl may have never been victimized and may be alive today, but Mass. LE chose to ignore me. + +#### Facts and ties to escort services and sex workers. + +O'Connell- paid a fourteen year old girl for sex over a period of years. He was also convicted for cocaine trafficking and there are several sudden deaths and attempted murders involving him and his family members. Trooper Kane, Coletti, and Manning work with him. He's friends with Norfolk DA Morrissey. + +Messina's- Drugged and gang raped my friend 'S' analy during 2006. She told me who did it but they were never charged. They are also wealthy developers and do business with Trooper Kane, Coletti, and Manning. Messina's are friends and donate heavily to Norfolk DA Morrissey where Trooper Kane was working. Attorney Kathleen Morrissey is also close with them. I was invited out with them that night but declined. Messina was approaching me at the gym during the same time Trooper Charlie Kane was. + +Mathias- A civilian who assists the troopers on police stings where they illegally detain women, film them, and have sex with them. Trooper Manning does the filming and then distributes it while protecting Mathias' identity. Mathias is friends with Manning and Kane and he's either a lawyer or the excavator in Kingston. He is also always on Craigslist with them advertising for women. Mathias was seen at the Kane clubs with Trooper Charlie Kane. + +Mathias posted a photo six years ago which was found on one of their many 'hooker' sites. This photo consisted of several women in black dresses. As soon as I found the photo and saved it, they deleted the site and the photo. It had his name on it and is shown below. I believe these illegal stings of the private investigators, their 'Sugar Daddy' websites, their many trips to strip clubs, silent owners of some, and their advertising on Craigslist for women to strip for them, are to screen women for their own escort business and the VIP tables at Kanes nightclubs. + +![](_page_32_Picture_2.jpeg) + +This photo was taken from their 'Mathiasparis' club website, a site which offers a bottle of grey goose for \$300.00. + +I have submitted at least fifty of their Mathias accounts recently. Most were out of 'Germany, but the troopers use Germany. + +I've submitted their many ties to strip clubs in both MA and RI. I found Kane to have all the club ties but O'Connell owns some as well. + +During 2008 and years after, the troopers used to post on Craigslist seeking attractive strippers to entertain them at private parties on the South Shore. + +I've submitted the rape threats they sent to me as well as rape threats directed at my fifteen year old daughter. There was no response from MSP or any MA law enforcement, including Maura Healey's Office. + +They're tied to Tom McCready, a Norwood bartender who drugged my drink years ago. I left the bar before it hit me so nothing happened to me. The bar where he worked could be owned by friends of theirs, or even Bob Long, but the connections are there. They are silent owners of many businesses. I know I was drugged because I only had two beers over a five hour period and felt fine before I left. McCready was the only one who served me the two beers, and kept asking me "how I was feeling" before I left. (He asked me at least six times) See Predator Cops document. + +During 2009, Jane Debo of Braintree, a woman who the troopers recruited to target me, tried luring me to O'Connells Granite Links Golf Course in Quincy for drinks. + +The cops have registered shell corporations for the wealthy under the names of the young rape victim, the nickname O'Connell called her which you can read in the article (Kookie), and Capuano. (The woman who brought the child to him) One of their shell corporations is below but they have them in all states. I told you, they're assisting the wealthy with laundering and they need shells to do so. They have over 250,000 of them. KOOKIES INC. is below. + +![](_page_33_Picture_3.jpeg) + +I hold photos of a cop's wife they placed online. She was stark naked and posed in many graphic photos. The cops swap photos of their wives with one another and post them online. Think about this, if they do this to someone they love', what do you think they'll do to women they don't know, or women they hate such as me? I know about this because I tried getting the photos removed from online. + +They had no problem recruiting two registered NH sex offenders of young girls to harass me and assist with stealing evidence from my residences, two of them being Dan Gallant and Kenneth G. Reed. + +They had many escort sites which catered to their group. All transactions related to these escort sites were among cops, lawyers, and those connected to the troopers. These were not sites where cops are trying to catch 'johns' or prostitutes and were immediately removed once I located them. + +One of their Ebay accounts showed a man complaining about the woman he had an encounter with, and the owner of the account told him "I put them through a two - three week thorough testing before dispatching them". + +(I will show you some of the 'sale' descriptions from their escort accounts below.) + +Many of their websites referred to underground dub services, VIP's, and offered a variety of women. Some are mentioned below. + +One of Kane's nightclub patrons told me a known escort works at his club and the VIP tables are known 'underground' services w/escorts. I also hold VIP Kane and Pimp EBay accounts which I will include but I'm sure they've discontinued them by now. + +One of their sites offered underage girls which I reported to the FBI and AG at the time. This would entice someone like O'Connell and I'm sure there are others. + +I found a website which sought underage Thai girls which had the Mathias and another wealthy civilian name from NH on it. + +They also run or ran a site called 'Sugar Daddy'. They kept sending me the link for over a year before I looked at it. I originally looked at it after reading the weird ads alluding to men requesting to be used by gold-diggers and I also suspected Frank Messina Sr. was a member. It turns out he was, along with his sons who raped my friend, and who do business with Kane and Manning. If no MSP arrests were ever made from this site, it means they ran it to find attractive women to recruit for themselves. + +I did interact with someone from this site but not for any 'daddy' reasons, I made fun of him for wanting to be used by gold diggers. This could also be how O'Connell came across some of his women, including the woman who brought a fourteen year old to him. (Phyllis Capuano). + +During 2007 Trooper Charlie Kane texted me and asked me to meet him at a condo in Weymouth where he was "house sitting" for a female friend but I declined. They have + +many properties and nightclubs; including O'Connells extensive properties to accommodate their women, and as you will read below, the hidden audio and visual devices are included. Kane probably thought I'd meet him and have sex so he could video it, but I've always turned down his sexual advances. (He is married or was at the time) + +I've been to their after hours bars in Quincy until 6AM where a trooper was bartending. ICanes night clubs stay open past 2 AM and who is going to do anything when they're that closely connected to the police, Quincy politicians, and O'Connell? I'd check the clubs underground or basement entertaining after hours, but I've been typing this for a week so I'm certain there are clean up efforts taking place. + +They were on Craigslist daily and nightly requesting all varieties of women to entertain them. I believe they were searching for women to work for them, because their demand was for all types of women. Asian, young, large women known as BBW's, etc. + +One of the troopers made a comment about their erotic women being too expensive so he was going elsewhere. + +MSP Trooper LeMar was arrested for going to the prostitutes at Brocktons Aria Salon. The owner of the salon said there were 23 other troopers who bought their services. This could be the cheaper place he was referring to. They have a large amount of 'Aria' accounts. + +I read a review of one of Kane's clubs which I believe ended up being shut down. The review stated the person was disgusted watching the nightclubs bouncers frequently taking unknown drunk women home. These were woman who stumbled out of the club and could hardly function. + +I'm going to throw out some of their online and known escort names they've used and have created websites under. I'm also going to show you some of their `customers' comments. All of this and more was sent during 2015 to MSP, DOJ, FBI, and AG, and all accounts were active at that time. Today, many accounts have been removed or canceled, but I sent them to all of you in MA who did nothing. + +Their hooker and escort club sites had the names Crystal Club, Paris Club, Hub51, and were run by the Mel rian Brothers. Some of their Ebay account names are below and were active five years ago. The melman account was definitely canceled and reissued to hide the original owner! I've thoroughly checked this! + +crystalclub ( 13 years 8 PA,United 234) months States + +I believe most were canceled as soon as I found them. + +In the past I've sent in many of their `peeping tom' and `bathroom' accounts. Some of their pimp accounts are below but they have many alluding to sex for money. + +apimp ( 52) 14 years 5 months Germany + +Just like their Kookie shell above out of MD, so is their Ebay account. + +vippimp ( i2 years 10 MD,United 53) months States + +escort ( 11) 14 years 6 months Germany + +pimpo ( 23) 4 years 0 months Switzerland + +One of these cops sites also hinted about their facility being in the "Red Light District" and they claimed it's their private "underground" club, which is probably a Kane or O'Connell club. Basically, their websites are disguised as upscale clubs and restaurants which offer VIP packages costing thousands of dollars. + +On these sites, take a closer look at the 'restaurants' thousand dollar packages, and you will see women's physical descriptions who are labeled by class, bra sizes, and the more expensive package claims they will equip you with " all of your audio and visual needs". + +Some of the tables at the Kane Clubs exceed \$5,000.00. Most of their accounts have now been deleted after I sent it to the FBI ,DOJ, AG several years ago. + +According to their website, the business package' offers "complimentary audio and visual with wireless microphones" and I've sent all of this to LE in the past right from these websites! + +This sounds similar to the Kanes Grand Nightclub and their offerings, but their erotic offerings are online only and disguised under various fictitious club and restaurant names. + +I'm certain the online phone numbers one would call from these sites to reserve a table would have been tied right to those at the Kane Clubs. (I have sent all of this information in depth years ago, and since then one of the corrupt has gone into my emails to delete all of it. ) + +All transactions on these accounts are between cops, lawyers, wealthy, corrupt, and all men.Again, because I typed this years ago, the below accounts are older than they appear, but I'm sure have been tampered with. + +redlights( az) + +at ( i8) + +4 years 2 months + +13 years 1 month + +"THANX SO MUCH FOR SHOPPING AT PRO STREET, WE APPRECIATE YOUR BUSINESS! XX" + +The group of men offering these women for a price went by the name Melman Brothers. Several years ago I pulled his account which originated during 1998. Today, I pulled the account again and they've had someone recreate the Melman account to hide the original owner who created the account during 1998. + +The new one is below and this is one way they are hiding their misconduct. + +You want to find the owner of the original account, the one I copied and pasted from Ebay over 17 years ago. + +The original account is out of CA and the newer one is out of TX.. Melman was one who claimed to run the "underground club". You can see below one of the cops recreated it, it was to hide the original owner, and there is a good reason why. + +melman ( 8 ) 1 year 11 months TX,United States (fake) + +melman ( 17 years 1 CA,United + +401) month Original acct + +Below is another Melman I found years ago and hasn't been changed or re-created. + +In order to change their Ebay accounts this quickly, they need to have a contact who works at the new Ebay Office in Boston. They would ensure one of their friends gets a job there and these will be the folks assisting them with changing their accounts, because without those connections it's really hard to do. + +xmelman ( La) 14 years 5 months NJ,United States + +Below is from the Melman Club Package found on their website which they deleted as I can no longer find it. I did copy and paste this from their website years ago. There were nothing but sexual innuendos on the site and included with the restaurant/clubs menu, and the comments were a lot more graphic than what I'm submitting today. It discussed these private sexual offerings in the luxury basement of the club. + +One important item I forgot to include. The dubs website had a"NO CHILDREN Allowed" policy on the front page of the site, but yet they offered a "Kids Menu" ! + +I definitely had this and am pretty sure someone deleted it from my docs. I probably have it printed, but my important documents are in my safety deposit boxes because the troopers kept having criminals break in my home to steal my evidence. + +I took the "kids menu" on this website to mean young girls. Below is what their menu actually said; + +#### "Catering Menu + +1. If you're into the group thing". + +### 2."Drink Menu + +If you want an umbrella in your drink, put it on the floor and stick yours in it." + +#### 3. "Dinner Menu + +Whether you're in the market for a nice piece of bass or a juicy burger, we've got your fix". + +Below are a couple of reviews posted by cops on the Neiman' brothers clubs and restaurants website. Does this or the below sound like a restaurant to you? + +Their Ebay will follow if I have it but the cops deleted my information via hacking me. + +#### From pk + +"After losing count of how many drinks I had, it was time to "break the seal". Guess what? Even the bathroom in this place was gorgeous. Individual stalls with solid wood doors and amazing lighting! With towel in hand I was in bathroom heaven." + +#### From Titanium + +"The Melman boyz are obviously doing something right because it's been over a year since Hub 51 opened their doors- and they are still absolutely packed!" + +(Titanium has canceled his account and I'm sure all of them have. This is why they block my letters because it buys them time to hide and delete evidence). + +titanium ( 114) + +#### From Tim K. O'shay.. + +17 years 2 months NY,United States + +"The 'chos, or "nachos", upgraded from pulled chicken to crab, were [high pitched] awesome. The beef jerky was f\*\* amazing. And I know my jerky. Hell, I do it every night" + +The below buyer wrote this feedback after buying a 'book' from the Ebay account ' hub51' + +"Thanks, everything worked very well and quickly. Great German Model. Happy again." + +On my original email, I provided one of their accounts so you could see their "3 weeks to test the product",or women, comments and feedback- (this is to ensure their escorts are disease free) + +One of their feedback comments from the accounts '88girls' and 8o8girls has "\*S\*P\*A\*S\*S\* "III" as a description of his purchase . This stands for SP- ASS. + +The 88 girls accounts have been changed, altered, or deleted, as has the Mathiaspass account, but as you can see below it did exist because I also copied and pasted this from + +Ebay a few years ago. I'm not sure what the reason is, but when they write 88 it's a reference to prostitution. I placed one Ghislaine account above, but they also have one with an 88 next to it. Ghislaine was Jeff Epstein's accomplice. + +unity 9 Feedback forum 9 Feedback profile + +## profile + +ghislaine88 (1) Not a registered user 0 + +Positive Feedback (last 12 months): 0% 0 + +Member since: Feb-17-04 in Mexico + +As I said about, Trooper Manning keeps spreading rumors I was or am a pro, so right after I had surgery on my neck during 2012, he had one witch nurse say to me (for no reason) "How old are you, 88"? That was his way of harassing me and having others spread his messages. I've since had close to ten others he sent say the same to me and two people admitted they had been told to say it. The 88 is tied to sex services. I did report that nurse. + +Clearly they had many accounts which discussed dispatching women, how attractive the model was, how nice her touch was, and they had much worse which I did not supply. Over the years they have canceled or altered these accounts to avoid detection. + +This is why they block my emails, faxes, and complaints, because it gives them time to delete evidence and the MA AG troopers assist them. Mathias has been involved with them and this business for over twenty years. He's one they are also protecting. + +mathiaspass ( 2 12 years 10 German ) months y + +Trust me, the troopers and ICane's are not selling sheets and pillows as shown below! A few of their item descriptions are below and found on their erotic women and 'club' accounts. These were taken off the Melman, MathiasParis, and Hub51 Ebay escort accounts. + +"Nice cover, it 's a standard not a queen. I should have asked the measurements." + +"Love the pillows!!! Everything was described to a T! " + +"Great sheets at a great price. A professional in every way." + +"A REAL BEAUTY TO MY EYES...IM SHOCKED AN PLEASED THOROUGHLY!!TY! A" + +"great bedding' + +" These pillows are GREAT!!" + +""Goods were picked up personally! Contact Cute !!! Gladly again !!!" + +"Thank you! Absolutely the exact fufillment of my want!" + +(#4343936292) + +BABY GIRL LOVES HER NEW SHEETS - EVERYTHING (he most likely got a very young one) + +"Cute eBayers, Cash !!! !!! highly recommended, gladly again :-))" + +"worth the money i paid for. thanks" + +"GREAT PILLOW !!! EXCELLENT QUALITY - EXREMELY " + +"Beautiful and very classy. Thank you." + +"t00% virgin material, so far no error occurred and fast shipping very friendly" + +""Hammer fast delivery, Top Ware, super Ebayer.so makes Ebay fun, happy again" + +"Darling figurine. Thanks for offering it." "pretty doll" + +A separate erotic business found on the Melman Brothers site was a place named Mon Ami and the account is below. These are the accounts to check their bank statements and transactions. Monami had really graphic and obvious sex for money services. Like I said, they shut down these sites, comments, and photos right after I find them, but they can be found by their Ebay accounts. The accounts have emails and bank accounts tied to them and this is why I submit them. + +If it were legitimate police work there would be no rush to shut them down. + +They're online with the rapist Messina boys, O'Connells, Mathias', and predators such as Manning, and many other predators who need to be taken off the street. MA troopers always use Germany. + +monami.b ( io years 9 German 53) months + +monami\* ( 482) i6 years o months Germany + +One of their Ebay accounts is below and tied into the online escort websites. + +Ebay account named sellherfanny' -account has been shut down. + +Redaction is another . + +redaction (5?) 19 years o months Germany + +fox\_lady + +fox\_lady ( 2027) 15 years 7 months Germany + +Finally, below are a couple of police officers from this corrupt group explaining exactly how and why he would run his own escort business and I've also provided his Ebay account. This person is most likely dose to Mathias, thus his defending the `johns' caught and his obvious resentment towards women. This could be why they protect Mathias during their illegal stings, yet degrade, film, and exploit the women. + +This is a trooper and I believe the account will be owned by the same trooper whos in all of the above accounts with Mathias. This is taken from the cops sex webcam site about filming women. I will start with his Ebay account. Leonard had a lot to say about the subject and he could be one who runs them. + +leonardia ( as) 14 years 8 months Germany + +As you read Leonards words below, notice in the beginning he wrote "The" . This is not a typo and its written that way because it has meaning to the others. + +I've showed you their coded way of writing when I submitted Manning laughing about vandalising my vehicle again. A comma placed in such a way usually means comm-a, for Commonwealth of MA , or State. The people taking the "cut" he writes about is most likely the nightclub or STATE running it. In their case, the ICanes. + +The FBI gets the coded way of writing, ask Peter Strzok! + +Their enterprise is online based and many things are written in a coded way by those who do business with them understand, or someone like me who has monitored them online for over fifteen years. They do this to try and hide what they are doing within the enterprise. + +It's no different than the terrorists while conspiring online using coded writing such as "Providence" in place of writing Pakistan. (FBI Segmented on news) + +You'll also notice he intentionally misspelled trafficking. He left out the FK for a reason, because it means something or they are his initials. It could also represent Kane. + +Leonard 13 said this misspellings are intentional) + +T"he house still takes a cut...the bouncers take a cut...and its the same penis with a condom going into a mouth and a vagina. The only difference is in Tijuana you can't talk much unless you speak Spanish...and in Detroit its more rushed and cramped. Same services...a whore is a whore regardless of language. + +And finally...while I believe prostitution should be legal and regulated...all crimes have victims. There aren't "okay crimes" and "not okay crimes". Or at least there shouldn't be. Either prostitution is a crime or it isn't. Either we arrest both parties and punish accordingly, or we don't. My whole point was that its a joke...because it is so prevalent...yet people act all "scared" they might get busted. Police don't care about hookers or strippers or johns or even pimps. They pretend to care about sex traficing...and they care about sex with kids...but like the previous poster mentioned...cops are paying for sex too... + +Of matter of fact...I talked to an escort once...asked her what the worst experience was ever with the profession. She told me it was when a cop showed up, called up 2 buddies, then proceeded to repeatedly rape and beat her..then steal her money. Cops generally believe they are above the law." + +(Below he writes about legalizing prostitution and how he would make it safer. Note his testing the girls for diseases. I read one of his replies to a bad Ebay feedback he received on their 'girls dispatched' and he wrote "It takes 3 weeks to take care of the testing before dispatching them". I feel he's both trying to promote and justify what they are running, and explaining why and how as LE they're running an escort business.) + +"z) escalate the clientel. Current clients are lawbreakers and sex addicts and morally challenged...only. legalizing brings in more mainstream clients that may still be "morally questionable"...but not as dangerous. Like strip dubs...you still get the creeps....but you also get the college kids and bachelor parties and old lonely guys. + +2) Allow women the ability to easily report problems. Now a woman has to admit being a prostitute to report a crime. Legalizing it means she's just a woman with a job and can report problems. + +(providing you don't report their group!) + +3) protects men...making sure the women are disease free...allowing men to come forward when they are robbed or assaulted. + +4) it allows law enforcement to focus on areas of real crime...kidnappings, sex slavery, violence, rapes, child exploitation. + +legalizing doesn't kills the roaches, but it turns the lights on and makes them scatter." + +#### Leonardia said + +Iowa + +APRIL 19, 2013 + +"I don't have a problem with it. I have a problem with paying for just the "idea" of it. And I have a problem that if I were to be busted...the gal would get a "talkin to" and id be in jail and a sex offender/sex trafficer." + +"And I'm fine with that arrangement...just don't be harder on the "Johns" than you are on the hookers. The hookers get a slap on the wrist and a warning. The Johns get their cars impounded, are fined \$300-\$500, and end up on a sex offender registry...and still have to go before a judge and probably lose their wife and kids and job/livlihood. Meanwhile the cops know that hooker by name and see her posting her ads every single night like clockwork. Its silly." + +"But walking out semi buzzed, out \$400 and knowing that I just blew my load in a tight 19 year old who if I met at a regular bar wouldn't give me the lime of day...at least "sorts" worth it." + +"But then...you start to touch...they don't mind...and you get the nerve to ask for more. And if you got the cash...even if that particular dancer won't play for pay...she'll point you to the dancers in the place that will. Its just common sense. If a guy asks you to strip to your panties and he'll give ya \$20...and you're okay with that...the next logical question is "what would ya do for \$50?" + +I agree with most folks here...legalize it, regulate it...let's stop pretending already! But where I get annoyed is the unfair treatment of "johns" versus the treatment of escorts/dancers/prostitutes as "victims". Victims!? Damn...where's the sympathy for us fellas that just dropped \$400 at the club and got nothin to show for it other than a used condom and a need to make sure we have a blood test done to rule out any "potential issues". + +Gawker wrote; "My favorite club has cops in and out all the time.. I know one dancer who provides extras to an off duty officer. It's not in anyone's best interest to stir up trouble. Why the government doesn't make consensual sex legal and tax it escapes me. So much of the sex trade is part of the underground cash economy that it never shows up on the federal or state books. Instead, many women make big bucks working on their backs, get welfare, health care, earned income tax credits, etc. many escorts do take credit cards as do most clubs, but the real money is cash." + +Gawkers Ebay + +gaincer ( 89) a years 5 months Germany + +They'll lie and tell you they are running illegal stings with the private investigators to stop prostitution, yet judging by their above comments and websites, they clearly pay for them, support them, and I believe run them. But, they have the high up law enforcement who will tip them off if anyone is about to raid them because I'm sure they're getting a little on the side as well. + +I can go on and on with this as I have many of their erotic women sites, but I've already sent it in to their friends at MSP, DOJ, and the AG who chose to ignore it. Now a little girl is dead and I'm sure plenty more women are being victimized by this group because no one cared enough to look into it. + +Perhaps one day MA will care, when they assault and degrade a female in their family, be it a daughter, sister, mother, or young grandchild. This is a group of misogynistic men and police who prey on women and their track record proves it. + +It's funny, a law abiding and honest trooper wrote the truth about arresting a judges daughter who propositioned him with sex for leniency, and the Massachusetts State Police were up in arms over that truth! The former Colonel immediately dragged the trooper out of bed to discipline him for writing the truth and commanding him to remove and alter the arrest report! + +So it's apparently okay for the common citizens, kids, or women to be degraded, physically raped, and abused, but they dare not touch or verbally speak truthfully about a cop, children of judges or law enforcement, and politicians! + +Trooper Manning told everyone I know I was a prostitute and I never propositioned anyone, nor was I ever charged with a crime as the judge's daughter was. + +Until law enforcement and their connections to the judiciary is cleaned up there will never be true or real justice, it's nothing but a sham criminal justice system where everyone is concerned about their own pockets and political future. + +I know I've supplied an awful lot today, but I've sent it one document at a time over the years. I wanted you to see the ties between the rapist O'Connell and their erotic connections to him, the troopers, and the nightclub owners. + +You don't have to read it all but it's there in case you need more information. Someone has to enforce the rule of law and reform law enforcement on ALL levels in order to straighten out the problems and injustices going on in New England. + +Law enforcement, lawyers, and judges are not above the law, but they are being treated as such, while the common citizens and poor are ruled with an iron fist. + +The Denise Robert document is below and is about an unsolved murder the FBI is investigating. I feel I may have been the intended target and it's explained here. There + +are many motives as to why they want me silenced but no motives found for killing her. We walked the same nightly route. + +https://docs.google.com/document/d/idTTJ3P52IluCvIZ5deo8ODOYrNvKsmUshkfJtD x8oDM/edit?usp=sharing + +My sexual assault document is below and gives more background information on each player above. It also shows you some of the violent and disgusting public writings of one Ma State Trooper (Manning) who is the one sending criminals my way to threaten, harass, and commit crimes against me. You can read his own words on this document and after doing so you may believe all of the above. He along with Kane are ones being protected by the union, lawyers, and politicians they work with on the side. + +https://docs.google.com/document/d/ikBGywweNHwgkn ulfxb4-TQBrG4oRdXX-6 og6zzGwQ/edit?usp=sharing + +I am fairly certain it's some of the wealthy business owners mentioned on my sexual assault document who are funding these troopers to chase me around and try to silence me. Trooper Manning has been hacking me and malting it hard for me to prepare this document and he will do all he can to ensure it's not received. He is doing his best to protect O'Connell, Messina's, and the BNEG Group the Kanes. + +I refer to them as a criminal enterprise because that's how they refer to themselves as shown on the below two documents titled 'Enterprise 1 and 2'. It also touches a little on their voting and campaign shells they've tried to hide. + +#### Enterprises + +https://docs.google.com/document/d/1C2 orcCBWD7onyEmm9eC9WUXZJNkmiuhr XQwFug41VQ/edit?usp=sharing + +### Enterprise2 + +https://docs.google.com/document/dRICHKsrWThq6yTwnYylm2-rI-EoYFYAsxAREIP hSKH s/edit?usp=sharing + +BNEG Nightclub Group/Kanes- This document is brand new and just sent to the DOJ in Boston. It was sent to Fred Wyshak and Zach Hafer. This is a small amount of what I've sent over the years but will give a little background on the club owners in case you are interested. + +https://docs.google.com/document/dRBTxxxmiZ24IVp1O2 R6BZMQMfY51LMqMzXC cacltnI/edit?usp=sharing + +BNEG- Liquor and Taxes - This document is also new and goes with the above doc. It offers suggestions of other illegal activities they could be engaging in. Tax free liquor for their many clubs and restaurants and tax evasion. + +https://docs.google.com/document/d/ivoin3pHCxWuvVmKShK qWOJNDwGGHOQ wtw9RqrViLTE/edit?usp=sharing + +### The PDF version of this document + +file:///home/chronos/u-e6bfef9c95cdaoc25a8o78a445b8o5fgbc8bbf2e/Downloads/BI LL%20O%E2%80%99CONNELLandChildVictim%20(2).pdf + +Morrissey-Aliases. One corrupt attorney and her many aliases. She works very closely with the wealthy construction co owners, (Messina and O'Connell), politicians, DOT, and works with the police on the side which she tries to hide. + +https://docs.google.com/document/d/nOxx-t31wkGMuL458oYH9hiPnIoAu\_XMycqVaZ 4P5Cclio/edit?usp=sharing + +This document was created mainly with hopes of investigating the little girls death and to stop this group from harming more children and women, but I added a bit extra in order to show you the mentality, cover ups, and criminality taldng place within this enterprise and to question why this little girls death wasn't properly investigated + +Why do they feel I'm more important to surveil for years as opposed to the cocaine trafficker and child rapist O'Connell, and why do LE and the politicians refuse to look his way? (money) + +Why have they attempted SO many set-up and entrapment tactics against me if I were really committing all of these crimes? + +Why the unlawful charges against me ? Because they want me put away in order to silence me. All unlawful charges were dismissed or I was found not guilty and they failed at all of their set-up and entrapment tactics. All have been explained to MA authorities who want to protect them. + +O'Connell and his family have been getting away with grave crimes for years and he will not stop abusing little girls knowing he is protected in Mass. Someone needs to stop him before he hurts another, and if you pass this document back to Massachusetts his protection circle will take over again and nothing will happen. + +Is the rule of law only for the poor? MA is a sham democracy operating as a lawless law enforcement agency. Their actions, or lack thereof, make it impossible for the good law enforcement officers to do their jobs properly and make it impossible for victims to get justice. + +How can the good police make arrests of protected major drug dealers or wealthy rapists when they know their political friends will get them off and they'll be targeted for doing their jobs? 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every day. + +We miss seeing you, but even when you are out of sight, we know we are lucky to have you. + +Stay safe and keep up the great work. \ No newline at end of file diff --git a/marker2/ds9/EFTA00083323/EFTA00083323.metadata.json b/marker2/ds9/EFTA00083323/EFTA00083323.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f59b846843ac449d6666402cd732b77b4571855e --- /dev/null +++ b/marker2/ds9/EFTA00083323/EFTA00083323.metadata.json @@ -0,0 +1,62 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083323.pdf", + "engine": { + "marker_major": "2", + "marker_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": 895, + "elapsed_seconds": 0.52, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + 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GHISLAINE MAXWELL, Defendant. x + +20 Cr. 330 (AJN) + +### MEMORANDUM OF GHISLAINE MAXWELL IN OPPOSITION TO THE GOVERNMENT'S MOTION FOR DETENTION + +Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 + +Jeffrey S. Pagliuca (pro hac vice admission pending) Laura A. Menninger HADDON, MORGAN & FORMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 + +Attorneys for Ghislaine Maxwell + +## TABLE OF CONTENTS + +| | Page | +|---------------------------------------------------------------------------|---------------------------------------------------------------| +| PRELIMINARY STATEMENT | 1 | +| ARGUMENT | 5 | +| I. The Conditions Created by the COVID-19 Pandemic Mandate the Release of | | +| Ms. Maxwell. | 5 | +| II. The Government Has Not Carried Its Burden Under 18 U.S.C. § 3142. | 9 | +| A. Applicable Law | 9 | +| B. Ms. Maxwell Has Rebutted the Presumption That She Poses a Flight | | +| Presence In Court | 11 | +| 1. Ms. Maxwell's Personal History and Characteristics | | +| Demonstrate That She Is Not a Flight Risk | 12 | +| 2. | The Nature and Circumstances of the Charges and the Weight of | +| the Evidence Militate in Favor of Bail | 17 | +| 3. | The Proposed Bail Package Is More Than Adequate to Secure | +| Ms. Maxwell's Presence | 20 | +| CONCLUSION | 22 | + +#### TABLE OF AUTHORITIES + +| | Page(s) | +|-----------------------------------------------------------------------------------------------------------------------|----------------| +| Cases | | +| Hung v. United States ,
439 U.S. 1326 (1978)..... | 16 | +| United States v. Abdellatif El Mokadem ,
No. 19-CR-646 (AJN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020)..... | 17 | +| United States v. Alindato-Perez ,
627 F. Supp. 2d 58 (D.P.R. 2009)..... | 18 | +| United States v. Bodmer ,
No. 03-cr-947(SAS), 2004 WL 169790 (S.D.N.Y. Jan. 28. 2004)..... | 16 | +| United States v. Boustani ,
932 F.3d 79 (2d Cir. 2019)..... | 20 | +| United States v. Carrillo-Villa ,
20-MJ-3073 (SLC)..... | 8 | +| United States v. Chandler , 19-CR-867 (PAC),
2020 WL 1528120 (S.D.N.Y. Mar. 31, 2020)..... | 8, 9 | +| United States v. Conway ,
No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3, 2011) ..... | 10, 18 | +| United States v. Crowell ,
No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) ..... | 11 | +| United States v. Deutsch ,
No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2020) ..... | 11, 18 | +| United States v. DiGiacomo ,
746 F. Supp. 1176 (D. Mass. 1990) ..... | 14 | +| United States v. Dominguez ,
783 F.2d 702 (7th Cir. 1986) ..... | 10 | +| United States v. Dreier ,
596 F. Supp. 2d 831 (S.D.N.Y. 2009)..... | 21 | +| United States v. English ,
629 F.3d 311 (2d Cir. 2011)..... | 10, 11 | + +| United States v. Epstein, | | +|-----------------------------------------------------------------------------------------------------|---------------| +| 425 F. Supp. 3d 306 (S.D.N.Y. 2019) United States v. Esposito, | 17 | +| 309 F. Supp. 3d 24 (S.D.N.Y. 2018) United States v. Friedman, | 21 | +| 837 F.2d 48 (2d Cir. 1988) United States v. Hansen, | 13, 18 | +| 108 F. App'x 331 (6th Cir. 2004) United States v. Hanson, | 16 | +| 613 F. Supp. 2d 85 (D.D.C. 2009) United States v. Karni, | 16 | +| 298 F. Supp. 2d 129 (D.D.C. 2004) United States v. Kashoggi, | 16 | +| 717 F. Supp. 1048 (S.D.N.Y. 1989) United States v. Mattis, | 16 | +| No. 20-1713, 2020 WL 3536277 (2d Cir. June 30, 2020) United States v. Moscaritolo, | 10 | +| No. 10 Cr. 4 (JL), 2010 WL 309679 (D.N.H. Jan. 26, 2010) United States v. Sabhnani, | 18 | +| 493 F.3d 63 (2d Cir. 2007) United States v. Salerno, | 9, 10, 16, 18 | +| 481 U.S. 739 (1987) United States v. Stephens, 15-CR-95 (MN), | 9 | +| 2020 WL 1295155 (S.D.N.Y. Mar. 19, 2020) United States v. Peres, | 5, 6, 7, 8 | +| No. 3:20-CR-18-J-32JBT, 2020 WL 1042051 (M.D. Fla. Mar. 4, 2020) United States v. Williants-Bethea, | 18 | +| No. 18-CR-78 (MN), 2020 WL 2848098 (S.D.N.Y. June 2, 2020) Statutes | 6 | +| 18 U.S.C. § 3142 | passim | + +#### PRELIMINARY STATEMENT + +Ghislaine Maxwell respectfully submits this Memorandum in Opposition to the government's July 2, 2020 Memorandum in Support of Detention ("Gov. Mem."). + +It is difficult to recall a recent case that has garnered more public attention than the government's prosecution of Jeffrey Epstein ("Epstein"). In July 2019, Epstein was indicted for offenses relating to sexual misconduct, amid overwhelming media attention focused on the nature of the charges and Epstein's wealth and lifestyle. On August 10, 2019, Epstein died in federal custody, and the media focus quickly shifted to our client—wrongly trying to substitute her for Epstein—even though she'd had no contact with Epstein for more than a decade, had never been charged with a crime or been found liable in any civil litigation, and has always denied any allegations of claimed misconduct. Many of these stories and online posts were threatening and harassing to our client and those close to her. + +But sometimes the simplest point is the most critical one: Ghislaine Maxwell is not Jeffrey Epstein. She was not named in the government's indictment of Epstein in 2019, despite the fact that the government has been investigating this case for years. Instead, the current indictment is based on allegations of conduct that allegedly occurred roughly twenty-five years ago. Ms. Maxwell vigorously denies the charges, intends to fight them, and is entitled to the presumption of innocence. Far from "hiding," she has lived in the United States since 1991, has litigated civil cases arising from her supposed ties to Epstein, and has not left the country even once since Epstein's arrest a year ago, even though she was aware of the pending, and highly publicized, criminal investigation. She should be treated like any other defendant who comes before this Court, including as to bail. Under the Bail Reform Act, case law in this Circuit and other circuits, as well as decisions of this Court, Ms. Maxwell should be released on bail, subject to the strict conditions proposed below. + +Background. Ms. Maxwell, 58, is a naturalized U.S. citizen who has resided in the United States since 1991. She is also a citizen of France, where she was born, and of the United Kingdom, where she was educated and spent her childhood and formative years. Ms. Maxwell graduated from Oxford University. She moved to the United States in 1991, and has lived in this country ever since that time. Ms. Maxwell has maintained extremely close relationships with her six siblings and her nephews and nieces. They all stood by her in the aftermath of the July 2019 indictment of Epstein and continue to stand by her now. She is especially close to two of her sisters and their children, all of whom reside in the United States. Ms. Maxwell also has numerous friends in the United States who themselves have children, and she is a godmother to many of them. Ms. Maxwell's family and friends have remained committed to her because they do not believe the allegations against her, which do not match the person they have known for decades. + +The Government's Position. The government has the burden of persuasion in showing that detention is warranted, and that there are no conditions or combination of conditions that will secure a defendant's appearance in court. In seeking to carry this burden, the government relies on the presumption of detention in 18 U.S.C. § 3142(e)(3)(E), and argues that Ms. Maxwell poses a flight risk because she supposedly lacks ties to the United States; is a citizen of the United Kingdom and France, as well as a citizen of the United States, and has passports for each country; has traveled internationally in the past; and has financial means. And echoing recent media stories, the government speculates that Ms. Maxwell was "hiding" from law enforcement during the pendency of the investigation, even though she has been in regular contact with the government, through counsel, since Epstein's arrest. Finally, the government argues that the nature and circumstances of the offense and the weight of the evidence warrant + +detention. Importantly, in contrast with the bail position it took with Epstein, the government does not and cannot assert that Ms. Maxwell presents a danger to the community under Section 3142(g)(4). + +Ms. Maxwell's Response. The Court should exercise its discretion to grant bail to Ms. Maxwell, on the strict conditions proposed below (or as modified by the Court), for two compelling reasons. + +First, the COVID-19 crisis and its impact on detained defendants warrants release. As this Court has noted, the COVID-19 pandemic represents an unprecedented health risk to incarcerated individuals, and COVID-19-related restrictions on attorney communications with pretrial detainees significantly impair a defendant's ability to prepare her defense. Simply put, under these circumstances, if Ms. Maxwell continues to be detained, her health will be at serious risk and she will not be able to receive a fair trial. (See infra Section I, pages 5 to 9). + +Second, the Court should grant bail because the government has not met its burden under the Bail Reform Act and controlling case law. The presumption relied on by the government may be rebutted, and is so here. Ms. Maxwell has strong ties to the community: she is a U.S. citizen and has lived in this country for almost 30 years; she ran a non-profit company based in the United States until the recent media frenzy about this case forced her to wind it down to protect her professional colleagues and their organizations; and she has very close ties with family members and friends in New York and the rest of the country. Nor does her conduct indicate that she is a flight risk: she has no prior criminal record; has spent years contesting civil litigation arising from her supposed ties to Epstein; and has remained in the United States from the time of Epstein's arrest until the present, with her counsel in regular contact with the government. She did not flee, but rather left the public eye, for the entirely understandable + +purpose of protecting herself and those close to her from the crush of media and online attention and its very real harms—those close to her have suffered the loss of jobs, work opportunities, and reputational damage simply for knowing her. The government's remaining arguments about Ms. Maxwell's passports, citizenship, travel and financial means— also fail because they would require that every defendant with multiple citizenship and financial means be denied bail, which is simply not the law. Finally, as discussed below, the government's position regarding the nature and circumstances of the offense and weight of its evidence, which relates to alleged conduct that is roughly twenty-five years old, is not persuasive and does not alter the bail analysis. (See infra Section II, pages 9 to 21). + +Proposed Bail Conditions. In light of the above, we propose the following bail conditions, which are consistent with those that courts in this Circuit have imposed in analogous situations: (i) a \$5 million personal recognizance bond, co-signed by six financially responsible people, all of whom have strong ties to Ms. Maxwell, and secured by real property in the United Kingdom worth over \$3.75 million; (ii) travel restricted to the Southern and Eastern Districts of New York; (iii) surrender of all travel documents with no new applications; (iv) strict supervision by Pretrial Services; (v) home confinement at a residence in the Southern District of New York with electronic GPS monitoring; (vi) visitors limited to Ms. Maxwell's immediate family, close friends and counsel; (vii) travel limited to Court appearances and to counsel's office, except upon application to Pretrial Services and the government; and (viii) such other terms as the Court may deem appropriate under Section 3142. + +The Bail Reform Act does not discard the presumption of innocence; Ms. Maxwell is entitled to that presumption here, as she is in all aspects of this case. See 18 U.S.C. § 31420) ("Nothing in this section [3142] shall be construed as modifying or limiting the presumption of + +innocence."). The government has failed to meet its burden of establishing that Ms. Maxwell presents an "actual risk of flight" and must be detained under Section 3142. The strict bail conditions outlined above are appropriate under the circumstances and are the "least restrictive" set of conditions that will "reasonably assure" Ms. Maxwell's appearance in Court, without the health and access to counsel risks inherent in the government's request that Ms. Maxwell be detained pending trial. See 18 U.S.C. § 3142 (c)(1)(B). Under the controlling legal standards, Ms. Maxwell should be released on bail. + +# ARGUMENT + +There are two compelling reasons why the Court should order Ms. Maxwell's release on bail pursuant to the strict conditions she has proposed: + +First, Ms. Maxwell will be at significant risk of contracting COVID-19 if she is detained, and she will not be able to meaningfully participate in the preparation of her defense due to the restrictions that have been placed on attorney visits and phone calls in light of the pandemic. + +Second, the government has failed to carry its burden under 18 U.S.C. § 3142 that no combination of conditions can be imposed that will reasonably assure Ms. Maxwell's presence in court. + +## I. The Conditions Created by the COVID-19 Pandemic Mandate the Release of Ms. Maxwell. + +Impact of COVID-I9 on the Prison Population. We submit that the conditions created by the COVID-19 pandemic compel Ms. Maxwell's release pursuant to appropriate bail conditions. Four months ago, this Court held in United States v. Stephens, 15-CR-95 (AJN), 2020 WL 1295155 (S.D.N.Y. Mar. 19, 2020), that COVID-19 is an "unprecedented and extraordinarily dangerous" threat that justifies release on bail. Id. at \*2. In that case, the defendant, who had no underlying medical conditions, filed an emergency motion for reconsideration of the Court's + +prior detention order based in part on the risks brought on by COVID-19. At the time, COVID-19 had only begun to take its devastating toll on New York, and there was no known outbreak in the prison population. Nevertheless, the Court noted that "inmates may be at a heightened risk of contracting COVID-19 should an outbreak develop," and, based in part on this changed circumstance, ordered the defendant released. Id. + +Since the Court issued its opinion in Stephens, the COVID-19 risks to inmates have increased dramatically, as there have been significant outbreaks of COVID-19 in correctional facilities. In the last month alone, the number of prison inmates known to have COVID-19 has doubled to 68,000, and prison deaths tied to COVID-19 have increased by 73 percent.' Indeed, as of July 2, 2020, nine of the ten largest known clusters of the coronavirus in the United States are in federal prisons and county jails.2 As this Court noted last month, "the `inability [of] individuals to socially distance, shared communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at \*5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced by the possibility of a second wave of coronavirus cases.; + +In particular, COVID-19 has begun to spread through the Metropolitan Detention Center (MDC), where Ms. Maxwell has been housed since the Bureau of Prisons (BOP) transferred her there on July 6, 2020. According to the MDC's statistics, as of April 3, 2020, two inmates and + +I Timothy Williams, et al., Coronavirus Cases Rise Sharply in Prisons Even as They Plateau Nationwide, N.Y. Times, available at https://www.nytimes.com/2020/06/16/uskoronavirus-inmates-prisons-jails.html (last updated June 30, 2020). + +2 Coronavirus in the U.S: Latest Map and Case Count, N.Y. Times, available at https://www.nytimes.com/interactive./2020/us/coronavirus-us-cases.htmlliclusters(last updated July 2, 2020). + +3See, e.g., Audrey Cher, WHO's Chief Scientist Says There's a "Very Real Risk" of a Second Wave of Coronavirus As Economies Reopen, CNBC, June 9, 2020, available at httns://www.cnbc.com/2020/06/10Avho-says-theres-realrisk-of-second-coronavirus-wave-as-economies-reopen.html. + +five staff had tested positive; by June 30, 2020, those numbers had risen to 14 and 41, respectively.4 The increased spread among prisons means that the COVID-19 risks that were present in the Stephens case four months ago are far more serious for Ms. Maxwell now and mandate her release. + +Impact of COVID-19 on the Ability to Prepare the Defense. The Stephens opinion provides yet another independent basis that, we submit, requires Ms. Maxwell's release: if she is detained, her ability to meet with her attorneys and prepare for her defense will be significantly impaired and she will not be able to meaningfully participate in the preparation of her defense. + +In Stephens, the Court found that this factor required the defendant's release under 18 U.S.C. § 3142(i), which provides for temporary release based on a determination that such release is "necessary for preparation of the person's defense." Stephens, 2020 WL 1295155 at \*3. The Court noted that the spread of COVID-19 had compelled the BOP to suspend all inperson visits, including legal visits, except as allowed on a case-by-case basis. Id. at \*3. That suspension persists to this day.5 In a case such as this, which will require assessing evidence relating to events that occurred approximately twenty-five years ago, including documents and personal recollections, numerous in-person meetings between counsel and Ms. Maxwell will be critical to the preparation of the defense. The recent resurgence of the pandemic calls into question whether these meetings will ever be able to happen in advance of her trial. As in + +See April 3, 2020 Report from the BOP regarding the Metropolitan Detention Center and Metropolitan Correctional Center ("MDC and MCC Report"), available at https://img.nyed.uscourts.gov/files/reports/bop/20200403 BOP Report.pdf and June 30, 2020 MDC and MCC Report, available at https://www.nyed.uscourts.gov/pubibop/MDC MCC 20200630 071147.pdf. + +\$ See BOP COVID-19 Modified Operations Plan, available at https://www.bop.govicoronavirus/covid19 status.jsp. + +Stephens, Ms. Maxwell's inability to meet with her attorneys while this policy is in effect constitutes a "compelling reason" requiring her release. Stephens, 2020 WL 1295155 at \*3.6 + +Even speaking by phone with Ms. Maxwell presents daunting challenges due to COVID-19-related protocols requiring at least 72 hours' notice to schedule a call, unless it is urgent, in which case counsel can email a request to the MDC. As counsel learned this past week, however, even an urgent call request does not mean the call will take place in the time required. At approximately 5:30 p.m. on July 6, 2020, the Court ordered us to confer with Ms. Maxwell about waiving her physical presence at the arraignment, initial appearance, and bail hearing, and ordered counsel for both sides to jointly report back by 9:00 p.m. that night with a proposed date and time for these proceedings. We promptly emailed the MDC to request an urgent call, making specific reference to the Court's Order, but were not connected with Ms. Maxwell until 9:00 p.m. There will no doubt be other orders of the Court with no guarantees we will be able to reach our client in time if she is detained.' In addition, during this past week, Ms. Maxwell has not been able to physically review documents and has had limited access to writing materials. + +The prohibition on in-person visits means we must read to her any documents requiring her review, and she has virtually no ability to take notes. The age of the allegations in this case compound these problems. Under the current circumstances, Ms. Maxwell cannot review + +6Since the Court issued its opinion in Stephens, numerous other courts in this District have ordered defendants released on bail, over the government's objection, due to the pandemic and its impact on the defendant's ability to prepare for trial. See, e.g., United States v. Carrillo-Villa, 20-MJ-3073 (SLC) (S.D.N.Y. Apr. 6, 2020) (releasing undocumented defendant in drug conspiracy case because of inability to meaningfully communicate with lawyer and risk of COVID-19); United States v. Hudson, 19-CR-496 (CM) (S.D.N.Y. Mar. 19, 2020) (releasing defendant in drug conspiracy, loansharking, and extortion case, whose two prior, pre-COVID-I9 bail applications were denied, because of inability to prepare for upcoming trial and risk of COVID-I9); United States v. Chandler, 19-CR-867 (PAC), 2020 WL 1528120, at \*1 (S.D.N.Y. Mar. 31, 2020) (releasing defendant on felon in possession case, with prior manslaughter conviction, due to inability to prepare for trial due to COVID-19 restrictions). + +7The government has recently worked with the BOP to set up a standing call between counsel and Ms. Maxwell each morning until the initial appearance to facilitate attorney-client communications. While we greatly appreciate these efforts, they are a short-term patch to a persistent problem that shows no signs of abating. Nor would it be appropriate, on an ongoing basis, for the prosecutors to be involved in and dictate the date and time of our communications with our client in connection with the preparation of our defense. + +documents and other evidence from approximately twenty-five years ago and meaningfully assist in the preparation of her defense. These restrictions are additional "compelling reasons" justifying her release. See id.8 + +# II. The Government Has Not Carried Its Burden Under 18 U.S.C. § 3142. + +The grave concerns raised by the current COVID-19 crisis notwithstanding, Ms. Maxwell must be released because she has met her limited burden of production showing that she does not pose a flight risk, and the government has entirely failed to demonstrate that no release condition or combination of conditions exist that will reasonably assure Ms. Maxwell's presence in court. + +# A. Applicable Law + +As the Supreme Court has recognized, "[i]n our society liberty is the norm, and detention prior to trial or without trial is the carefully limited exception." United States v. Salerno, 481 U.S. 739, 755 (1987). Pretrial detention is appropriate only where "no condition or combination of conditions will reasonably assure the appearance of the [defendant]." United States v. Sabhnani, 493 F.3d 63, 75 (2d Cir. 2007) (quoting 18 U.S.C. § 3142(e)). The Bail Reform Act provides that a court "shall order the pretrial release" of the defendant (18 U.S.C. § 3142(b)) (emphasis added), but may impose bail conditions if "such release will not reasonably assure the appearance" of the defendant in court. 18 U.S.C. § 3142(c). Where conditions are necessary, such release shall be "subject to the least restrictive . . . set of conditions that [the court] determines will reasonably assure the appearance of the person as required." 18 U.S.C. § 3142(c)(1)(B) (emphasis added). Consequently, "[u]nder this statutory scheme, `it is only a limited group of offenders who should be denied bail pending trial."' Sabhnani, 493 F.3d at 75 (citation and internal quotation marks omitted). + +8See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence of in-person visitation, highly limited VTC and telephone call capacity, and issues pertaining to legal mail and legal documents). + +The government bears a dual burden in seeking pre-trial detention. First, the government must show "by a preponderance of the evidence that the defendant ... presents an actual risk of flight." Sabhnani, 493 F.3d at 75 (emphasis added). If the government is able to satisfy this burden, it must then "demonstrate by a preponderance of the evidence that no condition or combination of conditions could be imposed on the defendant that would reasonably assure his presence in court." Id. + +In determining whether there are conditions of release that will reasonably assure the appearance of the defendant, the court must consider (1) the nature and circumstances of the offense charged; (2) the weight of the evidence against the person; (3) the history and characteristics of the person; and (4) the nature and seriousness of the danger to any person or the community that would be posed by the person's release. 18 U.S.C. § 3142(g). + +In this case, unlike in the Epstein case, the government does not contend that Ms. Maxwell poses any danger to the community, and therefore the fourth factor does not apply. + +The Bail Reform Act contains a rebuttable presumption, applicable based on certain of the crimes charged here, that no conditions will reasonably assure against flight. See 18 U.S.C. § 3 I42(e)(3)(E). In cases where this presumption applies, the "defendant bears a limited burden of production—not a burden of persuasion—to rebut that presumption by coming forward with evidence that [she] does not pose ... a risk of flight." See United States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (quotation omitted). This rebuttable presumption can be readily satisfied, United States v. Conway, No. 4-11-70756 MAG (DMR), 2011 WL 3421321, at \*2 (N.D. Cal. Aug. 3, 2011), and "[a]ny evidence favorable to a defendant that comes within a category listed in § 3142(g) can affect the operation" of the presumption. United States v. Dominguez, 783 F.2d 702, 707 (7th Cir. 1986); see also United States v. Mattis, No. 20-1713, + +2020 WL 3536277, at \*4-5 (2d Cir. June 30, 2020). Although the presumption "remains a factor to be considered" even after the defendant has met her burden of production, "[a]t all times ... the government retains the ultimate burden of persuasion by ... a preponderance of the evidence" that the defendant poses a flight risk that cannot be addressed by any bail conditions. English, 629 F.3d at 319 (citation and internal quotation marks omitted); see also United States v. Deutsch, No. I 8-CR-502 (FB), 2020 WL 3577398, at \*5 (E.D.N.Y. July I, 2020). And regardless of the presence of the presumption or the nature of the charges alleged, "[n]othing in this section [3142] shall be construed as modifying or limiting the presumption of innocence." 18 U.S.C. § 3142(j); see also United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736, at \*3 (W.D.N.Y. Dec. 7, 2006) (those charged with crimes involving minors "continue to enjoy the presumption of innocence in setting conditions of release."). + +### B. Ms. Maxwell Has Rebutted the Presumption That She Poses a Flight Risk, and the Government Has Not Carried Its Burden That No Combination of Conditions Can Be Imposed To Reasonably Assure Her Presence In Court + +The government has not carried its burden of establishing that no set of conditions will reasonably assure Ms. Maxwell's appearance in court. As set forth below, Ms. Maxwell's personal history, her family and other ties to this country, and her conduct prior to her arrest easily rebut the presumption that she presents a risk of flight. For these same reasons, the government cannot establish that the strict bail conditions she proposes, which are consistent with a number of cases in this Circuit in which courts have ordered release, will not "reasonably assure" her presence in court. Accordingly, the Court should order Ms. Maxwell released pursuant to her proposed conditions. + +### 1. Ms. Maxwell's Personal History and Characteristics Demonstrate That She Is Not a Flight Risk + +- a. Ms. Maxwell Has No Prior Criminal Record, and Has Significant Ties to the United States and the New York Region + +Ms. Maxwell's history and characteristics do not "strongly support detention," as the government contends (Gov. Mem. at 6), but instead demonstrate that she is firmly rooted in this country and that her appearance can be reasonably assured with appropriate bail conditions. Ms. Maxwell has no criminal record, which includes the approximately twentyfive-year period from the time the conduct alleged in the indictment took place to the present. Ms. Maxwell also has significant ties to the United States. She has lived in this country for almost 30 years and became a naturalized U.S. citizen in 2002. Ms. Maxwell also has strong family ties to this country. Two of her sisters, who have agreed to co-sign her bond, live in the United States, and they have several children who are U.S.-born citizens. Ms. Maxwell is very close with her sisters and maintains regular contact with them, as well as with her nieces and nephews. Ms. Maxwell also has numerous close friends and professional colleagues who reside in this country. In sum, the United States has been Ms. Maxwell's home for decades. + +- b. Ms. Maxwell Has Actively Litigated Civil Cases in this District and Has Not Left the United States Since Epstein's 2019 Arrest + +Ms. Maxwell has never once attempted to "hide" from the government or her accusers, and has never shown any intent to leave the country. To the contrary, Ms. Maxwell has always vehemently denied that she was involved in illegal or improper conduct related to Epstein, and her conduct has been entirely consistent with someone who fully intends to remain in this country and fight any allegations brought against her. For example, since 2015, and continuing through today, Ms. Maxwell has actively litigated several civil + +cases related to Epstein in the Southern District of New York and has sat for depositions in those cases. Similarly, throughout the course of the criminal investigation of this case, which has been publicly reported on for nearly a year, Ms. Maxwell has remained in the United States. Indeed, on July 7, 2019, the day after Epstein's arrest, Ms. Maxwell reached out to the prosecutors in the Southern District of New York, through counsel, and maintained regular contact with them right up to the point of her arrest. + +The government's broad assertion that Ms. Maxwell has engaged in "frequent international travel" in the last three years (Gov. Mem. at 6) obscures the critical point: she has not left the country even once since Epstein's arrest. Ms. Maxwell's decision to remain in the United States after Epstein's arrest and subsequent death in August 2019 is particularly significant because any incentive she may have had to flee would have been even more acute at that time. Within days of Epstein's death, a steady stream of press articles began turning the public's attention to Ms. Maxwell—wrongly substituting her for Epstein—and speculating that she had become the prime target of the government's investigation.9 Adding even more fuel to this fire, several of the women claiming to be victims of Epstein's abuse began publicly calling for her immediate arrest and prosecution. Despite the increasing risk of being criminally charged, and the media firestorm that was redirected toward her after Epstein's death, and despite having ample opportunity to leave the country, Ms. Maxwell stayed in the United States for almost an entire year until she was arrested. These actions weigh heavily in favor of release. See United States v. Friedman, + +9 See, e.g., Spotlight turns on Jeffrey Epstein's British socialite :fixer' Ghislaine Maxwell after his suicide — but will she be prosecuted?, Daily Mail (Aug. 10, 2019) https:/Avww.dailymail.co.uk/news/arlicle-7344765/Spotlight-turns-Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html• Ghislaine Maxwell• the woman accused of helping Jeffrey Epstein groom girls, The Guardian (Aug. 12, 2019), htlps://www.theguardian.com/us-news/2019/aug/12/ghislainemaxwell-woman-accusethjeffrepepstein-groom-girls•British socialite Ghislaine Maxwell in spotlight after Epstein's apparent suicide, NBC News (Aug. 12, 2019) https://vnvw.nbcnews.corninews/us-news/british-socialiteghislaine-maxwell-spotlight-after-epstein-s-apparent-suicide-n 1041111. + +837 F.2d 48, 49-50 (2d Cir. 1988) (overturning district court's decision that defendant posed a flight risk based in part on the ground that the defendant took "no steps" to flee jurisdiction in three-week period between execution of search warrant at home and arrest); United States v. DiGiacomo, 746 F. Supp. 1176, 1179-80 (D. Mass. 1990) (concluding defendants did not present a flight risk because each of them "for three years knew there was substantial evidence of the likely charges against them and did not attempt to flee before indictment"). + +Indeed, the absence of any allegation by the government that Ms. Maxwell was taking steps to leave the country at the time of her arrest is conspicuous. The government has offered no proof that she was making plans to leave the country. In fact, had the government alerted her counsel that she was about to be arrested, we would have arranged for Ms. Maxwell's prompt, voluntary surrender. Instead, the government arrested Ms. Maxwell without warning on the day before the July 4th holiday, thus ensuring that she would be in federal custody on the one-year anniversary of Epstein's arrest. + +- c. Ms. Maxwell's Actions to Protect Herself From Intrusive Media Coverage and Death Threats Do Not Demonstrate an Intent to Flee + +Furthermore, the steps Ms. Maxwell took to leave the public eye after Epstein's arrest are not indicative of a risk of flight. The government notes that Ms. Maxwell dropped out of public view after Epstein's arrest, which the government seeks to portray as "hiding" from the law. The government further argues that she has taken several steps to avoid detection, including moving residences and switching her phone and email address. (Gov. Mem. at 8). But Ms. Maxwell did not take these steps to hide from law enforcement or evade prosecution. Instead, they were necessary measures that Ms. Maxwell was forced to + +take to protect herself, her family members, her friends and colleagues, and their children, from unrelenting and intrusive media coverage, threats, and irreparable reputational harm. + +Ever since Epstein's arrest, Ms. Maxwell has been at the center of a crushing onslaught of press articles, television specials, and social media posts painting her in the most damning light possible and prejudging her guilt. The sheer volume of media reporting mentioning Ms. Maxwell is staggering. Since Epstein's arrest, she has been mentioned in literally thousands of media publications, news reports, and other online content. The media attention also spawned a carnival-like atmosphere of speculation about her whereabouts. In November 2019, the British tabloid, The Sun, even offered a £10,000 bounty for information about Ms. Maxwell's location. A headline reminiscent of a Wild West wanted poster read: "WANTED: The Sun is offering a £10,000 reward for information on Jeffrey Epstein pal Ghislaine Maxwell."10 And in the days leading up to her arrest, there was a deluge of media reports (all untrue) claiming that Ms. Maxwell was hiding out in an apartment in Paris to avoid questioning by the FBI." She has seen helicopters flying over her home and reporters hiding in the bushes. Indeed, since Ms. Maxwell's arrest on July 2, 2020, her counsel has been flooded with hundreds of media inquiries and solicitations from members of the public. + +The "open season" declared on Ms. Maxwell after Epstein's death has come with an even darker cost — she has been the target of alarming physical threats, even death threats, and has had to hire security guards to ensure her safety. The media feeding frenzy, which has only intensified in recent months, has also deeply affected her family and friends. Some of Ms. Maxwell's closest friends who had nothing whatsoever to do with Epstein have lost their jobs or + +I°See https://uww.the-sun.cominews/740 I 8/the-sun-is-offering-a-10000-reveard-for-informatiomon-jeffrey-epsteinpal-ghislaine-maxwellt + +See, e.g., https://www.dailymail.co.ukinews/ article-8444137/Jeffrey-Epsteins-fugitive-madam-Ghislaine-Maxwell-hiding-luxury-Paris.html. + +suffered severe professional and reputational damage simply by being associated with her. Ms. Maxwell therefore did what any responsible person would do — she separated herself from everyone she cares about and removed herself from the public eye in order to keep herself and her friends out of harm's way.12 + +Lacking any evidence required under the governing standard that Ms. Maxwell presents an "actual risk of flight," Sabhnani, 493 F.3d at 75, the government's flight risk argument is reduced to the following: Ms. Maxwell is a woman of means who has foreign citizenship and has traveled internationally in the past, and who now faces serious charges. But if that were sufficient, then virtually every defendant with a foreign passport and any meaningful amount of funds would need to be detained as a flight risk. See Hung v. United States 439 U.S. 1326, 1329 (1978) (to detain based on risk of flight, government must show more than "opportunities for flight," and instead must establish an "inclination on the part of [the defendant] to flee"). That is not what the Bail Reform Act requires. Indeed, courts in this Circuit and elsewhere commonly find that bail conditions can adequately address risk of flight, even where individuals have foreign citizenship and passports or otherwise substantial foreign connections, and financial means. See, e.g., Sabhnani, 493 F.3d at 66; United States v. Hansen, 108 F. App'x 331 (6th Cir. 2004); United States v. Hanson, 613 F. Supp. 2d 85 (D.D.C. 2009); United States v. Bodmer, No. 03-cr-947(SAS), 2004 WL 169790, at \*2-3 (S.D.N.Y. Jan. 28. 2004); United States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004); United States v. Kashoggi, 717 F. Supp. 1048, 1050-52 (S.D.N.Y. 1989). + +Finally, the ongoing travel restrictions caused by the COVID-19 pandemic would pose a significant hurdle to Ms. Maxwell's ability to flee the United States, particularly to + +12 The media spotlight has also drawn out people who claim to speak for Ms. Maxwell, and even purport to have had direct communications with her, but who, in fact, have no ties to Ms. Maxwell whatsoever. One such person has even given numerous television interviews on news shows in the United Kingdom. + +France and the United Kingdom.13 Notably, two weeks ago, this Court recognized in United States v. Abdellatif El Mokadem, No. 19-CR-646 (AN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020) that "concerns regarding risk of flight are mitigated by the ongoing [COVID-19] pandemic, which has understandably curtailed travel across the country, and, indeed, around the world." Id. at \*1. In that case, despite finding detention to be warranted on two prior occasions, the Court concluded that the government could no longer establish flight risk and ordered the defendant released pending sentencing. Id. ("Taking account of the COVID-19 pandemic, which had not yet reached this country when the Court last considered Defendant's custody status, the balance now clearly and convincingly tips in Defendant's favor . . ."). Consideration of this factor weighs heavily in favor of release on the proposed bail conditions here. + +### 2. The Nature and Circumstances of the Charges and the Weight of the Evidence Militate in Favor of Bail + +The Defense Has Rebutted the Presumption Relating to Certain of the Charges. The government relies on the statutory presumption of detention applicable to offenses involving minor victims. (Gov. Mem. at 4-5.) But unlike the position it took with Epstein, the government does not contend that Ms. Maxwell poses any danger to the community, or that she suffers from compulsive or addictive sexual proclivities. See United States v. Epstein, 425 F. Supp. 3d 306, 314-15 (S.D.N.Y. 2019). Even according to the indictment, Ms. Maxwell's alleged participation in offenses involving minors ended in 1997. Here, the only + +13 See, e,g., E.U. Formalizes Reopening, Barring Travelers From U.S., N.Y. Times, (June 30, 2020), available at https://www.nytimes.com/2020/06/30/world/europe/eu-reopening-blocics-us-travelers.html (confirming that the European Union will not open its borders to travelers from the United States, and "[t]ravelers' country of residence, not their nationality, will be the determining factor for their ability to travel to countries in the European Union"); England Drops Its Quarantine for Mast Visitors, but Not Those From the U.S., N.Y. Times (July 3, 2020), available at https://www.nytimes.com/2020/07/03/world/europeThritain-quarantine-us-coronavirus.html (confirming that England will leave mandatory 14-day quarantine restrictions in place for travelers coming from the United States). + +applicable presumption relates to risk of flight, and, as noted, Ms. Maxwell has rebutted that presumption based on her ties to the United States, her decision to remain in this country after Epstein's arrest, and all of the other reasons discussed above. This Court should follow other courts in this Circuit and elsewhere that have found that defendants rebutted the presumption and imposed appropriately strict bail conditions in cases involving alleged offenses against minors. See Deutsch, 2020 WL 3577398, at \*5-6; United States v. Veres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051, at \*3-4 (M.D. Fla. Mar. 4, 2020); Conway, 2011 WL 3421321, at \*4-5. + +The Impact of the Potential Penalties Is Overstated. The government asserts that detention is warranted because of the potential for a long sentence in this case. (Gov. Mem. at 4-5.) This oversimplifies the governing standard. Although the severity of potential punishment is a relevant consideration, the Second Circuit "require[s] more than evidence of the commission of a serious crime and the fact of a potentially long sentence to support a finding of risk of flight." Friedman, 837 F.2d at 49-50 (district court's finding that defendant posed a risk of flight was clearly erroneous, despite potential for "long sentence of incarceration"); see also Sabhnani, 493 F.3d at 65, 76-77 (reversing detention order where defendants agreed to significant physical and financial restrictions, despite the fact that they faced a "lengthy term of incarceration"). Accordingly, the asserted potential for a long sentence does not meet the government's burden of persuasion.14 + +14 The government relies on United States v. Alindato-Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009), cited approvingly by United States v. Moscaritolo, No. 10 Cr. 4 (IL), 2010 WL 309679, at •2 (D.N.H. Jan. 26, 2010) for the proposition that "[t]he steeper the potential sentence, the more probable the flight risk is, especially considering the strong case of the government ...." (Gov. Mem. at 5.) But Alindato-Perez is easily distinguished on its facts from Ms. Maxwell's case. Alindato-Perez was a narcotics case that did not involve 20-year old conduct as here, but instead involved a conspiracy that "continu[ed] until the date of the indictment." 627 F. Supp. 2d at 60-61. The evidence included eleven "clearly incriminating video tapes" and testimony from various cooperating witnesses, and the defendant faced a 10-year mandatory minimum sentence. Id. at 61-64. These factors are not present in this case. + +Moreover, the government overstates the potential for Ms. Maxwell to spend "decades in prison" if she is convicted. (Gov. Mem. at 5.) In fact, her likely total exposure even if she were convicted on all counts is 10 years, assuming the Court were to follow the traditional practice in this District and impose concurrent sentences. Although a 10-year sentence would be significant, it is a far cry from the government's forecast, further demonstrating that the government has not met its burden of showing Ms. Maxwell is an actual risk of flight. + +The Government's Case Is Subject to Significant Challenges. In evaluating the strength of the government's case, we note that Ms. Maxwell intends to mount several legal challenges to the indictment, including that: (i) this prosecution is barred by Epstein's September 24, 2007 non-prosecution agreement with the Department of Justice, which covers "any potential co-conspirators of Epstein"; (ii) the conspiracy, enticement of minors, and transporting of minors charges are time-barred and otherwise legally flawed; and (iii) the two perjury charges are subject to dismissal on several legal grounds. as In addition, as we understand from the face of the indictment, the government's case is based primarily on the testimony of three individuals about events that allegedly occurred roughly 25 years ago between 1994 and 1997. It is inherently more difficult to prosecute cases relating to decades-old conduct. These issues further call into question the strength of the government's case, and provide an independent basis justifying release on bail. + +1S The defense is also considering whether the government's comments in connection with this case conform to Local Criminal Rule 23.1, and whether to seek appropriate relief from the Court. + +### 3. The Proposed Bail Package Is More Than Adequate to Secure Ms. Maxwell's Presence + +For the reasons stated above, the Court should release Ms. Maxwell because the circumstances created by the COVID-19 pandemic will greatly increase her personal risk and prevent her from meaningfully participating in her defense, and because the government has not carried its burden under 18 U.S.C. § 3142. We respectfully submit that the proposed bail package represents the "least restrictive" set of conditions that will reasonably ensure Ms. Maxwell's presence in court. 18 U.S.C. § 3142 (c)(1)(B). + +The package includes six co-signers-Ms. Maxwell's siblings, relatives and friends—many of whom reside in the United States, and all of whom continue to support her despite the unrelenting media attacks that Ms. Maxwell and they, themselves, have suffered as a result of this case. Each of them has voluntarily agreed to assume responsibility for an extremely large bond amount of \$5 million, in order to secure her appearance. The bond is also to be secured by real property in the United Kingdom worth roughly \$3.75 million. The package also includes stringent travel and physical restrictions, including surrendering all passports and no new travel applications, travel restricted to the Southern and Eastern Districts of New York, and home detention with electronic GPS monitoring. Ms. Maxwell, for personal reasons, will continue to need security guards to protect her upon release. Under the circumstances, if the Court requires it, the security guards could report to Pretrial Services.16 + +16 In United States v. Houston!, 932 F.3d 79 (2d Cir. 2019), the Second Circuit curtailed the circumstances under which a court can grant pretrial release to a defendant on the condition that the defendant pays for private armed security guards. Boustani, nevertheless, held that a defendant may be released on such a condition if the defendant "is deemed to be a flight risk primarily because of his wealth. In other words, a defendant may be released on such a condition only where, but for his wealth, he would not have been detained." Id. (emphasis in original). We submit that a similarly situated defendant who, like Ms. Maxwell, had no prior criminal record, significant ties to the United States, and a demonstrated lack of intent to flee the country, as well as numerous, supportive co-signers, but who did + +Ms. Maxwell has a number of other family members and friends who, under normal circumstances, would also co-sign and secure her bond. She is not relying on them in connection with this bail application in an effort to safeguard their privacy and protect them and their families from harm. + +The proposed bail conditions are consistent with those approved by courts in this Circuit in other high-profile cases, and should be approved here. See, e.g., United States v. Esposito, 309 F. Supp. 3d 24, 32 (S.D.N.Y. 2018) (alleged leader of Genovese crime family who was charged with racketeering and extortion granted release subject to conditions), aff'd, 749 F. App'x 20 (2d Cir. 2018); United States v. Dreier, 596 F. Supp. 2d 831, 832 (S.D.N.Y. 2009) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," granted release subject to conditions). + +not have Ms. Maxwell's means, would be released on bail conditions. Accordingly, if the Court deems it necessary, it may impose private security guards as a condition of release. + +### CONCLUSION + +For the foregoing reasons, Ms. Maxwell respectfully requests that the Court order her release on bail pursuant to the conditions she has proposed. + +Dated: July 10, 2020 + +Respectfully submitted, + +/s/ Mark S. Cohen + +Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 + +Jeffrey S. Pagliuca (pro hac vice admission pending) Laura A. Menninger HADDON, MORGAN & FORMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 + +Attorneys for Ghislaine Maxwell \ No newline at end of file diff --git a/marker2/ds9/EFTA00083324/EFTA00083324.metadata.json b/marker2/ds9/EFTA00083324/EFTA00083324.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9bec4bab442813cc682fec3082545c67639b5ad9 --- /dev/null +++ b/marker2/ds9/EFTA00083324/EFTA00083324.metadata.json @@ -0,0 +1,1339 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083324.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 26, + "chars": 52975, + "elapsed_seconds": 8.74, + "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 + ], + [ + 281.419189453125, + 71.28 + ], + [ + 281.419189453125, + 99.7330322265625 + ], + [ + 68.544, + 99.7330322265625 + ] + ] + }, + { + "title": "MEMORANDUM OF GHISLAINE MAXWELL \nIN OPPOSITION TO THE GOVERNMENT'S MOTION FOR DETENTION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 102.81600000000002, + 332.90999999999997 + ], + [ + 508.8299560546875, + 332.90999999999997 + ], + [ + 508.8299560546875, + 361.4830322265625 + ], + [ + 102.81600000000002, + 361.4830322265625 + ] + ] + }, + { + "title": "TABLE OF CONTENTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 238.68, + 71.28 + ], + [ + 374.134521484375, + 71.28 + ], + [ + 374.134521484375, + 86.2330322265625 + ], + [ + 238.68, + 86.2330322265625 + ] + ] + }, + { + "title": "TABLE OF AUTHORITIES", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 228.88800000000003, + 72.08999999999999 + ], + [ + 383.6007995605469, + 72.08999999999999 + ], + [ + 383.6007995605469, + 85.8170166015625 + ], + [ + 228.88800000000003, + 85.8170166015625 + ] + ] + }, + { + "title": "PRELIMINARY STATEMENT", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 219.70799999999997, + 72.08999999999999 + ], + [ + 391.927978515625, + 72.08999999999999 + ], + [ + 391.927978515625, + 86.103515625 + ], + [ + 219.70799999999997, + 86.103515625 + ] + ] + }, + { + "title": "ARGUMENT", + "heading_level": null, + "page_id": 8, + "polygon": [ + [ + 264.996, + 263.25 + ], + [ + 346.6669616699219, + 263.25 + ], + [ + 346.6669616699219, + 278.853515625 + ], + [ + 264.996, + 278.853515625 + ] + ] + }, + { + "title": "I. 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Maxwell, + +Defendant. + +USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 12/28/20 + +20-CR-330 (MN) + +ORDER + +ALISON J. NATHAN, District Judge: + +On December 8, 2020, Defendant Ghislaine Maxwell filed a renewed motion for release on bail. Dkt No. 97. In an Opinion and Order concurrently filed under temporary seal, the Court DENIES the Defendant's motion. + +In light of the fact that the Opinion includes potentially confidential information that should not be filed on the public docket, the Court will permit the parties 48 hours to propose any redactions to the Court's Opinion and Order and to justify those redactions by reference to the Second Circuit's decision in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110(2d Cir. 2006). After determining which, if any, portions of the Opinion and Order should be redacted, the Court will file the Opinion and Order on the public docket. + +This Order provides the bottom line of the Court's resolution. On July 14, 2020, this Court conducted an extensive bail hearing and determined that pre-trial detention was warranted because the no conditions or set of conditions could reasonably assure the Defendant's appearance at future proceedings. Under 18 U.S.C. § 3142(0, a bail hearing may be reopened if the Court 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 whether there are conditions of release that will reasonably assure the appearance of such person as required." The Court concludes that + +none of the new information that the Defendant presented in support of her application has a material bearing on the Court's determination that she poses a flight risk. + +Furthermore, for substantially the same reasons as the Court determined that detention was warranted in the initial bail hearing, the Court again concludes that no conditions of release can reasonably assure the Defendant's appearance at future proceedings. In reaching that conclusion, the Court considers the nature and circumstances of the offenses charged, the weight of the evidence against the Defendant, the history and characteristics of the Defendant, and the nature and seriousness of the danger that the Defendant's release would pose. *See* 18 U.S.C. § 3142(g). The Government does not contend that the Defendant poses a danger to the community. Nonetheless the Court determines that the other three factors warrant detention under 18 U.S.C. § 3142(e). The Court also finds that the Defendant's proposed bail conditions would not reasonably assure her appearance at future proceedings. + +As a result, the Court concludes that the Government has met its burden of persuasion that the Defendant poses a flight risk and that pre-trial detention continues to be warranted. + +On or before December 30, 2020, the parties are ORDERED to submit a joint letter indicating whether they propose any redactions and the justification for any such proposal. + +This resolves Dkt No. 97. + +SO ORDERED. + +Dated: December 28, 2020 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00083350/EFTA00083350.metadata.json b/marker2/ds9/EFTA00083350/EFTA00083350.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bab039c5545247d002d0b290d8552d1d8c93f847 --- /dev/null +++ b/marker2/ds9/EFTA00083350/EFTA00083350.metadata.json @@ -0,0 +1,116 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083350.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3214, + "elapsed_seconds": 5.71, + "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 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Line", + 32 + ], + [ + "Text", + 11 + ], + [ + "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 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 23 + ], + [ + "Text", + 16 + ], + [ + "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/EFTA00083350" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083352/EFTA00083352.md b/marker2/ds9/EFTA00083352/EFTA00083352.md new file mode 100644 index 0000000000000000000000000000000000000000..3d75aee552aa4afae76594b477bb77f83feba962 --- /dev/null +++ b/marker2/ds9/EFTA00083352/EFTA00083352.md @@ -0,0 +1,50 @@ +**From:** "[REDACTED] (USANYS)" <[REDACTED]> +**To:** "[REDACTED] (USANYS)" <[REDACTED]> +**Cc:** "Berman, Geoffrey (USANYS)" <[REDACTED]>, "[REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED] (USANYS)" <[REDACTED]> + +**Subject:** Re: DAG Memos/call with [REDACTED] +**Date:** Fri, 24 May 2019 13:38:34 +0000 + +**Importance:** Normal + +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] +[REDACTED] +[REDACTED] +[REDACTED] + +Sent from my iPhone + +Begin forwarded message: + +**From:** "[REDACTED] (ODAG)" <[irlan@jmd.usdoj.gov](mailto:irlan@jmd.usdoj.gov)> +**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] +[REDACTED] Here are the two memos for your briefing with Ed of the DAG, one from Geoff and the other from me on the recusal matters. + +After you and I spoke, we realized that we should add Epstein and we have done so. As always, please feel free to call with any comments or questions. + + + + \ No newline at end of file diff --git a/marker2/ds9/EFTA00083352/EFTA00083352.metadata.json b/marker2/ds9/EFTA00083352/EFTA00083352.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f36d18729f6cbedb8dc522589c9a6f1bf5cf1d63 --- /dev/null +++ b/marker2/ds9/EFTA00083352/EFTA00083352.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083352.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1560, + "elapsed_seconds": 5.73, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 52 + ], + [ + "Text", + 40 + ], + [ + "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", + 13 + ], + [ + "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/EFTA00083352" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083354/EFTA00083354.md b/marker2/ds9/EFTA00083354/EFTA00083354.md new file mode 100644 index 0000000000000000000000000000000000000000..1afb094dd55928bcf70bb2c0dbe3a3842dcd7e47 --- /dev/null +++ b/marker2/ds9/EFTA00083354/EFTA00083354.md @@ -0,0 +1,21 @@ +From: (USANYS) [Contractor]" + +To: (USANYS)' + +Subject: RE: + +Date: Sun, 12 Apr 2020 14:23:45 +0000 + +I haven't found anything yet either online or on the Epstein shared drive. I will keep looking though. + +Ori inal Messa e + +From: (USANYS) alMIE> + +Sent: Saturda , April 11, 2020 7:10 PM + +To: (USANYS) [Contractor] + +Subject: + +Can you check whether there were any interrogatories answered by Maxwell in the lawsuit? \ No newline at end of file diff --git a/marker2/ds9/EFTA00083354/EFTA00083354.metadata.json b/marker2/ds9/EFTA00083354/EFTA00083354.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..69ea21cf72d5bd16620f25d80c2aea457ceb9e9b --- /dev/null +++ b/marker2/ds9/EFTA00083354/EFTA00083354.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083354.pdf", + "engine": { + "marker_major": "2", + "marker_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": 0.55, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Line", + 12 + ], + [ + "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/EFTA00083354" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083355/EFTA00083355.md b/marker2/ds9/EFTA00083355/EFTA00083355.md new file mode 100644 index 0000000000000000000000000000000000000000..7dae30f106b965f48db0893f16afb76385aa1573 --- /dev/null +++ b/marker2/ds9/EFTA00083355/EFTA00083355.md @@ -0,0 +1,15 @@ +To: + +Subject: + +Date: Wed, 15 Apr 2020 15:15:01 +0000 + +62. Epstein, Maxwell, and returned to Epstein's ranch. Upon returning from the movie, Maxwell repeatedly told that she wanted to give her a massage. was very uncomfortable with the idea of Maxwell touching her, but realized that she was completely alone with Epstein and Maxwell. feared what would happen if she did not comply with their demands. said that she had never had a massage and tried to avoid having Maxwell touch her body, but Maxwell continued to pressure her. Maxwell directed to take off all of her clothes and lay on the massage table. was extremely scared to be naked in front of Epstein and Maxwell. + +63. Maxwell left the door open so that Epstein could view naked body during the massage. + +64. Maxwell touched intimate parts of body against her will for the sexual benefit of Maxwell and E stein. + +65. Maxwel + +66. was extremely distressed and afraid. She was a child in a massive ranch in New Mexico, away from her family ined isolated from any source of help. She was alone with Epstein and Maxwell. She had no way to access a phone or other method of communication without Epstein or Maxwell knowing. She had no way of leaving. \ No newline at end of file diff --git a/marker2/ds9/EFTA00083355/EFTA00083355.metadata.json b/marker2/ds9/EFTA00083355/EFTA00083355.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..938cb8fdc8a7242eee8ca2cc5607bfa33f6f8af1 --- /dev/null +++ b/marker2/ds9/EFTA00083355/EFTA00083355.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083355.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1202, + "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", + 22 + ], + [ + "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/EFTA00083355" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083356/EFTA00083356.md b/marker2/ds9/EFTA00083356/EFTA00083356.md new file mode 100644 index 0000000000000000000000000000000000000000..91900c771051da03a24a74c29906be513f0c873f --- /dev/null +++ b/marker2/ds9/EFTA00083356/EFTA00083356.md @@ -0,0 +1,1220 @@ +To: + +![](_page_0_Picture_2.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Date: Fri, 19 Feb 2021 14:47:46 +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; Blosteinjpg; KCGMarch2017.jpg + +If you follow me on twitter: you'll see a nice summary/explanation of the true issues: + +NITE/VIRT: public company. per my TCR: Joyce joined from Broadcort/Merrill. Knight was clearing through Broadcort/Merrill. Joyce saw the massive fraud from naked shorting. He was perfect fit to run Knight. First thing he did: take Knight self clear. "lower costs". The effect: KNOWINGLY mis classified liabilities as assets: massive ,ongoing accounting fraud. Insolvency. Glitch. Who is on the hook? shareholders. SEC facilitated fraud. + +CDEL: self clears for internal funds but NOT CDEL Securities: RH,OTCM etc + +WHY the inconsistency? Because CDEL Securities is a private entity. LLc with Ken Griffin's name on it. Who would be on the hook for Self Clear accounting fraud/liabilities/insolvency? Ken F'n Griffin. So, the inconsistency: WHY self clear for internal funds but NOT CDEL Securities? Griffin not about to be on the hook. + +CDEL Securities clears Pershing/BoNY Mellon. The largest US correspondent clearing Broker and a HUGE BoNY/Mellon balance sheet that can hide the fraud. Third party. + +Ironically, Pershing was sister company of DU and Autranet where I worked. First Equitable. Then Autranet/Pershing sold to BoNY Mellon. DU to CS First Boston. + +Want to get a template?? start with NITE/VIRT. + +Griffin yesterday: the SEC eliminated illegal naked shorting with Reg Sho:KNOWINGLY LIED + +SEC fails data is DTCC/NSCC ONLY + +Obligation Warehouse: Ex CLEARING + +Created by the grossly corrupt SEC so criminals like NITE/CDEL can circumvent close out REQUIREMENTS of 204. SEC knows EXACTLY level of naked short fails in OW/Ex Clear. They don't disclose. Intentionally misleading the public there is no illegal naked shorting. + +Janey et al at the grossly corrupt SEC: I think I've read that somewhere before. + +Cheers! + +Christopher J Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio + +Sent: Wednesday. February 17 2021 3:53 PM + +![](_page_1_Picture_20.jpeg) + +![](_page_2_Picture_81.jpeg) + +**Subject:** Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +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_2_Figure_88.jpeg) + +Here Glitchy Glitchy + +Cheers! + +Christopher J Dilorio + +Whistleblower Extraordinaire + +[REDACTED] + +[REDACTED] + +**From:** Chris Dilorio <[REDACTED]> + +![](_page_2_Picture_97.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 + +![](_page_4_Picture_0.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. ET. Contents: Prepared Remarks; Questions and Answers; Call Participants; Prepared Remarks: Operator. Good day, and ... + +www.fool.com + +Cheers! + +Christopher J Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio + +Sent: Thursday, February 11, 20216:14 AM + +![](_page_4_Picture_11.jpeg) + +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. + +https://www.sec.gov/Archives/edgar/data/1592386/000110465921020227/tm216148d1 ex99-1.htm + +What is tangible book? + +WHY does receivable not fluctuate? + +WHY all the trading inventory for an HFT with no DMM? + +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 Dilorio + +Sent: Friday, November 6, 2020 7:09 AM + +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 + +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 + +Payable: \$675 million + +Difference: \$1.2 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 + +![](_page_6_Picture_25.jpeg) + +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://innasdaq.comIstatic-files/6b1ca278-75f0-4259-9372-5b3351126a8b + +ir.nasdaq.com + +121 e< 2 h- 21 e< 16\$ 8;1‹ 76 =23854 -:;2((1 -&22 + +irnasclaq.corn + +SunGard was then sold to FIS. AFTER it had developed a very interesting product converting Russian Rubles to dollars in real time. + +https://www.finextra.com/pressarticle/49357/otkritie-capital-taps-sungard-for-automated-ruble-conversion + +![](_page_8_Picture_3.jpeg) + +# 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 Sent: Thursday, September 17, 2020 9:17 AM + +u ject: w: Formal appea enial covered action night 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,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 + +u je w. Formal appeal ema covere mgnt capital Appenaix + +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_11_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_12_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... + +VAVVi 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_12_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 + +![](_page_14_Picture_10.jpeg) + +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_16_Picture_116.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. (). The note is available here: NETE April 2018 Update Note. Net Element, Inc. (NASDAQ: NETE, "Net Element") is a global financial + +[www.netelement.com](http://www.netelement.com) + + + +![](_page_16_Picture_121.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. (). 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](http://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 <[REDACTED]> + +**Sent:** Tuesday, June 30, 2020 1:01 PM + +[REDACTED] + +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; + [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; + +![]()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 SH!T? 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. + + + +## FINRA Fines Three Firms \$900,000 for Inadequate Anti-Money Laundering Programs | 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](http://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](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 + +the Jaclin shell factory also linked to Honig,Stetson,Alpha Cap, Frost as well + +![](_page_20_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 jec : w: Formal appeal or preliminary denial covered action -ulb/ Knignt Capital Appendix + +small typos/corrections: + +Mirror trade activity peaked in 1H2O14 not 2H2O14 and this coincides with OTCM astronomical share volume data in 1O2014 and 2O2014 that were expunged from KCG 10Q SEC filings. Not 2O2014 and 3O2014 SEC reviewed 10O'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 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_27_Picture_5.jpeg) + +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 1 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: Wednesda , A.ril 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. + +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 J Dilorio + +Whistleblower + +From: Chris Dilorio > + +Sent: Tuesday, April 28, 2020 7:24 AM + +![](_page_31_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. + +vo.vw sec cloy + +(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. + +hups://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://wwwpr.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 + +[REDACTED] >; [REDACTED] < [REDACTED] >; +[REDACTED] < [REDACTED] >; [REDACTED] + +**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](https://www.finra.org/sites/default/files/fda_documents/2009018668801_FDA_KMX39652.pdf) + +**of - FINRA** + +which is FINRA a party, to the entry of findings and violations consistent with the allegations of the (as Complaint sanctions amended and by the Offer of Settlement), to the imposition of the set forth and below, understands fully that this Order will become part of Respondent's permanent disciplinary and record may anybe considered in future actions brought by FINRA. BACKGROUND ... + +[www.finra.org](http://www.finra.org) + +**The SEC** + + + +**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 OF 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](http://www.sec.gov) + +**FINCEN** + + + +FinCEN Fines Oppenheimer & Co. Inc. \$20 Million for Continued Anti-Money Laundering Shortfalls | 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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I'll review the transcript and will then bring yotato speed. I know about he case because asked me to be the declarant for some of the withholdings. Ms recused from Noel and Tartaglione so I have not included him. + +Sent from my iPhone + +Begin forwarded message: + +From: '. :3" + +Date: A ril 9 2021 at 7:21:47 PM EDT + +To: + +Cc: + +Subject: Epstein FOIA Update + +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 Tartaglione 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. + +Thanks, + +![]()![]()![]() \ No newline at end of file diff --git a/marker2/ds9/EFTA00083398/EFTA00083398.metadata.json b/marker2/ds9/EFTA00083398/EFTA00083398.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..242d524808e9b7eb48a33075acf1f4436646de9a --- /dev/null +++ b/marker2/ds9/EFTA00083398/EFTA00083398.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083398.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2634, + "elapsed_seconds": 2.25, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 33 + ], + [ + "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", + 11 + ], + [ + "Text", + 10 + ], + [ + "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/EFTA00083398" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083400/EFTA00083400.md b/marker2/ds9/EFTA00083400/EFTA00083400.md new file mode 100644 index 0000000000000000000000000000000000000000..8e54b0077c0c0b2e27be7d10266a4b60881f8ac0 --- /dev/null +++ b/marker2/ds9/EFTA00083400/EFTA00083400.md @@ -0,0 +1,45 @@ +To:" + +Cc: + +Subject: Re: Maxwell Investigation - Friendly Subpoena to Real Estate Attorney + +Date: Wed, 08 Jul 2020 01:21:41 +0000 + +Approved. + +Sent from my iPhone + +On Jul 7, 2020, at 7:51 PM, > wrote: + +Audrey, I recommend you approve this friendly attorney subpoena. + +As reflected in email below, the team would like to subpoena the attorney who handled the purchase of the New Hampshire property that Maxwell was arrested in, as the circumstances of the purchase are relevant to the ongoing financial side of our investigation. The subpoena does not seek any privileged communications. The attorney reached out to us to offer her assistance and requested the formality of a subpoena. As such, it requires your approval but not PSEU. + +From: + +Sent: Tuesday, July 7, 2020 5.27 PM + +To: + +Cc: + +Subject: FW: Maxwell Investigation - Friendly Subpoena to Real Estate Attorney + +Approved. Friendly subpoena for non-privileged documents related to a real estate transaction. + +From: + +Sent: Tuesday, July 7, 2020 5:04 PM + +To: + +Cc: + +Subject: Maxwell Investigation - Friendly Subpoena to Real Estate Attorney + +The Maxwell team would like to send a "friendly subpoena" to real estate attorney who handled the purchase of Maxwell's New Hampshire property in 2019. Hudkins reached out to the FBI following Maxwell's arrest and offered her assistance. She requested via email the formality of a subpoena before providing us non-privileged documents from her file. As such, we do not need PSEU's approval, but we do need Audrey's approval to issue the subpoena. The proposed subpoena is attached to this email. In short, we are seeking any non-privileged documents and records regarding the purchase of Maxwell's New Hampshire property. These records are relevant to our ongoing investigation into Maxwell's finances, including any financial ties to Epstein and any efforts Epstein may have made to buy Maxwell's silence. + +Thanks, + +<2020.07.07, subpoena to Attorney at Law.docx> \ No newline at end of file diff --git a/marker2/ds9/EFTA00083400/EFTA00083400.metadata.json b/marker2/ds9/EFTA00083400/EFTA00083400.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2d79be99ac11ca0186b49c399d37418990584b9b --- /dev/null +++ b/marker2/ds9/EFTA00083400/EFTA00083400.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083400.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1.11, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "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 + } + }, + { + "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/EFTA00083400" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083402/EFTA00083402.md b/marker2/ds9/EFTA00083402/EFTA00083402.md new file mode 100644 index 0000000000000000000000000000000000000000..d31989ed6fc4a452e2d88b077a3bbd59e478c3a7 --- /dev/null +++ b/marker2/ds9/EFTA00083402/EFTA00083402.md @@ -0,0 +1,19 @@ +From: ' + +To: ' + +Subject: RE: k. + +Date: Wed, 13 Mar 2019 21:21:50 +0000 + +Thank you and will convey. + +From + +Sent: Wednesday, March 13, 2019 5:06 PM + +To: + +Subject: RE + +Attached is the Epstein memo. \ No newline at end of file diff --git a/marker2/ds9/EFTA00083402/EFTA00083402.metadata.json b/marker2/ds9/EFTA00083402/EFTA00083402.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1363442bf10a9b39d0c5256e4221245533d5194d --- /dev/null +++ b/marker2/ds9/EFTA00083402/EFTA00083402.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083402.pdf", + "engine": { + "marker_major": "2", + "marker_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": 194, + "elapsed_seconds": 0.52, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00083402" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083403/EFTA00083403.md b/marker2/ds9/EFTA00083403/EFTA00083403.md new file mode 100644 index 0000000000000000000000000000000000000000..60e0c0453ed0f4b6dd43d51b2f971c033a8e1a63 --- /dev/null +++ b/marker2/ds9/EFTA00083403/EFTA00083403.md @@ -0,0 +1,1165 @@ +To: + +![](_page_0_Picture_2.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Date: Thu, 19 Nov 2020 14:29:43 +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; Blosteinjpg; KCGMarch2017.jpg + +Laney, + +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". + +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_1_Picture_9.jpeg) + +![](_page_2_Picture_53.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_2_Picture_63.jpeg) + +--- + +**From:** Chris Dilorio <[REDACTED]> + +**Sent:** Friday, November 13, 2020 8:13 AM + +![](_page_2_Picture_66.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 SDNY 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_3_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 + +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_4_Picture_3.jpeg) + +## Ebrahim Daoud Nonoo - Wikipedia + +Ebrahim Daoud Nonoo (Arabic ;is.; )556 ral yl , 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_4_Picture_9.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 + +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 e > + +Sent: Wednesday, October 14, 2020 9:32 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +From: Chris Dilorio e > + +Sent: Wednesday, October 14, 2020 9:00 AM + +![]()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 + + + +## 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](http://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 + + + +[ir.nasdaq.com](http://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. + +https://www.finextra.com/pressarticle/49357/otkritie-capital-taps-sungard-for-automated-ruble-conversion + +![](_page_8_Picture_4.jpeg) + +# 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 SDNY. 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 1 Dilorio Whistleblower + +From: Chris Dilorio Sent: Thursday, September 17, 2020 9:17 AM + +Su •Ject: Fw: Forma appea or pre iminary • enia covere• action 2015-016 Knig t Capita TCR : Appen• ix + +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: Wednesda Se •tember 16 2020 3:01 PM + +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: Wednesda Se itember 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 + +Christopher J Dilorio + +Whistleblower + +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 + +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. + +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.comilibraryidetailaspx?g=9e2b4e49-See2-48f6-b8c7-03d39d02b5ca + +![](_page_12_Picture_7.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 + +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. + +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 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 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 + +#### 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_16_Picture_4.jpeg) + +## 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 + +tutps://www.netelement.conn/press-releaseskelease-content/1073467 I #.XwRXGuWSnIV + +![](_page_16_Picture_9.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, lioecker et al, + +Please update my Net Element and AQR TCR's + +Cheers! + +Christopher J Dilorio + +Whistleblower + +![](_page_16_Picture_21.jpeg) + +Not just irony but a massive fraud on the + +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 + +From: Chris Dilorio Sent: Tuesday, June 30, 2020 7:36 AM + +![](_page_18_Picture_1.jpeg) + +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 + +www.finra.org + +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 ... + +VAVVISeC goy + +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.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 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-lawm1 + +![](_page_20_Picture_6.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 Laney, + +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.vw.secgov + +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 Laney. + +Cheers! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Tuesday, June 23, 2020 4:11 PM + +u ject: Fw: Formal appeal or 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 10O's as I previously stated + +corrected below + +Chris + +From: Chris Dilorio + +Sent: Tuesday, June 23, 2020 9:48 AM + +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/Rakishev/Trump/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 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 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 1H2O14. 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. + +Wistleblower + +From: Chris Dilorio + +Sent: Wednesda 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 + +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: 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 Aril 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 + +![](_page_30_Picture_3.jpeg) + +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. + +"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 + +![](_page_31_Picture_12.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 + +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. + +vo.vvy sec g ov + +https://www.sec.gov/Archives/edgar/data/1322587/000114420413065095/v361773\_sc I 3g.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. + +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.prcom + +htips://www.pr.corn/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 + +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 + +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 + +# 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 + +vAyvv.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 illgotten gains...." + +## 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" + +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 OCIE Examinations of Bernard L. Madoff Investment Securities, LLC Executive Summary Background. On June 25, 2009, the Securities and Exchange Commission's + +VONW.SEC goy + +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 Dal 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. 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&CI K=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. + +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 + +'An:MISPC goy + +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 + +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. + +www.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. + +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 \$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/EFTA00083446/EFTA00083446.md @@ -0,0 +1,1301 @@ +From: Chris Dilorio fr" + +To: + +![](_page_0_Picture_2.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-0161 Knight Capital TCR & Appendix + +Date: Tue, 24 Nov 2020 13:47:17 +0000 + +Attachments: KCG\_Appendix\_3-20\_13\_penultimate.doex; KCG\_TCR\_3-20-13-penultimate\_draft.pdf; KCG\_TCR\_3-20-13-penultimate\_draft.doex; KCG\_Appendix\_3-20\_13\_penultimate.pdf; Cifu.jpg; Blosteinjpg; KCGMarch2017.jpg + +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 shit, really? + +1 1/2 years prior to the SEC/BX/JEF/Handler/Stifel/JPM/GS/Sandler et al "glitch" + +Russia's Otkritie lures team from Knight Capital I Reuters + +![](_page_1_Picture_0.jpeg) + +# 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 ... + +yoAr\v.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" Laney: + +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_1_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. + +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 + +Joey Manko Jr + +Swiss Private Bank. Deutsche Bank. Horton. Blink + +Team I The Horton Fund + +![](_page_2_Picture_6.jpeg) + +Joey Manko is BUISSSSYYYYY + +### 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 + +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 + +From: Chris Dilorio < > + +Sent: Thursday, November 19, 2020 7:29 AM + +![](_page_3_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_4_Picture_9.jpeg) + +![](_page_5_Picture_0.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 Dilorio + +Whistleblower Extraordinaire + +![](_page_5_Picture_10.jpeg) + +From: Chris Dilorio < + +Sent: Friday, November 13, 2020 8:13 AM + +![](_page_5_Picture_13.jpeg) + +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_6_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/Archi vesiedgar/data/1070050/000157570520000214/apcx 8k.larn + +https://www.sec.gov/Archives/edgaddata/1070050/000157570520000214/ex10 2.1ilm + +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_7_Picture_3.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_7_Picture_9.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 F. Supp. 2d 491, see flags on bad law, and search Casetext's comprehensive legal database + +casetext.com + +Cheers! + +Christopher Dilorio + +Whistleblower + +From: Chris Dilorio a> + +Sent: Tuesda , November 3, 2020 3:34 PM + +u ject: w: orma appea or pre iminarydenial covere action - nig t apita ppen ix + +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 a> + +Sent: Wednesday, October 14, 2020 9:32 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +From: Chris Dilorio a> + +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 + +irnasdaq.corn + +SunGard was then sold to FIS. AFTER it had developed a very interesting product converting Russian Rubles to dollars in real time. + +https://www.finextra.com/pressarticle/49357/otkritie-capital-taps-sungard-for-automated-ruble-conversion + +![](_page_11_Picture_3.jpeg) + +# 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 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,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 aemai coverea action ZU1S-Ulb/ itnignt capital ILK tk Appenaix + +I look forward to speaking with you + +Regards, + +Chris + +From: Chris Dilorio < + +Sent: Monday, September 14, 2020 6:02 AM + +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_15_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... + +VAVW 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_15_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 + +Su•Ject: Fw: Forma appea or pre iminary •enia covere• action 2015-016 Knig t Capita 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_19_Picture_115.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. (). The note is available here: NETE April 2018 Update Note. Net Element, Inc. (NASDAQ: NETE, "Net Element") is a global financial + +[www.netelement.com](http://www.netelement.com) + + + +![](_page_19_Picture_120.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. (). 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](http://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 <[REDACTED]> + +**Sent:** Tuesday, June 30, 2020 1:01 PM + +![]()![]()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_23_Picture_0.jpeg) + +# Gt' 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) + +yAvw.secgov + +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 1O2014 and 2O2014 that were expunged from KCG 10Q SEC filings. Not 2O2014 and 3O2014 SEC reviewed 10O'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 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_30_Picture_5.jpeg) + +Sent: Wednesda , 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: Monda Ma 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] + +**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]> + +--- + +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 \_I Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Tuesday, April 28, 2020 7:24 AM + +![](_page_34_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. + +VON1V sec cloy + +(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](http://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 J Dilorio + +Whistleblower + +**From:** Chris Dilorio <[REDACTED]> + +**Sent:** Tuesday, April 28, 2020 6:43 AM + +[REDACTED] + +**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. + + + +[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.corn/press-release/355247 + +#### GGSI Bahamas is Now Offering Pink Sheet Clearance + +Offshore Broker Adds to Buying and Selling Services + +www.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. + +VONW. p r co m + +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/EFTA00083492/EFTA00083492.md @@ -0,0 +1,1445 @@ +To: + +![](_page_0_Picture_2.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Date: Mon, 30 Nov 2020 14:13:32 +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; Blosteinjpg; KCGMarch2017.jpg + +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: + +Bravatek: also Fife and NITE trading billions of shares: MY F'N 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 Ad: 34 ... + +vo.vw sec cloy + +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. + +www.whoisraisingmoney.com + +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.piyrix.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_2_Picture_7.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_2_Picture_13.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 ... + +vo.,,w.wsj.com + +Will DB buy Net Element/Pay Online as part of their EU/Russia expansion in "payment processing"??? + +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/SONY: 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. + +www. 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_3_Picture_12.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_4_Picture_7.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_4_Picture_13.jpeg) + +#### 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 for 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? + +1 1/2 years prior to the SEC/BX/JEF/Handler/Stifel/JPM/GS/Sandler et al "glitch" + +Russia's Otkritie lures team from Knight Capital I Reuters + +![](_page_6_Picture_0.jpeg) + +# 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 ... + +yoArw.ft.corn + +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" Laney: + +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_6_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. + +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 + +Joey Manko Jr + +Swiss Private Bank. Deutsche Bank. Horton. Blink + +Team I The Horton Fund + +![](_page_7_Picture_6.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_8_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_9_Picture_9.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 Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio e > + +Sent: Friday. November 13 2020 8:13 AM + +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_11_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/edgar/data/1070050/0001575705200002 I 4/apcx 8k.htm + +https://www.sec.gov/Archives/edgar/data/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_12_Picture_3.jpeg) + +![](_page_12_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_12_Picture_10.jpeg) + +![](_page_12_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 F. 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 •ject: 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 + +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-filest6b1ca278-75f0-4259-9372-5b3351126a8b + +ir.nasdaq.com + +121 e< 2 h"' 21 e< 16\$ 8; l< 76 =23 \$ 54 -:;2((1 -&22 + +irnasciaq.corn + +SunGard was then sold to FIS. AFTER it had developed a very interesting product converting Russian Rubles to dollars in real time. + +https://www.finextra.com/pressarticle/49357/otkritie-capital-taps-sungard-for-automated-ruble-conversion + +![](_page_16_Picture_3.jpeg) + +# 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 Sent: Thursda Se.tember 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: Wednesda , Se.tember 16, 20203:01 PM 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 + +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 + +### \$14 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_20_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_20_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_24_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 + +hups://www.netelement.com/press-releases/release-content/10734671/1.XwRXGuWSnIV + +![](_page_24_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_24_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_28_Picture_0.jpeg) + +# Gt' 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) + +yAvw.secgov + +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 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_35_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: Monda Ma 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 1 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 8/27/21 | + +20-CR-330 (AJN) + +ORDER + +ALISON J. NATHAN, District Judge: + +On May 11, 2021, the Court informed the parties that it set a tentative trial date for November 29, 2021. The Court accordingly requested a jury trial for that date pursuant to the COVID rules for centralized jury trial scheduling in the district. The Clerk's Office has now confirmed that a jury trial in this case has been scheduled to commence on November 29, 2021. This is a firm trial date. When the information is available, the Court will provide courtroom location and public access information by separate order. + +Due to space limitations resulting from the SDNY COVID protocols, the Clerk's Office has also provided the following dates for administering a juror questionnaire and conducting voir dire: November 4, 5, and 12 (questionnaire), and November 16-19 (voir dire). The Court intends to use a streamlined questionnaire as much as feasible given all relevant circumstances. The parties shall bear this in mind when they discuss and jointly propose a questionnaire and voir dire on the schedule outlined below. + +In light of the firm dates discussed above, it is hereby ORDERED that the parties appear for a telephone conference to discuss jury selection matters on October 21, 2021 at 12:00 P.M. Dial-in information for the parties and for public access will be provided when it is available by separate order. + +In light of the jury selection dates provided by the Clerk's Office, the Court amends the schedule that it set on June 2, 2021 as follows. The parties shall meet and confer and submit a joint proposed juror questionnaire and joint proposed voir dire by October 11, 2021. The parties shall file a joint proposed charge and verdict sheet, with any differing proposals supported by authority or other justification, by October 27, 2021. Any motions in limine must be simultaneously filed by October 18, 2021, and any responses to motions in limine are due by October 25, 2021. Otherwise, the parties shall continue to follow the schedule that the Court set on June 2, 2021. Dkt. No. 297. + +IT IS FURTHER ORDERED that the parties appear for an in-person pretrial conference on November 1, 2021 at 11:00 A.M. Location information and public access information will be provided by separate order when available. + +SO ORDERED. + +Dated: August 27, 2021 New York, New York c)J14/1. + +ALISON J. NATHAN United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00083543/EFTA00083543.metadata.json b/marker2/ds9/EFTA00083543/EFTA00083543.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d75f28213fa34baa3d07b30ef6b4e1ab751b48fd --- /dev/null +++ b/marker2/ds9/EFTA00083543/EFTA00083543.metadata.json @@ -0,0 +1,128 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083543.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1.37, + "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 + ], + [ + 281.419189453125, + 72.08999999999999 + ], + [ + 281.419189453125, + 99.7330322265625 + ], + [ + 68.544, + 99.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 66 + ], + [ + "Line", + 33 + ], + [ + "Text", + 10 + ], + [ + "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": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 20 + ], + [ + "Text", + 5 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 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/EFTA00083543" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083545/EFTA00083545.md b/marker2/ds9/EFTA00083545/EFTA00083545.md new file mode 100644 index 0000000000000000000000000000000000000000..f248b0bc5c2dd7a1d8812ce7599bcd705f7fc814 --- /dev/null +++ b/marker2/ds9/EFTA00083545/EFTA00083545.md @@ -0,0 +1,135 @@ +**To:** [REDACTED] > + +**Cc:** [REDACTED] >, " [REDACTED] > + +**Subject:** Re: Testifying Witness Questions + +**Date:** Wed, 06 Oct 2021 15:44:51 +0000 + +--- + +Thanks for checking! + +> On Oct 6, 2021, at 11:23 AM, [REDACTED] > wrote: + +> + +> I found the attached on Relativity, which I think is the same as what [REDACTED] sent but the attached includes the FBI cover sheet. I think the notes referenced in the 302 (i.e., the ones provided by [REDACTED]) are the last few pages of the attached, but I don't think that we have any agent notes taken during the interview. + +> + +> From: [REDACTED] > + +> Sent: Wednesday, October 6, 2021 10:50 AM + +> To: [REDACTED] >; [REDACTED] > + +> [REDACTED] > + +> Cc: [REDACTED] > + +> Subject: FW: Testifying Witness Questions + +> + +> Did you guys ever find the notes of [REDACTED] 8/17/2006 interview by chance? + +> + +> From: [REDACTED] > + +> Sent: Tuesday, October 5, 2021 3:38 PM + +> To: [REDACTED] <[REDACTED]>; + +> [REDACTED] > + +> Cc: [REDACTED] <[REDACTED]>; [REDACTED] > + +> [REDACTED] ; [REDACTED] > + +> [REDACTED] ; [REDACTED] > + +> [REDACTED] ; [REDACTED] > + +> Subject: Re: Testifying Witness Questions + +> + +> That's all that was in this 1A. If I come across additional notes I'll send over. + +> + +> Special Agent [REDACTED] > + +> FBI New York Field Office + +> Child Exploitation/Human Trafficking + +> + +> From: [REDACTED] > + +> Sent: Tuesday, October 5, 2021 3:34:45 PM + +> To: [REDACTED] ; [REDACTED] > + +> [REDACTED] > + +> Cc: [REDACTED] > + +[REDACTED] > + +[REDACTED] > + +> Thanks so much, This looks like the documents provided, but I'm not seeing the notes the agents took of the interview. + +> From: cMINIMIE> + +> Sent: Tuesda October 5, 2021 2:27 PM + +> To: + +> Cc: + +mailto + +mailto + +> Subject: RE: Testifying Witness Questions + +> Just FYI, the notes and documents for well. were in 31E-MM-108062 — GJ 1A4. They are attached here as + +> Special Agent + +> FBI New York Field Office + +> Child Exploitation/Human Trafficking + +> Desk: + +> From: + +> Sent: Monda , October 4, 2021 7:58 PM + +> To: + +> Cc + +> Subject: [EXTERNAL EMAIL] - Testifying Witness Questions + +> I'm attaching the 302 fo from an interview on August 22, 2006. The last paragraph refers to her providing a copy of the hours s e worked at Epstein's residence as well as some notes she made at her time of + +> Also can you please send the notes of the 8/15/06 interview WM.? The 302 is attached. + +> Thanks! + +> + +> 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/EFTA00083545/EFTA00083545.metadata.json b/marker2/ds9/EFTA00083545/EFTA00083545.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ade9cd58cff04309c891f01a483e42842944d4ff --- /dev/null +++ b/marker2/ds9/EFTA00083545/EFTA00083545.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083545.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2538, + "elapsed_seconds": 9.72, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 75 + ], + [ + "Span", + 67 + ], + [ + "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": [ + [ + "Text", + 52 + ], + [ + "Span", + 47 + ], + [ + "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": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Text", + 29 + ], + [ + "Span", + 17 + ], + [ + "Line", + 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/EFTA00083545" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083548/EFTA00083548.md b/marker2/ds9/EFTA00083548/EFTA00083548.md new file mode 100644 index 0000000000000000000000000000000000000000..b7316de151a5e23c93eb1bf2cb47402d134b57e0 --- /dev/null +++ b/marker2/ds9/EFTA00083548/EFTA00083548.md @@ -0,0 +1,369 @@ +ATTENTION: [REDACTED] +FAX [REDACTED] + +FROM [REDACTED] + +[REDACTED] 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: [REDACTED] R- [REDACTED] R WORK & CHANGE AIR FILTERS), +PAINTER, CARPENTER, ELECTRICIAN, PC COMPUTER WORKER, PEADON'S CLEANING, +LARRY & CHRISTOF FOR CARS, GEROME (OUTSIDE LANDSCAPE & YARD WORK) + +PLEASE FED-X CHECK TO: + +[REDACTED] + +\*MICHELLE PLEASE CALL ME TO CONFIRM THAT YOU RECEIVED THIS FAX- THANKS +SO MUCH + +HOURS X 26 = \$ 7.00 + +10 HOURS X 20 = \$ 20.00 + +10 HOURS X 20 = \$ 20.00 + +10 HOURS X 20 = \$ 20.00 + +10 HOURS X 20 = \$ 20.00 + +10 HOURS X 20 = \$ 20.00 + +10 HOURS X 20 = \$ 20.00 + +10 HOURS X 20 = \$ 20.00 + +10 HOURS X 20 = \$ 20.00 + +10 HOURS X 20 = \$ 20.00 + +ATTENTION: [REDACTED] E +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 FED-X CHECK TO: + +[REDACTED] + +[REDACTED] + +LEASE CALL ME TO CONFIRM THAT YOU RECEIVED THIS FAX - THANKS + +IIII + +ATTENTION: [REDACTED] +FAX [REDACTED] + +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] + +Please End x check [REDACTED] for CLEANERS PROJECT [REDACTED] +[REDACTED] PROJECT [REDACTED] +[REDACTED] PROJECT [REDACTED] +[REDACTED] PROJECT [REDACTED] +[REDACTED] PROJECT [REDACTED] + +THANK YOU VERY MUCH.....HAPPY HOLIDAYS!!!!!! + +1-400 TX VILLAGE + +CLEANERS PEST EXTERMINATOR + +FORM X 52000 FS 050 + +ATTENTION: [REDACTED] +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: [REDACTED] +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 + +1 HOUR + +DOOR CODE FROM (WPB) + +STAFF OUT OF TOWN + +Please MAIL check to: [REDACTED] STAFF HOUSE + +THANK YOU ! + +[REDACTED] + +[REDACTED] STAFF HOUR + +[REDACTED] STAFF HOUR CVT 4 + +[REDACTED] S \$100.00 + +ATTENTION: [REDACTED] +FAX: 212-879-8204 + +FROM: [REDACTED] + +[REDACTED] HOURS + +8/24/04 TUES 12:00 NOON-5:00 PM + +[REDACTED] OUT FOR THE DAY + +PEADON'S CLEANING + +JOHN C CASSIDY AIR CAME AND CHANGED AIR FILTER + +COLLECTED MAIL AND PUT 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 SARAH THAT SHE WANTED LENNY TO FIX SHUTTERS + +HAD SARAH FAX LENNY A PAPER CONFIRMING THE QUOTE WAS + +APPROVED TO SHUTTERS + +8 HOURS x 20.00= \$160.00 + +MAXWELL MADE APPOINTMENT + +Please MAIL check to: [REDACTED] TO DIS + +RE \$1,000 FOR + +PAING AT CARMINES + +THANK YOU! + +MAXWELL MADE APPOINTMENT + +25.00 + +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] + +THANK YOU! + +ATTENTION: [REDACTED] MS. MAXWELL +FAX: [REDACTED] + +FROM: [REDACTED] [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 + +Please MAIL check to: +(ADDRESS UNTIL HOUSE IS BUILT) + +[REDACTED] + +THANK YOU! + +to \$20,000 + +Epstein House + +Main House 4312 + +Staff 4313 + +Alarm 7509 + +Password-Paula + +1 AIL NEEDS TO BE SENT + +~~VIA~~ ~~FED-X~~ ON + +THOR. + +I CALL [REDACTED] + +2 A PICK UP. JUST +IP TOP COPY. + +3 Y WILL GIVE YOU A +K UP #. 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+ "debug_data_path": "debug_data/EFTA00083548" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083559/EFTA00083559.md b/marker2/ds9/EFTA00083559/EFTA00083559.md new file mode 100644 index 0000000000000000000000000000000000000000..be4e014be1581e2a2c36535c8328b5a4f413777a --- /dev/null +++ b/marker2/ds9/EFTA00083559/EFTA00083559.md @@ -0,0 +1,489 @@ +To: + +Subject: [EXTERNAL] Senior NY Judge Flouting Vax Mandate Provokes Unions' Ire + +Date: Thu, 07 Oct 2021 09:11:13 +0000 + +![](_page_0_Picture_4.jpeg) + +# NEW YORK + +Thursday, October 7, 2021 Le.;Follow Law360 + +## TOP NEWS + +# Senior NY Judge Flouting Vax Mandate Provokes Unions' Ire + +New York state court employees facing termination if they fail to comply with the chief judge's COVID-19 vaccination mandate on Wednesday called out the comparatively light treatment of the lone judge flouting the order, Court of Appeals Judge Jenny Rivera. + +Read full article » + +## Maxwell Jury May Be Asked To Sit During Holiday Season + +A group of 12 New Yorkers may spend the holiday season hearing sextrafficking evidence against Ghislaine Maxwell, after a Manhattan federal judge on Tuesday floated the idea of having jurors sit between Christmas and New Year's Day. + +Order attached I Read full article » + +# FDNY Can't Dodge 'Boys' Club' Sex Harassment Suit + +A federal judge refused to toss a lawsuit from a female paramedic who claimed the New York City Fire Department ignored her complaints about coworkers sending her lewd photos then slashed her hours and gave her dangerous assignments as punishment for objecting to unwelcome advances. + +Order attached I Read full article » + +## Ex-Partner's Feud With Dentons Up To Arbitrator, Judge Says + +A New York state judge has declined to weigh in further on a former Dentons partner's claims that he was wrongfully fired, ruling Tuesday that it's up to an arbitrator to determine how to proceed while a parallel appeal plays out in California. + +Order attached I Read full article » + +## Rakoff Won't Call 'Foul' On NBA Agent's Truck Gift For Player + +An NBA agent who accused a rival of illegally luring away New York Knicks center Mitchell Robinson with a Chevy truck can't use the court system to enforce professional rules, Manhattan federal judge Jed Rakoff said Wednesday as he explained why he dismissed the suit. + +Order attached I Read full article » + +![](_page_0_Picture_26.jpeg) + +Law360 MVPs 2021 + +#### LAW FIRMS + +Aaronson Rappaport + +Arnold & Porter + +Ashby & Geddes + +Bingham McCutchen + +Blank Rome + +Canton Fields + +Cipriani & Werner + +Cohen & Gresser + +Cohen Ziffer + +Cummings & Lockwood + +DLA Piper + +Dentons + +Fox Rothschild + +Gibson Dunn + +Gorayeb & Associates + +Greenspoon Marder + +Haddon Morgan + +Harris Bricken + +Hunton Andrews + +Jones Day + +A KSL Capital Partners entity has loaned \$61 million to an entity affiliated with Arnold & Porter for a Manhattan hotel, and Kelley Drye worked on the matter, according to records made public in New York City on Wednesday. + +Read full article » + +#### Real Estate Rumors: Ascentris, Charlesbank, Bridge Industrial + +An Ascentris venture has reportedly sold a Florida office campus for \$77.3 million, Charlesbank Capital Partners is said to be leasing 15,475 square feet in New York, and Bridge Industrial is reportedly buying 175.2 acres in Florida and is hoping to rezone the property. + +Read full article » + +#### INSURANCE + +## Spirit Airlines Sues AIG Over Coronavirus Coverage + +Spirit Airlines is suing AIG unit American Home Assurance Co. for coverage of losses it suffered because of the coronavirus pandemic, telling a New York state court the virus caused physical damage to its properties. + +Complaint attached I Read full article » + +# Prison Medical Provider's COVID-19 Coverage Suit Tossed + +A medical care provider for jails and prisons lost its bid for COVID-19 coverage after a New York state judge dismissed its suit against more than a dozen insurers. + +Order attached I Read full article )> + +# PRODUCT LIABILITY + +# 2nd Circ. Revives Bladder Cancer Suit Against DuPont + +The Second Circuit on Wednesday gave a Goodyear worker another shot at allegations that chemicals manufactured by a predecessor of E.I. DuPont de Nemours and Co. gave him bladder cancer, finding that the district court was wrong in excluding his expert witness. + +Opinion attached I Read full article » + +# PERSONAL INJURY & MEDICAL MALPRACTICE + +## Cyclist Keeps \$3.9M Verdict In NYC Bus Crash Suit + +A New York appeals court has upheld a \$3.9 million verdict awarded to a cyclist who says he was sideswiped by a New York City Transit Authority Bus, saying the amount is in line with similar cases the courts have heard. + +Opinion attached I Read full article » + +# BENEFITS + +# DOL Urges Revival Of Hartford ERISA Suit At 2nd Circ. + +The Second Circuit should resurrect a former Hartford Life & Accident Insurance Co. employee's ERISA suit seeking disability benefits and reverse a federal district court's ruling that the ex-worker prematurely filed suit before exhausting his administrative remedies, the U.S. Department of Labor said. + +Brief attached I Read full article » + +# SECURITIES & WHITE COLLAR + +# Feds Jump-Cut To Key Witness At Ex-Iconix CEO's Fraud Trial + +A star witness in the Manhattan U.S. attorney's case charging ex-Iconix Brand Group CEO Neil Cole with an \$11 million accounting fraud pointed the finger at Cole on Wednesday morning, moments after Cole's lawyers asserted during trial openings that the witness is a liar. + +King & Spalding + +Kirkland & Ellis + +Kloss Stenger + +Labaton Sucharow + +Latham & Watkins + +Law Offices of Jeffrey Delott + +Lipsitz & Ponterio + +Lowenstein Sandler + +Maranda E. Fritz PC + +McDermott Will + +Miedel & Mysliwiec + +Morris James + +Mound Cotton + +Moye White + +Murphy Rosen + +O'Melveny & Myers + +Orrick Herrington + +Parsons Behle + +Paul Hastings + +Paul Weiss + +Perkins Coie + +Phillips Lytle + +Quinn Emanuel + +Robbins Geller + +Robinson & Cole + +Sheppard Mullin + +Skadden Arps + +Sullivan & Cromwell + +Taylor English + +Trusted Counsel Ashley LLC + +WilmerHale + +Wollmuth Maher + +Woods Lonergan + +Zelle LLP + +## COMPANIES + +AXA XL Ltd. + +Acreage Holdings Inc. + +Alpine Securities Corp. + +Altice SA + +Altice USA + +American Bankruptcy Institute + +American Bar Association + +American Home Assurance Co. + +American International Group Inc. + +BTI Consulting Group Inc. + +Beacon Capital Partners LLC + +Bridge Investment Group LLC + +Read full article » + +#### SEC Hits Back At Bid To Curb Its AML Reporting Enforcement + +The U.S. Securities and Exchange Commission is urging the U.S. Supreme Court to turn down a penny-stock broker's challenge to the agency's enforcement of anti-money laundering reporting requirements, arguing that its exercise of authority in this area fits within its broader investor protection mandate. + +Brief attached I Read full article » + +#### Prosecutors Back Boston US Atty Pick Amid GOP Opposition + +A group of 66 prosecutors urged the U.S. Senate on Tuesday to confirm Rachael Rollins, President Joe Biden's pick for U.S. attorney in Massachusetts, defending her approach to criminal justice reform and slamming Republican lawmakers for holding up the appointment with "fearmongering." + +Statement attached I Read full article » + +# Goldman, Investors Lay Out Cert. Fight Args For NY Judge + +After a winding path to and from the U.S. Supreme Court, Goldman Sachs and its investors are back before the New York federal judge where their decade-old stock-drop case began, once again presenting arguments for and against class certification. + +2 documents attached I Read full article » + +# NY Fund Boss Gets 7 Years For \$26M Belize Airport Scam + +The owner of an investment fund has been sentenced to seven years in prison for swindling \$26 million from dozens of investors by lying to them about an airport he was purportedly building in Belize that never materialized. + +Read full article » + +# BANKRUPTCY + +# Ex-Cred Exec Rips Efforts To Block His Bankruptcy Discharge + +An embattled former executive of bankrupt cryptocurrency venture Cred has objected to the Office of the U.S. Trustee's efforts to block his discharge from bankruptcy, saying he's been scapegoated and subjected to a "proxy criminal prosecution." + +3 documents attached Read full article » + +# Medley Ch. 11 Plan Supporters Clarify Cash Flow + +Supporters of Medley LLC's proposed Chapter 11 plan on Wednesday clarified for a Delaware bankruptcy judge the asset management firm's cash flow from its operating subsidiaries. + +Read full article » + +# CANNABIS + +# Pot Atty Wants Canopy Added To \$200M Suit Against Acreage + +A cannabis attorney claiming he holds a financial stake in one of the original licensed medical marijuana businesses in New York asked to add pot giant Canopy Growth as a defendant in a sprawling, yearslong, \$200 million lawsuit. + +2 documents attached I Read full article » + +# INTERNATIONAL ARBITRATION + +Charlesbank Capital Partners LLC + +China International Economic and Trade Arbitration Commission + +Citigroup Inc. + +Crum & Forster Holdings Corp. + +DuPont de Nemours Inc. + +Early Warning Services LLC + +Global Brands Group Holding Ltd. + +Goodyear Tire & Rubber Co. + +HDI Global Specialty SE + +Highgate Hotels Inc. + +Iconix Brand Group, Inc. + +KSL Capital Partners LLC + +Kenneth Cole Productions Inc. + +Kona Grill Inc. + +Lexington Insurance Co. + +LexisNexis Group + +Li & Fung Ltd. + +Medley Management Inc. + +MetLife Inc. + +Metropolitan Transportation + +Authority + +National Basketball Players Association + +New York Knicks + +New York Law School + +QUALCOMM Inc. + +RELX PLC + +Securities Investor Protection Corp. + +Spirit Airlines Inc. + +Tampa International Airport + +The Goldman Sachs Group Inc. + +The Great Atlantic & Pacific Tea Company, Inc. + +United Overseas Bank + +Wellpath + +#### GOVERNMENT AGENCIES + +Centers for Disease Control and Prevention + +District Council 37 + +Equal Employment Opportunity Commission + +Federal Bureau of Investigation + +Federal Communications Commission + +Federal Reserve System + +Financial Crimes Enforcement Network + +Montana Attorney General's Office + +A New York federal judge won't let Preble-Rish Haiti SA pause its \$23 million award enforcement suit against the Haitian government, ruling Tuesday that the engineering firm most likely won't succeed while appealing for discovery access to the country's central bank funds. + +Opinion attached I Read full article » + +# TELECOMMUNICATIONS + +#### Altice Hit With Suit Over Canceled Internet During Pandemic + +Altice USA has been hit with a proposed class action accusing the telecommunications company of cutting off internet and phone service to its customers during the COVID-19 pandemic, despite signing a Federal Communications Commission pledge not to do so. + +Complaint attached I Read full article + +# PEOPLE + +# Cipriani & Werner Adds Ex-Manhattan DA To Cyber Team + +Pittsburgh-based Cipriani & Werner continued its growth this year with the addition of a former Manhattan district attorney with over a decade of experience working on a variety of enforcement and cybersecurity matters to its Philadelphia office, the firm announced Tuesday. + +Read full article » + +# PRACTICAL GUIDANCE + +# Structured Ch. 11 Dismissals Aren't Dead, Despite Jevic + +A New York bankruptcy court's recent approval of structured Chapter 11 dismissals in KG Winddown demonstrates that the rumored demise of such distributions hasn't come to pass, in part due to the U.S. Supreme Court's failure to address their legality in its 2017 opinion in Jevic, say Dan Prieto and Mark Douglas at Jones Day. + +Read full article » + +# LEGAL INDUSTRY + +# These 4 Law Firms Are The Most 'Fearsome' + +Four law firms were dubbed the most "fearsome" to face off against in court, according to a new report by BTI Consulting Group coming out Thursday. + +Read full article » + +# Litigation Spending Outpaces Case Growth In US + +For the first time in nearly a decade, the amount of money being spent on litigation in the United States is outpacing the growth in cases, a new report shows. + +Read full article » + +# Sussmann Seeks Clarity On 'Vague,"Confusing' Indictment + +Former Perkins Coie LLP partner Michael Sussmann asked a D.C. federal court on Wednesday to require the U.S. Department of Justice to provide more specificity to the "vague" and "confusing" indictment that accuses the cybersecurity expert of lying to the FBI in the run-up to the 2016 presidential election. + +Read full article » + +# BigLaw Wants 'Unicorn' In Ga. Mergers, Comes Up Short + +There's an appetite among large law firms to enter or grow in the Georgia legal market through a combination, but for many firms the perfect acquisition partner either doesn't exist or isn't interested, local legal recruiters say. + +U.S. Attorney's Office for the District of Massachusetts + +U.S. Attorney's Office for the Southern District of New York + +U.S. Bankruptcy Court for the District of Delaware + +U.S. Bankruptcy Court for the Southern District of New York + +U.S. Court of Appeals for the District of Columbia Circuit + +U.S. Court of Appeals for the Second Circuit + +U.S. Department of Justice + +U.S. Department of Labor + +U.S. Department of the Treasury + +U.S. District Court for the District of Columbia + +U.S. District Court for the Eastern District of New York + +U.S. District Court for the Southern District of New York + +U.S. Securities and Exchange Commission + +U.S. Senate + +U.S. Supreme Court + +U.S. District Judge Lucy H. Koh, one of President Joe Biden's nominees for the Ninth Circuit, defended herself against criticism from Republicans over her decision upholding California COVID-19 restrictions on indoor at-home religious gatherings when she testified before a Senate panel considering her nomination Wednesday. + +Read full article » + +#### Atty Tardiness Leads Court To Nix Quinn Emanuel Bias Suit + +The D.C. Circuit declined Wednesday to revive a fired associate's race and gender discrimination lawsuit against Quinn Emanuel Urquhart & Sullivan, scolding the attorney for repeatedly missing deadlines in her appeal and ignoring the court's warnings about her tardiness. + +Read full article » + +# ABA To Attorneys: When In Doubt, Use A Translator + +If there is any uncertainty surrounding a client's ability to understand the case against them or their attorney's advice, that lawyer should err on the side of caution and hire a translator, an American Bar Association panel said in newly issued guidelines. + +Read full article » + +## Montana Firm Challenges State's Employer Vax Mandate Ban + +A Montana-based law firm asked a state court on Tuesday to do away with the state's ban on employer vaccine mandates, claiming the measure runs afoul of Montana's constitution and places its employees at "increased risk to their health and safety." + +Read full article » + +#### JOBS + +Search full listings or advertise your job opening + +Not sure if your firm subscribes? 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It seems like an excellent and very important case! I'm glad (and unsurprised) to see you are doing so well up there. + +Best regards, + +Anthony + +Special Assistant United States Attorney Eastern District of Virginia \ No newline at end of file diff --git a/marker2/ds9/EFTA00083564/EFTA00083564.metadata.json b/marker2/ds9/EFTA00083564/EFTA00083564.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..af0966db22f6b162ae37e2f27b2b7c2291e53d7b --- /dev/null +++ b/marker2/ds9/EFTA00083564/EFTA00083564.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083564.pdf", + "engine": { + "marker_major": "2", + "marker_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": 342, + "elapsed_seconds": 0.69, + "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/EFTA00083564" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083565/EFTA00083565.md b/marker2/ds9/EFTA00083565/EFTA00083565.md new file mode 100644 index 0000000000000000000000000000000000000000..2680b81dd4221d74e0363ea9d1793252e8003103 --- /dev/null +++ b/marker2/ds9/EFTA00083565/EFTA00083565.md @@ -0,0 +1,27 @@ +To: + +Subject: FW: Epstein + +Date: Fri, 09 Aug 2019 00:00:24 +0000 + +Accidentally left you off the cc + +From + +Sent: Thursda , Au ust 8, 2019 8:00 PM + +To: + +Subject: FW: Epstein + +FYI --- please reach out, and sounds like you should have an agent on the line. + +From: Berman, Geoffrey (USANYS) III. + +Sent: Thursday, August 8, 2019 7:5 + +To; + +Subject: Epstein + +A friend of mine from NJ was contacted by a NJ doctor and businessman who he knows, ho says he wants to connect the SDNY with a NY-based Canadian who supposedly has information relevant to Epstein. is a somewhat sketchy guy, but it's probably worth calling him to follow up. His cell is Geoff \ No newline at end of file diff --git a/marker2/ds9/EFTA00083565/EFTA00083565.metadata.json b/marker2/ds9/EFTA00083565/EFTA00083565.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..12b02cef755b6b37c619fb4284a46ad854b989c1 --- /dev/null +++ b/marker2/ds9/EFTA00083565/EFTA00083565.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083565.pdf", + "engine": { + "marker_major": "2", + "marker_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": 643, + "elapsed_seconds": 0.76, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 36 + ], + [ + "Line", + 18 + ], + [ + "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/EFTA00083565" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083566/EFTA00083566.md b/marker2/ds9/EFTA00083566/EFTA00083566.md new file mode 100644 index 0000000000000000000000000000000000000000..1b46ba292cbd6f88f22753182fd999a8407b132d --- /dev/null +++ b/marker2/ds9/EFTA00083566/EFTA00083566.md @@ -0,0 +1,300 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO. 08-80736-CIV-MARRA + +JANE DOE 1 AND JANE DOE 2, + +Petitioners, + +vs. + +UNITED STATES, + +Respondent. + +### OPINION AND ORDER + +This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Partial Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE 408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and Jane Doe 2's Motion for Finding Waiver of Work Product and Similar Protections by Government and for Production of Documents (DE 414). The Motions are fully briefed and ripe for review. The Court has carefully considered the Motions and is otherwise fully advised in the premises. + +# I. Background + +The facts, as culled from affidavits, exhibits, depositions, answers to interrogatories and reasonably inferred, for the purpose of these motions, are as follows: + +From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls, including Petitioners Jane Doe 1 and Jane Doe 2 (hereinafter, "Petitioners"), at his mansion in Palm Beach, Florida, and elsewhere in the United States and overseas. (Government Resp. to Petitioner's Statement of Undisputed Material Facts (hereinafter, "DE 407" at 9 1.) Because + +Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they committed violations of not only Florida law, but also federal law. (DE 407 at ¶ 2.) In addition to his own sexual abuse of the victims, Epstein directed other persons to abuse the girls sexually. (DE 407 at ¶ 3.) Epstein used paid employees to find and bring minor girls to him. Epstein worked in concert with others to obtain minors not only for his own sexual gratification, but also for the sexual gratification of others. (DE 407 at ¶ 8.) + +In 2005, the Town of Palm Beach Police Department ("PBPD") received a complaint from the parents of a 14 year old girl about her sexual abuse by Jeffery Epstein. The PBPD ultimately identified approximately 20 girls between the ages of 14 and 17 who were sexually abused by Epstein. (DE 407 at ¶ 4.) In 2006, at the request of the PBPD, the Federal Bureau of Investigation ("FBI") opened an investigation into allegations that Epstein and his personal assistants used the facilities of interstate commerce to induce girls between the ages of 14 and 17 to engage in illegal sexual activities. (DE 407 at ¶ 5.) The FBI ultimately determined that both Jane Doe 1 and Jane Doe 2 were victims of sexual abuse by Epstein while they were minors. Jane Doe 1 provided information about her abuse and Jane Doe 2% abuse to the FBI on August 7, 2007. (DE 407 at ¶ 6.) + +From January of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to present during a meeting at the Office the same day. (DE 407 at ¶ 10.) + +By March 15, 2007, the Office was sending letters to victims informing them of their rights pursuant to the Crime Victims' Rights Act ("CVRA"). (DE 407 at ¶ 11.) By May of 2007, the Office had drafted an 82-page prosecution memorandum and a 53-page indictment outlining numerous federal sexual offenses committed by Epstein. (DE 407 at ¶ 12.) On or about June 7, 2007, FBI agents had delivered to Jane Doe 1 a standard CVRA victim notification letter.' The notification letter promised that the Justice Department would make its "best efforts" to protect Jane Doe l's rights, including "the reasonable right to confer with the attorney for the United States in the case" and " to be reasonably heard at any public proceeding in the district court involving [a] ... plea." The notification further stated that, "[a]t this time, your case is under investigation." (DE 407 at ¶ 13.) Jane Doe 1 relied on those representations and believed that the Government would protect those rights and keep her informed about the progress of her case. (DE 407 at ¶ 14.) + +On July 6, 2007, Epstein's lawyers sent a 23-page letter lodging numerous arguments to persuade the Office that no federal crimes had been committed by him. (DE 407 at ¶ 15.) By August 3, 2007, the Government had rejected Epstein's various arguments against federal + +Initially, Jane Doe 2 was unwilling to provide any information to the FBI or the Office unless she was assured her statements would not be used against her. She also described Epstein as "an awesome man" and stated that she hoped "nothing happens to" him. (DE 415 at ¶¶ 14- 15.) This was during the time period where Jane Doe 2 had obtained counsel paid for by Epstein. (Jane Doe 2 Dec1.11 5-7.) + +Assistant United States Attorney ("AUSA") ("line prosecutor" "Villafaiia") testified that both Jane Doe 1 and Jane Doe 2 received letters describing their rights under the CVRA. Although Jane Doe 1 and 2 were given and the FBI agent's name and phone number, neither contacted either of them. 5, DE 403-19.) + +On or about August 11, 2006, Jane Doe 2 received the same CVRA letter. (DE 407 at ¶ 7.) + +charges and sent a letter to Epstein's counsel stating, "[w]e would reiterate that the agreement to Section 2255 [a civil restitution provision] liability applies to all of the minor girls identified during the federal investigation, not just the 12 that form the basis of an initial planned charging instrument." (DE 407 at ¶ 17.) On September 10, 2007, multiple drafts of a non-prosecution agreement ("NPA") had been exchanged between Epstein's counsel and the Office. (DE 407 at 18.) + +On September 12, 2007, while attempting to create alternative charges against Epstein, the Office expressed concern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territorial jurisdiction of the United States" because the Government had "no evidence of any assaults occurring either on Mr. Epstein's plane or offshore from his residence." (DE 407 at ¶ 19.) On September 13, 2007, the line prosecutor emailed Epstein's counsel indicating an effort to come up with a solution to the aforementioned concern and she stated that she had been "spending some quality time with Title 18 looking for misdemeanors." The line prosecutor further indicated, "I know that someone mentioned there being activity on an airplane. I just want to make sure that there is a factual basis for the plea that the agents can confirm." Epstein's counsel responded, "[a]lready thinking about the same statutes." (DE 407 at ¶ 20.) + +On September 14, 2007, after having spoken on the telephone about the subject matter of the September 13 emails, Epstein's counsel and the line prosecutor exchanged emails including a proposed plea agreement for Epstein to plead guilty to assaulting one of his coconspirators. (DE 407 at ¶ 21.) On September 15, 2007, the line prosecutor sent an email to the Epstein defense team raising concerns about a resolution that would not involve one of + +Epstein's minor victims and stating: + +I have gotten some negative reaction to the assault charge with [a co-conspirator] as the victim, since she is considered one of the main perpetrators of the offenses that we planned to charge in the indictment. Can you talk to Mr. Epstein about a young woman named [Jane Doe]? We have hearsay evidence that she traveled on Mr. Epstein's airplane when she was under 18, in around the 2000 or 2001 time frame. + +(DE 407 at 122.) + +On September 16, 2007, the line prosecutor corresponded with Epstein's counsel about having Epstein plead guilty to obstruction of justice for pressuring one of his co-conspirators not to turn over evidence or complying with a previously-served grand jury subpoena. (DE 407 at 123.) The Office also stated, "On an 'avoid the press' note, I believe that Mr. Epstein's airplane was in Miami on the day of the [co-conspirator] telephone call. If he was in Miami-Dade County at the time, then I can file the charge in the District Court in Miami, which will hopefully cut the press coverage significantly." They also discussed having Epstein plead guilty to a second charge of assaulting a different co-conspirator. (DE 407 at 1 24.) + +On September 16, 2007, the line prosecutor wrote to Epstein's counsel indicating that the Office did not like the factual basis for the proposed charges as the Office was "not investigating Mr. Epstein [for] abusing his girlfriend." (DE 407 at 11- 25.) The correspondence further stated: + +Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are tying to create federal jurisdiction for prison purposes. + +I will include our standard language regarding resolving all criminal liability and I will mention `co-conspirators,' but I would prefer not to highlight for the judge all of the other crimes and all of the other persons that we could charge. Also, we do not have the power to bind Immigration . . . there is no plan to try to proceed on any immigration charges against either Ms. [co-conspirator] or Ms. [coconspirator] + +(Ex. 7, DE 361-7.) + +In the same email, the line prosecutor wrote to defense counsel about a meeting outside the U.S. Attorney's Office: "Maybe we can set a time to meet. If you want to meet 'off campus' somewhere, that is fine." (DE 407 at ¶ 27.) On about September 16, 2007, Epstein's counsel provided a proposed NPA to the Government that extended immunity from federal prosecution not only to Epstein, but also to certain co-conspirators. (DE 407 at ¶ 28.) + +On September 17, 2007, the line prosecutor wrote to defense counsel Jay Lefkowitz: "Please send [a document] to my home e-mail address — [redacted] and give me a call on my cell [redacted] so I can be ready for some discussions tomorrow." (DE 407 at ¶ 29.) On September 17, 2007, Lefkowitz responded: "[D]o you have another obstruction proffer I can review that you have drafted? Also, if we go that route, would you intend to make the deferred prosecution agreement public?" (DE 407 at ¶ 30.) + +On September 18, 2007, the Office responded: "A non-prosecution agreement would not be made public or filed with the Court, but it would remain part of our case file. It probably would be subject to a FOIA request, but it is not something that we would distribute without compulsory process." (DE 407 at ¶ 31.) On September 20, 2007, the U.S. Attorney's Office wrote: "On the issue about 18 USC 2255, we seem to be miles apart. Your most recent version not only had me binding the girls to a trust fund administered by the state court, but also promising that they will give up their 2255 rights.... In the context of a non-prosecution agreement, the office may be more willing to be specific about not pursuing charges against others." (DE 407 at ¶ 32.) + +On September 21, 2007, Palm Beach County State Attorney Barry Krischer wrote the line prosecutor about the proposed agreement and added: "Glad we could get this worked out for reasons I won't put in writing. After this is resolved I would love to buy you a cup at Starbucks and have a conversation." (DE 407 at ¶ 33.) On September 21, 2007, the line prosecutor emailed Epstein's counsel stating, "I think that the attached addresses the concerns about having an unlimited number of claimed victims, without me trying to bind girls whom I do not represent." (DE 407 at ¶ 34.) On September 23, 2007, the U.S. Attorney's Office sent an email to Lefkowitz stating: "It is factually accurate that the list we are going to give you are persons we have identified as victims. If we did not think they were victims, they would have no right to bring suit." (DE 407 at ¶ 35.) + +On September 24, 2007, the line prosecutor sent an e-mail to a prospective representative for the Epstein victims, entitled "Conflict Check." The email confirmed the girls' status as victims, stating: "Please keep this confidential because these are minor victims. This is a preliminary list." Later on September 24, 2007, the line prosecutor sent an email to Lefkowitz stating: "I have compiled a list of 34 confirmed minors." (DE 407 at ¶ 36.) As correspondence continued on September 24, 2007, and the NPA was being executed, Lefkowitz sent an email to the line prosecutor stating: "Marie — Please do whatever you can to keep this i.e. the NPA] from becoming public." (DE 407 at ¶ 37.) + +On September 24, 2007, Epstein and the Office formally reached an agreement whereby the United States would defer federal prosecution in favor of prosecution by the State of Florida. Epstein and the Office accordingly entered into a NPA reflecting such an agreement. (DE 407 at ¶ 38.) The NPA provided that "the United States, in consultation with and subject to the good faith approval of Epstein's counsel, shall select an attorney representative for [the victims], who shall be + +paid for by Epstein." The NPA also provided that if any of the victims elected to bring suit under 18 U.S.C. § 2255, they must agree to waive any other claim for damages. As part of the NPA, Epstein would not contest the jurisdiction of the United States District Court and waived his right to contest liability and damages. (NPA, DE 361-62.) + +Among other provisions, the NPA expanded immunity to any "potential coconspirator" of Epstein's: "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 + +(DE 407 at ¶ 40.) The NPA also provided that: "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." (DE 407 at ¶ 41.) + +From the time the FBI began investigating Epstein until September 24, 2007—when the NPA was concluded—the Office never conferred with the victims about a NPA or told the victims that such an agreement was under consideration. (I Dec1.1 7, DE 361-64; DE 407 at ¶ 43.) Many, if not all, other similarly-situated victims received standard CVRA victim notification letters substantively identical to those sent to Jane Doe 1 and Jane Doe 2. (DE 407 at ¶ 44.) The Office did not consult or confer with any of the victims about the NPA before it was signed. (DE 407 at ¶T 45-46.) + +Epstein's counsel was aware that the Office was deliberately keeping the NPA secret from the victims and, indeed, had sought assurances to that effect. (DE 407 at ¶ 48.) After the NPA was signed, Epstein's counsel and the Office began negotiations about whether the victims would be told about the NPA. (DE 407 at ¶ 49.) It was a deviation from the Government's standard practice to negotiate with defense counsel about the extent of crime victim notifications. (DE 407 at ¶ 50.) + +On September 24, 2007, the Office sent an email to Lefkowitz: + +Thank you, Jay. I have forwarded your message only to [United States Attorney] Alex [Acosta], Andy, and Roland. I don't anticipate it going any further than that. When I receive the originals, I will sign and return one copy to you. The other will be placed in the case file, which will be kept confidential since it also contains identifying information about the girls. + +When we reach an agreement about the attorney representative for the girls, we can discuss what I can tell him and the girls about the agreement. I know that Andy promised Chief Reiter an update when a resolution was achieved.... Rolando is calling, but Rolando knows not to tell Chief Reiter about the money issue, just about what crimes Mr. Epstein is pleading guilty to and the amount of time that has been agreed to. Rolando also is telling Chief Reiter not to disclose the outcome to anyone. + +(DE 407 at ¶ 52.) + +On September 25, 2007, the line prosecutor sent an e-mail to Lefkowitz stating: "And can we have a conference call to discuss what I may disclose to . . . the girls regarding the agreement." (DE 407 at ¶ 53.) Also on September 25, 2007, the line prosecutor sent an email to Lefkowitz which stated in part: "They [Ted Babbitt, Stuart Grossman, Chris Searcy, [L]ake Lytal] are all very good personal injury lawyers, but I have concerns about whether there would be an inherent tension because they may feel that THEY might make more money (and get a lot more press coverage) if they proceed outside the Terms of the plea agreement. (Sony — I just have a bias against plaintiffs' attorneys.) One nice thing about Bert is that he is in Miami where there has been almost no coverage of this case." (DE 407 at ¶ 54.) + +On September 26, 2007, the line prosecutor sent an e-mail to Lefkowitz in which she + +stated: "Hi Jay — Can you give me a call at 561-[xxx-xxxx] this morning? I am meeting with the agents and want to give them their marching orders regarding what they can tell the girls." (DE 407 at ¶ 55.) On September 27, 2007, the attorney representative for the victims emailed the Office and asked whether he could get a copy of the indictment or plea agreement to find out "exactly what Epstein concedes to in the civil case." (Sept. 27, 2007 email, DE 362-2.) Upon inquiry from the Office, Lefkowitz responded by stating that the attorney representative "certainly [] should not get a copy of any indictment." (DE 407 at ¶ 57.) That same day, the line prosecutor informed Epstein's counsel of concerns raised by the attorney representative for the girls. Specifically, "[t]he concern is, if all 40 girls decide they want to sue, they don't want to be in a situation where Mr. Epstein says this is getting too expensive, we won't pay anymore attorneys' fees." (DE 407 at ¶ 58.) + +Also on that same day, the line prosecutor sent an email to state prosecutors= : "Can you let me know when Mr. Epstein is going to enter his guilty plea and what judge that will be in front of? I know the agents and I would really like to be there, 'incognito.'" (DE 407 at ¶ 59.) + +On October 3, 2007, the Office sent a proposed letter that would have gone to a special master for selecting an attorney representative for the victims under the NPA's compensation procedure. The letter described the facts of the Epstein case as follows: "Mr. Epstein, through his assistants, would recruit underage females to travel to his home in Palm Beach to engage in lewd conduct in exchange for money. Based upon the investigation, the United States has identified 40 young women who can be characterized as victims pursuant to 18 U.S.C. § 2255. Some of those women went to Mr. Epstein's home only once, some went there as many as 100 times or more. Some + +of the women's conduct was limited to performing a topless or nude massage while Mr. Epstein masturbated himself. For other women, the conduct escalated to full sexual intercourse." (DE 407 at ¶ 60.) + +On October 10, 2007, Lefkowitz sent a letter to U.S. Attorney Alex Acosta stating, in pertinent part: "Neither federal agents nor anyone from your Office should contact the identified individuals to inform them of the resolution of the case, including appointment of the attorney representative and the settlement process. Not only would that violate the confidentiality of the agreement, but Mr. Epstein also will have no control over what is communicated to the identified individuals at this most critical stage. We believe it is essential that we participate in crafting mutually acceptable communication to the identified individuals." The letter further proposed that the attorney representative for the victims be instructed that "[t]he details regarding the United States's investigation of this matter and its resolution with Mr. Epstein is confidential. You may not make public statements regarding this matter." (DE 407 at ¶ 61.) + +U.S. Attorney Acosta then met with Lefkowitz for breakfast and Lefkowitz followed up with a letter stating, "I also want to thank you for the commitment you made to me during our October 12 meeting in which you ... assured me that your Office would not ... contact any of the identified individuals, potential witnesses, or potential civil claimants and their respective counsel in this matter." (DE 407 at ¶ 63.) + +On October 24, 2007, AUSA .\_sent a letter to Jay Lefkowitz, proposing an addendum to the NM clarifying the procedures for the third-party representative for the victims under the NPA's compensation provisions. (DE 407 at ¶ 64.) On October 25, 2007, AUS sent a letter to Retired Judge selecting an attorney to represent the victims tinder the NPA's compensation procedure. (DE 407 at ¶ 65.) + +On about October 26 or 27, 2007, Special Agents and met in person with Jane Doe 1. They explained that Epstein would plead guilty to state charges, he would be required to register as a sex offender for life, and he had made certain concessions related to the payment of damages. (DE 407 at ¶ 70.) According to Jane Doe 1, the Agents did not explain that the NPA had already been signed. (Jane Doe 1 Decl. ¶ 5, DE 361-26.) Jane Doe 1's understanding was that the federal investigation would continue. (Jane Doe 1 Decl. ¶ 6.) In contrast, Special Agent ated that the meeting with Jane Doe 1 was to advise her of the main terms of the NPA.2 Decl. ¶ 8, DE 403-18.) After the meeting, Special Agent ecame concerned about what would happen if Epstein breached the NPA, and thought that if the victims were aware of the NPA, the provision about monetary damages could be grounds for impeachment of the victims and herself. ()ecl. ¶ 9.) According to Special Agent the investigation of Epstein continued through 2008. Sea ¶ II.) + +In addition to Jane Doe I, FBI agents only talked to two other victims out of the 34 identified victims about the "general terms" of the NPA, including the provision providing a federal civil remedy to the victims. (DE 407 at ¶ 76.) After these meetings with three victims, Epstein's defense team complained. (DE 407 at ¶ 77.) + +On about November 27, 2007, AUSA Sloman sent an e-mail to Lefkowitz, (with a copy to U.S. Attorney Acosta) stating that the Office had a statutory obligation to notify the victims about Epstein's plea to state charges that was part of the NPA: + +2 Special Agent also stated that on August 7, 2007, Jane Doe 1 never asked to confer with anyone from the government about charging decisions or any resolution of the matter. ( Decl. ¶ 7.) + +The United States has a statutory obligation (Justice for All Act of 2004) to notify the victims of the anticipated upcoming events and their rights associated with the agreement entered into by the United States and Mr. Epstein in a timely fashion. Tomorrow will make one full week since you were formally notified of the selection. I must insist that the vetting process come to an end. Therefore, unless you provide me with a good faith objection to Judge Davis's selection [as special master for selecting legal counsel for victims pursuing claims against Epstein] by COB tomorrow, November 28, 2007, I will authorize the notification of the victims. Should you give me the go-head on [victim representative] . . . selection by COB tomorrow, I will simultaneously send you a draft of the letter. I intend to notify the victims by letter after COB Thursday, November 29th. + +(DE 407 at ¶ 79.) + +On November 28, 2007, the Government sent an email to Lefkowitz attaching a letter dated November 29, 2007 (the apparent date upon which it was intended to be mailed) and explained that "I am writing to inform you that the federal investigation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing the following terms." The proposed letter then spelled out a number of the provisions in the NPA, including that because Epstein's plea of guilty to state charges was "part of the resolution of the federal investigation," the victims were "entitled to be present and to make a statement under oath at the state sentencing." (DE 407 at ¶ 80.) + +On November 29, 2007, Lefkowitz sent a letter to U.S. Attorney Acosta objecting to the proposed victim notification letter, stating that it is inappropriate for any letter to be sent to the victims before Epstein entered his plea or had been sentenced. Lefkowitz also told the Government that the victims should not be invited to the state sentencing, that they should not be encouraged to contact law enforcement officials, and that encouraging the attorney representative to do anything other than get paid by Epstein to settle the cases was to encourage an ethical conflict. (DE 407 at ¶ 82.) + +On about November 30, 2007, U.S. Attorney Acosta sent a letter to one of Epstein's defense attorneys, Kenneth Starr, stating: "I am directing our prosecutors not to issue victim notification letters until this Friday at 5 p.m., to provide you with time to review these options with your client." The letter also explained that the line prosecutor had informed U.S. Attorney Acosta "that the victims were not told of the availability of Section 2255 relief during the investigation phase of this matter" despite the fact that the "[r]ule of law . . now requires this District to consider the victims' rights under this statute in negotiating this Agreement." (DE 407 at ¶ 83.) On December 5, 2007, Starr sent a letter to U.S. Attorney Acosta (with copy to AUSA Sloman) asking about issuance of victim notification letters and stating: "While we believe that it is wholly inappropriate for your Office to send this letter under any circumstances, it is certainly inappropriate to issue this letter without affording us the right to review it." (DE 407 at ¶ 85.) + +On about December 6, 2007, AUSA Sloman sent a letter to Lefkowitz stating in part: + +[E]ach of the listed individuals are persons whom the Office identified as victims. [T] he Office is prepared to indict Mr. Epstein based upon Mr. Epstein's `interactions' with these individuals. This conclusion is based upon a thorough and proper investigation - one in which none of the victims was informed of any right to receive damages of any amount prior to the investigation of her claim. + +[T]he Office can say, without hesitation, that the evidence demonstrates that each person on the list was a victim of Mr. Epstein's criminal behavior. + +Finally, let me address your objections to the draft Victim Notification Letter. You write that you don't understand the basis for the Office's belief that it is appropriate to notify the victims. Pursuant to the 'Justice for All Act of 2004,' crime victims are entitled to: 'The right to reasonable, accurate, and timely notice of any public court proceeding ... involving the crime' and the 'right not to be excluded from any such public court proceeding....' 18 U.S.C. § 3771(a)(2) & (3). Section 3771 also commands that 'employees of the Department ofJustice ... engaged in the detection, investigation, or prosecution of crime shall make their best efforts to see that crime + +victims are notified of, and accorded, the rights described in subsection (a).' 18 U.S.C. § 377I(c)(1).... + +With respect to notification of the other information that we propose to disclose, the statute requires that we provide a victim with the earliest possible notice of: the status of the investigation, the filing of charges against a suspected offender, and the acceptance of a plea. 42 U.S.C. I 0607(c)(3). Just as in 18 U.S.C. 3771, these sections are not limited to proceedings in a federal district court. Our Non-Prosecution Agreement resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identified through the federal investigation should be appropriately informed, and our Non-Prosecution Agreement does not require the U.S. Attorney's Office to forego its legal obligations. [T]he Office believes that it has proof beyond a reasonable doubt that each listed individual was a victim of Mr. Epstein's criminal conduct while the victim was a minor. The law requires us to treat all victims "with fairness and with respect for the victim's dignity and privacy." 18 U.S.C. 3771(a)(8). + +The letter included a footnote stating: "Unlike the State's investigation, the federal investigation shows criminal conduct by Mr. Epstein at least as early as 2001, so all of the victims were minors at the time of the offense." (DE 407 at ¶ 83.) + +On December 7, 2007, defense attorney Lilly Ann Sanchez sent a letter to AUSA Sloman, requesting "that the Office hold off on sending any victim notification letters." No letters were sent in December of 2007. (DE 407 at ¶ 88.) On December 13, 2007, the line prosecutor sent a letter to Lefkowitz stating that "You raised objections to any victim notification, and no further notifications were done." (DE 407 at ¶ 89.) On December 19, 2007, U.S. Attorney Acosta sent a letter to Lilly Ann Sanchez stating, "I understand that the defense objects to the victims being given notice of time and place of Mr. Epstein's state court sentencing hearing. We intend to provide victims with notice of the federal resolution, as required by law. We will defer to the discretion of the State Attorney regarding whether he wishes to provide victims with notices of the state proceedings. (DE 407 at ¶ 90.) + +In January of 2008, any requirement that Epstein carry out his obligations under the NPA was delayed while he sought higher level review within the Justice Department. (DE 407 at ¶ 92.) On January 10, 2008, Jane Doe 1 and Jane Doe 2 were sent victim notification letters from the FBI advising them that It]his case is currently under investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation." (DE 407 at ¶ 93.) The January 10, 2008 notification letters did not disclose that the Jane Doe 1 and Jane Doe 2 case in the Southern District of Florida was the subject of the NPA entered into by Epstein and the Office, or that there had been any potentially binding resolution. (DE 407 at ¶ 94.) Other victims received the same letters as sent to Jane Doe 1 and Jane Doe 2. (DE 407 at ¶ 95.) + +According to the declaration of Jane Doe 1, she believed that criminal prosecution of Epstein was important and she wanted to be consulted by prosecutors before any resolution. Based on the letters received, she believed the Government would contact her before reaching any final resolution. (Jane Doe 1 Decl. ¶ 9.) On January 31, 2008, Jane Doe 1 met with FBI Agents and an AUSA from the U.S. Attorney's Office. She provided additional details of Epstein's sexual abuse of her. The AUSA did not disclose to Jane Doe 1 at this meeting that they had already negotiated a NPA with Epstein. (DE 407 at ¶ 97.) According to the declaration of Jane Doe 2, while she recognizes she did not initially help the investigation, she later tried to cooperate with the investigation but was never given an opportunity to cooperate with the investigation.' (Jane Doe 2 + +The Government believed that a negotiated resolution was in the best interest of the Office and the victims as a whole based on information obtained from the victims and the agents assigned to the case. (Villafafia Decl. ¶ 19.) The Government also believed that Epstein was trying to set aside the NPA and therefore the Government needed to be prepared for a prosecution. (Villafaiia Decl. ¶ 34.) Petitioners object to this evidence, claiming the Government previously claimed work product and similar protections over internal materials. Given that the Court is ruling in favor of Petitioners on the present motions, the Court need not address this + +Decl. 13-14, DE 361-27.) + +On March 19, 2008, the line prosecutor sent a lengthy email to a prospective pro bono attorney for one of Epstein's victims who had been subpoenaed to appear at a deposition. The email listed the attorneys representing Epstein, the targets of the investigation, and recounted in detail the investigation that had been conducted to that point. The email did not reveal the fact that Epstein had signed the NPA in September 2007. (DE 407 at' 98.) + +On May 30, 2008, Jane Doe 5, who was recognized as an Epstein victim by the Office, received a letter from the FBI advising her that "[t]his case is currently under investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation." (DE 407 at ¶ 99.) The May 30, 2008 victim letter to Jane Doe 5 also acknowledged the victims' rights under the CVRA . (DE 407 at ¶ 100.) + +In mid-June of 2008, Mr. Bradley Edwards, the attorney for Petitioners, contacted the line prosecutor to inform her that he represented Jane Doe 1 and, later, Jane Doe 2. Edwards asked to meet to provide information about the federal crimes committed by Epstein against these victims. The line prosecutor and Edwards discussed the possibility of federal charges being filed in the future. Edwards was led to believe federal charges could still be filed, with no mention whatsoever of the existence of the NPA or any other possible resolution to the case. (DE 407 at ¶ 101.) + +At the end of the call, the line prosecutor asked Edwards to send any information that he wanted considered by the Office in determining whether to file federal charges. The line prosecutor did not inform Edwards about the NPA. (DE 407 at ¶ 102.) On June 19, 2008, Edwards + +issue. To the extent it might have an impact on future rulings, Petitioners may reassert this argument if and when appropriate. + +sent an email to the line prosecutor requesting to meet and discuss plans. (DE 407 at ¶ 103.) + +On June 23, 2008, the line prosecutor sent an email to Lefkowitz stating that the Deputy Attorney General had completed his review of the Epstein matter and "determined that federal prosecution of Mr. Epstein's case [wa]s appropriate. Accordingly, Mr. Epstein ha[d] until the close of business on Monday, June 30, 2008, to comply with the terms and conditions of the agreement between the United States and Mr. Epstein." (DE 407 at ¶ 105.) + +On or about June 27, 2008, the Office called Edwards to provide notice to his clients regarding the entry of Epstein's guilty plea in state court. (DE 407 at ¶ 107.) According to Edwards, the line prosecutor only told him that Epstein was pleading guilty to state solicitation of prosecution. He was not told that the state plea was related to the federal investigation or that the state plea would resolve the federal crimes. Edwards claims he was not told his clients could address the state court. (Edwards Decl. ¶¶17-18, DE 416-1.) In contrast, the line prosecutor claims she told Edwards that his clients could address the state court. (' Decl. ¶ 38, DE 403-19.) + +On or before June 30, 2008, the Office prepared a draft victim notification to be sent to the victims. The notification was designed to inform the victims of the provisions of the deferral of federal prosecution in favor of state charges. The notification letter began by describing Epstein's guilty plea in the past tense: "On June 30, 2008, Jeffrey Epstein ... entered a plea of guilty to violations of Florida statutes forbidding the solicitation of minors to engage in prostitution and felony solicitation of prostitution." Later, a substantively identical letter was prepared for Epstein's and his counsel's review. (DE 407 at ¶ 110.) + +On June 30, 2008, the Office sent an e-mail to Epstein's counsel: "The FBI has received several calls regarding the Non-Prosecution Agreement. I do not know whether the title of the document was disclosed when the Agreement was filed under seal, but the FBI and our office are declining comment if asked." (DE 407 at ¶ 111.) That same day, Epstein pled guilty to state law solicitation of prostitution charges. (DE 407 at ¶ 112.) Immediately following the June 30, 2008 hearing, the line prosecutor told one of the victims' attorneys that Epstein had "pled guilty today in state court." (DE 407 at ¶ 113.) Also after the plea, the line prosecutor emailed the assistant state attorney a copy of the NPA to be filed under seal. (July 1, 2008 email, DE 362-38.) + +On June 30, 2008, based on what she had been told by the Government, Jane Doe 1 thought that the Office was still investigating and pursuing her case. She did not receive notice that Epstein's state guilty plea affected her rights in any way. If she had been told that the state plea had some connection to blocking the prosecution of her case, she would have attended and tried to object to the judge to prevent that plea from going forward. (Jane Doe 1 Decl. ¶ 13.) According to the line prosecutor, Edwards did not tell her that Jane Doe 1 wanted to meet with her before a resolution was reached. (Villafaria Decl. ¶ 37, DE 403-19.) + +On July 3, 2008, as specifically directed by the Office, Edwards sent a letter to the Office communicating the wishes of Jane Doe 1, Jane Doe 2, and Jane Doe 5 that federal charges be filed against Epstein: "We urge the Attorney General and our United States Attorney to consider the fundamental import of the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take the steps necessary to protect our children from this very dangerous sexual predator." (DE 407 at ¶ 118.) + +On July 7, 2008, the line prosecutor corresponded with Epstein's counsel seeking his signed agreement concerning a notification letter to the victims before beginning the distribution of that + +letter. (DE 407 at ¶ 120.) That same day, Jane Doe 1 filed an emergency petition for enforcement of her rights under the CVRA. (DE 407 at ¶ 126.) On July 9, 2008, Edwards saw the first reference to the NPA when the Government filed its responsive pleading to Jane Doe's emergency petition. (Edwards Decl. ¶ 21.) + +On July 8, 2008, the line prosecutor sent a letter to Epstein's counsel stating that victims would be informed about the civil compensation provision of the NPA the next day: + +In accordance with the terms of the Non-Prosecution Agreement, on June 30, 2008, the United States Attorney's Office provided you with a list of thirty-one individuals "whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein." ... In deference to your vacation, we allowed you a week to provide us with any objections or requested modifications of the list and/or the Notification language. Yesterday, I contacted you via telephone and e-mail, but received no response. Accordingly, the United States hereby notifies you that it will distribute the victim notifications tomorrow, July 9, 2008, to each of the thirty-two identified victims, either directly or via their counsel. + +(DE 407 at ¶ 127.) + +On July 9, 2008, Epstein's counsel sent a letter to the line prosecutor raising concerns about the notifications, and suggesting modifications to the notification letter. Epstein's counsel also objected to the victim notification letters containing certain information about the NPA. (DE 407 at ¶ 128.) The line prosecutor responded: "Without such an express Acknowledgment by Mr. Epstein that the notice contains the substance of that Agreement, I believe that the victims will have justification to petition for the entire agreement, which is contrary to the confidentiality clause that the parties have signed." (DE 407 at ¶ 129.) That same day, the U.S. Attorney's Office sent victim notification letters to Jane Doe 1 and Jane Doe 5, via their attorney, Edwards, and to other identified victims of Epstein. That notification contained a written explanation of + +some of the civil compensation provisions of the NPA. The notification did not provide the full terms of the NPA. + +On July 10, 2008, Epstein's counsel continued to protest victim notification as evidenced by an email to the line prosecutor stating, "we respectfully request a reasonable opportunity to review and comment on a draft of the modified notification letter you intend to mail before you send it." (DE 407 at ¶ 131.) + +On August 10, 2008, Jane Doe 1 and Jane Doe 2 filed a motion seeking release of the NPA. (DE 407 at ¶ 136.) On August 14, 2008, the line prosecutor emailed Epstein's counsel stating that the court has "ordered us to make the Agreement available to the plaintiffs." (DE 407 at 1 141.) + +On August 18, 2008, Lefkowitz wrote the line prosecutor that Epstein objected to disclosure of the terms of the NPA, but that Epstein would "cooperate with the government to reach an agreement as to substance of the notification to be sent to the government's list of individuals. Based on the Agreement, the information contained in the notification should be limited to (1) the language provided in the Agreement dealing with civil restitution (paragraphs 7-10) and (2) the contact information of the selected attorney representative. We object to the inclusion of additional information about the investigation of Mr. Epstein, the terms of the Agreement other than paragraphs 7-10 and the identity of other identified individuals." (DE 407 at ¶ 143.) On August 21, 2008, the Government sent a letter to Epstein's counsel stating that, "[c]opies of the victim notifications will continue to be provided to counsel for Mr. Epstein." + +Jane Doe 2 was not informed of the contents of the NPA until August 28, 2008, when the line prosecutor provided a copy to Edwards. (DE 407 at ¶ 146.) On September 2, 2008, the line + +prosecutor sent an email to Epstein's counsel stating, "I will start sending out the victim notifications today. In accordance with your request, I have changed the language regarding the victims' right to receive a copy of the Agreement." (DE 407 at ¶ 147.) On September 2 and 3, 2008, the Office sent to Jane Doe 1 and other identified victims amended notification letters, stating "the United States has agreed to defer federal prosecution in favor of this state plea and sentence." (Sept. 3, 2008 letter, DE 363-66; (DE 407 at ¶ 148.) + +On September 16, 2008, attorney Jeffrey Herman, who represented several Epstein victims, wrote to the line prosecutor to object to the restitution procedures established in the NPA after learning that another attorney, established through the NPA, would be making unsolicited contacts to the victims. Mr. Herman explained that the notification letters were "misleading" because they referred generally to a waiver of "any other claim for damages," without informing them that this waiver might include a valuable punitive damages claim against an alleged billionaire. (DE 407 at ¶ 152.) On September 17, 2008, the line prosecutor sent an email to State Attorney Bany Krischer, explaining that the NPA "contain[ed] a confidentiality provision that require[ed] us to inform Mr. Epstein's counsel before making any disclosure." (DE 407 at ¶ 153.) + +Around this same time period, Jane Doe 1 and Jane Doe 2 filed actions in Palm Beach County, seeking money damages from Epstein from sexually abusing them. (Petitioners' Resp. to Gov't's Statement of Undisputed Material Facts (hereinafter "DE 415") at ¶ ¶ 8-9.) Eventually, they received monetary settlements of their lawsuits. (DE 415 at ¶ 12.) + +In moving for summary judgment, the Petitioners make the following arguments in support of their contention that the Government violated their CVRA rights. The Government violated Petitioners' right to confer under the CVRA: (1) when the Government was negotiating and signing the NPA; (2) when the Government sent letters telling Petitioners to be patient while the Government completed its investigation and (3) when the Government did not tell the victims that the state plea would extinguish the federal case. Petitioners also claim the Government violated their right to be treated with fairness under the CVRA by concealing the negotiations of the NPA. Additionally, Petitioners contend the Government violated their rights to reasonable and accurate notice when it concealed that the NPA and the federal investigation were implicated in the state court proceeding. + +In moving for and responding to summary judgment, the Government contends that there is no right to notice or conferral about a NPA; it was reasonable for the Government to send letters to victims while continuing to investigate the case because the Government could not assume that Epstein would plead guilty; and the line prosecutor contacted Petitioners' attorneys about the state court plea hearing. The Government also claims it did not violate the right to reasonable, accurate and timely notice because the CVRA does not create any right to notice of state court proceedings and, in any event, the Government gave notice. The Government asserts it did not treat the victims unfairly and used its best efforts to comply with the CVRA, including complying with the Attorney General's guidelines for victim assistance. Furthermore, the Government argues that Petitioners are equitably estopped from challenging the NPA because they relied upon the NPA in their state court civil actions against Epstein. Lastly, the Government contends that Petitioners are judicially estopped from challenging the validity of the NPA because they have asserted mutually inconsistent positions; namely, that the NPA is invalid in federal court but was binding on Epstein in state court. + +## II. Summary Judgment Standard + +The Court may grant summary judgment "if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed. R. Civ. P. 56(a). The stringent burden of establishing the absence of a genuine issue of material fact lies with the moving party. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). The Court should not grant summary judgment unless it is clear that a trial is unnecessary, Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986), and any doubts in this regard should be resolved against the moving party. Adickes v. S.H. Kress & Co., 398 U.S. 144, 157 (1970). + +The movant "bears the initial responsibility of informing the district court of the basis for its motion, and identifying those portions of [the record] which it believes demonstrate the absence of a genuine issue of material fact." Celotex Corp., 477 U.S. at 323. To discharge this burden, the movant must point out to the Court that there is an absence of evidence to support the nonmoving party's case. Id. at 325. + +After the movant has met its burden under Rule 56(a), the burden of production shifts and the nonmoving party "must do more than simply show that there is some metaphysical doubt as to the material facts." Matsushita Electronic Industrial Co. v. Zenith Radio Corp., 475 U.S. 574, 586 (1986). "A party asserting that a fact cannot be or is genuinely disputed must support the assertion by citing to particular parts of materials in the record . . . or showing that the materials cited do not establish the absence or presence of a genuine dispute, or that an adverse party cannot produce admissible evidence to support the fact." Fed. R. Civ. P. 56(c)(1)(A) and (B). + +Essentially, so long as the non-moving party has had an ample opportunity to conduct discovery, it must come forward with affirmative evidence to support its claim. Anderson, 477 U.S. at 257. "A mere 'scintilla' of evidence supporting the opposing party's position will not suffice; there must be enough of a showing that the jury could reasonably find for that party." Walker v. Darby, 911 F.2d 1573, 1577 (11th Cir. 1990). If the evidence advanced by the nonmoving party "is merely colorable, or is not significantly probative, then summary judgment may be granted." Anderson 477 U.S. 242, 249-50. + +#### III. Discussion + +The CVRA was designed to protect victims' rights and ensure their involvement in the criminal justice process. United States v. Moussaoui, 483 F.3d 220, 234 (4th Cir. 2007); Kenna v. U.S. Dist. Court, 435 F.3d 1011, 1016 (9th Cir. 2006) ("The [CVRA] was enacted to make crime victims full participants in the criminal justice system."). The statute enumerates the following ten rights: + +- (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. + +(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 (42 U.S.C. 10607(c)) and provided contact information for the Office of the Victims' Rights Ombudsman of the Department of Justice. + +18 U.S.C. § 3771(a). + +This Court previously held the following with respect to the CVRA: First, the rights under the CVRA attach before the Government brings formal charges against a defendant. Does v. United States, 817 F. Supp. 2d 1337, 1341 (S.D. Fla. 2011). Second, the CVRA authorizes the rescission or "reopening" of a prosecutorial agreement, including a non-prosecution agreement, reached in violation of a prosecutor's conferral obligations under the statute. Doe v. United States, 950 F. Supp. 2d 1262, 1267 (S.D. Fla. 2013). Third, section 3771(d)(5) of the CVRA authorizes the setting aside of pre-charge prosecutorial agreements, despite the fact that the particular statutory enforcement provision expressly refers to the reopening of a plea or sentence. Id. at 1267. Fourth, the "reasonable right to confer ... in the case" extends to the pre-charge state of criminal investigations and proceedings. Id. Fifth, the federal sex offense crimes involving minors allegedly committed by Epstein renders these Petitioners crime victims under the CVRA. Id. at 1269. Sixth, "questions pertaining to [the] equitable defense[s] are properly left for resolution after development of a full evidentiary record." Id. at 1269 n. 6. + +Here, it is undisputed that the Government entered into a NPA with Epstein without conferring with Petitioners during its negotiation and signing. Instead, the Government sent letters to the victims requesting their "patience" with the investigation even after the Government + +entered into the NPA. At a bare minimum, the CVRA required the Government to inform Petitioners that it intended to enter into an agreement not to prosecute Epstein. Although the binding effect of the NPA was contingent upon Epstein pleading guilty to the state charges, that contingency was out of the control of the Government. The Government's hands were permanently tied if Epstein fulfilled his obligations under the NPA. Thus, Petitioners and the other victims should have been notified of the Government's intention to take that course of action before it bound itself under the NPA. Had the Petitioners been informed about the Government's intention to forego federal prosecution of Epstein in deference to him pleading guilty to state charges, Petitioners could have conferred with the attorney for the Government and provided input. In re Dean 527 F.3d 391, 394 (51b Cir. 2008) (there are rights under the CVRA including the "reasonable right to confer with the attorney for the Government"). Hence, the Government would have been able to "ascertain the victims' views on the possible details of the [non-prosecution agreement]." Id. Indeed, it is this type of communication between prosecutors and victims that was intended by the passage of the CVRA. See United States v. Heaton 458 F. Supp. 2d 1271 (D. Utah 2006)(government motion to dismiss charge of using facility of interstate commerce to entice minors to engage in unlawful sexual activity would not be granted until government consulted with victim); United States v. Ingrassia,No. CR-04-0455ADSJO, 2005 WL 2875220, at \*17 n. 11 (E.D.N.Y. Sept. 7, 2005) (Senate debate supports the view that the contemplated mechanism for victims to obtain information on which to base their input was conferral with the prosecutor concerning any critical stage or disposition of the case). + +Particularly problematic was the Government's decision to conceal the existence of the + +NPA and mislead the victims to believe that federal prosecution was still a possibility.' When the Government gives information to victims, it cannot be misleading. While the Government spent untold hours negotiating the terms and implications of the NPA with Epstein's attorneys, scant information was shared with victims. Instead, the victims were told to be "patient" while the investigation proceeded. + +The Government, however, interprets the CVRA as only obligating the prosecutor to answer inquiries by a crime victim and does not impose a duty on the prosecutor to give notice about case developments, other than what is required in section 3771(a)(2). Such an interpretation is in direct contravention of the intent of the CVRA. See Ingrassia 2005 WL 2875220, at \*17 n.11 (Senate debate explaining the right to confer is "intended to be expansive" including the right of victim to confer "concerning any critical state of disposition of the case"). In any event, no meaningful conferral could take place as long as the Government chose to conceal the existence of the NPA from the victims! + +Nor does the Court agree with the Government that the 2015 amendment to the CVRA, section 3771(a)(9), which gave victims the "right to be informed in a timely manner of any plea + +&#x27; Even if the Court accepted the Government's version of the facts relative to the Agent having told Jane Doe 1 the "main terms" of the NPA (which is left undefined), the victims were not told about it until after it was signed and the Government was bound. This precluded the Government from obtaining any input from the victims. + +\$ The Government devotes time to distinguishing between the words "confer" and "notice" and suggesting that "confer" is more limited in scope than "notice." Nothing about the definition of confer, however, suggests it is limited to one party bearing the burden of communication. See Merriam-Webster Online Dictionary, https://www.meniam-webster.coml dictionary (last visited January 7, 2019) ("to compare views or take counsel"); Blacks Law Dictionary (10\* ed. 2014) ("to hold a conference, to consult with one another"). + +bargain or deferred prosecution agreement" specifically excluded the right of victims to be informed of a non-prosecution agreement. Prior to this amendment, this Court held that the right to confer extended to the pre-charge state of criminal investigations and proceedings. Doe, 950 F. Supp. 2d at 1267; see also 157 Cong. Rec. 57060-01, 157 Cong. Rec. S7060-01, S7060 (CVRA co-sponsor Senator Jon Kyl's 2011 letter to the Attorney General, explaining that "Congress intended the CVRA to broadly protect crime victims throughout the criminal justice process-from the investigative phases to the final conclusion of a case.") + +The 2015 amendment did not serve to repeal or restrict the obligations of the Government to confer with victims in the early stages of a case. Instead, the 2015 amendment clarified that certain events, such as plea agreements or deferred prosecution agreements, must be conveyed to the crime victim. Put another way, the 2015 amendment codified what the courts had been interpreting the CVRA to require, such as entitlement to notice of a plea bargain. See In re Dean, 527 F.3d at 394 ("the government should have fashioned a reasonable way to inform the victims of the likelihood of criminal charges and to ascertain the victims' views on the possible details of a plea bargain"); United States v. Okun, No. CRIM. 3:08CR132, 2009 WL 790042, at \*2 (E.D. Va. Mar. 24, 2009) (the statutory language of the CVRA gives the victims' rights before the accepting of plea agreements). + +To the extent the Government relies upon the "interpretive canon, expressio unius est exclusio alterius, 'expressing one item of [an] associated group or series excludes another left unmentioned' the Court is not persuaded. Chevron U.S.A. Inc. v. Echazabal, 536 U.S. 73, 80 (2002) (quoting United States v. Vonn, 535 U.S. 55, 65 (2002)). "The force of any negative implication ... depends on context." Marx v. General Revenue Corp., 568 U.S. 371, 381 (2013). "[T]he expressio unius canon does not apply unless it is fair to suppose that Congress considered the unnamed possibility and meant to say no to it, and that the canon can be overcome by contrary indications that adopting a particular rule or statute was probably not meant to signal any exclusion." Id. (internal citations and quotation marks omitted). + +The expansive context of the CVRA lends itself to only one interpretation; namely, that victims should be notified of significant events resulting in resolution of their case without a trial. See Kenna v. U.S. Dist. Court for C.D.Cal., 435 F.3d 1011, 1016 (9th Cir. 2006) Mlle statute was enacted to make crime victims full participants in the criminal justice system"); Heaton 458 F. Supp. 2d at 1273 (the right to confer is "not limited to particular proceedings" but is "expansive" and applies broadly to "any critical stage or disposition of the case"). Reading into the statute a negative implication that victims need not be informed of non-prosecution agreements, and only informed of the more common events of plea bargains or deferred prosecution agreements, would be inconsistent with the goal of the CVRA.\* In the context of plea agreements, the CVRA provides victims with rights prior to the acceptance of plea agreements. See In re Dean 527 F.3d at 394; United States v. Okun, No. CRIM. 3:08CR132, 2009 WL 790042, at \*2 (E.D. Va. Mar. 24, 2009). Furthermore, victims obtain rights under the CVRA even before prosecution. Okum, 2009 WL 790042, at '2 (citing In re Dean, 527 F.3d at 394). Based on this authority, the Court concludes that the CVRA must extend to conferral about non-prosecution agreements. + +A NPA entered into without notice has a more damaging impact on the victims than a plea agreement entered into without notice. When a plea agreement is entered into without notice, the victims will at least have an opportunity to provide input to a judge at sentencing. Once a NPA is entered into without notice, the matter is closed and the victims have no opportunity to be heard regarding any aspect of the case. + +Next, the Government claims it did not violate the right to confer when, in January of 2008, it sent letters to the victims counseling patience because, at that time, Epstein's attorneys were seeking review of the NPA at higher levels within the Department of Justice. As indicated previously, however, at this point, the Government had bound itself to the terms of the NPA unless Epstein failed to comply with its terms. It was a material omission for the Government to suggest to the victims that they have patience relative to an investigation about which it had already bound itself not to prosecute. While Epstein was within his rights to attempt to persuade higher authorities within the Department of Justice to overrule the prosecutorial decisions of the U. S. Attorney's Office in the Southern District of Florida, the CVRA was designed to give the victims the same opportunity to attempt to affect prosecutorial decisions before they became final. Instead, the Office engaged in lengthy negotiations with Epstein that included repeated assurances that the NPA would not be "made public or filed with the Court." (DE 407 at I 31.) + +Nor did the Justice Department guidelines create an exemption from the CRVA's statutory requirements. Although the Government points to guidelines that conflicted with the requirements of the CVRA (by restricting CVRA rights until after a formal indictment), the Court is not persuaded that the guidelines were the basis for the Government's decision to withhold information about the NPA from the victims. If that had been the case, the Government would not have sent the victim letters telling them that they had rights protected under the CVRA. Nor would they have told Epstein's attorneys that it had obligations to notify the victims. In any event, an agency's own "'interpretation' of a statute cannot supersede the language chosen by Congress." Mohasco Corp. v. Silver, 447 U.S. 807, 825 (1980). + +Next, the Court rejects the Government's contention that Jane Doe 2 is not protected by + +the CVRA because she made statements favorable to Epstein early in the investigation.' There is no dispute that Epstein sexually abused Jane Doe 2 while she was a minor. Therefore, regardless of her comments to the prosecutor, she was a victim. See 18 U.S.C. § 3771(e) (the CVRA defines a victim as "a person directly and proximately harmed as a result of the commission of a Federal offense"); In re Stewart, 552 F.3d 1285, 1288 (1 Cir. 2008) ("to determine a crime victim, then, first, we identify the behavior constituting 'commission of a Federal offense.' Second, we identify the direct and proximate effects of that behavior on parties other than the United States. If the criminal behavior causes a party direct and proximate harmful effects, the party is a victim under the CVRA."). + +The Court need not resolve the factual questions surrounding what and when the victims were told about the state court proceeding and whether a state court proceeding is covered by the CVRA. Under the facts of this case, once the Government failed to advise the victims about its intention to enter into the NPA, a violation of the CVRA occurred. + +Nor does the Court need to consider the Government's estoppel arguments at this time. These arguments relate only to the remedy, and not the determination of whether there was a CVRA violation. Therefore, the Court will address this issue at the appropriate juncture. + +Lastly, the Court will address the Government's argument that its prosecutorial discretion permitted it to enter into the NPA. The Government correctly notes that the CVRA provides that "[njothing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." 18 U.S.C.A. § 3771(d)(6). The Court is not ruling + +In fact, the Office considered Jane Doe 2 a victim as early as August of 2006 when it sent her a CVRA letter. + +that the decision not to prosecute was improper. The Court is simply ruling that, under the facts of this case, there was a violation of the victims rights under the CVRA. + +# IV. Conclusion + +Accordingly, it is hereby ORDERED AND ADJUDGED as follows: + +- 1) Jane Doe 1 and Jane Doe 2's Motion for Partial Summary Judgment (DE 361) is GRANTED to the extent that Petitioners' right to conferral under the CVRA was violated. +- 2) The United States's Cross-Motion for Summary Judgment (DE 408) is DENIED. +- 3) Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) is DENIED WITHOUT PREJUDICE. +- 4) Jane Doe 1 and Jane Doe 2's Motion for Finding Waiver of Work Product and Similar Protections by Government and for Production of Documents (DE 414) is DENIED WITHOUT PREJUDICE. +- 5) The parties should confer and inform the Court within 15 days of the date of entry of this Order how they wish to proceed on determining the issue of what remedy, if any, should be applied in view of the violation. + +DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, + +Florida, this 215` day of February, 2019. + +rZ KENNETH A. 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to\_Audrey\_Strauss.pdf + +Stay well, + +Jennifer + +Jennifer Freeman + +Marsh Law Firm PLLC + +Direct Dial + +Skype for Business + +Recipient 2019 PowerPlay Advocacy Award + +Kog I Facebook I Twitter I Linkedin + +2,http://childlaw.us/NCVBA.png + +CONFIDENTIALITY NOTICE: The information contained in this message and any attachment is confidential and may be subject to the attorney-client privilege, or otherwise protected from disclosure by applicable law. Any disclosure, distribution, copying, or use of the information contained in this message or any attachment by anyone other than the intended recipient, regardless of address or routing, is strictly prohibited. If you are not the intended recipient, please telephone or email the sender and delete this message and any attachment from your system. + +IF YOU ARE NOT A CLIENT: This material is general information of an educational nature and is not legal advice. This comm :::: ication does not establish or constitute the retention of Marsh Law Firm PLLC for the provision of legal services, unless explicitly so stated herein. 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Time for the "SEC criminal Obstruction/corruption" Friday edition. + +The record Janey. Well, the SEC hasn't limited its massive fraud on JUST the SDNY 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. + +company=Apptech&matchr&CIK=&filenumr&Stater&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_1_Picture_1.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.see.gov/Archives/edgar/data/1070050/0001575705200002 14/apcx 8k.htm + +https://www.sec.gov/Archives/edgar/data/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_1_Picture_14.jpeg) + +### Ebrahim Daoud Nonoo - Wikipedia + +Ebrahim Daoud Nonoo (Arabic: .9.5.9, ).9.96 , Hebrew: DITUN no 717 , 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 + +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_2_Picture_2.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 creditors. 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 + +To: + +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 F. Supp. 2d 491, see flags on bad law, and search Casetext's comprehensive legal database + +casetext.com + +Cheers! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio C + +Sent: Tuesday, November 3, 2020 3:34 PM + +To: + +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 +[REDACTED] + +--- + +**From:** Chris Dilorio <[REDACTED]> +**Sent:** Wednesday, October 14, 2020 9:32 AM + +**Subject:** Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +--- + +**From:** Chris Dilorio <[REDACTED]> +**Sent:** Wednesday, October 14, 2020 9:00 AM + +**To:** [REDACTED] +[REDACTED] <[REDACTED]>; + +[REDACTED] +[REDACTED] <[REDACTED]> +[REDACTED] <[REDACTED]>; + +**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 + +# 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;1‹ 76=23554 -:;2((1 -&22 + +irnasciaq.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. + +https://www.finextra.com/pressarticle/49357/otkritie-capital-taps-sungard-for-automated-ruble-conversion + +![](_page_5_Picture_12.jpeg) + +# 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 c > + +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: Thursda September 17 2020 9:17 AM + +![](_page_6_Picture_13.jpeg) + +![](_page_7_Picture_105.jpeg) + +**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 + +![](_page_7_Picture_116.jpeg) + +**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? + +Christopher J Dilorio Whistleblower + +From: Chris Dilorio + +Sent: Monday, September 14, 2020 9:22 AM + +To: + +Su jec : w: orma appea or preliminarydenial covere ac ion Knight Capi a Appendix + +I look forward to speaking with you + +Regards, + +Chris + +From: Chris Dilorio < + +Sent: Monday, September 14, 2020 6:02 AM + +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 + +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_10_Picture_0.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 + +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: Tuesday, July 7, 2020 6:09 AM + +![](_page_12_Picture_4.jpeg) + +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 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_14_Picture_112.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. (). The note is available here: NETE April 2018 Update Note. Net Element, Inc. (NASDAQ: NETE, "Net Element") is a global financial + +[www.netelement.com](http://www.netelement.com) + + + +![](_page_14_Picture_117.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. (). 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](http://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 <[REDACTED]> + +**Sent:** Tuesday, June 30, 2020 1:01 PM + +[REDACTED] + +![]()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_18_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 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_25_Picture_5.jpeg) + +Sent: Wednesda 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 .1 Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Tuesda , Ma 12, 2020 8:54 AM + +To: + +Subject: Fw: Forma appea or preliminarydenial covere action 15-016/ 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: Wednesday, Aern 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. + +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. + +vrww.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." + +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 + +![](_page_29_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. + +vo.vw.sec.qov + +(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 + +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 + +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 c + +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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+oid sha256:f3b98810cd196590da0490983bd86d552781861025da2254525f17bef8050530 +size 6213 diff --git a/marker2/ds9/EFTA00083600/_page_7_Picture_116.jpeg b/marker2/ds9/EFTA00083600/_page_7_Picture_116.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..b36d5c3833b8a07d0c81bc8776edf01f6c6ad4b6 --- /dev/null +++ b/marker2/ds9/EFTA00083600/_page_7_Picture_116.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:e69d9d6d026f5248c1b0ccbc062558420f40ca54cab730857fc8efeb4cf8657e +size 11348 diff --git a/marker2/ds9/EFTA00083641/EFTA00083641.md b/marker2/ds9/EFTA00083641/EFTA00083641.md new file mode 100644 index 0000000000000000000000000000000000000000..d223fbea70b3290e3e5c092e6bf45a6d6772c988 --- /dev/null +++ b/marker2/ds9/EFTA00083641/EFTA00083641.md @@ -0,0 +1,157 @@ +To: + +Cc: + +Subject: Daily Beast story on Epstein investigation + +Date: Tue, 29 Oct 2019 14:31:51 +0000 + +Inline-Images: image006.jpg; image007.jpg; image008.jpg; image009.jpg; image010jpg + +https://www.thedailybeast.com/jeffrey-epstein-case-federal-prosecutors-are-lining-up-witnesses-against-his-cronies? ref=home + +T'S NOT OVER + +## Federal Prosecutors Are Lining Up Witnesses + +## Against Jeffrey Epstein's Cronies + +Numerous Epstein victims have met with prosecutors in recent days. + +Kate Briquelet + +Senior Reporter + +Pervaiz Shallwani + +Senior Editor & Writer + +Published 10.29.19 4:47AM ET + +## EXCLUSIVE + +Photo Illustration by The Daily Beast/Photos Getty + +It's been more than two months since Jeffrey Epstein killed himself, but the investigation into possible accomplices is still very much alive. In recent days, federal prosecutors probing the financier's sex-trafficking ring have been asking Epstein victims if they could serve as witnesses in the criminal case they are building. + +Representatives from the U.S. Attorney's Office for the Southern District of New York traveled to Florida for an Oct. 15 meeting with several of Epstein's victims and their counsel. The staffers, who worked in the victim services unit, held a similar meeting in New York on Oct. 23, lawyers for the women and a law enforcement source told The Daily Beast. + +Two people familiar with the investigation said that prosecutors have heard from "dozens" of witnesses or victims since Epstein's arrest in July. + +Following Epstein's death in August, which was ruled a suicide by hanging, the Department of Justice said that it would continue to investigate anyone who helped Epstein procure underage girls or helped him to cover up crimes. A spokesman for the Manhattan U.S. Attorney's Office declined to comment on where the probe stands, only saying that the "investigation is continuing." + +Spencer Kuvin, a Palm Beach attorney who represents two women who were abused by Epstein, said the U.S. Attorney's Office for the Southern District of New York offered counseling services to the group of victims who gathered in Miramar, Florida. + +The representatives also worked to debunk conspiracy theories, which the victims have encountered online, related to Epstein's jailhouse suicide. According to Kuvin, prosecutors continue to battle wild speculation on how the 66-year-old moneymanager died, along with rumors that he isn't dead at all. + +"The U.S. Attorney's Office wanted to put to rest some of those conspiracy theories that he was killed, that he's still alive. There are people still talking about that," Kuvin told The Daily Beast. "There are still people that think this was an absolute ruse and he's sitting pretty in another part of the world." + +Kuvin said investigators assured the women that their probe into Epstein's alleged co-conspirators was ongoing. The lawyer declined to comment on the identities of those suspected accomplices. + +## ADVERTISING + +"They wanted to meet with some of the victims to discuss whether or not they could be potential witnesses in that ongoing investigation," Kuvin said. "One of my clients is going to meet with them privately about that issue." + +During the Florida meeting, coordinators for federal prosecutors answered questions from the women, some of whom felt burned over their treatment 12 years ago, when + +the U.S. Attorney's Office in Miami secretly negotiated a cushy plea deal for Epstein. Back then, the feds promised the women they'd prosecute the creepy multimillionaire; instead, they collaborated with his legal team to downgrade the charges. + +"The focus really is: What are you doing now and are you honestly going to pursue the co-conspirators or are those just words?" Kuvin said. + +"They've been wronged by the system numerous times," Kuvin added of his clients and other victims of Epstein, "from the late 2000S all the way up to him killing himself. Every time an official comes forward and says, `Don't worry. We're going to do the right thing,' they shake their heads and say, `We'll see.'" + +In New York last week, prosecutors met with victims at a federal building downtown where local FBI headquarters is housed to inform the women of their rights and offer counseling services. + +Duncan Levin, a former assistant U.S. Attorney and chief of asset forfeiture at the Manhattan District Attorney's office, said Epstein's inner circle shouldn't rest easy. + +"There is at least some evidence that other people facilitated his crimes, and there's obviously enough public interest in the case that [prosecutors] aren't going to drop it just because he's dead," said Levin, managing partner at Tucker Levin, PLLC. + +Levin said prosecutors are likely to thoroughly investigate Epstein's alleged enablers and seek forfeiture of Epstein's properties that were used to facilitate the sex crimes. + +![](_page_2_Picture_7.jpeg) + +A bare-bones rundown of Epstein's assets submitted by his lawyers following his arrest, and bank records obtained by prosecutors, provided a glimpse into Epstein's net worth which is estimated at more than \$550 million, but it may not be a complete accounting. The listed assets included \$56 million in cash and another \$500 million in properties and investments. + +The properties include \$85 million worth of real estate in the U.S. Virgin Islands including his own private island—an \$8.6 million Paris apartment, a \$12 million Palm Beach estate, a \$17 million New Mexico ranch, and his Manhattan mansion which Epstein claimed is worth \$55 million but prosecutors have said is worth \$77 million. + +"Justice is a slow-moving train," Levin said. "This is par for the course. Investigations are measured in months and years not days and weeks." + +"I would be very nervous if I were somebody who helped Jeffrey Epstein at this point and would be seeking legal counsel," Levin added. + +Epstein was arrested on July\_6 and charged with sex-trafficking and conspiracy to commit sex-trafficking. The indictment referred to three victims and three unnamed employees of Epstein who allegedly assisted in the sex pyramid scheme. + +According to the complaint, Epstein created a "network of minor victims in multiple states to sexually abuse and exploit" and "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." + +From 2002 to 2005, the indictment states, Epstein "enticed and recruited" minor girls as young as 14 to visit his mansions and engage in sex acts with him, after which he or his assistants gave the victims hundreds of dollars in cash. + +It's unclear which alleged co-conspirators prosecutors are targeting. + +In one July court filing, prosecutors requested a protective order, indicating they planned to produce certain documents and materials that "would impede, if + +prematurely disclosed, the Government's ongoing investigation of uncharged individuals." + +In 2008, when Epstein pleaded guilty to state charges, his non-prosecution agreement with the feds granted [immunity to his alleged accomplices](#), "including but not limited to [REDACTED]" + +![](_page_4_Picture_86.jpeg) + +[REDACTED] lawyer, Michael Bachner, previously told The Daily Beast: "At no time during [REDACTED] employment with Epstein did she ever engage in any misconduct." + +Attorneys for [REDACTED] told CNN last month that she was a victim herself and "is and has been severely traumatized." They added: "She needs time to process and make sense of what she has been through before she is able to speak out." + +According to the report, [REDACTED] spokeswoman had a similar explanation. "Very soon after [REDACTED] was brought into Epstein's world, he began to sexually abuse her, and this abuse went on for years. Sarah continues to struggle with the trauma of her experiences and has chosen not to speak publicly at this time." + +Ross hasn't spoken publicly on the allegations. + +One lawsuit, filed by a Jane Doe in September against Epstein's estate, describes [REDACTED] and Groff as a pair of adult employees who "specifically facilitated his abuse." + +The women scheduled the girl's visits to Epstein's Manhattan mansion and "often asked Doe to bring other girls with her," paying her every time she did so. + +Meanwhile, Groff, a former assistant to Epstein, is facing [a lawsuit from \[REDACTED\]](#) + +[REDACTED] who says she was in high school when Epstein raped and abused her. A second assistant [REDACTED] is also listed as a defendant in the case. + +Araoz's complaint also targets Epstein's alleged madam, Ghislaine Maxwell—who's kept a low profile since the hedge-funder's arrest and has long faced accusations of recruiting underage girls and taking part in sexual abuse herself. + +Another lawsuit, recently filed by Priscilla Doe, alleges that "in addition to providing sexual instruction, Ghislaine Maxwell further made sure that Plaintiff and the other young females were constantly on call to sexually service Jeffrey Epstein." + +Maxwell isn't the only Epstein friend under scrutiny in the press. Authorities in France are looking into sexual misconduct claims against talent scout Jean-Luc Brunel, accused in civil court filings of procuring young models for Epstein to exploit. + +"Jeffrey Epstein has told me that he has slept with over 1,000 of Brunel's girls, and everything that I have seen confirms this claim," said accuser a 2015 affidavit. says she was 16 when Maxwell recruited her into Epstein's trafficking ring. + +In response, Brunel issued a statement denying claims, saying he never participated "directly nor indirectly, in the actions Mr. Jeffrey Epstein is being accused of." + +![](_page_5_Picture_5.jpeg) + +Last year, Epstein may have attempted to buy the silence of alleged co-conspirators just as his name re-emerged in the press. + +Prosecutors say Epstein wired payments to two unnamed women—one received \$250,000 while the other got \$100,000—shortly after the Miami Herald's exposé on Epstein's 2007 sweetheart deal. Those individuals were listed as possible coconspirators in Epstein's non-prosecution agreement, the U.S. Attorney's Office said in July. + +At a bail hearing that month, Assistant U.S. Attorney told the court that "after seven days of this case being public following months of a covert investigation, the evidence is already significantly stronger and getting stronger every single day. + +"Many individuals identifying themselves as victims and witnesses have contacted the government," ontinued, "and we are in the process of receiving and corroborating this additional evidence." + +Brad Edwards, an attorney who sued the government on behalf of victims over Epstein's lenient plea deal, said, "I assume that if there are others that should be held accountable for crimes that can still be prosecuted, then they will." + +Edwards said he trusts that New York prosecutors "are trying to leave no stone unturned." + +Last month, U.S. District Judge Kenneth Marra refused to scrap the non-prosecution agreement that shielded Epstein and his alleged co-conspirators from facing serious charges—despite Marra's ruling that the agreement was illegal. + +Marra also denied the victims' requests for other relief: attorneys' fees, a hearing where victims could speak, and the release of documents including grand jury materials. The decision was part of a 2008 lawsuit Jane Does 1 and 2 filed against the United States, alleging the feds violated the Crime Victims' Right Act. + +who has come forward as Jane Doe 1, has appealed to the U.S. Court of Appeals for the iith Circuit. Oral arguments are scheduled for January. + +"A ruling rescinding the immunity provisions would have permitted the victims to confer with government prosecutors about the possibility of obtaining prosecution of Epstein's co-conspirators in the Southern District of Florida — i.e., would have afforded them their rights under the CVRA," Wild's appeal states. + +![](_page_7_Picture_0.jpeg) + +Kate Briquelet + +Senior Reporter + +kbriqueletkate.briquele thedail east.com + +![](_page_7_Picture_4.jpeg) + +Pervaiz Shallware + +Senior Editor & Writer \ No newline at end of file diff --git a/marker2/ds9/EFTA00083641/EFTA00083641.metadata.json b/marker2/ds9/EFTA00083641/EFTA00083641.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9b786ddbcc71269e6bf53748ffa7878f7280359d --- /dev/null +++ b/marker2/ds9/EFTA00083641/EFTA00083641.metadata.json @@ -0,0 +1,399 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083641.pdf", + "engine": { + 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sha256:9ee3a8ccf12079b3a1b0d2b813e5d75966ca6838506dd7b5c7f8d19bec83749f +size 16352 diff --git a/marker2/ds9/EFTA00083649/EFTA00083649.md b/marker2/ds9/EFTA00083649/EFTA00083649.md new file mode 100644 index 0000000000000000000000000000000000000000..e34f4b69e4f016f15131e8f0d91478d5a1bb6a8c --- /dev/null +++ b/marker2/ds9/EFTA00083649/EFTA00083649.md @@ -0,0 +1,47 @@ +To: + +Cc: + +Subject: RE: Daily Beast story on Epstein investigation + +Date: The, 29 Oct 2019 15:44:35 +0000 + +Inline-Images: image001.jpg; image002.jpg; image003.jpg; image004.jpg; image005.jpg + +For whatever it's worth, this article seems to be almost entirely based on information from Spencer Kuvin, who has been an extremely frustrating and unhelpful presence during our case—he routinely has been quoted in media reports saying things that are completely wrong (and actively harmful to the investigation). As an example, he wasn't even at either of the meetings he's purporting to have information on here. Additionally, none of us on the team has literally ever spoken with him or met him, nor are we aware of any victim clients that he actually currently represents (despite his repeated claims that he actively represents victims), and we're also not aware of anyone who intends to meet with us who's a client of his. + +Obviously we have no control over him or anyone who uses him as a source, but he has put inaccurate information out a number of times (including that he has any clients who have spoken with us and/or intend to) so I figured it might be useful to let you know. + +From: + +Sent: Tuesda October 29, 2019 10:32 + +To: + +Cc: + +Subject: Daily Beast story on Epstein investigation + +![](_page_1_Picture_2.jpeg) + +![](_page_2_Picture_0.jpeg) + +![](_page_3_Picture_0.jpeg) + +![](_page_3_Picture_1.jpeg) + +![](_page_4_Picture_3.jpeg) + +ich + +![](_page_4_Picture_6.jpeg) + +![](_page_5_Picture_0.jpeg) + +![](_page_6_Picture_0.jpeg) + +![]()KS + +@ + +KS \ No newline at end of file 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a/marker2/ds9/EFTA00083649/_page_6_Picture_0.jpeg b/marker2/ds9/EFTA00083649/_page_6_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..e8fc67b252a62ca08223aecae0669fe4adab3897 --- /dev/null +++ b/marker2/ds9/EFTA00083649/_page_6_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:a7be806a197defe7f016046f3d03febff649eb7b5bdf467c224301d1776cb783 +size 64452 diff --git a/marker2/ds9/EFTA00083657/EFTA00083657.md b/marker2/ds9/EFTA00083657/EFTA00083657.md new file mode 100644 index 0000000000000000000000000000000000000000..36ee157b5f3e43ac34d3efff7d1c6f96bc5afa47 --- /dev/null +++ b/marker2/ds9/EFTA00083657/EFTA00083657.md @@ -0,0 +1,15 @@ +From: 'I > + +To: ' + +Cc: + +Subject: indictment to deputy chief? + +Date: Fri, 28 Jun 2019 16:46:17 +0000 + +Importance: Normal + +Attachments: 2019-06-25,\_JE,\_first\_indictment,\_draft.docx + +M, it occurs to me that although we've gotten sign-off from the front office folks that we still need to get a deputy chief to sign, and I think most or many of them are out next week — with the caveat that we can continue to proof-read and change precise wording if we need to, should we get the indictment and pros memo to = today? The attached indictment version incorporates very small edits (and had no edits). If it's alright, I'll give to = right now. \ No newline at end of file diff --git a/marker2/ds9/EFTA00083657/EFTA00083657.metadata.json b/marker2/ds9/EFTA00083657/EFTA00083657.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ac779aa7101a5d7c8137af958b0d0bd2319fea1a --- /dev/null +++ b/marker2/ds9/EFTA00083657/EFTA00083657.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083657.pdf", + "engine": { + "marker_major": "2", + "marker_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": 642, + "elapsed_seconds": 0.46, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 13 + ], + [ + "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/EFTA00083657" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083658/EFTA00083658.md b/marker2/ds9/EFTA00083658/EFTA00083658.md new file mode 100644 index 0000000000000000000000000000000000000000..3c4181f9718fb2b8c6efe20cd3a80e0a61e8a02c --- /dev/null +++ b/marker2/ds9/EFTA00083658/EFTA00083658.md @@ -0,0 +1,91 @@ +)" <• To: )'I + +Cc: "-(USANYS)" + +Subject: RE: updates + +Date: Sat, 06 Jul 2019 20:39:51 +0000 + +Importance: Normal + +From Geoff: + +Where we currently say "In fall 2007, the defendant entered into a non-prosecution agreement with the SDFL in connection with the conduct at issue in that investigation -- i.e., the abuse of numerous minor girls in the Palm Beach area." + +He would like us to change to: + +"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 identifies as including investigations into the defendant's abuse of minor girls in the Palm Beach area." + +His concern is their investigation (like ours) involved some girls who were 18 at the time and also we don't want to ourselves characterize the scope of the NPA. + +Fix the typo: + +" the defendant cannot overCOME the statutory presumption in favor of detention in this case." + +"As an initial matter, all of the conduct is timely charged, pursuant to 18 U.S.C. §3283, which permits the prosecution of sex offenses against children at any time during the lifetime of the minor victim." + +per our discuss, let's modify this language + +"he currently is a registered sex offender." + +Geoff asks "Is it worth pointing out that, I believe, he is in the highest risk category for re-offense?" + +What about pointing out that he, at least as of 2011, has no appreciation of the gravity of his offense or necessarily reoffense. This is from a NY Post article: + +"I'm not a sexual predator, I'm an offender. It's the difference between a murderer and a person who steals a bagel." + +MI think this is a good suggestion + +"GEOFFREY S. BERMAN ACTING United States Attorney" + +--- + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Saturday, July 6, 2019 4:23 PM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] (USANYS) <[REDACTED]> +**Subject:** Fwd: updates + +In addition to these, I have a number of smaller things from Geoff that I will forward on shortly. + +Sent from my iPhone + +Begin forwarded message: + +**From:** [REDACTED] <[REDACTED]> +**Date:** July 6, 2019 at 3:15:59 PM EDT +**To:** "[REDACTED]" <[REDACTED]>, "[REDACTED] (USANYS)" <[REDACTED]>, "Berman, Geoffrey (USANYS)" <[REDACTED]> +**Cc:** "[REDACTED]" <[REDACTED]>, "[REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED]" <[REDACTED]>, "[REDACTED]" <[REDACTED]> +**Subject:** RE: updates + +Thanks for circulating. I think this is very well done. I have a few comments and suggested edits in the attached. Also, we should be careful when conforming on Monday morning – if we are submitting it to a magistrate judge, as expected, we should change the header to so reflect. + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Saturday, July 6, 2019 1:18 PM +**To:** [REDACTED] (USANYS) <[REDACTED]>; Berman, Geoffrey (USANYS) <[REDACTED]> +**Cc:** Birger, Laura (USANYS) <[REDACTED]>; Strauss, Craig (USANYS) <[REDACTED]>; Stewart, Craig (USANYS) <[REDACTED]>; Strauss, Audrey (USANYS) <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: updates + +Attached is the most recent draft, which includes placeholders that we would plan to update on Monday morning before filing. Any comments are most welcome, and thanks in advance. + +--- + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Saturday, July 6, 2019 12:51 PM +**To:** Berman, Geoffrey (USANYS) <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; Birger, Laura (USANYS) <[REDACTED]>; Stewart, Craig (USANYS) <[REDACTED]>; Strauss, Audrey (USANYS) <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** Re: updates + +On Jul 6, 2019, at 12:44 PM, Berman, Geoffrey (USANYS) < wrote: + +ells me that he is confirmed on board. Wheels up. Geoff + +On Jul 6, 2019, at 11:10 AM, •z: > wrote: + +Good morning all— + +asked me to pass along two quick updates. First, Judge Moses signed the search warrant this morning. Second, our case agent told us that FBI received a flight manifest from CBP last night. The passengers listed are Epstein and two pilots. Of course, that is subject to change, and I'm told that FBI will try to get confirmation of the passengers after the flight takes off. + +Assistant United States Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00083658/EFTA00083658.metadata.json b/marker2/ds9/EFTA00083658/EFTA00083658.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..75d3dcd492696607b3e0dc42e00f86a0e9625145 --- /dev/null +++ b/marker2/ds9/EFTA00083658/EFTA00083658.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083658.pdf", + "engine": { + "marker_major": "2", + "marker_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": 4372, + "elapsed_seconds": 129.37, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 33 + ], + [ + "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": "surya", + "block_counts": [ + [ + "Span", + 87 + ], + [ + "Text", + 44 + ], + [ + "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": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "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/EFTA00083658" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083661/EFTA00083661.md b/marker2/ds9/EFTA00083661/EFTA00083661.md new file mode 100644 index 0000000000000000000000000000000000000000..2a9aed3009f04fc9bf5fa8a9de9c51b6c4934684 --- /dev/null +++ b/marker2/ds9/EFTA00083661/EFTA00083661.md @@ -0,0 +1,76 @@ +To: + +Subject: Cut and done? + +Date: Wed, 30 Oct 2019 21:33:12 +0000 + +![](_page_0_Picture_4.jpeg) + +Bloomberg + +Good afternoon. Here's what you need to know to end your day. + +- The Fed came through with a cut, but that might be it for a while. +- Facebook and Apple exceeded earnings expectations. +- A jug of wine, a loaf of bread—and manga. + +The Fed slashed interest rates for the third time this year, but signaled policy may stay on hold for the time being. The FOMC dropped its pledge to "act as appropriate to sustain the expansion," while adding a promise to monitor data as officials assess their next move. Two members voted against the 25 basis point cut, preferring no change. Traders trimmed bets of more easing this year. + +- "Monetary policy is in a good place," Fed Chairman Jerome Powell told a news conference following the decision. "We see the current stance of policy as likely to remain appropriate as long as incoming information about the economy remains broadly consistent with our outlook." +- Meanwhile, the Treasury expressed continued interest in issuing a 50-year bond, for the first time, as part of efforts to expand its investor base as the budget deficit widens to \$1 trillion. The department said it's also weighing a 20-year bond and an inaugural floating-rate note with a one-year maturity linked to SOFR. +- America's GDP increased at a 1.9% annualized rate in the third quarter, topping expectations for 1.6% growth as helped the economy expand. Still, that's down from 2% in the second quarter and is the lowest since the end of 2018. resilient consumers + +![](_page_0_Picture_10.jpeg) + +Facebook's sales rose a better-than-projected 29%, weathering a period rife with regulatory challenges and criticism by boosting ad revenue and + +adding about 35 million new users. It also said Susan Desmond-Hellmann, its lead independent director, is stepping down from the board. Earlier, the company agreed to pay 500,000 pounds (\$644,000) to end a U.K. privacy probe in the wake of the Cambridge Analytica scandal. + +- Apple's projection for holiday revenue beat estimates, signaling solid demand for the latest iPhones, new services like Apple TV+ and wearables. "We're very optimistic about what the holiday quarter has in store," CEO Tim Cook said. Fourth-quarter earnings and sales also topped expectations. +- Starbucks jumped in late trading after posting in China and the U.S. The coffee chain forecast comparable sales will be up between 3% and 4% globally and announced it would boost its dividend. strong sales gains +- But pizza and beer may be losing their charm. Yum! Brands slid on third-quarter sales that trailed estimates as the company's Pizza Hut chain struggled. And Molson Coors posted disappointing numbers and disclosed plans to cut as many as 500 jobs and close an office in Denver, where it moved in just a few years ago. +- General Electric rose nearly 12% after boosting its 2019 cash-flow forecast for the second straight quarter. The industrial businesses will generate as much as \$2 billion in free cash this year, GE said after previously forecasting no more than \$1 billion. Third-quarter adjusted earnings of 15 cents a share also beat expectations. + +# What Else is Happening + +Twitter will ban political advertising from its platform, effective Nov. 22, CEO Jack Dorsey said in a tweet. The company plans to publish a new political ads policy outlining the change in a few weeks. The move comes as rival Facebook faces pressure from its employees to stop letting politicians lie in ads. + +Kamala Harris is hemorrhaging cash. As the 2020 presidential candidate drops in the polls, she plans to cut staff in her Baltimore headquarters and slash pay for advisers in an effort to keep her campaign afloat. Campaign manager Juan Rodriguez outlined the restructuring in a memo, citing an "incredibly competitive resources environment" and a need to reduce spending to maximize prospects in Iowa. + +Chile canceled next month's APEC summit in Santiago where Donald Trump and Xi Jinping were expected to sign a preliminary trade deal. President Sebastian Pinera also called off the COP25 climate change conference set for December, highlighting his government's trouble after almost two weeks of deadly protests. The announcement seemed to catch the White House off guard, though a spokesman said Trump still plans to sign a partial trade deal with Xi at about the same time in November. + +At least 10 large wildfires are burning across California, including one that erupted Wednesday morning in Ventura County that's threatening the Ronald Reagan Presidential Library. About 365,000 PG&E customers remained without electricity from the company's last two blackouts through the late morning. The state now faces "a heightened credit challenge" as the frequency of wildfires increases and the traditional fire season lengthens, according to Moody's. The good news is that winds are expected to ebb this weekend. + +![](_page_2_Picture_2.jpeg) + +Smoke rises behind the Marine One on display at the Ronald Reagan Presidential Library. Photographer Patrick T. Fallon/Bloomberg + +#### Opinion + +The Fed needs to do more than just head off a recession, Karl Smith writes for Bloomberg Opinion. Part of its mandate is to ensure that as many Americans as possible have jobs. There's little sign of full employment, and market-based measures of inflation expectations are falling. It should continue cutting rates to ensure inflation rises above 2%, and stays there for two or three quarters. + +The NCAA probably hopes to draw the line at allowing college athletes to earn money on their name, image and likeness, Bloomberg Opinion's Joe Nocera writes. But it's more likely that this marks the beginning, not the end, of payments for players. Once some athletes begin to reap endorsement money, players without endorsement deals are going to want some form of compensation. + +# Businessweek Today + +Three decades ago, drones were available to only the most technologically developed state military organizations. Today they're everywhere, being used by weaker states, small military forces and many non-state actors. Because armies no longer have the monopoly, others can now impose their will on the global stage, said Raphael Marcus from the department of war studies at King's College London. And it's already leading to greater instability, as demonstrated by the attack on the Saudi Abqaiq oil processing facility. + +Life on Africa's Zambezi River is hard. The climate crisis is making it deadly. Take Victoria Falls, known locally as Mosi oa Tunya—or "The Smoke That Thunders." The world's biggest sheet of falling water is 1.2 miles wide and drops 328 feet into a chasm. At the peak of its flow, it churns up a mist that can be seen 30 miles away. But this year, with the water at its lowest level in more than two decades, there's no thunder. That's just one effect on impoverished African coastal or riverine communities. little smoke and + +![](_page_3_Picture_2.jpeg) + +## What Everybody's Talking About + +Trump plans to take a break from the impeachment fight in Washington to watch another brawl in New York City. The president is tentatively set to attend a mixed martial arts bout on Saturday night at Madison Square Garden, according to people familiar. The event, which comes just days after Trump was booed while attending the World Series, will be headlined by a contest between welterweights Jorge Masvidal and Nate Diaz. + +Jeffrey Epstein's autopsy is more consistent with strangulation than suicide, a forensic pathologist hired by the disgraced financier's brother told Fox & Friends. "The evidence points toward homicide rather than suicide," said Dr. Michael Baden, a former New York City medical examiner. He pointed to fractures in the hyoid bone that are "very unusual for suicide." The findings were disputed by the city's chief medical examiner, who reiterated that Epstein hanged himself. + +## By the Way + +Pop the corks: The Drops of God manga series has finally been translated into English The tale of two half-brothers who compete to inherit their father's vast wine collection by identifying 13 rare wines from his notes has already sold hundreds of millions of copies in Japan, South Korea, and Taiwan. Amazon's ComiXology Originals and partner Kodansha have just released the first 11 of 44 volumes. The rest will arrive next year along with an online wine club. + +![](_page_4_Picture_1.jpeg) + +You received this message because you are subscribed to Bloomberg's The Bloomberg Close —Americas newsletter. + +> Unsubscribe I Bloomberg.com I Contact Us Bloomberg L.P. 731 Lexington, New York, NY, 10022 \ No newline at end of file diff --git a/marker2/ds9/EFTA00083661/EFTA00083661.metadata.json b/marker2/ds9/EFTA00083661/EFTA00083661.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1ffc4d70596fe1f4d3887e108235261703a88e71 --- /dev/null +++ b/marker2/ds9/EFTA00083661/EFTA00083661.metadata.json @@ -0,0 +1,340 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083661.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 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sha256:1af542fee29ec3a68678d1ef4bb18ce7ace60c97cfd103ffb7f2eb700bfad492 +size 14584 diff --git a/marker2/ds9/EFTA00083666/EFTA00083666.md b/marker2/ds9/EFTA00083666/EFTA00083666.md new file mode 100644 index 0000000000000000000000000000000000000000..20868c9c6fa41e0cf4d5f94428c80efa7d581f75 --- /dev/null +++ b/marker2/ds9/EFTA00083666/EFTA00083666.md @@ -0,0 +1,92 @@ +# Pnitekratuteo Piotrict Court SOUTHERN DISTRICT OF NEW YORK + +TO: Metropolitan Correctional Center Attn: Adam Johnson, Esq. 150 Park Row New York, New York 10007 + +## 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: September 10, 2019 Appearance Time: 10:00 a.m. + +to testify and give evidence in regard to an alleged violation of : + +18 U.S.C. §§ 371, 1001, 1519, 2 + +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: + +Please see attached rider. Personal appearance required. + +Failure to attend and produce any items hereby demanded will constitute contempt of court and will subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law. + +DATED: New York, New York August 20, 2019 + +oCOGES•SS• galli•Art + +GEOFFREY S. BERMAN United States Attorney for the ew York + +Assistant United States Attorneys One St. Andrew's Plaza New York, New York 10007 Telephone: Email: + +![](_page_0_Picture_16.jpeg) + +#### RIDER + +(Grand Jury Subpoena to MCC, dated August 20, 2019) + +Ref. No. 2019R01059 + +#### A. Definitions and Instructions: + +- 1. This Subpoena calls for the preservation and production of specific documents, including handwritten notes and records and e-mails and text messages, in the possession, custody or control of the Metropolitan Correctional Center ("MCC") or any employee of MCC. Except as set forth below, the time period for production pursuant to this Subpoena is June 1, 2019 to the present. We request that you additionally preserve all documents that would be responsive to this Subpoena for the time period January 1, 2019 to the present. +- 2. This Subpoena applies to any responsive documents wherever they may be found, including any facility that holds records for the MCC, personal electronic devices, cellular phone or other telephone, pager, tablet, laptop computer, desktop computer, personal email, cloud storage, messaging or social media accounts used by employees of the MCC to conduct the MCC's business, and including any and all handwritten notes and records in possession of any employees of the MCC. +- 3. With the exception of documents containing handwritten notes, please produce requested records 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. Please provide the originals of all papers, notepads, notebooks, diaries, or calendars upon which responsive handwritten notes may be found. +- 4. The term "documents" includes writings, emails, text messages, drawings, graphs, charts, calendar entries, photographs, audio or visual recordings, images, and other data or data compilations, and includes materials in both paper and electronic form. +- 5. If the MCC has knowledge of any document that would be responsive to this Subpoena but has been lost, destroyed, or discarded since January 1, 2019, it shall identify to the extent possible each such document and provide an explanation for the loss, destruction, or discarding (including identification of each person authorizing or having knowledge of the loss, destruction, or discarding). +- 6. 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 must be identified on a privilege log with descriptions sufficient to identify their dates, authors, recipients, and general subject matter. + +# B. Custodian of Records: + +- I. The MCC is to designate an employee having personal and thorough knowledge of the MCC's records and who shall have been responsible for the search for documents responsive to this Subpoena. That person shall appear before the Grand Jury on the Subpoena return date, produce the materials called for, and be examined concerning the completeness of the response. + +#### C. Materials to be Preserved and/or Produced: + +- I. All institutional count slips and records related to the count, including but not limited to the regular institutional count slips and the 30-minute round count slips, including but not limited to such records for the Special Housing Unit ("SHU"). +- 2. All documents, including communications, regarding the counts slips described in Request I, including but not limited to any communications regarding the creation, maintenance, storage, destruction, or description of such records. +- 3. All documents, including e-mail and internal correspondence and notes, and the Form 292, related to and for inmate Jeffrey Epstein, Reg. No. 76318-054. +- 4. TRUSCOPE entries reflecting the institutional count, and 30-minute rounds, for the institution and the SHU. +- 5. Any logs or logbooks kept in the normal course of business, including but not limited to the visitor's log, attorney visit log, lieutenant's log, and control center log. +- 6. Posted picture file for the SHU. +- 7. Post orders for the SHU. +- 8. High Risk List(s), as well as any communications regarding the High Risk List and/or any inmates on or being considered for the High Risk List. +- 9. Internal telephone records. +- 10. Records of staff and shift assignments, including but not limited to staff rosters. +- II. Records of trainings and staff attendance at trainings for the time period June 1, 2018 to the present. + +![](_page_3_Picture_0.jpeg) + +## U.S. Department of Justice + +United States Attorney Southern District of New York + +The Silvio J. Mollo Building One Saint Andrew-s Plaza + +New York, New York 10007 + +August 20, 2019 + +Metropolitan Correctional Center Attn: Adam Johnson, Esq. 150 Park Row New York, New York 10007 + +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. 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 Grand Jury Subpoena request to a third party, please let me know before making any such disclosure. + +In addition, we request that you preserve all records that might be responsive to the requests set forth herein that are created on a going forward basis, for the next 180 days. + +Thank you for your cooperation in this matter. + +Very truly yours, + +GEOFFREY S. 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The charges stem from their conduct on the night that Jeffrey Epstein committed suicide. USAO-SDNY previously indicated that it would seek the Indictment on November 14. For operational reasons, USAO-SDNY now plans to seek the Indictment on November 19, and FBI-NY will conduct the arrests the same day. \ No newline at end of file diff --git a/marker2/ds9/EFTA00083670/EFTA00083670.metadata.json b/marker2/ds9/EFTA00083670/EFTA00083670.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4fe13383d88a35e4fbbdf56c8d7029d45403f24d --- /dev/null +++ b/marker2/ds9/EFTA00083670/EFTA00083670.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083670.pdf", + "engine": { + "marker_major": "2", + "marker_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": 902, + "elapsed_seconds": 0.54, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 40 + ], + [ + "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/EFTA00083670" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083671/EFTA00083671.md b/marker2/ds9/EFTA00083671/EFTA00083671.md new file mode 100644 index 0000000000000000000000000000000000000000..e917cc0c6885261affbe2e2375563dd08bd0f350 --- /dev/null +++ b/marker2/ds9/EFTA00083671/EFTA00083671.md @@ -0,0 +1,17 @@ +From: 'a + +To: "brittany@epllc.com" + +Cc: "brad athtdustice.com" + +Subject: + +Date: Mon, 23 Sep 2019 18:26:44 +0000 + +Hi Brittany, + +We met with last week in California, which was helpful. She mentioned that she had provided you with a batch of emails relating to her encounters with Epstein. She indicated that she would be willing to share those with us, and that we should contact you to coordinate. Are you able to share those documents with us? If you have any questions or if you think a call would be helpful to discuss, please let us know. + +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/EFTA00083671/EFTA00083671.metadata.json b/marker2/ds9/EFTA00083671/EFTA00083671.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bb819daaa68942a3ace39d06abd19286970ec155 --- /dev/null +++ b/marker2/ds9/EFTA00083671/EFTA00083671.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083671.pdf", + "engine": { + "marker_major": "2", + "marker_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": 703, + "elapsed_seconds": 0.65, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 16 + ], + [ + "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/EFTA00083671" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083672/EFTA00083672.md b/marker2/ds9/EFTA00083672/EFTA00083672.md new file mode 100644 index 0000000000000000000000000000000000000000..f4462fe21b7f32b789b9a21ca0695b28ebeb1979 --- /dev/null +++ b/marker2/ds9/EFTA00083672/EFTA00083672.md @@ -0,0 +1,29 @@ +From: ' To: ' + +Subject: FW: Re Jeffrey Epstein/Bill Clinton Date: Wed, 25 Sep 2019 15:22:00 +0000 + +Can I tell her that I sent the information to the FBI agents. + +From: Sent: Wednesday, September 25, 2019 10:55 AM To: Subject: Re: Re Jeffrey Epstein/Bill Clinton + +Dear + +Please tell me who you forwarded my email to please, I am surprised no-one has contacted me. + +Regards + +From: =, (USANYS) Sent: 23 September 2019 20:09 To: Subject: RE: Re Jeffrey Epstein/Bill Clinton + +Thank you for your email. + +United States Attorney's Office Southern District of New York New York, New York 10007 + +From: Sent: Monday, September 23, 2019 2:48 PM To: Subject: Re Jeffrey Epstein/Bill Clinton + +Dear S I'm sorry I dont have the correct contactaddress, could you forward this please to Mr Berman? + +I have information about a sexual predator who was a pilot for Bill Clinton, he may or may not be involved in the Jeffrey Epstein scandal but I believe his flight manifests and lifestyle deserve a closer look. I am one of his abandoned children and can say that his profile fits that of someone who could assist your enquiries and maybe with personal involvement, he shows strong indications of being a sociopath and his son + +If Mr Berman's office would like to know more, please let me know. I live in London but have close knowledge of this gentleman and his history. + +Regards \ No newline at end of file diff --git a/marker2/ds9/EFTA00083672/EFTA00083672.metadata.json b/marker2/ds9/EFTA00083672/EFTA00083672.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7a11874e7ba8e61c308ad144e265674bfb419319 --- /dev/null +++ b/marker2/ds9/EFTA00083672/EFTA00083672.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083672.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1358, + "elapsed_seconds": 0.71, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "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": "pdftext", + "block_counts": [ + [ + "Span", + 7 + ], + [ + "Line", + 4 + ], + [ + "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/EFTA00083672" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083674/EFTA00083674.md b/marker2/ds9/EFTA00083674/EFTA00083674.md new file mode 100644 index 0000000000000000000000000000000000000000..72b2430c544b20c532f8961a75a6246d12c1f3b8 --- /dev/null +++ b/marker2/ds9/EFTA00083674/EFTA00083674.md @@ -0,0 +1,122 @@ +**To:** [REDACTED] + +**Cc:** [REDACTED] + +**Subject:** RE: Taint Review - Epstein + +**Date:** Tue, 01 Oct 2019 21:34:05 +0000 + +**Inline-Images:** image001.png + +The HD (screen shot below) matches the Relativity data, 453 MB in the IDEloadfiles, 35 MB in the Loose Media, 2.3 GB in the windows load files (so not a lot of data). Also below is a list of the info that is useful to have in a chart when you have a lot of electronic SW returns. + +- ◦ A chart showing + - ▪ Type of data (*e.g.* email, phone, computer, hard copy) + - ▪ Description of data (*e.g.* identify the account holder or owner of data) + - ▪ Location of data (*e.g.* Relativity, hard drive) (the Prosecution Team is responsible for knowing all data locations) + +| Name | Date modified | Type | +|------------------------------------------------|-------------------|-------------| +| IDEloadFiles | 8/23/2019 3:05 PM | File folder | +| Loose Media loadFiles | 8/23/2019 3:05 PM | File folder | +| windows load files | 8/23/2019 3:05 PM | File folder | + +**From:** [REDACTED] + +**Sent:** Monday, September 30, 2019 5:28 PM + +**To:** [REDACTED] + +**Cc:** [REDACTED] + +**Subject:** RE: Taint Review - Epstein + +Great, thanks – we're working on this with the agents and will circle back when we have more info. Thanks again. + +**From:** [REDACTED] + +**Sent:** Monday, September 30, 2019 14:33 + +**To:** [REDACTED] + +**Cc:** [REDACTED] + +**Subject:** RE: Taint Review - Epstein + +I just checked with [REDACTED] and he said that there was not very much on the drive. Can you check with the agents and find out what they put on the drive? If they don't know, I'll check the drive when I'm back in the office tomorrow. And you can look at the NP folders. + +Following up on the Epstein materials, it seems to us like 20,000 documents is exceedingly low given the volume of devices we seized. Can you please tell us how many source devices those documents are from, so we can crossreference? The seizure records appear to reflect that there were approximately 38 computers and/or electronic storage devices seized along with an additional approximately 55 CDs—see the attached seizure report. I just can't imagine that would only result in 20,000 documents. Please advise? + +thanks, + +Original Message + +From: Sent: Thursda , Se tember 26, 2019 11:37 To: Subjec : :Taint Review -Epstein + +FYI. + +Ori inal Messa e + +From: Sent: s a , e em er . To: Subje : e: ain ewew -Epstein + +About 20K but a lot are non-user files, like adobe instructions. + +Assistant United States Attorney Southern District of New York New York, NY 10007 + +> On Sep 26, 2019, at 11:32 AM, > Out of curiosity, do you know what the volume of NP documents is? Thanks. > Original Message > From: > Sent: Thursda Se I tember 26.2019 11:02 AM > To: > Cc: > Subjec : : aunt eview - ps em rote: • > I've run all the terms that Epstein's attorney gave me and segregated the hits, there were not many. Can I release the NP or did you come to some agreement with the defense that we would give them notice or let them review them first? + +> Original Message + +> From: + +> Sent: Monda , September 23, 2019 8:46 PM + +> To: + +> Cc: + +> Subject: RE: Taint Review + +> Great, thanks very much. + +> Original Message + +> From: + +> Sent: Monda September 23 2019 16:56 + +> To: + +> Cc: + +> Subject: RE: Taint Review + +> We are running the lawyer/paralegal names now, you should have access in a couple of days. + +> Ori inal Messa e + +> From: + +> Sent: Satur ay, September 21, 2019 5:02 PM + +> To: + +> Cc: + +> Subject: FW: Taint Review + +> The agents on the Epstein case have asked, below, about the status of the taint review of the materials seized from his Manhattan residence, which were made available on September 10 (see attached). I know that you had dealt directly with Epstein's attorneys regarding search terms, etc., so we haven't had visibility on that, but could you please let us know the current status, and when you expect we'll be able to get access to the materials? + +> thanks ver much + +Original Message + +> From: + +> Sent: Tuesday, September 17, 2019 17:17 + +> Subject: Taint Review + +> Hey guys, + +> Our supervisors are requesting a status update on the taint review process on your end. I simple percentage complete is fine, they just want to know before tomorrow they have a meeting with the ADIC about the case. \ No newline at end of file diff --git a/marker2/ds9/EFTA00083674/EFTA00083674.metadata.json b/marker2/ds9/EFTA00083674/EFTA00083674.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..888599d0824b231efe5e94216272efe5089b4cf9 --- /dev/null +++ b/marker2/ds9/EFTA00083674/EFTA00083674.metadata.json @@ -0,0 +1,122 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083674.pdf", + "engine": { + "marker_major": "2", + "marker_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": 4424, + "elapsed_seconds": 8.1, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Text", + 60 + ], + [ + "Line", + 37 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "Table", + 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", + 68 + ], + [ + "Line", + 35 + ], + [ + "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", + 69 + ], + [ + "Text", + 48 + ], + [ + "Line", + 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/EFTA00083674" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083677/EFTA00083677.md b/marker2/ds9/EFTA00083677/EFTA00083677.md new file mode 100644 index 0000000000000000000000000000000000000000..7a4d93bb7dde0466eb2e23ef37f7095bbdd8c4f5 --- /dev/null +++ b/marker2/ds9/EFTA00083677/EFTA00083677.md @@ -0,0 +1,48 @@ +**From:** "[REDACTED]" <[REDACTED]> +**To:** "[REDACTED]" <[REDACTED]>, "[REDACTED]" +<[REDACTED]> +**Subject:** FW: Subpoena - JP Morgan Chase Re [REDACTED] +**Date:** Tue, 08 Oct 2019 15:09:54 +0000 + +--- + +I know we're just sort of deferring to [REDACTED] on whatever projects he's working on, but do you guys think we want to have any kind of conversation / oversight with him on any of this? It occurs to me in particular for entities he's subpoenaing where we already have ongoing interactions with counsel, for example. I don't have super strong feelings either way but wanted to check in on it. + +-----Original Message----- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Tuesday, October 08, 2019 11:07 +**To:** [REDACTED] <[REDACTED]>; +[REDACTED] <[REDACTED]> +[REDACTED] +**Subject:** RE: Subpoena - JP Morgan Chase Re [REDACTED] + +Subpoena attached, thanks. + +[REDACTED] +Assistant United States Attorney +Southern District of New York +1 St. Andrew's Plaza +New York, NY 10007 +[REDACTED] + +-----Original Message----- + +**From:** [REDACTED] +**Sent:** Tuesday, October 8, 2019 8:10 AM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] +<[REDACTED]>; [REDACTED] <[REDACTED]> +[REDACTED] +**Subject:** Subpoena - JP Morgan Chase Re [REDACTED] + +Please prepare and return to me a subpoena for JP Morgan Chase regarding [REDACTED] I have attached the rider for the subpoena. I will serve the subpoena. + +Please forward the results in an electronic format to Special Agen Investigation, 26 Federal Plaza, New York, NY 10278, telephone + +If you have any questions or comments, please contact me. + +Thanks + +Mark + +Forensic Accountant FBI New York Field Office 26 Federal Plaza NYC, \ No newline at end of file diff --git a/marker2/ds9/EFTA00083677/EFTA00083677.metadata.json b/marker2/ds9/EFTA00083677/EFTA00083677.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..36493776934fd868a5eac049c4c2ff2447eccfbb --- /dev/null +++ b/marker2/ds9/EFTA00083677/EFTA00083677.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083677.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1688, + "elapsed_seconds": 5.74, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 26 + ], + [ + "Text", + 24 + ], + [ + "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 + ], + [ + "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/EFTA00083677" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083679/EFTA00083679.md b/marker2/ds9/EFTA00083679/EFTA00083679.md new file mode 100644 index 0000000000000000000000000000000000000000..c77a71d0a257c6543716911f6b4d60ce553560b3 --- /dev/null +++ b/marker2/ds9/EFTA00083679/EFTA00083679.md @@ -0,0 +1,57 @@ +To: + +Subject: RE: Epstein Client Meetings + +Date: Thu, 10 Oct 2019 19:02:50 +0000 + +Inline-Images: image001.png + +I'm totally available on the 22nd and 23rd, and I have he morning of the 24th but should be done by noon. So sounds like we'll have coverage basically anytime we need on those days. And also happy to split up on the AUSA and and add and/or to double up on interviews if that's helpful as well. + +From: + +Sent: Thursday, October 10, 2019 14:24 + +To: + +Subject: RE: Epstein Client Meetings + +I'm wide open on 10/22 as well. + +From: + +Sent: Thursday, October 10, 2019 2:23 PM + +To: >; >; + +Subject: FW: Epstein Client Meetings + +Sigrid also mentioned she has 2 to 3 that would like to be interviewed on 10/22 and 10/23 + +On Oct 10, 2019 2:15 PM, " > wrote: + +See below. I'm available on 10/23 after 2pm and all day on 10/24. What works for you guys? + +From: Brittany Henderson + +Sent: Thursday, October 10, 2019 2:08 PM + +To: + +Cc: Brad Edwards •z: > + +Subject: Epstein Client Meetings + +We have been coordinating with to schedule the following victim interviews for October 23 & 24: + +Let us know what works best for you. + +![](_page_1_Picture_2.jpeg) + +T' in EDWARDS L POTT INGER L LC + +Brittany Henderson + +Trial Attorney + +I www.epllc.com \ No newline at end of file diff --git a/marker2/ds9/EFTA00083679/EFTA00083679.metadata.json b/marker2/ds9/EFTA00083679/EFTA00083679.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b8768de5a46a6b47ba33bbc96a21098a2e96e5c3 --- /dev/null +++ b/marker2/ds9/EFTA00083679/EFTA00083679.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083679.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1226, + "elapsed_seconds": 1.24, + "image_assets": [ + "_page_1_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "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", + 18 + ], + [ + "Line", + 9 + ], + [ + "Text", + 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/EFTA00083679" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083679/_page_1_Picture_2.jpeg b/marker2/ds9/EFTA00083679/_page_1_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..3dd913d3375cc31e6e621a572ded238bd309ebf1 --- /dev/null +++ b/marker2/ds9/EFTA00083679/_page_1_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:636c4fad407b96ebdd99ede49da533bb0d8851b3e583f9a618bf3d2c796ef61d +size 2800 diff --git a/marker2/ds9/EFTA00083681/EFTA00083681.md b/marker2/ds9/EFTA00083681/EFTA00083681.md new file mode 100644 index 0000000000000000000000000000000000000000..37e5546c7f733e2c2e668f19d8b5f01dedccce22 --- /dev/null +++ b/marker2/ds9/EFTA00083681/EFTA00083681.md @@ -0,0 +1,47 @@ +Cc: "MN ( ye < + +Subject: FW: FBI Victim Services Division Briefing for Victims of Jeffrey Epstein + +Date: Tue, 08 Oct 2019 21:43:19 +0000 + +Attachments: image004.png + +Inline-Images: image005.jpg + +Hey all, + +Below is the letter that was sent out to the victims. I think some confusion may have been that the US Attorney's Office was mentioned in the letter because it was communicated to our office that a representative from SONY would be in attendance initially. + +From: VictimServices + +Sent: Friday, September 27, 2019 5:14 PM + +To: VictimServices + +Subject: FBI Victim Services Division Briefing for Victims of Jeffrey Epstein + +![](_page_0_Picture_11.jpeg) + +Federal Bureau of Investigation Victim Assistance Program New York Division + +September 27, 2019 + +RE: Case Number: NY-3027571 + +Dear Victim Services COPY, + +The FBI Victim Services Division invites you to attend a meeting with FBI Victim Services representatives and members of the FBI NY Field Office and the U.S. Attorney's Office for the Southern District of New York to learn more about the victim services that may be available to you. While we will not be able to provide specific details about the active investigation, we will provide you with information about the types of services we can provide and that you are entitled to, and Victim Specialists will be on site to try to address any specific questions you may have. + +These meetings will be held in two different locations, New York and Florida. Please choose which meeting you prefer to attend: + +Date: October 23, 2019 + +Time: 10:00 AM + +Location: 290 Broadway, New York, NY 10007 + +Participation is limited to you and one support person. If you are interested in attending, please respond by October 4, 2019 to VictimServices@jbi.ggs with your name, and if you choose, the name of one support person who will accompany you, as well as the meeting location you wish to attend. We will follow up with additional information to finalize your attendance. + +Thank you, + +FBI Victim Services Division \ No newline at end of file diff --git a/marker2/ds9/EFTA00083681/EFTA00083681.metadata.json b/marker2/ds9/EFTA00083681/EFTA00083681.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..529146938b09cdb0cb554bf1a998b541d69aa793 --- /dev/null +++ b/marker2/ds9/EFTA00083681/EFTA00083681.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083681.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2032, + "elapsed_seconds": 1.03, + "image_assets": [ + "_page_0_Picture_11.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 33 + ], + [ + "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 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Line", + 10 + ], + [ + "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/EFTA00083681" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083681/_page_0_Picture_11.jpeg b/marker2/ds9/EFTA00083681/_page_0_Picture_11.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..0db5bc0a419cfded11cfa52834f9dfeda75a7a32 --- /dev/null +++ b/marker2/ds9/EFTA00083681/_page_0_Picture_11.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:ee1ab8271fc1c1610ddb6f877e869fe23d0a4a67218b342551b66ea2568b0bfc +size 7863 diff --git a/marker2/ds9/EFTA00083683/EFTA00083683.md b/marker2/ds9/EFTA00083683/EFTA00083683.md new file mode 100644 index 0000000000000000000000000000000000000000..dd619aa8a2b228128f633b2d3d17b3a25fdee265 --- /dev/null +++ b/marker2/ds9/EFTA00083683/EFTA00083683.md @@ -0,0 +1 @@ +![](_page_0_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00083683/EFTA00083683.metadata.json b/marker2/ds9/EFTA00083683/EFTA00083683.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..40784e74a1964eb044564866b9b96209437aa1d7 --- /dev/null +++ b/marker2/ds9/EFTA00083683/EFTA00083683.metadata.json @@ -0,0 +1,56 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083683.pdf", + "engine": { + "marker_major": "2", + "marker_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": 27, + "elapsed_seconds": 0.19, + "image_assets": [ + "_page_0_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "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/EFTA00083683" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083683/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00083683/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..657ebdd42f94b3817be8fcb20ffb1a4632000018 --- /dev/null +++ b/marker2/ds9/EFTA00083683/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:892c41cd4b1b307278e2013b2a28f0853ace8d5b0a1df59cc090012940cadda7 +size 88253 diff --git a/marker2/ds9/EFTA00083684/EFTA00083684.md b/marker2/ds9/EFTA00083684/EFTA00083684.md new file mode 100644 index 0000000000000000000000000000000000000000..fa586ecaf1f57e4a3c1ece0a42bf85c53d39c8d8 --- /dev/null +++ b/marker2/ds9/EFTA00083684/EFTA00083684.md @@ -0,0 +1,139 @@ +From: + +To: + +Cc: + +Subject: Re: Taint Review - Epstein + +Date: Mon, 30 Sep 2019 23:02:52 +0000 + +Great and I'll check the drive tomorrow. + +Assistant United States Attorney Southern District of New York + +New York, NY 10007 + +On Sep 30, 2019, at 5:28 PM wrote: + +Great, thanks — we're working on this with the agents and will circle back when we have more info. Thanks again. + +From: + +Sent: Monday, September 30, 2019 14:33 + +To: + +Cc: + +Subject: RE: Taint Review - Epstein + +i just checked with and he said that there was not very much on the drive. Can you check with the agents and find out what they put on the drive? If they don't know, I'll check the drive when I'm back in the office tomorrow. And you can look at the NP folders. + +From: + +Sent: Monday, September 30, 2019 1:54 PM + +To: + +Cc: + +Subject: RE: Taint Review - Epstein + +Following up on the Epstein materials, it seems to us like 20,000 documents is exceedingly low given the volume of devices we seized. Can you please tell us how many source devices those documents are from, so we can crossreference? The seizure records appear to reflect that there were approximately 38 computers and/or electronic storage devices seized along with an additional approximately 55 CDs—see the attached seizure report. I just can't imagine that would only result in 20,000 documents. Please advise? + +thanks, + +Sent: urs ay, ep em er , . • + +To: + +Subje : TT : am eview- ps em + +FYI. + +Original Message + +From: + +Sent: Thursda Se tember 26 2019 11:37 AM + +To: + +Subject: e: Taint Review - pstein + +About 20K but a lot are non-user files, like adobe instructions. + +Assistant United States Attorney Southern District of New York + +New York, NY 10007 + +> On Sep 26, 2019, at 11:32 AM, wrote: + +> Out of curiosity, do you know what the volume of NP documents is? Thanks. + +> Original Message + +> From: + +> Sent: Thursda , Se I tember 26, 2019 11:02 AM + +> To: + +> Cc: + +> Subject: RE: Taint Review - Epstein + +• > I've run all the terms that Epstein's attorney gave me and segregated the hits, there were not many. Can I release the NP or did you come to some agreement with the defense that we would give them notice or let them review them first? + +> Thanks, + +> Ori •,inal Message + +> From: + +> Sent: Monda , September 23, 2019 8:46 PM + +> To: + +> Cc + +> Su jec ain eview + +> Great, thanks very much. + +> Subjec . . ain eview + +> We are running the lawyer/paralegal names now, you should have access in a couple of days. + +> Original Message + +> From: + +> Sent: Saturday, September 21, 2019 5:02 PM + +> To: + +> Cc: + +> Subject: FW: Taint Review + +> The agents on the Epstein case have asked, below, about the status of the taint review of the materials seized from his Manhattan residence, which were made available on September 10 (see attached). I know that you had dealt directly with Epstein's attorneys regarding search terms, etc., so we haven't had visibility on that, but could you please let us know the current status, and when you expect we'll be able to get access to the materials? + +> thanks very much + +> Ori :coal Messa:e + +> From: + +> Sent: Tuesday, September 17, 2019 17:17 + +> To: + +> Subject: Taint Review + +> Hey guys, + +> Our supervisors are requesting a status update on the taint review process on your end. I simple percentage complete is fine, they just want to know before tomorrow they have a meeting with the ADIC about the case. + +> Thanks \ No newline at end of file diff --git a/marker2/ds9/EFTA00083684/EFTA00083684.metadata.json b/marker2/ds9/EFTA00083684/EFTA00083684.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..95e119fe9b42c507814672c92f32a1448d2e1d9e --- /dev/null +++ b/marker2/ds9/EFTA00083684/EFTA00083684.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083684.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3357, + "elapsed_seconds": 2.22, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 60 + ], + [ + "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", + 83 + ], + [ + "Text", + 44 + ], + [ + "Line", + 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", + 51 + ], + [ + "Text", + 32 + ], + [ + "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/EFTA00083684" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083687/EFTA00083687.md b/marker2/ds9/EFTA00083687/EFTA00083687.md new file mode 100644 index 0000000000000000000000000000000000000000..35328baccb7304985991360b553c264737349dc1 --- /dev/null +++ b/marker2/ds9/EFTA00083687/EFTA00083687.md @@ -0,0 +1,46 @@ +From: ' To: Brittany Henderson I. ' Cc: Brad Edwards I. ' 11 + +Subject: RE: Epstein Client Meetings + +Date: Thu, 10 Oct 2019 19:35:54 +0000 + +Inline-Images: image001.png + +Hi Brittany, + +Thanks very much for reaching out. I would propose the following dates and times for interviews: + +- 10/23 at 1 pm — +- 10/23 at 3 pm — +- 10/24 at 10 am — +- 10/24 at 12 pm — + +Would those work on your end? + +Thanks again, + +Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 + +=16 + +From: Brittany Henderson < + +Sent: Thursday, October 10, 2019 2:08 PM + +To: >; + +Cc: Brad Edwards < + +Subject: Epstein Client Meetings + +We have been coordinating with to schedule the following victim interviews for October 23 & 24: + +Let us know what works best for you. + +![](_page_1_Picture_2.jpeg) + +Brittany Henderson + +Trial Attorney + +I www.epllc.com \ No newline at end of file diff --git a/marker2/ds9/EFTA00083687/EFTA00083687.metadata.json b/marker2/ds9/EFTA00083687/EFTA00083687.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..076ae7d386335539b08ae1c07710af9baa8f248b --- /dev/null +++ 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b/marker2/ds9/EFTA00083689/EFTA00083689.md new file mode 100644 index 0000000000000000000000000000000000000000..ea1f52ef1f5c3d6d7134fd48b704718d1dcce8cc --- /dev/null +++ b/marker2/ds9/EFTA00083689/EFTA00083689.md @@ -0,0 +1,33 @@ +From: "EMMEMME > + +To: + +Cc: + +Subject: two communications from individuals who may have JE information + +Date: Thu, 10 Oct 2019 22:31:49 +0000 + +Attachments: 20191010 153452.wav + +Consistent with passing along all tips that somehow come to us, attached please find a voicemail I received earlier today. + +Se aratel , yesterday I got a call from an attorney named Blair Fellows, who said that she has a client named who has information about Epstein--I didn't et into the substance (because no witness) and said I would pass along her contact information, which is + +thanks, + +Ori final Messa e + +From: + +Sent: urs a cto r , : + +To: + +Cc: + +Subject: Voice Message Attached fro + +Time: Oct 10, 2019 3:34:52 PM + +Click attachment to listen to Voice Message \ No newline at end of file diff --git a/marker2/ds9/EFTA00083689/EFTA00083689.metadata.json b/marker2/ds9/EFTA00083689/EFTA00083689.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..75e06e522d533d991c4b2eac6c376dc9694784ac --- /dev/null +++ b/marker2/ds9/EFTA00083689/EFTA00083689.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083689.pdf", + "engine": { + "marker_major": "2", + "marker_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": 0.84, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Line", + 21 + ], + [ + "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/EFTA00083689" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083690/EFTA00083690.md b/marker2/ds9/EFTA00083690/EFTA00083690.md new file mode 100644 index 0000000000000000000000000000000000000000..956f84528f78914dbf0d91c29f37d7156b31e83f --- /dev/null +++ b/marker2/ds9/EFTA00083690/EFTA00083690.md @@ -0,0 +1,15 @@ +To: + +Subject: RE: Adams Case + +Date: Sat, 12 Oct 2019 03:15:39 +0000 + +C19 Epstein Death invest: 90A-NY-3151227 + +From: + +Sent: Friday, October 11, 2019 3:23 PM To: + +Subject: Adams Case + +Could you send me the FBI file number? Thanks! \ No newline at end of file diff --git a/marker2/ds9/EFTA00083690/EFTA00083690.metadata.json b/marker2/ds9/EFTA00083690/EFTA00083690.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..67b28821934c215bd7a2300a5908925a1e186a1e --- /dev/null +++ b/marker2/ds9/EFTA00083690/EFTA00083690.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083690.pdf", + "engine": { + "marker_major": "2", + "marker_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": 229, + "elapsed_seconds": 0.45, + "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/EFTA00083690" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083691/EFTA00083691.md b/marker2/ds9/EFTA00083691/EFTA00083691.md new file mode 100644 index 0000000000000000000000000000000000000000..49f489cfc34c278df108efa35a1d78c6135509f7 --- /dev/null +++ b/marker2/ds9/EFTA00083691/EFTA00083691.md @@ -0,0 +1,56 @@ +Fifth Third Bank 5050 Kingsley Drive Mail Drop 1MOC2Q Cincinnati, OH 45263 + +Attention: Subpoena Processing Dept. + +Delivered via: FedEx + +## ALL OPEN AND CLOSED ACCOUNTS + +Please provide all images of documents in Adobe PDF files on CDs. + +Rider + +Please provide from account inception to present any and records pertaining to the following accounts(s)/organization(s)/individuals(s) whether held jointly or severally or as trustee or fiduciary as well as custodian, executor or guardian: + +A. Please use the following identifiers: + +| NAMES/ENTITIES | +|------------------| +| | +| | +| | +| | +| DOB | +| SSN | +| ADDRESS | +| | +| | +| | +| PHONE | +| | +| | +| EMAIL | +| | +| ACCOUNT NUMBERS: | + +B. Records to be produced should include but are not limited to the items listed below: + +- 1. DATA TRANSACTION FILES +- 2. Documents (checks, debit memos, cash in tickets, wires in, wires out, etc.) reflecting additions and/or subtractions to the account and how the account balances are being satisfied on a monthly basis; +- 3. Signature cards; +- 4. Proof of identification (including but not limited to copies of identification used to open the account); +- 5. Opening account(s) documents with attachments, including any and all applications, internal documents generated to open account(s), and identification information or other documentation provided by Customer; and Customer's email address +- 6. "Know your customer" documentation; +- 7. Wire transfer records (incoming and outgoing, and any and all applications and instructions); +- 8. Safe deposit records, including applications, signature cards, and sign-in records; +- 9. Trust accounts; +- 10. Monthly statements; +- 11. Credit card statements; +- 12. Bank, travelers, or cashier checks drawn on account or purchased with an account check; +- 13. Prepaid debit cards, certified checks, cashiers' checks, money orders, and traveler's checks; +- 14. Loan, lease, and/or mortgage application files (whether granted or denied) including credit reports, applications, and payments made on loans; +- 15. Online banking information- All information regarding the electronic use of banking systems to include the following: username, registration IP address, online account creation date, online account status and IP logs/history, MAC addresses and online session times and duration; +- 16. Any and all corporate resolutions, certifications of incorporation, business certificates and/or partnership agreements; and +- 17. Any and all correspondence, electronic or otherwise, including memoranda, emails and text messages, that reference or concern items (1) through (16), above, and/or any financial interests involving the individuals and/or entities identified in Section A. + +If you have any questions or comments, please contact Forensic Accountant, at \ No newline at end of file diff --git a/marker2/ds9/EFTA00083691/EFTA00083691.metadata.json b/marker2/ds9/EFTA00083691/EFTA00083691.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d5b891b930b13f20b73240895fc5564169458c3f --- /dev/null +++ b/marker2/ds9/EFTA00083691/EFTA00083691.metadata.json @@ -0,0 +1,124 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083691.pdf", + "engine": { + "marker_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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[ + "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/EFTA00083691" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083693/EFTA00083693.md b/marker2/ds9/EFTA00083693/EFTA00083693.md new file mode 100644 index 0000000000000000000000000000000000000000..1cf6b2d04a8846a9adfbc7bc6ede558687bc5cc8 --- /dev/null +++ b/marker2/ds9/EFTA00083693/EFTA00083693.md @@ -0,0 +1,25 @@ +To: ' + +Cc: Brad Edwards + +Subject: Epstein Client Meetings + +Date: Thu, 10 Oct 2019 18:08:08 +0000 + +Inline-Images: image001.png + +We have been coordinating with to schedule the following victim interviews for October 23 & 24: + +If possible, the morning on October 24 works best for would prefer the 23 to minimize her travel into the City. and are available either day. + +Let us know what works best for you. + +![](_page_0_Picture_14.jpeg) + +rrri EDWARDS POTTING ER LLC + +Brittany Henderson + +Trial Attorney + +www.eplIc.com \ No newline at end of file diff --git a/marker2/ds9/EFTA00083693/EFTA00083693.metadata.json b/marker2/ds9/EFTA00083693/EFTA00083693.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b812a14574bf2fcc2dca6b7035b2761158508530 --- /dev/null +++ b/marker2/ds9/EFTA00083693/EFTA00083693.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083693.pdf", + "engine": { + "marker_major": "2", + "marker_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": 513, + "elapsed_seconds": 1.03, + "image_assets": [ + "_page_0_Picture_14.jpeg" + ], + "marker_metadata": { + 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a/marker2/ds9/EFTA00083694/EFTA00083694.md b/marker2/ds9/EFTA00083694/EFTA00083694.md new file mode 100644 index 0000000000000000000000000000000000000000..29f1d00185be5e096c56a82e9333add0dbf89f26 --- /dev/null +++ b/marker2/ds9/EFTA00083694/EFTA00083694.md @@ -0,0 +1,39 @@ +**From:** [REDACTED] +**To:** [REDACTED] +**Subject:** FW: Subpoena AMEX Re [REDACTED] +**Date:** Thu, 10 Oct 2019 14:48:40 +0000 +**Attachments:** AMEX\_Subpoena [REDACTED].docx + +--- + +Do you still want me to be cutting these subpoenas? Or do you want to discuss first? + +-----Original Message----- + +**From:** [REDACTED] +**Sent:** Thursday, October 10, 2019 10:44 AM +**To:** [REDACTED] +**Cc:** [REDACTED] +**Subject:** Subpoena AMEX Re [REDACTED] + +Please prepare and return to me a subpoena for American Express regarding [REDACTED] I have attached the rider for the subpoena. I will serve the subpoena. + +Additionally, please utilize the following text in the subpoena: + +If you have any questions, please contact Forensic Accountant [REDACTED] + +Please forward the results in an electronic format to Special Agent [REDACTED], Federal Bureau of Investigation, [REDACTED], New York, NY 10278, telephone [REDACTED], [REDACTED] + +If you have any questions or comments, please contact me. + +Thanks + +[REDACTED] + +[REDACTED] + +Forensic Accountant +FBI New York Field Office +[REDACTED] +NYC, NY 10278 +Office: [REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00083694/EFTA00083694.metadata.json b/marker2/ds9/EFTA00083694/EFTA00083694.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ea152f09832775dfde1c6403ea812f729e733870 --- /dev/null +++ b/marker2/ds9/EFTA00083694/EFTA00083694.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083694.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1122, + "elapsed_seconds": 4.93, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Text", + 40 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00083694" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083695/EFTA00083695.md b/marker2/ds9/EFTA00083695/EFTA00083695.md new file mode 100644 index 0000000000000000000000000000000000000000..a395a14ada9a70e2e97dcc5281c741970fb438d4 --- /dev/null +++ b/marker2/ds9/EFTA00083695/EFTA00083695.md @@ -0,0 +1,59 @@ +American Express 43 Butterfield Circle El Paso, TX 79906 + +Attention: Subpoena Response Unit + +Delivered via: FEDEX + +Rider + +## ALL OPEN AND CLOSED ACCOUNTS + +Please provide from inception to present, in an electronic format, any and records pertaining to the following accounts(s)/organization(s)/individuals(s) whether held jointly or severally or as trustee or fiduciary as well as custodian, executor or guardian: + +Please use the following identifiers: + +| NAMES/ENTITIES | AKA: | [REDACTED] | +|----------------|------------|------------| +| | [REDACTED] | [REDACTED] | +| | [REDACTED] | [REDACTED] | +| | [REDACTED] | [REDACTED] | +| | [REDACTED] | [REDACTED] | +| | [REDACTED] | [REDACTED] | +| DOB | [REDACTED] | [REDACTED] | +| SSN | [REDACTED] | [REDACTED] | +| ADDRESS | [REDACTED] | [REDACTED] | +| | [REDACTED] | [REDACTED] | +| | [REDACTED] | [REDACTED] | +| | [REDACTED] | [REDACTED] | +| | [REDACTED] | [REDACTED] | +| | [REDACTED] | [REDACTED] | +| PHONE | [REDACTED] | [REDACTED] | +| | [REDACTED] | [REDACTED] | +| | [REDACTED] | [REDACTED] | +| EMAIL | [REDACTED] | [REDACTED] | +| | [REDACTED] | [REDACTED] | +| | [REDACTED] | [REDACTED] | + +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. 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; +- 5. "Know your customer" documentation; +- 6. Correspondence files (including correspondence with any regulatory or law enforcement authority); +- 7. Memoranda, notes or other records of telephone conversations (including conversations with any regulatory or law enforcement authority); +- 8. Internal memoranda and reports; +- 9. Wire transfer records (incoming and outgoing, and any and all applications and instructions); +- 10. Safe deposit records, including applications, signature cards, and sign-in records +- 11. Trust accounts; +- 12. Monthly statements; +- 13. Credit card statements; +- 14. Bank, travelers, or cashier checks drawn on account or purchased with an account check; +- 15. Prepaid debit cards, certified checks, cashiers' checks, money orders, and traveler's checks; +- 16. Loan, lease, and/or mortgage application files (whether granted or denied) including credit reports, applications, and payments made on loans; +- 17. Any and all corporate resolutions, certifications of incorporation, business certificates and/or partnership agreements; and +- 18. Any and all correspondence, electronic or otherwise, including memoranda, emails and text messages, that reference or concern items (1) through (18), above, and/or any financial interests involving the individuals and/or entities identified in Section A. + +If s ou have any questions or comments, please contact-, Forensic Accountant, at or at \ No newline at end of file diff --git a/marker2/ds9/EFTA00083695/EFTA00083695.metadata.json b/marker2/ds9/EFTA00083695/EFTA00083695.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f258bee94647089528540f54842856143dd51d73 --- /dev/null +++ b/marker2/ds9/EFTA00083695/EFTA00083695.metadata.json @@ -0,0 +1,132 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083695.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3450, + "elapsed_seconds": 11.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "ALL OPEN AND CLOSED ACCOUNTS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 211.403076171875 + ], + [ + 230.94342041015625, + 211.403076171875 + ], + [ + 230.94342041015625, + 223.5841064453125 + ], + [ + 68.544, + 223.5841064453125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 23 + ], + [ + "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", + 59 + ], + [ + "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/EFTA00083695" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083697/EFTA00083697.md b/marker2/ds9/EFTA00083697/EFTA00083697.md new file mode 100644 index 0000000000000000000000000000000000000000..24bad3ac67c4b451282a0f7a7f1a4fa778608c22 --- /dev/null +++ b/marker2/ds9/EFTA00083697/EFTA00083697.md @@ -0,0 +1,77 @@ +From: ' + +Subject: FW: Labyrinth of Deception --Jeff Epstein + +Date: Fri, 27 Sep 2019 16:46:01 +0000 + +Passing along the below email per our practice of conveying any tips we receive related to the Epstein case. + +Thanks, + +Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York. NY 10007 + +From: + +Sent: Friday, September 27, 2019 9:46 AM + +To: + +Subject: FW: Labyrinth of Deception --Jeff Epstein + +This is addressed to but sent to me. Should I send it to send it to all of you. will send it to will + +From: Disanto, Patrick .: I.edu> + +Sent: Friday, September 27, 2019 9:21 AM + +To: + +Subject: Labyrinth of Deception --Jeff Epstein + +Victim/Witness Coordinator + +United States Attorney's Office + +Good Morning, within two scripts that sat on Harvey Wiensteins desk in lower Manhatten were "sponsorship" PSA's (public service announcements) on one of Epsteins victims, a 13 year old female, thoughts are not always clear and events upsetting, that seem should have been looked into deeper. Jas given those of us that came into contact with these predators, hope. The plight of the young south American girl (from ages 6-14) mentioned is detailed and a very moving account of the life of a "sponsored" person in + +2009. The 1st film is JAKE about Martin Luther King HS soccer coach Martin Jacobsen, a sport film where she appears as side story a PSA because we could not draw attention in 2009 to her situation. + +No advocate agency would help her of the 200+ we contacted and the fact she was "sponsored" by a Canadian official and American official is disturbing in itself. The second script was 35 cents a larger story this time a murder mystery about the young American boys from Texas are ages 13-22, that have vanished at an alarming rate. A municipal sheriff was identified as well as a judge making this an unpopular segment in the second film we put "sponsorship" PSA within. Intended to be as cautionary tale for youth to become aware of putting themselves in compromising situations and hope for those in them. + +I feel as did the other writers that people need to understand rehabilitation for not only the victims but for those involved in the transaction of human life, to comprehend what they have participated in, the innocence they have interrupted and changed forever. The public needs to really look at this problem within our officials as well as in the moral fabric of our America is experiencing, not look for the noose but step back and find a remedy a solution to the problem. This is the only release for the victims of predator stalking/malice/abuse of another human life. + +I am asking your advice on presenting this to iswell as Geoffery S. Berman covering the subject currently - most intimately Jeff Epstein as he is connected directly to the young girl, who at last check was doing well protected a decade later in a new community by a church out of the United States. + +The boys effected by these predators, not having the same advocacy tracking mechanism in place and they are a very under investigated section of this equation as men and sexuality often includes deep shame. From what we have witnessed most often leading to death, our story was presented as success the combination of three lives to get it to a point where viewers could digest it. These are from the perspective of actual victims too young to process the complex emotions of coming in contact with a predators such as Epstien, Klein, Wienstein, Cooper or Mandlebaum. Sponsorships are not of interest to most, people believe these victims have done something illegal to end up in this situation, most often they simply are young, inexperienced, ill educated, and traumatized. + +This writing for these films cost me considerably, aside from the TBI/CTE, the mistruths invented creating a riff between myself and my own children (we suspect gas lighting/Stockholm Syndrome) as individuals involved confiscated most of the research findings from a storage locker. Fortunately the staff at the studio was large and hard headed, many intimidation and scare tactics have had to be confronted in attempts to snuff these stories. + +![](_page_2_Picture_0.jpeg) + +![](_page_2_Picture_1.jpeg) + +Athlete stalked then brutally attacked while portraying a young man mixed up in slavery and sex trafficking; Patrick di Santo who portrayed Matt MacKlee in the MEDIAiidp/Kronogruffix Pictures, film "35 cents" was reportedly harassed by officials -including having his children removed from his custody, for the portrayal of the abused teen. Crew and cast complained to local courts and agencies with no relief, Disanto was then assaulted himself, shutting down production, stating reasons of safety. + +Opposing attorneys and child care advocates represented to the courts that di Santo was an unfit parent due to the homosexual content in this film, proving Americans are not safe from their own officials. The officials in question ignored he had been the sole primary caregiver for his children for 10 years prior with no record of the children ever suffering in his care (Stein). + +Representation: + +Attorney + +M. Jim Jenkins + +![](_page_2_Picture_7.jpeg) + +![](_page_2_Picture_8.jpeg) + +Pensacola, Florida 32502 + +Sylvia Penner + +Fleeson, Gooing, Coulson & Kitch, LLC + +![](_page_2_Picture_12.jpeg) + +Wichita, KS 67202 + +![](_page_2_Picture_14.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00083697/EFTA00083697.metadata.json b/marker2/ds9/EFTA00083697/EFTA00083697.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c5a091f2cac27476b9667b5700ebcf960a9fb1ef --- /dev/null +++ b/marker2/ds9/EFTA00083697/EFTA00083697.metadata.json @@ -0,0 +1,151 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083697.pdf", + "engine": { + "marker_major": "2", + "marker_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": 5340, + "elapsed_seconds": 1.36, + 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GHISLAINE MAXWELL, Defendant. x + +20 Cr. 330 (AJN) + +### MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL + +Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: + +Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: + +Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: + +Attorneys for Ghislaine Maxwell + +## INTRODUCTION + +Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. + +As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in United States for 30 years, has strong family ties and the support of friends and family residing in this country. She wants nothing more than to remain in the United States under whatever conditions the Court deems necessary so that she can effectively prepare for trial and vigorously defend against the 25-year-old charges in the Indictment. Ms. Maxwell has already proposed an expansive and, to our knowledge, unprecedented set of bail conditions that would reasonably assure her appearance. (See Dkt. 97.) In light of the Court's denial of that application (see Dkt. 106), Ms. Maxwell now proposes two additional bail conditions to supplement the extraordinarily restrictive bail package she has already offered. + +- First, Ms. Maxwell will renounce her French and British citizenship to eliminate any opportunity for her to seek refuge in those countries, if the Court so requires. +- Second, Ms. Maxwell will have her and her spouse's assets—excluding funds earmarked for living expenses, for legal fees and other expenses necessary to defend her against the criminal charges in this case and related civil lawsuits and for taxes—placed in a new account that will be monitored by a retired federal District Court judge and former United States Attorney who will function as asset monitor and will have co-signing authority over the account. + +The former condition goes well beyond the extradition waivers that the Court deemed insufficient and should satisfy any concerns the Court may have that Ms. Maxwell may try to seek a safe haven in France or the United Kingdom. (See id. at 11-13). As a non-citizen, Ms. Maxwell will not be able to avail herself of any protections against extradition that may apply to citizens of those countries. The latter condition will restrain Ms. Maxwell's assets so they cannot be used for flight or harboring her outside of the jurisdiction of this Court. This should satisfy the Court's concern that the proposed bond was not fully secured and left assets unrestrained that could be used for such purposes. (See id. at 17-18). + +In addition, since the last bail application, Ms. Maxwell has submitted twelve pretrial motions that raise substantial legal and factual issues that may result in the dismissal of some or all of the charges against her. Ms. Maxwell referenced some of these motions in her initial bail application (see Dkt. 18 at 19) but was not in a position to fully articulate them until she had the chance to review the discovery and research the legal issues in advance of the motion deadline of January 25. These motions significantly call into question the strength of the government's case against Ms. Maxwell and the underlying justification for continued detention. + +Ms. Maxwell has already been denied a fair chance in the court of public opinion. She has been maligned by the media, which has perpetuated a false narrative about her that has poisoned any open-mindedness and impartiality of a potential jury. She has been relentlessly attacked with vicious slurs, persistent lies, and blatant inaccuracies by spokespeople who have neither met nor spoken to her. She has been depicted as a cartoon-character villain in an attempt to turn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined and welcomes the opportunity — to face her accusers at trial and clear her name. The additional proposed bail conditions should quell any concerns that she would try to flee. The Court should therefore grant bail under the proposed conditions so that Ms. Maxwell can adequately prepare for trial. + +#### The Proposed Additional Bail Conditions Will Reasonably Assure Nis. \ la kV% CH'S Appearance in Court + +As set forth above, Ms. Maxwell now proposes two additional restrictions that eliminate any means or opportunity that she may have to leave the country. The Court should therefore reconsider its earlier ruling and grant bail under the proposed conditions. See United States v. Rowe, No. 02 CR. 756 LMM, 2003 WL 21196846, at \*1 (S.D.N.Y. May 21, 2003) ("[A] release order may be reconsidered even where the evidence proffered on reconsideration was known to the movant at the time of the original hearing."); see also United States v. Petrov, No. I 5-CR-66- LTS, 2015 WL 11022886, at \*3 (S.D.N.Y. Mar. 26, 2015) (noting "Court's inherent authority for reconsideration of the Court's previous bail decision"). + +## A. Renunciation of Foreign Citizenship + +To demonstrate her commitment to abide by her conditions of release and to provide further assurance to the Court that she will not attempt to leave the country, Ms. Maxwell is willing to formally renounce her foreign citizenships in France and the United Kingdom. Should the Court feel this drastic condition is necessary, the required documents will be submitted to the appropriate authorities. Moreover, as a standard condition of bail, all of Ms. Maxwell's passports will be surrendered to the government and no further application will be made. + +If the Court deems it a necessary condition of release, Ms. Maxwell will formally commence the procedure to renounce her foreign citizenship. The requisite paperwork is in the process of being completed. Renunciation of UK citizenship can be accomplished immediately upon granting of bail. The process of renouncing her French citizenship, while not immediate, may be expedited. + +Citizenship is a precious and priceless asset. Ms. Maxwell's decision to give up citizenship from the county of her birth and the country of her upbringing demonstrates her earnestness to abide by the conditions of her release and underscores that she has no intention to flee and reflects her deep need to communicate freely with counsel to prepare for her defense. Her renunciation of foreign citizenship obviates the Court's concerns about the validity of waivers of extradition. (See Dkt. 106 at 13). Ms. Maxwell will have no ability to contest extradition from France or the United Kingdom on the basis of citizenship, which removes any incentive the Court and government believe she may have to seek refuge in those countries. + +# B. Restraint and Monitoring of Assets + +In denying bail, the Court noted that the bond was not fully secured, and that Ms. Maxwell and her spouse would still have several million dollars in unrestrained assets that could be used to facilitate her flight from the country. (See id. at 17-18). To assuage any concerns that those assets would be available to finance flight to and shelter in a foreign country, Ms. Maxwell has taken steps to create a monitorship that will place meaningful restraints on the assets that are not used to secure the bond, while still allowing Ms. Maxwell to pay for her legal defense, for her spouse to pay for daily living expenditures and for payment of taxes. + +## 1. New Account + +All assets of Ms. Maxwell and her spouse, with the exception of money currently held in escrow for legal fees and related defense expenses and the funds contained in the bank account in the name of Ms. Maxwell's spouse ("the Personal Account")', will be deposited in a newly created account ("the New Account") to be overseen by an asset monitor appointed pursuant to order of the Court. The New Account will contain all of Ms. Maxwell's and her spouse's remaining cash and other liquid assets, including any proceeds that result from the pending sale + +1The Personal Account is identified as Account Ion page 9 of the Financial Report annexed to Ms. Maxwell's Renewed Bail Application. (See Dkt. 97, Exhibit 0.) + +of Ms. Maxwell's London house and any other assets, excluding salary, hereinafter acquired. The asset manager will approve the financial institution at which the New Account is created and must approve and co-sign any expenditure from the New Account, with the exception of disbursements for Ms. Maxwell's legal fees in connection with the ongoing criminal and civil litigation and for payment of taxes, which will not require authorization. No illiquid assets may be sold, conveyed or transferred without approval of the asset monitor. + +### 2. Other Assets + +The only funds that will not be included in the New Account are (I) the money currently held in escrow by Ms. Maxwell's attorneys, which will be used exclusively for her defense; and (2) the roughly \$450,000 in the Personal Account which her spouse will use only for living expenses. The asset monitor shall regularly receive information regarding activity of the Personal Account, including the account balance, on a weekly basis. The asset monitor must also receive five-day advance notice of any check, on-line payment, or transfer of finds in any amount exceeding \$5,000, and the reason for such payment. Ms. Maxwell's spouse agrees to be bound by these restrictions and reporting requirements. + +The asset monitor shall report to Pretrial Services any possible non-compliance or disbursement in violation of the terms and conditions specified above. + +## 3. Selected Asset Monitor + +The Honorable William S. Duffey, Jr., a retired federal District Court judge and the former United States Attorney for the Northern District of Georgia, has agreed to undertake the position of asset monitor. (Judge Duffey's bio is attached as Exhibit A.) Judge Duffey has extensive experience evaluating and monitoring funds held in and disbursed from financial + +accounts and will be entrusted with the authority to oversee the assets of Ms. Maxwell and her spouse, as described above. + +Restraining Ms. Maxwell's assets that are not used to secure the bond and placing them under the supervision of a former federal District Court judge eliminates any concern that such funds could be used to violate the terms of release. + +#### IL Ms. Maxwell's Pretrial Motions Raise Substantial Legal and Factual Issues That Could Result in Dismissal of Some or All of the Charges Against Her + +In addition to the new conditions proposed above, the numerous substantive pretrial motions now before the Court amply challenge the purported strength of the government's case. Ms. Maxwell's pretrial motions raise serious legal issues that could result in dismissal of charges, if not the entire indictment. Among the dozen submissions are motions to dismiss the superseding indictment for breach of the non-prosecution agreement, for pre-indictment delay, and for being based on improperly obtained evidence in violation of Ms. Maxwell's constitutional rights under the Fifth and Sixth the Amendments. Other motions seek dismissal of the Mann Act charges as being time-barred and the perjury charges as based on non-perjurious statements. These motions are substantial with a likelihood of success on the merits. These motions cast substantial doubt on the alleged strength of the government's case and warrant granting bail on the conditions proposed. + +# III. The Court Should Grant Bail + +Under the Bail Reform Act of 1984, a defendant must be released on personal recognizance or unsecured personal bond unless the judicial officer determines "that such release will not reasonably assure the appearance of the person as required or will endanger the safety of any other person or the community." 18 U.S.C. § 3142(b). The enhanced bail package proposed by Ms. Maxwell contains financial burdens and a combination of restrictions that reasonably + +assure her appearance as required. Before preventive detention may be ordered under § 3142(e), the Court is obliged to determine both whether the defendant is likely to flee the jurisdiction if released, and whether any conditions of release will be reasonably certain to guard against this propensity to flee. The Court expressed concerns and denied bail without indicating what conditions would be reasonably certain to assure Ms. Maxwell's appearance. Ms. Maxwell is no danger to the community and not alleged to have been involved in ongoing criminal activity. To say that there are absolutely no conditions flies in the face of cases where non-United States citizens with no ties to the district, let alone the country, were released on lesser conditions for alleged criminality ongoing up to or within hours of the time of arrest, in contrast to 26-year-old claims alleged against Ms. Maxwell.' + +The additional conditions set forth above, which supplement the exceptional bail package previously proposed, are sufficient to address the hypothetical risk of flight and secure Ms. Maxwell's presence at trial. The financial magnitude of the proposed bonds, the collateral pledged to secure the bonds, the stringent requirements of home detention, the renunciation of foreign citizenship and monitoring of assets contained in a special account from which no funds can be withdrawn without the approval and signature of a retired federal District Court judge and former United States Attorney are conditions that amply satisfy the concerns expressed by the government and the Court. These cnditions are unique and unprecedented. They profoundly + +2 See Dkt. 97 at 34 (case-comparison chart in the Renewed Motion for Bail); cf. People v. Dominique Strauss-Kahn, 02526/201 I(S.Ct. N.Y. County). Strauss-Kahn, a French citizen with no ties to the United States, was arrested on a Paris-bound flight at JFK minutes before takeoff and later charged with several counts of sexual assault, including felony charges punishable up to 25 years imprisonment, for sexual assault and attempted rape of a Manhattan hotel housekeeper on the day of his arrest. The accusations were corroborated by semen containing Strauss-Kahn's DNA on the accuser's uniform. The New York State Supreme Court granted bail in the amount of \$ I million cash, 24 hour home detention electronic monitoring ankle bracelet, and private 24/7 security guards. After surrendering his French passport and posting an additional \$5 million bail bond, Strauss-Kahn was placed under house arrest in a residence in Manhattan. See https://www.theguardian.comAvorld/20 Ill may/20/dominiquc-strauss-kahn-ncw-yorkapartment. + +affirm Ms. Maxwell's earnestness in seeking bail to properly prepare her defense, not to flee. + +The Court should grant bail to Ghislaine Maxwell. + +## CONCLUSION + +The proposed additional conditions of release—renunciation of foreign citizenship and restraint and monitoring of assets by a retired District Court judge—enhance the already extraordinarily restrictive bail conditions proposed in Ms. Maxwell's Renewed Motion for Bail. + +In combination, these conditions satisfy the Bail Reform Act and reasonably assure Ms. + +Maxwell's appearance at trial. To deny Ms. Maxwell bail when such extraordinary and restrictive conditions are available would be a miscarriage of justice. + +Dated: February 23, 2021 + +Respectfully submitted, + +goat C. Sitagn. + +Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: + +Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: + +Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: \ No newline at end of file diff --git a/marker2/ds9/EFTA00083701/EFTA00083701.metadata.json b/marker2/ds9/EFTA00083701/EFTA00083701.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8ce83675a6f0d7fcedd2aa6330acd29368a291d6 --- /dev/null +++ b/marker2/ds9/EFTA00083701/EFTA00083701.metadata.json @@ -0,0 +1,615 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083701.pdf", + "engine": { + "marker_major": "2", + "marker_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": 15943, + "elapsed_seconds": 1.27, + "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 + ], + [ + 281.7991943359375, + 71.28 + ], + [ + 281.7991943359375, + 99.7330322265625 + ], + [ + 68.544, + 99.7330322265625 + ] + ] + }, + { + "title": "MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S \nTHIRD MOTION FOR RELEASE ON BAIL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 133.416, + 345.87 + ], + [ + 479.59716796875, + 345.87 + ], + [ + 479.59716796875, + 375.7330322265625 + ], + [ + 133.416, + 375.7330322265625 + ] + ] + }, + { + "title": "INTRODUCTION", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 255.204, + 96.38999999999999 + ], + [ + 356.9654541015625, + 96.38999999999999 + ], + [ + 356.9654541015625, + 111.9735107421875 + ], + [ + 255.204, + 111.9735107421875 + ] + ] + }, + { + "title": "The Proposed Additional Bail Conditions Will Reasonably Assure Nis. \\ la kV% CH'S \nAppearance in Court", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 525.708, + 71.28 + ], + [ + 525.708, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + }, + { + "title": "A. 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Mollo Building +One Saint Andrew's Plaza +New York, New York 10007* + +December 16, 2020 + +**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: + +Pursuant to the Court's December 7, 2020 Order (Dkt. 89), the Government respectfully submits under seal an unredacted version of its memorandum of law and two accompanying exhibits in opposition to the defendant's renewed motion for bail. Additionally, the Government respectfully submits proposed redactions to its memorandum of law. Consistent with the redactions contained in the defense motion, the Government's proposed redactions are narrowly tailored to cover (1) information implicating the privacy interests of third parties previously articulated by the defense (Dkt. 86), and (2) Confidential Material produced by the Government in discovery and governed by paragraph 15 of the Protective Order in this case (Dkt. 36). + +Respectfully submitted, + +AUDREY STRAUSS +Acting United States Attorney + +[REDACTED] + +By: + +[REDACTED] / [REDACTED] / [REDACTED] + +Assistant United States Attorneys +Southern District of New York + +Tel: [REDACTED] + +Cc: All Counsel of Record (By email) \ No newline at end of file diff --git a/marker2/ds9/EFTA00083710/EFTA00083710.metadata.json b/marker2/ds9/EFTA00083710/EFTA00083710.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e47ba9b09eefcaccc70ad0017877403fde693ac6 --- /dev/null +++ b/marker2/ds9/EFTA00083710/EFTA00083710.metadata.json @@ -0,0 +1,111 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083710.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1437, + "elapsed_seconds": 5.9, + "image_assets": [ + "_page_0_Picture_112.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 319.464, + 25.11 + ], + [ + 462.06000000000006, + 25.11 + ], + [ + 462.06000000000006, + 39.69 + ], + [ + 319.464, + 39.69 + ] + ] + }, + { + "title": "BY ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 69.156, + 154.71 + ], + [ + 116.892, + 154.71 + ], + [ + 116.892, + 167.67000000000002 + ], + [ + 69.156, + 167.67000000000002 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 62 + ], + [ + "Line", + 32 + ], + [ + "Text", + 29 + ], + [ + "SectionHeader", + 4 + ], + [ + "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/EFTA00083710" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083710/_page_0_Picture_112.jpeg b/marker2/ds9/EFTA00083710/_page_0_Picture_112.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..033fa0aaedb43a51f2608231ed575dc9e4873d84 --- /dev/null +++ b/marker2/ds9/EFTA00083710/_page_0_Picture_112.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:b6716eb6b3ba3c83fa26f4d84fac7010f6f4e165e3993074977a8d412862db19 +size 3420 diff --git a/marker2/ds9/EFTA00083711/EFTA00083711.md b/marker2/ds9/EFTA00083711/EFTA00083711.md new file mode 100644 index 0000000000000000000000000000000000000000..69505784292a9a6cca780ea6fa09543def691f2c --- /dev/null +++ b/marker2/ds9/EFTA00083711/EFTA00083711.md @@ -0,0 +1,21 @@ +From: 'MMM :3' + +To: ' + +Cc: + +Subject: Maxwell - Third Bail Application + +Date: Mon, 01 Mar 2021 20:28:00 +0000 + +Attachments: MAXWELL\_BAIL\_APPLICATION\_with\_EXHIBIT\_2-23-17.pdf + +M, + +Maxwell filed a third bail application last week (attached here). As you may recall, after her second bail application had been denied by Judge Nathan, she filed a notice of appeal to the Second Circuit. She has not yet filed any briefing. We are planning to oppose the third bail application, but wanted to check in with you about whether there are any arguments we should raise in our opposition in light of her pending appeal. (I know I had emailed you about an appeal divesting the district court from jurisdiction in a different context last week, but we wanted to raise this since it is a fuzzy area that depends on the order being appealed). Happy to discuss. + +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 \ No newline at end of file diff --git a/marker2/ds9/EFTA00083711/EFTA00083711.metadata.json b/marker2/ds9/EFTA00083711/EFTA00083711.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9187db33bad2388313ae5e63a9062694dbdff467 --- /dev/null +++ b/marker2/ds9/EFTA00083711/EFTA00083711.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083711.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1005, + "elapsed_seconds": 0.66, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 21 + ], + [ + "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/EFTA00083711" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083712/EFTA00083712.md b/marker2/ds9/EFTA00083712/EFTA00083712.md new file mode 100644 index 0000000000000000000000000000000000000000..eca5c6417c4352d6071db548bc5f7c954972b687 --- /dev/null +++ b/marker2/ds9/EFTA00083712/EFTA00083712.md @@ -0,0 +1,100 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x + +20 Cr. 330 (AJN) + +#### MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL + +Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 + +Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 + +Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 + +Attorneys for Ghislaine Maxwell + +### INTRODUCTION + +Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. + +As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in United States for 30 years, has strong family ties and the support of friends and family residing in this country. She wants nothing more than to remain in the United States under whatever conditions the Court deems necessary so that she can effectively prepare for trial and vigorously defend against the 25-year-old charges in the Indictment. Ms. Maxwell has already proposed an expansive and, to our knowledge, unprecedented set of bail conditions that would reasonably assure her appearance. (See Dkt. 97.) In light of the Court's denial of that application (see Dkt. 106), Ms. Maxwell now proposes two additional bail conditions to supplement the extraordinarily restrictive bail package she has already offered. + +- First, Ms. Maxwell will renounce her French and British citizenship to eliminate any opportunity for her to seek refuge in those countries, if the Court so requires. +- Second, Ms. Maxwell will have her and her spouse's assets—excluding funds earmarked for living expenses, for legal fees and other expenses necessary to defend her against the criminal charges in this case and related civil lawsuits and for taxes—placed in a new account that will be monitored by a retired federal District Court judge and former United States Attorney who will function as asset monitor and will have co-signing authority over the account. + +The former condition goes well beyond the extradition waivers that the Court deemed insufficient and should satisfy any concerns the Court may have that Ms. Maxwell may try to seek a safe haven in France or the United Kingdom. (See id. at 11-13). As a non-citizen, Ms. Maxwell will not be able to avail herself of any protections against extradition that may apply to citizens of those countries. The latter condition will restrain Ms. Maxwell's assets so they cannot be used for flight or harboring her outside of the jurisdiction of this Court. This should satisfy the Court's concern that the proposed bond was not fully secured and left assets unrestrained that could be used for such purposes. (See id. at 17-18). + +In addition, since the last bail application, Ms. Maxwell has submitted twelve pretrial motions that raise substantial legal and factual issues that may result in the dismissal of some or all of the charges against her. Ms. Maxwell referenced some of these motions in her initial bail application (see Dkt. 18 at 19) but was not in a position to fully articulate them until she had the chance to review the discovery and research the legal issues in advance of the motion deadline of January 25. These motions significantly call into question the strength of the government's case against Ms. Maxwell and the underlying justification for continued detention. + +Ms. Maxwell has already been denied a fair chance in the court of public opinion. She has been maligned by the media, which has perpetuated a false narrative about her that has poisoned any open-mindedness and impartiality of a potential jury. She has been relentlessly attacked with vicious slurs, persistent lies, and blatant inaccuracies by spokespeople who have neither met nor spoken to her. She has been depicted as a cartoon-character villain in an attempt to turn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined and welcomes the opportunity — to face her accusers at trial and clear her name. The additional proposed bail conditions should quell any concerns that she would try to flee. The Court should therefore grant bail under the proposed conditions so that Ms. Maxwell can adequately prepare for trial. + +#### The Proposed Additional Bail Conditions Will Reasonably Assure Nis. \ la kV% CH'S Appearance in Court + +As set forth above, Ms. Maxwell now proposes two additional restrictions that eliminate any means or opportunity that she may have to leave the country. The Court should therefore reconsider its earlier ruling and grant bail under the proposed conditions. See United States v. Rowe, No. 02 CR. 756 LMM, 2003 WL 21196846, at \*1 (S.D.N.Y. May 21, 2003) ("[A] release order may be reconsidered even where the evidence proffered on reconsideration was known to the movant at the time of the original hearing."); see also United States v. Petrov, No. I 5-CR-66- LTS, 2015 WL 11022886, at \*3 (S.D.N.Y. Mar. 26, 2015) (noting "Court's inherent authority for reconsideration of the Court's previous bail decision"). + +# A. Renunciation of Foreign Citizenship + +To demonstrate her commitment to abide by her conditions of release and to provide further assurance to the Court that she will not attempt to leave the country, Ms. Maxwell is willing to formally renounce her foreign citizenships in France and the United Kingdom. Should the Court feel this drastic condition is necessary, the required documents will be submitted to the appropriate authorities. Moreover, as a standard condition of bail, all of Ms. Maxwell's passports will be surrendered to the government and no further application will be made. + +If the Court deems it a necessary condition of release, Ms. Maxwell will formally commence the procedure to renounce her foreign citizenship. The requisite paperwork is in the process of being completed. Renunciation of UK citizenship can be accomplished immediately upon granting of bail. The process of renouncing her French citizenship, while not immediate, may be expedited. + +Citizenship is a precious and priceless asset. Ms. Maxwell's decision to give up citizenship from the county of her birth and the country of her upbringing demonstrates her earnestness to abide by the conditions of her release and underscores that she has no intention to flee and reflects her deep need to communicate freely with counsel to prepare for her defense. Her renunciation of foreign citizenship obviates the Court's concerns about the validity of waivers of extradition. (See Dkt. 106 at 13). Ms. Maxwell will have no ability to contest extradition from France or the United Kingdom on the basis of citizenship, which removes any incentive the Court and government believe she may have to seek refuge in those countries. + +# B. Restraint and Monitoring of Assets + +In denying bail, the Court noted that the bond was not fully secured, and that Ms. Maxwell and her spouse would still have several million dollars in unrestrained assets that could be used to facilitate her flight from the country. (See id. at 17-18). To assuage any concerns that those assets would be available to finance flight to and shelter in a foreign country, Ms. Maxwell has taken steps to create a monitorship that will place meaningful restraints on the assets that are not used to secure the bond, while still allowing Ms. Maxwell to pay for her legal defense, for her spouse to pay for daily living expenditures and for payment of taxes. + +# 1. New Account + +All assets of Ms. Maxwell and her spouse, with the exception of money currently held in escrow for legal fees and related defense expenses and the funds contained in the bank account in the name of Ms. Maxwell's spouse ("the Personal Account")', will be deposited in a newly created account ("the New Account") to be overseen by an asset monitor appointed pursuant to order of the Court. The New Account will contain all of Ms. Maxwell's and her spouse's remaining cash and other liquid assets, including any proceeds that result from the pending sale + +1The Personal Account is identified as Account Ion page 9 of the Financial Report annexed to Ms. Maxwell's Renewed Bail Application. (See Dkt. 97, Exhibit 0.) + +of Ms. Maxwell's London house and any other assets, excluding salary, hereinafter acquired. The asset manager will approve the financial institution at which the New Account is created and must approve and co-sign any expenditure from the New Account, with the exception of disbursements for Ms. Maxwell's legal fees in connection with the ongoing criminal and civil litigation and for payment of taxes, which will not require authorization. No illiquid assets may be sold, conveyed or transferred without approval of the asset monitor. + +#### 2. Other Assets + +The only funds that will not be included in the New Account are (I) the money currently held in escrow by Ms. Maxwell's attorneys, which will be used exclusively for her defense; and (2) the roughly \$450,000 in the Personal Account which her spouse will use only for living expenses. The asset monitor shall regularly receive information regarding activity of the Personal Account, including the account balance, on a weekly basis. The asset monitor must also receive five-day advance notice of any check, on-line payment, or transfer of finds in any amount exceeding \$5,000, and the reason for such payment. Ms. Maxwell's spouse agrees to be bound by these restrictions and reporting requirements. + +The asset monitor shall report to Pretrial Services any possible non-compliance or disbursement in violation of the terms and conditions specified above. + +# 3. Selected Asset Monitor + +The Honorable William S. Duffey, Jr., a retired federal District Court judge and the former United States Attorney for the Northern District of Georgia, has agreed to undertake the position of asset monitor. (Judge Duffey's bio is attached as Exhibit A.) Judge Duffey has extensive experience evaluating and monitoring funds held in and disbursed from financial + +accounts and will be entrusted with the authority to oversee the assets of Ms. Maxwell and her spouse, as described above. + +Restraining Ms. Maxwell's assets that are not used to secure the bond and placing them under the supervision of a former federal District Court judge eliminates any concern that such funds could be used to violate the terms of release. + +#### IL Ms. Maxwell's Pretrial Motions Raise Substantial Legal and Factual Issues That Could Result in Dismissal of Some or All of the Charges Against Her + +In addition to the new conditions proposed above, the numerous substantive pretrial motions now before the Court amply challenge the purported strength of the government's case. Ms. Maxwell's pretrial motions raise serious legal issues that could result in dismissal of charges, if not the entire indictment. Among the dozen submissions are motions to dismiss the superseding indictment for breach of the non-prosecution agreement, for pre-indictment delay, and for being based on improperly obtained evidence in violation of Ms. Maxwell's constitutional rights under the Fifth and Sixth the Amendments. Other motions seek dismissal of the Mann Act charges as being time-barred and the perjury charges as based on non-perjurious statements. These motions are substantial with a likelihood of success on the merits. These motions cast substantial doubt on the alleged strength of the government's case and warrant granting bail on the conditions proposed. + +## III. The Court Should Grant Bail + +Under the Bail Reform Act of 1984, a defendant must be released on personal recognizance or unsecured personal bond unless the judicial officer determines "that such release will not reasonably assure the appearance of the person as required or will endanger the safety of any other person or the community." 18 U.S.C. § 3142(b). The enhanced bail package proposed by Ms. Maxwell contains financial burdens and a combination of restrictions that reasonably + +assure her appearance as required. Before preventive detention may be ordered under § 3142(e), the Court is obliged to determine both whether the defendant is likely to flee the jurisdiction if released, and whether any conditions of release will be reasonably certain to guard against this propensity to flee. The Court expressed concerns and denied bail without indicating what conditions would be reasonably certain to assure Ms. Maxwell's appearance. Ms. Maxwell is no danger to the community and not alleged to have been involved in ongoing criminal activity. To say that there are absolutely no conditions flies in the face of cases where non-United States citizens with no ties to the district, let alone the country, were released on lesser conditions for alleged criminality ongoing up to or within hours of the time of arrest, in contrast to 26-year-old claims alleged against Ms. Maxwell.' + +The additional conditions set forth above, which supplement the exceptional bail package previously proposed, are sufficient to address the hypothetical risk of flight and secure Ms. Maxwell's presence at trial. The financial magnitude of the proposed bonds, the collateral pledged to secure the bonds, the stringent requirements of home detention, the renunciation of foreign citizenship and monitoring of assets contained in a special account from which no funds can be withdrawn without the approval and signature of a retired federal District Court judge and former United States Attorney are conditions that amply satisfy the concerns expressed by the government and the Court. These cnditions are unique and unprecedented. They profoundly + +2 See Dkt. 97 at 34 (case-comparison chart in the Renewed Motion for Bail); cf. People v. Dominique Strauss-Kahn, 02526/201 I(S.Ct. N.Y. County). Strauss-Kahn, a French citizen with no ties to the United States, was arrested on a Paris-bound flight at JFK minutes before takeoff and later charged with several counts of sexual assault, including felony charges punishable up to 25 years imprisonment, for sexual assault and attempted rape of a Manhattan hotel housekeeper on the day of his arrest. The accusations were corroborated by semen containing Strauss-Kahn's DNA on the accuser's uniform. The New York State Supreme Court granted bail in the amount of \$ I million cash, 24 hour home detention electronic monitoring ankle bracelet, and private 24/7 security guards. After surrendering his French passport and posting an additional \$5 million bail bond, Strauss-Kahn was placed under house arrest in a residence in Manhattan. See https://www.theguardian.comAvorld/20 Ill may/20/dominiquc-strauss-kahn-ncw-yorkapartment. + +affirm Ms. Maxwell's earnestness in seeking bail to properly prepare her defense, not to flee. The Court should grant bail to Ghislaine Maxwell. + +### CONCLUSION + +The proposed additional conditions of release—renunciation of foreign citizenship and restraint and monitoring of assets by a retired District Court judge—enhance the already extraordinarily restrictive bail conditions proposed in Ms. Maxwell's Renewed Motion for Bail. In combination, these conditions satisfy the Bail Reform Act and reasonably assure Ms. Maxwell's appearance at trial. To deny Ms. Maxwell bail when such extraordinary and restrictive conditions are available would be a miscarriage of justice. + +Dated: February 23, 2021 + +Respectfully submitted, + +goat C. Sitagn. + +Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 + +Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 + +Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 \ No newline at end of file diff --git a/marker2/ds9/EFTA00083712/EFTA00083712.metadata.json b/marker2/ds9/EFTA00083712/EFTA00083712.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5c8111701178f6388fc4ea2a9f84fd59a0aedc3e --- /dev/null +++ b/marker2/ds9/EFTA00083712/EFTA00083712.metadata.json @@ -0,0 +1,615 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083712.pdf", + "engine": { + "marker_major": "2", + "marker_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": 16020, + "elapsed_seconds": 1.35, + "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 + ], + [ + 281.7991943359375, + 71.28 + ], + [ + 281.7991943359375, + 99.7330322265625 + ], + [ + 68.544, + 99.7330322265625 + ] + ] + }, + { + "title": "MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S \nTHIRD MOTION FOR RELEASE ON BAIL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 133.416, + 345.87 + ], + [ + 479.59716796875, + 345.87 + ], + [ + 479.59716796875, + 375.7330322265625 + ], + [ + 133.416, + 375.7330322265625 + ] + ] + }, + { + "title": "INTRODUCTION", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 255.204, + 96.38999999999999 + ], + [ + 356.9654541015625, + 96.38999999999999 + ], + [ + 356.9654541015625, + 111.9735107421875 + ], + [ + 255.204, + 111.9735107421875 + ] + ] + }, + { + "title": "The Proposed Additional Bail Conditions Will Reasonably Assure Nis. \\ la kV% CH'S \nAppearance in Court", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 525.708, + 71.28 + ], + [ + 525.708, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + }, + { + "title": "A. 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Sorry for my delayed response — I somehow missed this email. I'll plan to respond to as follows but let me know if this doesn't get it right. + +We can conduct searches with multiple search terms. That said, to the extent we are asked to run several variations to get a sense of the volume of documents, we would ask that those requests be specific and focused. I hope that helps. Happy to discuss if you have any additional questions. + +From: Sent: Monday, February 08, 2021 5:11 PM To: Subject: RE: Brunel ) < + +The short answer is yes, Relativity permits searches with multiple search restrictions. There is a limit to how man i variations and connectors we're willing to test-run for volume, of course. If they asked us to run all the different name constructions as search terms in combination with all of the other terms they gave us, we'd have to run dozens and dozens of searches. So they'd need to send us a narrow universe of very specific requests in order for us to run searches this way. + +Feel free to call me if you have any questions about this. And I know you've both used relativity, so let me know if you have a different take. + +From: Sent: Monday, February 8, 2021 4:48 PM To: Cc: Subject: RE: Brunel ) < >; >; + +Is it possible to do a search for documents that contain, for example + +U.S. Embassy, Paris + +--- + +**From:** [REDACTED] ([REDACTED]) <[REDACTED]> +**Sent:** Tuesday, February 2, 2021 3:18 PM +**To:** [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] +[REDACTED] +**Subject:** Re: Brunel + +[REDACTED] +This list represents unique documents for each term. + +Best, +[REDACTED] + +On Feb 2, 2021, at 8:22 AM, [REDACTED] <[REDACTED]> wrote: + +Thanks, [REDACTED]. + +Can you remind if this list represents unique documents, or does it instead refer to hits (i.e., potentially reflecting multiple times the same word appears in one document). - [REDACTED] + +[REDACTED] +[REDACTED] +U.S. Embassy, Paris +[REDACTED] +[REDACTED] +[REDACTED] + +--- + +**From:** [REDACTED] ([REDACTED]) <[REDACTED]> +**Sent:** Monday, February 1, 2021 7:26 PM +**To:** [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] +[REDACTED] +**Subject:** RE: Brunel + +[REDACTED] +Thanks for speaking earlier today. The below chart reflects the search terms we ran in Relativity and the number of results for each term: + +[REDACTED] + +Please let us know if you have any questions. + +Thanks, + +From: + +Sent: Sunday, January 31, 2021 2:38 PM + +To: + +Cc: >; + +Subject: Re: Brunel + +No problem. + +9:15 it is. + +Sent from my iPhone + +On Jan 31, 2021, at 5:51 PM, tz )\* wrote: + +With apologies, does 9:15 or 9:30 work instead for you? + +Thanks, + +From: + +Sent: Saturday, January 30, 2021 11:13 AM + +To: + +Cc: + +Subject: RE: Brunel + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Saturday, January 30, 2021 3:03 AM +**To:** [REDACTED] ([REDACTED]) <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED]-[REDACTED] +**Subject:** Re: Brunel + +Sure, I can do 9 or 10am on Monday. + +Sent from my iPhone + +On Jan 29, 2021, at 10:36 PM, [REDACTED] ([REDACTED]) <[REDACTED]> wrote: + +Hi [REDACTED] + +I hope all is well. I wanted to follow up on my email from earlier this week – any chance you are free Monday to speak before 11 am day? + +Thanks so much, and have a great weekend, + +[REDACTED] + +--- + +**From:** [REDACTED] ([REDACTED]) +**Sent:** Wednesday, January 27, 2021 7:15 PM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] +<[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED]-[REDACTED] +**Subject:** RE: Brunel + +Thanks again, [REDACTED]. We had a chance to look at the search terms and were hoping to chat with you briefly about them. Are you available for a call Friday before 10 am EST? + +Thanks, + +[REDACTED] + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Wednesday, January 27, 2021 4:44 AM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] ([REDACTED]) <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED]-[REDACTED] +**Subject:** RE: Brunel + +[REDACTED] + +[REDACTED] + +From: + +Sent: Tuesday, January 26, 2021 11:02 PM + +To: + +Cc: >; + +Subject: RE: Brunel + +![](_page_4_Picture_7.jpeg) + +Thanks again, + +From: + +Sent: Tuesday, January 26, 2021 4:23 PM + +To: >; + +Cc: ) < >; + +Subject: RE: Brunel + +![](_page_4_Picture_15.jpeg) + +[REDACTED] +[REDACTED] +[REDACTED] + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Tuesday, January 26, 2021 6:13 PM +**To:** [REDACTED] ([REDACTED]) <[REDACTED]>; [REDACTED] +<[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED]-[REDACTED]> +**Subject:** RE: Brunel + +[REDACTED] + +The witnesses' attorney just emailed us to indicate that her clients do not wish to be interviewed by the French authorities. The attorney gave us permission to provide the attorney's name and email address to the French so that they may contact her directly. [REDACTED] +[REDACTED] + +The attorney is [REDACTED], and her email address is [REDACTED]. [REDACTED] represents [REDACTED] adult victims who have described instances of abuse by Epstein in Paris. Please let me know if you need us to draft anything more formal conveying this information, or if you can just provide the name and email address directly to the French. + +Thanks, +[REDACTED] + +--- + +**From:** [REDACTED] ([REDACTED]) <[REDACTED]> +**Sent:** Friday, January 22, 2021 11:31 AM +**To:** [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED]-[REDACTED]> +**Subject:** RE: Brunel + +Thanks very much! + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Friday, January 22, 2021 9:04 AM +**To:** [REDACTED] ([REDACTED]) <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED]-[REDACTED]> +**Subject:** RE: Brunel + +[REDACTED]: + +I sent the request off today. Here are the final versions. + +[REDACTED] + +[REDACTED] +[REDACTED] +U.S. Embassy, Paris +[REDACTED] + +--- + +**From:** [REDACTED] ([REDACTED]) <[REDACTED]> +**Sent:** Thursday, January 21, 2021 5:52 PM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] - [REDACTED] +[REDACTED] > +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: Brunel + +Thanks, [REDACTED] We have not yet heard back, but will reach out. + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Wednesday, January 20, 2021 10:43 AM +**To:** [REDACTED] ([REDACTED]) <[REDACTED]>; [REDACTED] - [REDACTED] +[REDACTED] > +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: Brunel + +For your request to France, no...we got the translation back and will be sending it along. + +[REDACTED] + +[REDACTED] +[REDACTED] +U.S. Embassy, Paris +[REDACTED] +[REDACTED] +[REDACTED] + +--- + +**From:** [REDACTED] ([REDACTED]) <[REDACTED]> +**Sent:** Wednesday, January 20, 2021 4:04 PM +**To:** [REDACTED] - [REDACTED] +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] +<[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: Brunel + +Hi – I hope you both are well. I wanted to check in on this and see if there is anything further you need from us. + +Thanks again, +[REDACTED] + +--- + +**From:** [REDACTED] ([REDACTED]) +**Sent:** Thursday, January 14, 2021 8:36 AM +**To:** [REDACTED] - [REDACTED] +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] +<[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** Re: Brunel + +Thanks very much! + +--- + +**From:** [REDACTED] ([REDACTED]) <[REDACTED]> +**Sent:** Wednesday, January 13, 2021 11:27 AM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] +<[REDACTED]>; [REDACTED] <[REDACTED]> +**Cc:** [REDACTED]-[REDACTED]> +**Subject:** RE: Brunel + +Thanks very much, [REDACTED] Attached is the 551. + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Wednesday, January 13, 2021 8:11 AM +**To:** [REDACTED] ([REDACTED]) <[REDACTED]>; [REDACTED] <[REDACTED]>; +[REDACTED] <[REDACTED]> +**Cc:** [REDACTED]-[REDACTED]> +**Subject:** RE: Brunel + +Here is the signed version. + +We'll send it for translation once we get the 551. - [REDACTED] + +[REDACTED] +[REDACTED] +U.S. Embassy, Paris +[REDACTED] +[REDACTED] +[REDACTED] + +--- + +**From:** [REDACTED] +**Sent:** Wednesday, January 13, 2021 11:13 AM +**To:** [REDACTED] ([REDACTED]) <[REDACTED]>; [REDACTED] <[REDACTED]>; +[REDACTED] <[REDACTED]> +**Cc:** [REDACTED]-[REDACTED]> +**Subject:** RE: Brunel + +[REDACTED] + +[REDACTED] +[REDACTED] +U.S. Embassy, Paris +[REDACTED] +[REDACTED] +[REDACTED] + +--- + +**From:** [REDACTED] +**Sent:** Wednesday, January 13, 2021 10:57 AM +**To:** [REDACTED] ([REDACTED]) <[REDACTED]>; [REDACTED] <[REDACTED]>; + +Cc: Subject: RE: Brunel + +Ok. + +Here the translation authorization paperwork. + +U.S. Embassy, Paris + +From: irt ) Sent: Tuesday, January 12, 2021 7:19 PM To: Cc: Subject: RE: Brunel + +IMM Thanks again for chatting. Please see attached. + +Best, + +From: Sent: Tuesday, January 12, 2021 10:06 AM To:-( 1 'c >; Cc: Subject: RE: Brunel + +Okay. + +U.S. Embassy, Paris + +From: Sent: Tuesday, January 12, 20214:05 PM To: c M> Cc: Subject: RE: Brunel + +From: [REDACTED] <[REDACTED]> +Sent: Tuesday, January 12, 2021 9:55 AM +To: [REDACTED] ([REDACTED]) <[REDACTED]>; [REDACTED] <[REDACTED]>; +[REDACTED] <[REDACTED]> +Cc: [REDACTED]-[REDACTED]> +Subject: RE: Brunel + +Sure, I can do 11am. + +Let me know what # to call. + +[REDACTED] +[REDACTED] +U.S. Embassy, Paris +[REDACTED] +[REDACTED] +[REDACTED] + +From: [REDACTED] ([REDACTED]) <[REDACTED]> +Sent: Tuesday, January 12, 2021 3:36 PM +To: [REDACTED] <[REDACTED]>; [REDACTED] +<[REDACTED]>; [REDACTED] <[REDACTED]> +Cc: [REDACTED]-[REDACTED]> +Subject: RE: Brunel + +Thanks very much, [REDACTED]. Do you have a few minutes to speak today about this? I'm available after 11 am EST. + +From: [REDACTED] <[REDACTED]> +Sent: Tuesday, January 12, 2021 6:11 AM +To: [REDACTED] ([REDACTED]) <[REDACTED]>; [REDACTED] <[REDACTED]>; +[REDACTED] <[REDACTED]> +Cc: [REDACTED]-[REDACTED]> +Subject: RE: Brunel + +Here are my comments. + +[REDACTED] +[REDACTED] +U.S. Embassy, Paris +[REDACTED] +[REDACTED] +[REDACTED] + +From: [REDACTED] ([REDACTED]) <[REDACTED]> +Sent: Friday, January 8, 2021 7:32 PM +To: [REDACTED] <[REDACTED]>; [REDACTED] +<[REDACTED]>; [REDACTED] <[REDACTED]> +Cc: [REDACTED]-[REDACTED]> +Subject: RE: Brunel + +Thanks again for the update and all of your help. Attached please find our MLAT request. Please let us know if you have any questions or would like to discuss. + +Best, + +From: + +Sent: Thursday, January07, 2021 11:12 PM + +To: C + +Cc: + +Subject: RE: Brunel + +![](_page_10_Picture_9.jpeg) + +Assistant United States Attorney + +Southern District of New York + +From: ) + +Sent: Thursday, January 7, 2021 5:17 PM + +To: < >; ( ) c ) + +Cc: + +Subject: Brunel + +Dear all: + +My meeting on Brunel went well this afternoon. Here is the quick read out: + +![](_page_10_Picture_23.jpeg) + +![](_page_11_Picture_0.jpeg) + +- [REDACTED] +[REDACTED] +[REDACTED] +U.S. Embassy, Paris +[REDACTED] +[REDACTED] +[REDACTED] + +--- + +**From:** [REDACTED] < [REDACTED] > +**Sent:** Thursday, January 7, 2021 12:38 AM +**To:** [REDACTED] < [REDACTED] >; [REDACTED] ( [REDACTED] ) +< [REDACTED] >; [REDACTED] < [REDACTED] > +**Cc:** [REDACTED] > +**Subject:** RE: France + +[REDACTED] + +Thanks, +[REDACTED] + +[REDACTED] +Assistant United States Attorney +Southern District of New York +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +--- + +**From:** [REDACTED] < [REDACTED] > +**Sent:** Wednesday, January 6, 2021 10:15 AM +**To:** [REDACTED] < [REDACTED] >; [REDACTED] ( [REDACTED] ) < [REDACTED] >; +[REDACTED] < [REDACTED] > +**Cc:** [REDACTED] > +**Subject:** RE: France + +[REDACTED] + +Further to our call yesterday, here are the points I plan to make at my meeting tomorrow. Thanks in advance for letting me know if you see any errors, omissions, or additions to make: + +[REDACTED] + +![](_page_13_Picture_41.jpeg) + +[Redacted] + +[Redacted] + +U.S. Embassy, Paris + +[Redacted] + +[Redacted] + +[Redacted] + +--- + +**From:** [Redacted] + +**Sent:** Tuesday, January 5, 2021 9:02 PM + +**To:** [Redacted] < [Redacted] >; [Redacted] ( [Redacted] ) < [Redacted] >; + +[Redacted] < [Redacted] > + +**Cc:** [Redacted] > + +**Subject:** France + +Here is our go-by for an outgoing request to France. + +[Redacted] + +[Redacted] + +U.S. Embassy, Paris + +[Redacted] + +[Redacted] + +[Redacted] \ No newline at end of file diff --git a/marker2/ds9/EFTA00083721/EFTA00083721.metadata.json b/marker2/ds9/EFTA00083721/EFTA00083721.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..57d30c6ee315deac20b9b21ff3b6772a7f8b0a8d --- /dev/null +++ b/marker2/ds9/EFTA00083721/EFTA00083721.metadata.json @@ -0,0 +1,463 @@ +{ + "source_pdf": 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17 Jul 2019 20:26:36 +0000 + +**From:** [REDACTED] +**Sent:** Wednesday, July 17, 2019 4:21 PM +**To:** [REDACTED] <[REDACTED]> +**Subject:** Re: info re: Epstein recruitment attempts after incarceration + +Thank you! Just making sure that Detective [REDACTED] with NYPD would be someone that you would anticipate giving me a return call. + +The phone number [REDACTED] + +Kosher? + +On Wed, Jul 17, 2019 at 12:33 PM [REDACTED] (USANYS) <[REDACTED]> wrote: + +Thank you for your email. I will forward your email to the case agents. + +[REDACTED] +[REDACTED] +United States Attorney's Office +Southern District of New York + +[REDACTED] +[REDACTED] + +**From:** [REDACTED] +**Sent:** Wednesday, July 17, 2019 1:15 PM +**To:** [REDACTED] <[REDACTED]> +**Subject:** Fwd: info re: Epstein recruitment attempts after incarceration + +[REDACTED] + +I'm forwarding this to you as there is someone who has represented to me in the past that they were employed by Epstein in a 'legitimate' capacity after completion of his term at the Palm Beach Stockade, and were eventually approached in New York to recruit "girls" for Epstein. + +Additionally, last night, this individual resumed communications with me, attempting to elicit information about M. [REDACTED] current whereabouts, and engaged in various forms of manipulation to get me to share additional information about what I have shared with law enforcement and associated investigations, leading me to believe that the individual may be more tightly integrated in Epstein's circle than originally stated, and actively engaging in the attempt to tie off any loose ends. + +Pm not a victim of assault at the hands of Epstein, but have been involved in this case for a few years, and believe that I could provide some additional information about attempts to intimidate victims and private citizens working to expose the story. I would be happy to share more information via another form of communication, or to speak with investigators in person, but I am not comfortable sharing info with individuals at call centers who don't have a solid understanding of the internals of what I believe this investigation to reflect. + +Additionally, in the off chance that anything should happen to me, I would like to authorize investigators to have access to any and all records, notes, and digital archives that may prove useful in the prosecution of Epstein and his associates. Please let me know if there is any formal way to signify or enable this - the threats and veiled public disclosures of my location have been ramping up in the past couple of weeks or so. I don't think anything I have necessarily is unknown to your investigators, save perhaps the microwave communications aspect in the USVI, which seemed to be a surprise to another informant... but just in case, I would consider it good security to have a formal mechanism in place. + +Forwarded message + +From: michelle lupei + +Date: Tue, Jul 16, 2019 at 4:14 PM + +Subject: info re: Epstein recruitment attempts after incarceration + +To: , + +Hello, + +I attempted to contact Ms yesterday, but it was a bit too late, as I was unaware of what time the bond hearing started. + +I have been in communication with someone since December 2016 who claims to have been an employee of Jeffrey Epstein after he was released from house arrest, who stated that shortly before she terminated her employment, either Epstein or his staff requested that she helped to procure "girls" for him, which she claimed to have refused. I'm unsure who specifically made the request, but I believe the conversations are in an encrypted Signal archive (my logs were all wiped from most of my computers after I tried to add signal to a new phone, but I retrieved the archive, which is intact and I would be willing to allow access for it to be decrypted if need be). + +If she has already come forward to you, and her story checks out, that's perfect; if not, please get in touch and I will gladly provide whatever assistance I can; I don't want to break a confidence, but this is a matter bigger than any one person. She has spoken with multiple media outlets before, but has not gone on the record with any, to the best of my knowledge. She said she was unwilling to come forward unless absolutely necessary, because she was protecting someone. + +It is possible that this was an elaborate catfishing attempt, though, as two months earlier I identified the significance of the ase and brought it to the Waterbury PD and NCMEC's attention; unfortunately, knowing of some issues in the allegiances of some in FBINYFO, I took it to first, as my primary interest was in•iri ' ' know that there was evidence to support her allegations, but my current understanding is that sold that information to Dylan Howard at AMI that night, prompting the shift from the vague "Spirit Cooking" narrative to the Pizzagate narrative within hours, as an attena both intimidate victims and discredit Ms. when she returns, as being a result of 'mass hysteria.' aever gave that info to her client before dropping the case, which I believe was setup involving AMI recruiting + +o target her intentionally to discredit future accusations of the involvement of those she accused in sex trafficking. + +I'd be happy to confirm or elaborate on any of this if needed; I additionally have some developing information on a > decade-old business relationship Epstein had with Gordon Ackley, yacht & media outlet owner & licensed microwave wireless operator in the USVI, with links to both VIGOP organizations, etc. I'm aware of the info that was handed over at the end of March of this year that indicates Epstein provided false information about his whereabouts during a proffer linked to his previous plea, and the subsequent fallout from that... and, of course, I have many hypotheses that I'm sure you're already working through sussing out, especially those linked to Foleygate, especially to Dennis Hastert and, who lived 3 doors down from me until I was 18... and knowing about his predatory nature, I ran comms strategy for his opponent in the 2006 election, consulting during the ramp-up to and fallout from Foleygate (and know/knew many of his victims personally)... especially the significance of the timing of the SMARTech breach as linked to his 2015 indictment. And the timing of the Bannon-Epstein meet within 24 hours ± 12 after I published theabduction report, along with other little things I've done along the way to drop small amounts of info to stimulate contacts between those conspiring to conceal the narrative. + +And, of course, if you would like for me to butt out of any additional attempts to contact you, please feel free to request that as well; else, I'll keep doing what I've been doing (although someone with LexisNexis access who claims to be an attorney threatened to doxx me the other day, and others have been making veiled threats against my parents, and it's made me pretty much unemployable until this fully drops). + +I've been at this for a few years now, and everything I've done was with the intent of protecting victims first, but otherwise to do whatever it takes to keep serial predators, and those who knowingly enable them, from holding positions of power, especially over their victims. + +If there is any way I can be of help, please feel free to contact me. \ No newline at end of file diff --git a/marker2/ds9/EFTA00083735/EFTA00083735.metadata.json b/marker2/ds9/EFTA00083735/EFTA00083735.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3a197ba32ed1bcecd47443bc88930c2af2585529 --- /dev/null +++ b/marker2/ds9/EFTA00083735/EFTA00083735.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083735.pdf", + "engine": { + "marker_major": "2", + "marker_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": 7506, + "elapsed_seconds": 7.19, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Text", + 30 + ], + [ + "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", + 85 + ], + [ + "Line", + 42 + ], + [ + "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": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 46 + ], + [ + "Line", + 24 + ], + [ + "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/EFTA00083735" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083738/EFTA00083738.md b/marker2/ds9/EFTA00083738/EFTA00083738.md new file mode 100644 index 0000000000000000000000000000000000000000..6f1a6cf33d905eea44ea9fbbfbe49c4e3542ef0e --- /dev/null +++ b/marker2/ds9/EFTA00083738/EFTA00083738.md @@ -0,0 +1,72 @@ +From: ' To: " , ' + +Subject: RE: info re: Epstein recruitment attempts after incarceration + +Date: Wed, 17 Jul 2019 20:57:03 +0000 + +Thanks very much. + +From: Sent: Wednesday, July 17, 2019 4:57 PM To: > + +Subject: RE: info re: Epstein recruitment attempts after incarceration + +done + +From: Sent: Wednesday, July 17, 2019 4:55 PM To: ; + +Subject: RE: info re: Epstein recruitment attempts after incarceration + +Please tell her is the person form our team who is trying to contact her. + +From: Sent: Wednesday, July 17, 2019 4:27 PM To: ;I + +Subject: FW: info re: Epstein recruitment attempts after incarceration + +From Sent: e nes ay, u y 17, 2019 4:21 PM To: Subj : e: in o re: ps ein recruitment attempts after incarceration + +Thank you! Just making sure that ith NYPD would be someone that you would anticipate giving me a return call. + +The phone number + +Kosher? + +On Wed, Jul 17, 2019 at 12:33 PM (USANYS) c > wrote: + +Thank you for your email. I will forward your email to the case agents. + +From Sent: Wddr dMe:Jilfy 17, 2019 1:15 PM To: Subject: Fwd: info re: Epstein recruitment attempts after incarceration + +Ms + +I'm forwarding this to you as there is someone who has represented to me in the past that they were employed by Epstein in a 'legitimate' capacity after completion of his term at the Palm Beach Stockade, and were eventually approached in New York to recruit "girls" for Epstein. + +Additional) , last night, this individual resumed communications with me, attempting to elicit information about M. current whereabouts, and engaged in various forms of manipulation to get me to share additions m ormation about what I have shared with law enforcement and associated investigations, leading me to believe that the individual may be more tightly integrated in Epstein's circle than originally stated, and actively engaging in the attempt to tie off any loose ends. + +Pm not a victim of assault at the hands of Epstein, but have been involved in this case for a few years, and believe that I could provide some additional information about attempts to intimidate victims and private citizens working to expose the story. I would be happy to share more information via another form of communication, or to speak with investigators in person, but I am not comfortable sharing info with individuals at call centers who don't have a solid understanding of the internals of what I believe this investigation to reflect. + +Additionally, in the off chance that anything should happen to me, I would like to authorize investigators to have access to any and all records, notes, and digital archives that may prove useful in the prosecution of Epstein and his associates. Please let me know if there is any formal way to signify or enable this - the threats and veiled public disclosures of my location have been ramping up in the past couple of weeks or so. I don't think anything I have necessarily is unknown to your investigators, save perhaps the microwave communications aspect in the USVI, which seemed to be a surprise to another informant... but just in case, I would consider it good security to have a formal mechanism in place. + +ssa e + +From: Date: ue, u , at : Subject: info re: Epstein recruitment attempts after incarceration To: decade-old business relationship Epstein had with Gordon Ackley, yacht & media outlet owner & licensed microwave wireless operator in the USVI, with links to both VIGOP organizations, etc. I'm aware of the info that was handed over at the end of March of this year that indicates Epstein provided false information about his whereabouts during a proffer linked to his previous plea, and the subsequent fallout from that... and, of course, I have many hypotheses that I'm sure you're already working through sussing out, especially those linked to Foleygate, especially to Dennis Hastert and, who lived 3 doors down from me until I was 18... and knowing about his predatory nature, I ran comms strategy for his opponent in the 2006 election, consulting during the ramp-up to and fallout from Foleygate (and know/knew many of his victims personally)... especially the significance of the timing of the SMARTech breach as linked to his 2015 indictment. And the timing of the Bannon-Epstein meet within 24 hours ± 12 after I published the [REDACTED] abduction report, along with other little things I've done along the way to drop small amounts of info to stimulate contacts between those conspiring to conceal the narrative. + +And, of course, if you would like for me to butt out of any additional attempts to contact you, please feel free to request that as well; else, I'll keep doing what I've been doing (although someone with LexisNexis access who claims to be an attorney threatened to doxx me the other day, and others have been making veiled threats against my parents, and it's made me pretty much unemployable until this fully drops). + +I've been at this for a few years now, and everything I've done was with the intent of protecting victims first, but otherwise to do whatever it takes to keep serial predators, and those who knowingly enable them, from holding positions of power, especially over their victims. + +If there is any way I can be of help, please feel free to contact me. + +[REDACTED] +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00083738/EFTA00083738.metadata.json b/marker2/ds9/EFTA00083738/EFTA00083738.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..49c331f423e39afbbd907e8382819d713b00a3c5 --- /dev/null +++ b/marker2/ds9/EFTA00083738/EFTA00083738.metadata.json @@ -0,0 +1,118 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083738.pdf", + "engine": { + "marker_major": "2", + "marker_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": 7649, + "elapsed_seconds": 14.0, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 32 + ], + [ + "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", + 81 + ], + [ + "Line", + 37 + ], + [ + "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": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 87 + ], + [ + "Line", + 44 + ], + [ + "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/EFTA00083738" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083741/EFTA00083741.md b/marker2/ds9/EFTA00083741/EFTA00083741.md new file mode 100644 index 0000000000000000000000000000000000000000..4b9e27121852f5413c80c709dc1c2c621d84edb9 --- /dev/null +++ b/marker2/ds9/EFTA00083741/EFTA00083741.md @@ -0,0 +1,521 @@ +To: + +Subject: 'Everybody In The Crosshairs' As DOJ Opioid Blitz Gets Real + +Date: Mon, 22 Jul 2019 07:45:15 +0000 + +![](_page_0_Picture_4.jpeg) + +1D-aw360 White + +Collar WHITE COLLAR + +Monday, July 22, 2019 Follow Law360 + +## TOP NEWS + +#### Analysis + +## 'Everybody In The Crosshairs' As DOJ Opioid Blitz Gets Real + +The U.S. Department of Justice's newest indictment of a painkiller distributor and its executives strongly suggests that the agency has embarked on a calculated criminal crackdown after years of civil enforcement failed to ease the opioid epidemic. + +Indictment attached I Read full article » + +## Craig Won't Use Ukraine Report From Judge's Firm At Trial + +Ex-Skadden partner Gregory Craig indicated Friday he didn't want to introduce at his upcoming trial a Ukraine-focused report authored by lawyers at the former firm of the D.C. federal judge overseeing his criminal case. + +Read full article » + +### Rep. Asks Feds If DOJ Policy Shielded Trump From Indictment + +The head of the House Oversight Committee wants federal prosecutors to explain whether a U.S. Department of Justice policy that bars indicting a sitting president impacted the decision not to indict President Donald Trump following allegations that he violated campaign finance laws by paying off women he had affairs with. + +Letter attached I Read full article + +### Ex-Credit Suisse Director Cops To Role In \$2B Loan Fraud + +A former Credit Suisse managing director on Friday admitted to his role in a bribery and investor fraud scheme involving \$2 billion in loans to statebacked companies in Mozambique, telling a New York federal judge he conspired to defraud those who invested in the debt. + +Read full article » + +### Hooper Lundy OK To Rep Husband & Wife In Varsity Blues' + +A California couple charged in the nationwide college admissions case known as "Varsity Blues" told a Massachusetts federal judge they are comfortable having Hooper Lundy & Bookman PC represent them both, despite several concerns raised by prosecutors during a hearing Friday. + +Read full article » + +# Courts Bolster Compassionate Release Under First Step + +Among the thousands of inmates released because of reforms under the First Step Act, a small group of prisoners have been granted compassionate release this year, many of them taking advantage of a new provision letting them make their case for release in court. + +![](_page_0_Picture_28.jpeg) + +;.,,'Law360 Pro Say Podcast + +Listen to our new podcast here + +### LAW FIRMS + +Addleshaw Goddard + +Akin Gump + +Allen & Overy + +Arnold & Porter + +Ashurst LLP + +Barrett & Singal + +Boles Schiller + +Cahill Gordon + +Caplin & Drysdale + +Cadton Fields + +Casner & Edwards + +Covington & Burling + +Dechert + +Drinker Biddle + +Duane Morris + +Edwards Pottinger + +Eversheds Sutherland + +Fenton Law Group + +Foreman Friedman + +Gerger Khalil + +The Palm Beach County Sheriffs Office announced on Friday an internal investigation into the Florida departments supervision of financier Jeffrey Epstein when he was jailed there a decade ago on sex crime charges, after a lawyer for some of Epstein's alleged victims implied the accused child rapist had abused the privileges of his work release. + +Read full article » + +### SECURITIES + +### Judge Won't Let HSBC Hong Kong Kill Discovery In Ponzi Suit + +A New York federal judge on Friday said he would not reconsider his decision to order jurisdictional discovery for claims that HSBC's Hong Kong affiliate aided a Ponzi scheme that pulled \$37 million from investors' pockets. + +Order attached I Read full article + +### Engine Maker Execs Inflated Revenues By \$25M, Feds Say + +An Illinois-based alternative-energy engine maker's former executives got hit with criminal and civil securities fraud charges Friday over claims they engaged in an accounting fraud scheme that inflated company revenues by \$25 million. + +2 documents attached I Read full article » + +### CFTC Gets \$2.9M Win Against No-Show Alleged Fraudster + +A Texas federal judge granted the Commodity Futures Trading Commission a \$2.9 million final judgment on Friday against an alleged fraudster who never appeared in the case or responded to the agency's complaint. + +Order attached I Read full article » + +### PUBLIC INTEGRITY + +### Ex-NSA Contractor Gets 9 Years For Classified Doc Theft + +A former National Security Agency contractor was sentenced to nine years in prison on Friday after amassing a hoard of top-secret and other classified documents over the course of roughly two decades, the U.S. Department of Justice announced. + +Read full article » + +#### Analysis + +### Massachusetts Cases To Watch: Midyear Report + +Boston courthouses have been hopping as spring has turned to summer and high-profile white collar cases, the anticipated verdict in a landmark education and employment case, and a pair of cases dealing with courthouse immigration arrests have been filling up the Bay State's dockets. Here, Law360 highlights some of the most important cases to watch in the second half of 2019. + +Read full article » + +## CYBERSECURITY + +## Targeted Ransomware Attacks Soar, Symantec Reports + +The number of targeted ransomware attacks has skyrocketed in the past year as new attackers have increasingly emerged, cybersecurity giant Symantec Corp. said in a recent report. + +Read full article » + +Hooper Lundy + +Husch Blackwell + +Irell & Manella + +Jones Day + +Katten Muchin + +Kirkland & Ellis + +Latham & Watkins + +Littler Mendelson + +Loeb & Loeb + +Markus/Moss + +Mayer Brown + +McDermott Will + +McElroy Deutsch + +Miller & James + +Morgan Lewis + +Nixon Peabody + +Pepper Hamilton + +Proskauer Rose + +Reed Smith + +Ropes & Gray + +Rothschild Barry + +SeegerWeiss + +Skadden + +Steptoe & Johnson LLP + +Stradling Yocca + +Todd & Weld + +Trout Cacheris + +Troutman Sanders + +Ward & Hagen + +Weil Gotshal + +Wilentz Goldman + +Willkie Fan + +WilmerHale + +Zeichner Ellman + +Zuckerman Spaeder + +#### COMPANIES + +American Bar Association + +American Media Inc. + +AmerisourceBergen Corp. + +Baltimore Ravens + +Bank Policy Institute + +Barnes & Noble Inc. + +BlueCross BlueShield of Illinois + +Booz Allen Hamilton Inc. + +Burford Capital LLC + +Carnival Corp. + +Chevron Corp. + +The Department of Homeland Security's watchdog has issued an alert about a scheme by an Atlanta-based transnational fraud ring that poses as government procurement officials to steal electronics from unsuspecting contractors. + +Read full article » + +### After Delay, Pa. Programmer Pleads To Siemens Sabotage + +A Pittsburgh-area computer programmer pled guilty in federal court Friday to planting code that would deliberately break programs he'd written under contract with Siemens Corp., after his previous plea hearing was halted in June amid disagreements over whether his motivation should have been considered. + +Read full article » + +### TRANSPORTATION + +### 2nd Circ. Revives NYC Taxi Drivers' Unfair Suspension Suits + +The Second Circuit ruled Friday that New York City's practice of summarily suspending licenses for taxi drivers who've been arrested but not yet convicted deprives them of due process by denying them meaningful opportunities to challenge their suspensions. + +Opinion attached I Read full article » + +## HEALTH + +# 7th Circ. Affirms 5-Year Sentence For Chiropractor's Fraud + +The Seventh Circuit on Thursday upheld a five-year sentence for an Illinois chiropractor found guilty of health care fraud, saying he failed to show evidence of an error that could have gotten him a lighter sentencing recommendation. + +Opinion attached I Read full article » + +## 4 Arrested Over \$10M Medicaid Fraud Via NYC Pharmacy + +A New York City pharmacy owner and three of her managers were arrested over a multifaceted scheme that included bribing customers to have their HIV drug prescriptions filled there and over \$10 million in Medicaid fraud, the New York attorney general announced Friday. + +Complaint attached I Read full article » + +# ENVIRONMENTAL + +# Judge Chides Carnival Execs To Take Lead On Pollution Fixes + +A frustrated Florida federal judge pressed Carnival Corp. leaders Friday to demonstrate their commitment to changing the company's approach after agreeing last month to pay \$20 million for violating a previous settlement for illegal dumping. + +Read full article » + +## TAX + +# Banque Bonhote Pays DOJ \$1.2M More Over US Accounts + +Switzerland-based Banque Bonhote & Cie SA agreed Friday to pay \$1.2 million extra to the U.S. for failing to disclose eight U.S.-related bank accounts with approximately \$33 million in assets when it first struck a nonprosecution agreement in 2015. + +1 document attached I Read full article 0 + +Getty Images Inc. + +Google Inc. + +HSBC Holdings PLC + +Hertz Global Holdings Inc. + +Honeywell International Inc. + +Humana Inc. + +Independence Blue Cross Inc. + +Instagram Inc. + +International Brotherhood of Electrical Workers + +Major Lindsey & Africa + +McKesson Corp. + +NASDAQ OMX Group Inc. + +NFL Enterprises LLC + +National Association of Letter Carriers + +New Jersey State Bar Association + +New York Times Co. + +Northeastern University + +Petrobras + +Power Solutions International Inc. + +Princess Cruise Lines Ltd. + +Princeton University + +Purdue Pharma LP + +QUALCOMM Inc. + +Rochester Drug Cooperative Inc. + +Siemens AG + +Silverfleet Capital LLP + +Spotify Technology SA + +State Bar of California + +Symantec Corp. + +Twitter Inc. + +Virage Capital Management LP + +Weaver LLP + +Yale University + +YouTube Inc. + +### GOVERNMENT AGENCIES + +Central Intelligence Agency + +Commodity Futures Trading Commission + +Department of Commerce + +Drug Enforcement Administration + +European Commission + +European Union + +Federal Acquisition Regulatory Council + +Federal Bureau of Investigation + +Federal Reserve System + +Federal Trade Commission + +Senate Finance Committee lawmakers said Friday they requested information from an Alabama real estate licensing board about an appraiser who is alleged to have participated in abusive conservation easement transactions that resulted in \$1.8 billion in federal tax deductions. + +Letter attached I Read full article + +## PEOPLE + +### Money Moves: Covington, Weil, Eversheds Sutherland + +Covington & Burling LLP snagged a lobbying firm's formal general counsel, Weil Gotshal & Manges LLP added to its London office and Eversheds Sutherland is building out its banking team after a record year — this is Law360's latest roundup of personnel moves in the banking arena. + +Read full article » + +### LEGAL INDUSTRY + +#### Exclusive + +### Ailing NFL Players And The Lawyer They Say Swindled Them + +The inside story of how an avaricious lawyer, an ex-con and an unlicensed doctor preyed on NFL players in hopes of getting rich off the league's landmark concussion settlement. + +Read full article » + +### Why Some Straddle The Line Between Law Firm And GC Gigs + +Some lawyers take the rare step of simultaneously holding roles at law firms and corporate legal departments. It can mean balancing time commitments and watching out for conflicts, but also richer portfolios of experience for those lawyers — and cost-effective options for companies. + +Read full article » + +### Law Firms Are Getting Less Of The Corporate Legal Pie + +Corporations are moving more work in-house and have increased their reliance on alternative legal service providers, and that trend is expected to continue, according to the results of a survey released Thursday. + +Read full article » + +### Justice Gorsuch Tells Law Student: Work Hard, Be Kind + +Since being sworn in as a U.S. Supreme Court justice in 2017, Justice Neil Gorsuch has already penned several significant opinions for the high court. But on Thursday, a very different piece of his writing drew the attention of thousands online — a letter he sent to a law student who had asked for his advice. + +Read full article )> + +### Former NJ Chief District Judge, 70, Dies After Cancer Battle + +U.S. District Judge Jerome B. Simandle, a former chief of New Jerseys federal bench who championed one of the nation's busiest courts amid its ongoing judicial vacancy crisis, has died at 70 after a battle with liver cancer, the Association of the Federal Bar of New Jersey and a longtime colleague said Friday. + +Read full article » + +### Do Atty Hopefuls With Criminal Records Get A Fair Shake? + +Attorney hopefuls must undergo a "moral character" screening that is supposed to protect the public from unscrupulous lawyers, but a new report from Stanford has found that the way bar examiners evaluate criminal records often has little to do with that purpose. + +Read full article >> + +Judicial Conference of the United States + +National Labor Relations Board + +National Reconnaissance Office + +National Security Agency + +Securities and Exchange Commission + +U.S. Attorney's Office + +U.S. Court of Appeals for the Second Circuit + +U.S. Court of Appeals for the Seventh Circuit + +U.S. Department of Homeland Security + +U.S. Department of Justice + +U.S. Department of Labor + +U.S. Department of the Treasury + +U.S. District Court for the District of Maryland + +U.S. District Court for the District of Massachusetts + +U.S. District Court for the Eastern District of New York + +U.S. District Court for the Northern District of Georgia + +U.S. District Court for the Northern District of Illinois + +U.S. District Court for the Southern District of Florida + +U.S. District Court for the Southern District of New York + +U.S. District Court for the Western District of Pennsylvania + +U.S. Environmental Protection Agency + +U.S. House of Representatives + +U.S. Immigration and Customs Enforcement + +U.S. Navy + +U.S. Senate + +U.S. Supreme Court + +The U.S. House of Representatives teed up a battle over minimum wage with the U.S. Senate, and groups of state attorneys general pushed for more federal guidance on cannabis as well as competition in labor markets. These are some of the stories in corporate legal news you may have missed in the past week. + +Read full article » + +#### In Case You Missed It: Hottest Firms And Stories On Law360 + +For those who missed out, here's a look back at the law firms, stories and expert analyses that generated the most buzz on Law360 last week. + +Read full article » + +#### Podcast + +#### Law360's Pro Say: Remembering Justice Stevens + +John Paul Stevens, a liberal icon who spent more than three decades as a justice on the U.S. Supreme Court, died July 16 at the age of 99. On this week's show, Supreme Court reporter Jimmy Hoover breaks down the life and legal legacy of the late justice. + +Read full article » + +#### JOBS + +Search full listings or advertise your job opening + +White Plains insurance boutique seeks associate defense litigator + +KLR Davis + +White Plains, New York + +Not sure if your firm subscribes? Ask your libtarian. + +We hope you found this message to be useful. 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@@ +version https://git-lfs.github.com/spec/v1 +oid sha256:178c23c2221b13e814eb24a01b381d0d11f2e27ef162373f9c833181464e7679 +size 1541 diff --git a/marker2/ds9/EFTA00083746/EFTA00083746.md b/marker2/ds9/EFTA00083746/EFTA00083746.md new file mode 100644 index 0000000000000000000000000000000000000000..47e3e1091cfd8e36f90795da46ef4aa3d73539b3 --- /dev/null +++ b/marker2/ds9/EFTA00083746/EFTA00083746.md @@ -0,0 +1,25 @@ +To: + +Subject: RE: video + +Date: Mon, 22 Jul 2019 20:54:06 +0000 + +Sure. When you say glitchy, do you mean it often pauses and is slow? If that's the case, the easiest thing to do will be to burn it locally. Once there it will play much more smoothly. + +From: + +Sent: Monday, July 22, 2019 4:08 PM + +To: + +Subject: video + +Hi + +We're hoping to play a particular video during a meeting with attorneys for a witness this week, but the file I have is glitchy. Any chance you could take a look and see if there's anything we can do? Lit support previously converted it, but it's still not great. + +Saved here: + +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/EFTA00083746/EFTA00083746.metadata.json b/marker2/ds9/EFTA00083746/EFTA00083746.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d6234be0bf645014640bf0c81c8d3dab4ccb5ea9 --- /dev/null +++ b/marker2/ds9/EFTA00083746/EFTA00083746.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083746.pdf", + "engine": { + "marker_major": "2", + "marker_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": 712, + "elapsed_seconds": 0.68, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 42 + ], + [ + "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/EFTA00083746" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083747/EFTA00083747.md b/marker2/ds9/EFTA00083747/EFTA00083747.md new file mode 100644 index 0000000000000000000000000000000000000000..c413f0bb07237fda8f372368056f6a516c5246c6 --- /dev/null +++ b/marker2/ds9/EFTA00083747/EFTA00083747.md @@ -0,0 +1,33 @@ +To: + +Subject: RE: video + +Date: Mon, 22 Jul 2019 21:51:55 +0000 + +Ah, that's helpful. It opens and freezes, which sounds like what you're describing. I tried to burn it to my desktop, but got an error message. Any chance you could try burning it to a disc? Thanks. + +From: + +Sent: Monday, July 22, 2019 4:54 PM + +To: + +Subject: RE: video + +Sure. When you say glitchy, do you mean it often pauses and is slow? If that's the case, the easiest thing to do will be to burn it locally. Once there it will play much more smoothly. + +From: + +Sent: Monday, July 22, 2019 4:08 PM + +To: + +Subject: video + +We're hoping to play a particular video during a meeting with attorneys for a witness this week, but the file I have is glitchy. Any chance you could take a look and see if there's anything we can do? Lit support previously converted it, but it's still not great. + +Saved here: + +Thanksl + +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/EFTA00083747/EFTA00083747.metadata.json b/marker2/ds9/EFTA00083747/EFTA00083747.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c2d318facea8c3c2ddfb55faaf067695e33dc9c4 --- /dev/null +++ b/marker2/ds9/EFTA00083747/EFTA00083747.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083747.pdf", + "engine": { + "marker_major": "2", + "marker_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": 0.86, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 52 + ], + [ + "Line", + 26 + ], + [ + "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/EFTA00083747" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083748/EFTA00083748.md b/marker2/ds9/EFTA00083748/EFTA00083748.md new file mode 100644 index 0000000000000000000000000000000000000000..be28fc1fc5586815eec221835a3a0719513a9e25 --- /dev/null +++ b/marker2/ds9/EFTA00083748/EFTA00083748.md @@ -0,0 +1,17 @@ +To: + +Cc: + +Subject: RE: St. Thomas airstrip employees + +Date: Mon, 22 Jul 2019 20:12:46 +0000 + +Multiple workers at the airstrip on St. Thomas have been quotes in two recent articles saying they repeatedly saw Epstein fly in with girls they believed were minors — see here, for example: + +https://www.insidercom/airport-workers-say-they-saw-jeffrey-epstein-traveling-with-teens-2019-7 + +Would it be possible to interview employees there to see if we can identify those folks (who are anonymous in the article) and get additional info? I think could be through leads or your folks, whatever is preferable for your unit. This could be relevant not just for the current case but in connection with a potential search warrant there, which I understand some of your folks have been asking about. + +thanks, + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00083748/EFTA00083748.metadata.json b/marker2/ds9/EFTA00083748/EFTA00083748.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d1a7af9c3e977b0fe2f17ba03ef724e1ff573f4a --- /dev/null +++ b/marker2/ds9/EFTA00083748/EFTA00083748.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083748.pdf", + "engine": { + "marker_major": "2", + "marker_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": 849, + "elapsed_seconds": 0.7, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 16 + ], + [ + "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/EFTA00083748" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083749/EFTA00083749.md b/marker2/ds9/EFTA00083749/EFTA00083749.md new file mode 100644 index 0000000000000000000000000000000000000000..18da7cdc48f437e4279659e3fb53662c79e7f855 --- /dev/null +++ b/marker2/ds9/EFTA00083749/EFTA00083749.md @@ -0,0 +1,45 @@ +From:1==MM" + +Sent: Friday, July 19, 2019 15:42 + +To: + +Cc: >; (USANYS) [Contractor] (c > (USANYS) <->; + +Subject: RE: Epstein Q + +Thanks! Sorry, but can you just point me to where? I have all the dots if you can just point me to the right one. + +From: ) < + +Sent: Frida Jul 19 2019 2:46 PM + +To + +Cc: I < (USANYS) [Contractor] <= > >; (USANYS) < (z > + +Subject: Re: Epstein Q + +We have, and they were. (Some of the images, at least, were in the same safe as the other stuff.) + +Sent from my iPhone + +On Jul 19, 2019, at 14:44, Biase, Nicholas (USANYS) < > wrote: + +Have we publicly stated whether the diamonds and passport were found in the same safe as the pictures of underaged girls? Thanks. + +Public Affairs + +United States Department of Justice + +U.S. Attorney's Office Southern District of New York + +[Mobile:-[ Press Office: \ No newline at end of file diff --git a/marker2/ds9/EFTA00083749/EFTA00083749.metadata.json b/marker2/ds9/EFTA00083749/EFTA00083749.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0eccba4d382f0b97f66c9d047bfd1aabe6ca1ba9 --- /dev/null +++ b/marker2/ds9/EFTA00083749/EFTA00083749.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083749.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1117, + "elapsed_seconds": 1.01, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 90 + ], + [ + "Line", + 40 + ], + [ + "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/EFTA00083749" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083750/EFTA00083750.md b/marker2/ds9/EFTA00083750/EFTA00083750.md new file mode 100644 index 0000000000000000000000000000000000000000..3e5da94572798e0d3e9d4fd1ab4c616f3a77f7bc --- /dev/null +++ b/marker2/ds9/EFTA00083750/EFTA00083750.md @@ -0,0 +1,103 @@ +To: + +Cc: + +Subject: RE: scheduling + +Date: Thu, 18 Feb 2021 20:11:55 +0000 + +Hey all, just letting you know that Menninger is calling =friends and family trying to get information. still need to clear a few dates with her for March. + +Panish Shea & Boyle LLP + +11111 Santa Monica Boulevard, Suite 700 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. + +From: + +Sent: Monday, February 01, 2021 4:01 PM + +To: + +Cc: + +Subject: RE: scheduling + +Thanks for speaking with us today Below is a link to the article I mentioned, along with a related article: + +Regarding scheduling, our team is available in the first week of March, and we're flexible on timing, so we're happy to meet whenever works best for you and your client. + +very much, + +From: + +Sent: Thursday, January 28, 2021 11:40 AM + +To + +Cc + +Subject: RE: scheduling + +Sorry - I just remembered that I have a hearing at 1.0 a.m. Totally forgot about that when I emailed you back yesterday. Can we do 11:30 instead? + +11111 Santa Monica Boulevard, Suite 700 25 + +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: Thursday, January 28, 2021 8:37 AM + +To: + +Cc: + +Subs : • • sc eeu ing + +Hi + +Thanks very much. Let's plan to speak at 10 a.m. PST on Monday (1 p.m our time). We can use this conference line: 844- + +Best, + +From: + +Sent: Wednesday, January 27, 2021 8:05 PM + +To: + +Cc: + +Subject: Re: scheduling + +Hi — I'm free between 10-12 and 2-4 on Monday. Both PST. Thanks. + +psoiaw.com + +On Jan 27, 2021, at 4:16 PM wrote: + +Hi Hope you re doing well. Our team was hoping to schedule a call with you for Monday to talk through a few things — are there times that might work for you for a call? + +Thanks very much, + +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/EFTA00083750/EFTA00083750.metadata.json b/marker2/ds9/EFTA00083750/EFTA00083750.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..39887f6efe28ee7018bfab8b4477703b263a46f5 --- /dev/null +++ b/marker2/ds9/EFTA00083750/EFTA00083750.metadata.json @@ -0,0 +1,139 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083750.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3380, + "elapsed_seconds": 1.56, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "CONFIDENTIALITY NOTICE:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 326.43 + ], + [ + 144.14854431152344, + 326.43 + ], + [ + 144.14854431152344, + 339.60113525390625 + ], + [ + 30.6, + 339.60113525390625 + ] + ] + }, + { + "title": "CONFIDENTIALITY NOTICE:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.823999999999998, + 81.0 + ], + [ + 144.14854431152344, + 81.0 + ], + [ + 144.14854431152344, + 92.10113525390625 + ], + [ + 31.823999999999998, + 92.10113525390625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 38 + ], + [ + "Text", + 26 + ], + [ + "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", + 71 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00083750" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083752/EFTA00083752.md b/marker2/ds9/EFTA00083752/EFTA00083752.md new file mode 100644 index 0000000000000000000000000000000000000000..34385e26c57b319f4233d2c9221116a9b9e33e60 --- /dev/null +++ b/marker2/ds9/EFTA00083752/EFTA00083752.md @@ -0,0 +1,169 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +United States of America, + +—v— + +Ghislaine Maxwell, + +Defendant. + +20-CR-330 (MN) + +OPINION AND ORDER + +ALISON J. NATHAN, District Judge: + +Defendant Ghislaine Maxwell has been indicted by a grand jury on charges of conspiracy to entice minors to travel to engage in illegal sex acts, in violation of 18 U.S.C. § 371; enticing a minor to travel to engage in illegal sex acts, in violation of 18 U.S.C. §§ 2422 and 2; conspiracy to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371; transporting minors to participate in illegal sex acts, in violation of 18 U.S.C. §§ 2423 and 2; and two charges of perjury, in violation of 18 U.S.C. § 1623. The Court held a lengthy bail hearing on July 14, 2020. After extensive briefing and argument at the hearing, the Court concluded that the Defendant was a clear risk of flight and that no conditions or combination of conditions would ensure her appearance. Bail was therefore denied. + +The Defendant has now filed a renewed motion for release on bail pending trial, which the Government opposes. In her renewed motion, the Defendant attempts to respond to the reasons that the Court provided in denying bail and proposes a substantially larger bail package. But by and large, the arguments presented either were made at the initial bail hearing or could have been made then. In any event, the new information provided in the renewed application only solidifies the Court's view that the Defendant plainly poses a risk of flight and that no + +combination of conditions can ensure her appearance. This is so because: the charges, which carry a presumption of detention, are serious and carry lengthy terms of imprisonment if convicted; the evidence proffered by the Government, including multiple corroborating and corroborated witnesses, is strong; the Defendant has substantial resources and foreign ties (including citizenship in a country that does not extradite its citizens); and the Defendant, who lived in hiding and apart from the family to whom she now asserts important ties, has not been fully candid about her financial situation. Thus, for substantially the same reasons that the Court denied the Defendant's first motion for release on July 14, 2020, the Court DENIES the Defendant's renewed motion for release on bail.' + +# I. Background + +On June 29, 2020, a grand jury in the Southern District of New York returned a six-count Indictment against the Defendant, charging her with facilitating Jeffrey Epstein's sexual abuse of multiple minor victims between approximately 1994 and 1997. See Dkt. No. 1. On July 2, 2020, the Indictment was unsealed, and that same day, the Defendant was arrested in New Hampshire. On July 8, 2020, the Government filed a Superseding Indictment, which contained only small ministerial corrections. Dkt. No. 17. + +On July 14, 2020, this Court held a hearing regarding the Defendant's request for bail. After a thorough consideration of all of the Defendant's arguments and of the factors set forth in 18 U.S.C. § 3142(g), the Court concluded that no conditions or combination of conditions could reasonably assure the Defendant's appearance, determining as a result that the Defendant was a flight risk and that detention without bail was warranted under 18 U.S.C. § 3142(e)(1). The + +&#x27; This Opinion & Order will be temporarily sealed in order to allow the parties to propose redactions to sensitive or confidential information. + +Defendant did not appeal the Court's determination that detention was required, and she has been incarcerated at the Metropolitan Detention Center since that time. + +#### IL Legal Standard + +Pretrial detainees have a right to bail under the Eighth Amendment to the United States Constitution, which prohibits the imposition of "[e]xcessive bail," and under the Bail Reform Act, 18 U.S.C. § 3141, et seq. The Bail Reform Act requires the Court to release a defendant "subject to the least restrictive further condition, or combination of conditions, that [it] determines will reasonably assure the appearance of the person as required and the safety of any other person and the community." 18 U.S.C. § 3142(c)(1)(B). Only if, after considering the factors set forth in 18 U.S.C. § 3I42(g), the Court concludes 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," may the Court order that the defendant be held without bail. 18 U.S.C. § 3142(e)(1). + +If there is probable cause to find that the defendant committed an offense specifically enumerated in § 3142(e)(3), a rebuttable presumption arises "that no condition or combination of conditions will reasonably assure" the defendant's appearance or the safety of the community or others. 18 U.S.C. § 3142(e)(3). In such circumstances, "the defendant `bears a limited burden of production . . . to rebut that presumption by coming forward with evidence that he does not pose a danger to the community or 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)); see also United States v. Rodriguez, 950 F.2d 85, 88 (2d Cir. 1991) ("[A] defendant must introduce some evidence contrary to the presumed fact in order to rebut the presumption."). Nonetheless, "'the government retains the ultimate burden of persuasion by clear and convincing evidence that the + +defendant presents a danger to the community,' and `by the lesser standard of a preponderance of the evidence that the defendant presents a risk of flight.'" English, 629 F.3d at 319 (quoting Mercedes, 254 F.3d at 436); see also United States v. Manly., 782 F.2d 1141, 1144 (2d Cir. 1986) ("The government retains the burden of persuasion [in a presumption case]."). Even when "a defendant has met his burden of production," however, "the presumption favoring detention does not disappear entirely, but remains a factor to be considered among those weighed by the district court." United States v. Mattis, 963 F.3d 285, 290-91 (2d Cir. 2020). + +After a court has made an initial determination that no conditions of release can reasonably assure the appearance of the Defendant as required, the Court may reopen the bail hearing if "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 pretrial detention is warranted. 18 U.S.C. § 3142(0. But the Court is not required to reopen the hearing or to conduct another hearing if it determines that any new information would not have a material bearing on the issue. See United States v. Raniere, No. 18-CR-2041 (NGG) (VMS), 2018 WL 6344202, at \*2 n.7 (E.D.N.Y. Dec. 5, 2018) (noting that "[a]s the court has already held one detention hearing, it need not hold another" the standards set forth in 18 U.S.C. § 3142(0(2) are met); United States v. Havens, 487 F. Supp. 2d 335, 339 (W.D.N.Y. 2007) (electing not to reopen a detention hearing because the new information would not have changed the court's decision to detain the defendant until trial). + +## III. Discussion + +The Defendant bases her renewed motion for bail on both 18 U.S.C. § 3142(0 and the Court's inherent powers to review its own bail decisions. See Def. Mot. at 7-9. As already noted, § 3142(0 provides that a bail hearing "may be reopened ... at any time before trial 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 whether there are conditions of release that will reasonably assure the appearance of such person as required and the safety of any other person and the community." A court may also revisit its own decision pursuant to its inherent authority, even where the circumstances do not match § 3142(0's statutory text. See, e.g., United States v. Rowe, No. 02-CR-756 (LMM), 2003 WL 21196846, at \*1 (S.D.N.Y. May 21, 2003) (noting 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. Petrov, No. 15-CR-66 (LTS), 2015 WL 11022886, at \*3 (S.D.N.Y. Mar. 26, 2015) (noting the "Court's inherent authority for reconsideration of the Court's previous bail decision"). + +In line with this, the Defendant's new motion aims to address the reasons that the Court provided when it originally determined that no conditions could reasonably assure her appearance and that pretrial detention was warranted. First, the Defendant proposes a more expansive set of bail conditions that she claims addresses any concerns regarding risk of flight. The newly proposed conditions include a \$28.5 million bail package, which consists of a \$22.5 million personal recognizance bond co-signed by the Defendant and her spouse and secured by approximately \$8 million in property and \$500,000 in cash, along with six additional bonds five co-signed by the Defendant's friends and family members and the sixth posted by the security company that would provide security services to the Defendant if she were granted bail and transferred to home confinement. See Def. Mot. at 2. The proposed conditions also provide that the Defendant would be released to the custody of a family member, who would serve as her third-party custodian under 18 U.S.C. § 3142(c)(1)(B)(i); that she would be placed in home confinement with GPS monitoring and that her travel would be restricted to the Southern and Eastern Districts of New York and would be limited to appearances in Court, meetings with + +counsel, medical visits, and upon approval by the Court or Pretrial Services. hi. at 2-3. + +Furthermore, the Defendant would have on-premises security guards that she would pay for who would prevent her from leaving the residence at any time without prior approval by the Court or Pretrial Services and who would escort her when she is authorized to leave. Id. at 3. + +The motion also presents new information that, according to the Defendant, addresses the concerns that the Court articulated when it determined that detention was warranted. This newly presented information, most of which was available to the Defendant at the time of the initial bail hearing, includes evidence of the Defendant's family ties in the United States, see Def. Mot. at 10-14; a detailed financial report that provides a more comprehensive outlook on the Defendant's financial conditions and assets, see id. at 15-18; evidence that according to her rebuts the Government's original contention that she attempted to evade law enforcement prior to her arrest, see id. at 18-25; waivers of her right to contest extradition from the United Kingdom and France, along with expert opinions claiming that the Defendant would not be able to resist extradition if she were to execute the waivers, see id. at 25-29; and evidence that she argues lays bare the weakness of the Government's case against her, see id. at 30-34. + +Finally, the Defendant argues that the conditions of her confinement, including as a result of the COVID-19 pandemic, present an additional factor favoring release. She claims that the conditions imposed are punitive and that those conditions interfere with her ability to participate in her defense, and she asserts that these factors further militate in favor of release. See id. at 34- 38. + +Having carefully considered all of the Defendant's arguments, the Court again concludes that no conditions or combination of conditions could reasonably assure her appearance and that + +detention without bail is warranted under 18 U.S.C. § 3142(e)(I). The Court accordingly denies Defendant's request to reopen the original bail hearing and denies her renewed motion for bail. + +#### A. The presumption in favor of detention applies + +The Court is required to presume that no condition or combination of conditions of pretrial release will reasonably assure the Defendant's appearance. The Bail Reform Act provides that if a defendant is charged with committing an offense involving a minor victim under 18 U.S.C. §§ 2422 or 2423, "it shall be presumed that no condition or combination of conditions will reasonably assure the appearance of the person as required and the safety of the community if the judicial officer finds that there is probable cause to believe that the person committed." 18 U.S.C. § 3142(e)(3)(E). The Defendant's indictment by a grand jury suffices to establish that there is probable cause to believe that she committed the offenses charged in the indictment. See, e.g., United States v. Contreras, 776 F.2d 51, 53-54 (2d Cir. 1985) (noting that that an indictment returned by a properly constituted grand jury "conclusively determines the existence of probable cause" and that "the return of an indictment eliminates the need for a preliminary examination at which a probable cause finding is made by a judicial officer pursuant to Rule 5(c) of the Federal Rules of Criminal Procedure." (citations omitted)). In light of the crimes charged in the indictment, the Court begins with the presumption that no condition or combination of conditions of pretrial release will reasonably assure the Defendant's appearance. + +When the presumption applies, the Defendant bears a limited burden of production "tending to counter the § 3142(e) presumption of flight," Contreras, 776 F.2d at 53 n.1. The Defendant's burden of production only requires that she "introduce a certain amount of evidence contrary to the presumed fact." United States v. Jessup, 757 F.2d 378, 380 (1st Cir. 1985), + +abrogated on other grounds by United States v. O'Brien, 895 F.2d 810 (1st Cir. 1990). That burden is "limited." United States v. Mercedes, 254 F.3d 433, 436 (2d Cir. 2001). The Defendant's proffer of evidence and information—including information relating to her financial conditions and her family ties to the United States, among other things-satisfies this limited burden. As the Court discussed at the July 14, 2020 hearing, these factors bear on the question of whether the Defendant poses a flight risk. And the evidence she advances in her renewed motion for bail reasonably disputes the presumption that she poses a flight risk. In that sense, this evidence is relevant to the ultimate determination and satisfies the relatively low threshold imposed by the burden of production. + +The presumption of flight does not disappear entirely, however, and it "remains a factor to be considered among those weighed by the district court." United States v. Mercedes, 254 F.3d 433, 436 (2d Cir. 2001) (quoting Martir, 782 F.2d at 1144). As a result, "[a] judicial officer conducting a detention hearing should, even after a defendant has come forward with rebuttal evidence, continue to give the presumption of flight some weight by keeping in mind that Congress has found that these offenders pose special risks of flight, and that `a strong probability arises' that no form of conditional release will be adequate to secure their appearance." Martir, 782 F.2d at 1144 (citation omitted). + +# B. The new information does not alter the Court's initial determination + +When determining whether there are conditions of release that will reasonably assure the appearance of the person as required, courts are required to consider the factors outlined in 18 U.S.C. § 3142(g). Thus, the Court considers (1) the nature and circumstances of the offense charged, including whether the offense involves a minor victim, (2) the weight of the evidence, (3) the defendant's history and characteristics, and (4) the nature and seriousness of the danger to any person or the community posed by pre-trial release. See Mercedes, 254 F.3d at 436; see also 18 U.S.C. § 3142(g). + +At the July 14, 2020 bail hearing, the Court considered these factors before concluding that no conditions of release could reasonably assure the appearance of the person as required. And the first and fourth factors remain unchanged. As already noted, the Defendant is charged with offenses involving minor victims, and it is undisputed that the nature and circumstances of the offenses charged in the Superseding Indictment weighs in favor of continued detention. On the other hand, the Government has not advanced any evidence that the Defendant poses a danger to any person or to the community, a factor that weighs against detention. The Defendant's arguments therefore focus on the second and third factors. + +As explained below, neither the arguments put forth in the Defendant's renewed motion for bail nor the evidence she submitted in conjunction with her motion rebut the Court's conclusions, and the Court continues to find, after again applying these factors, that no conditions of release will reasonably assure the Defendant's appearance at future proceedings. + +# 1. The Weight of the Evidence + +The Court will address the strength of the Government's case first. The Defendant argues that the Government lacks any meaningful documentary corroboration of the witness testimony and that the discovery produced to date has included only a "small number of documents from the time period of the conspiracy." Def. Mot. at 5. And she claims, as a result, that the Government overstated the strength of its case in advance of the July 14, 2020 bail hearing. See id. at 30-33. So she argues that the second § 3142(g) factor supports release. + +The Court disagrees. Arguing that the case against her "is based almost exclusively on the recollections of the three accusers, who remain unidentified," the Defendant contends that the weight of the evidence is weak. Def. Reply at 2. But she too easily discredits the witness testimony. According to the Government, and as reflected in the indictment, it 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 Gov't Opp'n at 10; see also Dkt. No. 17, SI Superseding Indictment, ¶¶ 7, II, 13, 17. Moreover, the Government proffers that additional evidence, including flight records and other witnesses' corroborating testimony, will further support the main witnesses' testimony and link the Defendant to Epstein's conduct. Gov't Opp'n at 10-11. And while the Defendant contends that much of this evidence focuses on Epstein, not the Defendant, the nature of the conspiracy charge (along with the evidence linking the Defendant to Epstein) renders this evidence relevant to the Government's charges against her. As the Court stated in the July 14,2020 hearing, although the Court does not prejudge the merits of the Government's case or of the Defendant's defenses, for purposes of the bail determination stage, the Government's proffered case against the Defendant remains strong. See Dkt. No. 93 ("Tr.") at 83:4-83:10. The Court again concludes that the Defendant's awareness of the potential strength of the government's case against her creates a risk of flight, and none of the Defendant's new arguments meaningfully alter that conclusion. As a result, the second factor supports detention. + +# 2. The Defendant's History and Characteristics + +At the July 14,2020 bail hearing, the Court determined that the Defendant was a flight risk in part because of her substantial international ties, including multiple foreign citizenships and familial and personal connections abroad and her ownership of at least one foreign property of significant value. See Tr. at 83:13-83:18. And the Court further noted that the Defendant's extraordinary financial resources could provide her the means to flee the country even despite + +COVID-I9 related travel restrictions. Id. at 83:21-83:25. The Court also observed that the Defendant had family and personal connections to the United States but concluded that the absence of any dependents, significant family ties, or employment in the United States also supported the conclusion that flight would not pose an insurmountable burden for her. Id. at 84:4-84:9. While the Defendant's renewed motion for bail addresses some of these factors, it does not alter the Court's conclusion. + +The first few considerations remain relatively unchanged. The Defendant continues to have substantial international ties and multiple foreign citizenships, and she continues to have familial and personal connections abroad. None of the evidence presented in support of the present motion fundamentally alters those conclusions. To address the Court's concern that the Defendant's French citizenship presented the opportunity that she could flee to France and that she would be able to resist extradition on that basis, see Tr. at 83:1843:20, the Defendant now offers to waive her right to extradition from both the United Kingdom and France, along with expert opinions reports claiming that such waivers would likely make it possible to resist an extradition request from the United States to either country. See Def. Mot., Exs. T, U, V. As the Government points out in its brief, however, the legal weight of the waivers is, at best, contested. The French Ministry of Justice, for instance, indicated in a letter submitted in conjunction to the Government's opposition that the French Code of Criminal Procedure "absolutely prohibits" the extradition of a French national. See Gov't Opp'n, Ex. B. And while the Defendant's own expert attempts to rebut the Ministry of Justice's letter, see Def. Reply, Ex. A, even the Defendant's own experts use probabilistic, rather than absolute, language, leaving open the possibility that extradition would be blocked. See, e.g., Def. Mot., Ex. U at 2 ("On the basis of the information currently known, it is highly unlikely that Ghislaine Maxwell would be able + +successfully to resist extradition to the United States in relation to the charges in the superseding indictment dated 7 July 2020."); Def. Mot., Ex. V ¶ 76 ("It would ... become a matter for the French government to decide on whether or not to issue an extradition decree against Ms. Ghislaine Maxwell."); id. ¶ 77 ("[I]t is highly unlikely that the French government would refuse to issue and execute an extradition decree against Ms Maxwell. . . ."). Nor has the Defendant presented any cases where courts addressed the question of whether an anticipatory waiver of extradition is enforceable; while she cites cases where defendants offered to waive extradition, the reasoning in those cases turned on other factors and the courts did not dwell on the enforceability of such waivers. See, e.g., United States v. Cirillo, No. 99-1514, 1999 WL 1456536, at \*2 (3d Cir. July 13, 1999); United States v. Salvagno, 314 F. Supp. 2d 115, 119 (N.D.N.Y. 2004); United States v. Karni, 298 F. Supp. 2d 129, 132-33 (D.D.C. 2004); United States v. Chen, 820 F. Supp. 1205, 1212 (N.D. Cal. 1992). In those cases, the courts included such waivers as one among several conditions of release, but they did not make any express determination that such waivers are enforceable. On the other hand, some courts have expressly opined that such waivers are unenforceable. See, e.g., United States v. Epstein, 425 F. Supp. 3d 306, 325 (S.D.N.Y. 2019) (describing the "Defense proposal to give advance consent to extradition and waiver of extradition rights" as "an empty gesture."); United States v. Morrison, No. 16-MR-118, 2016 WL 7421924, at \*4 (W.D.N.Y. Dec. 23, 2016) ("Although the defendants have signed a waiver of extradition, such a waiver may not become valid until an extradition request is pending in Canada and may be subject to withdrawal."); United States v. Stroh, No. 396-CR-139 (AHN), 2000 WL 1832956, at \*5 (D. Conn. Nov. 3, 2000) ("[I]t appears that there is a substantial legal question as to whether any country to which he fled would enforce any waiver of extradition signed under the circumstances presented in this case. At any event, + +extradition from Israel (or any other country) would be, at best, a difficult and lengthy process and, at worst, impossible."). + +Having carefully reviewed the experts' reports and the cases cited by the Defendant,2 the Court's analysis of the relationship between the Defendant's French citizenship and the risk of flight remains fundamentally unchanged. Its reasoning is guided in part by the substantial legal questions regarding the legal weight of anticipatory extradition waivers and the likelihood that any extradition would be a difficult and lengthy process (including, for instance, the likelihood that the Defendant would contest the validity of those waivers and the duration it would take to resolve those legal disputes). The likelihood that the Defendant would be able to frustrate any extradition requests—even if she were correct that she would be unable to stop extradition entirely—weighs strongly in favor of detention. + +In addition, the Defendant's extraordinary financial resources also continue to provide her the means to flee the country and to do so undetected. To be sure, this factor alone does not by itself justify continued detention. But as the Court noted at the initial bail hearing, the Defendant's financial resources, in combination with her substantial international ties and foreign connections and her experience avoiding detection (whether from the government, the press, or otherwise), do bear significantly on the flight risk analysis. See Tr. at 88:6-88:23 (distinguishing this case from United States v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018), + +2 The Defendant also argues that "a defendant's waiver of the right to appeal an extradition order has been recognized as an indication of the defendant's intent not to flee." Def. Mot. at 27 (citing United States v. Khashoggi, 717 F. Supp. 1048, 1052 (S.D.N.Y. 1989)). The Court places little weight on this argument. Under the Defendant's theory, a defendant could strategically offer to waive the right to extradition while intending to resist any subsequent extradition that might result. The Court is unpersuaded. + +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)). + +The Court's concerns regarding the absence of any dependents, significant family ties, or employment in the United States, meanwhile, apply with somewhat less force in light of the evidence submitted in support of this motion. See id. at 84:4-84:9. The Defendant has submitted a litany of letters of support written by friends and family members. See Def. Mot., Exs. A—N, W—X. These letters, according to the Defendant, support her claim that she has significant ties to the United States and attest to the Defendant's character. The Defendant places particular emphasis on the letter written by her spouse, whose identity and connection to the Defendant was withheld from the Court at the initial bail hearing. See Def. Mot. at 11-13. In that letter, her spouse expounds on the lives they led before her arrest, noting in particular that the Government's characterization of the Defendant's "transient" lifestyle, Dkt. No. 4 at 9, was belied by the "quiet family life" that they had enjoyed. Def. Mot. at 11; see also Def. Mot, Ex. A 4-5. Other letters similarly highlight that the Defendant's family and affective ties in the United States are stronger than was originally presented to the Court in the initial bail hearing. + +These letters substantiate the Defendant's claim that she has important ties to people in the United States, but they leave unaltered the Court's conclusion that flight would not pose an insurmountable burden for the Defendant. Among other things, the Defendant now argues that her newly revealed relationship with her spouse signals her deep affective ties in the country, but at the time she was arrested, she was not living with him and claimed to be getting divorced. See Pretrial Services Report at 3. Indeed, she does not propose to live with him were she to be released on bail, undercutting her argument that that relationship would create an insurmountable burden to her fleeing. Furthermore, the fact that she has friends and family in the United States + +does not mean that those people would be unable to visit her were she to flee to another country. In addition, the Defendant continues to lack any employment ties to the United States—another factor weighing in favor of detention. Furthermore, it is apparent from the letters that the Defendant has significant ties to family and friends abroad. In light of this, nothing in the renewed motion for bail alters the Court's fundamental conclusion that flight would not pose an insurmountable burden to the Defendant. + +Other factors that similarly speak to the Defendant's history and characteristics weigh in favor of detention. Most notably, the Defendant's pattern of providing incomplete or erroneous information to the Court or to Pretrial Services bears significantly on the Court's application of the third factor to the present case. Among other things, in July 2020 the Defendant represented to Pretrial Services that she possessed around \$3.5 million worth of assets (while leaving out her spouse's assets and assets that had been transferred to trust accounts) and the representation that the New Hampshire property was owned by a corporation and that she was "just able to stay there." See Pretrial Services Report at 2. The Defendant now claims that she "was detained at the time and had no access to her financial records and was trying to piece together these numbers from memory. According to the Macalvins report, [the financial figures] are a close approximation of the value of the assets that Ms. Maxwell held in her own name at the time of her arrest.... For the reasons already discussed, Ms. Maxwell was reluctant to discuss anything about her [spouse] and expressed that to Pretrial Services." Def. Mot. at 16 n.5. Even if the Defendant was unable to provide an exact number, however, the difference between the number she originally reported to Pretrial Services and the number now presented to the Court in the Macalvins report, a report on the Defendant's finances prepared by a prominent accounting firm for purposes of this motion, see Def. Mot., Ex. O, makes it unlikely that the misrepresentation + +was the result of the Defendant's misestimation rather than misdirection. And while the Defendant's concerns regarding her spouse's privacy are not insignificant, she fails to furnish any explanation as to why those concerns led her to misrepresent key facts to Pretrial Services and, by extension, the Court. In sum, the evidence of a lack of candor is, if anything, stronger now than in July 2020, as it is clear to the Court that the Defendant's representations to Pretrial Services were woefully incomplete. That lack of candor raises significant concerns as to whether the Court has now been provided a full and accurate picture of her finances and as to the Defendant's willingness to abide by any set of conditions of release. + +For the reasons stated above, the Court concludes that the third factor continues to weigh in favor of detention. + +# C. Pretrial detention continues to be warranted + +In light of the reasons stated above, the Government has again met its burden of persuasion by "a preponderance of the evidence that the defendant presents a risk of flight." English, 629 F.3d at 319 (quoting Mercedes, 254 F.3d at 436). Taking the § 3142(g) factors into account, the Court concludes that the presumption in favor of detention, the nature and characteristics of the charged offenses, the weight of the evidence, and the history and characteristics of the Defendant all weigh in favor of detention. Along similar lines, the Government has also shown, and the Court concludes for the reasons outlined below, that the Defendant's proposed bail package cannot reasonably assure her appearance. Thus, the Court's original conclusion that the Defendant poses a flight risk and that no set of conditions can reasonably assure her future appearance remains unaltered. + +As already noted, the Defendant now proposes a \$28.5 million bail package, which includes a \$22.5 million personal recognizance bond co-signed by the Defendant and her spouse and secured by approximately \$8 million in property and \$500,000 in cash, along with six additional bonds—five co-signed by the Defendant's friends and family members and the sixth posted by the security company that would provide security services to the Defendant if she were granted bail and transferred to home confinement. See Def. Mot. at 2. At the initial hearing, the Court noted that the opaqueness of the Defendant's finances rendered it difficult to set financial bail conditions that could reasonably assure her appearance in court. The financial information that the Defendant presented to the Court at the initial bail hearing was undisputedly incomplete, and as the Court noted, the Court lacked "a clear picture of Ms. Maxwell's finances and the resources available to her." Tr. at 86-87. + +The Defendant has now presented to the Court what is perhaps a more thorough report on her finances prepared by Macalvins, an accounting firm in the United Kingdom. Macalvins analyzed the Defendant's assets and finances for the past five years, basing its analysis on, among other things, bank statements, tax returns, and FBAR filings, providing a summary of the assets held by the Defendant and her spouse as well as the assets held in trust for the benefit of the Defendant for the period stemming from 2015 to 2020. See Def. Mot., Ex. O. In addition, the Defendant retained a Certified Fraud Examiner and a former IRS Special Agent, who reviewed the Macalvins report and the underlying documents and determined that report accurately represents the assets held by the Defendant and her spouse. See Def. Mot., Ex. P. The Defendant's new bail proposal is based on the numbers derived from the Macalvins report. + +But even assuming that the financial report provides an accurate analysis of the Defendant's finances, the Court is unpersuaded by her argument that the bail package reasonably assures her appearance. As the Government argues, the bail package would leave unrestrained + +millions of dollars and other assets that she could sell in order to support herself. See Gov't Opp'n at 23. Furthermore, the proposed bond is only partially secured. Taking into account the vast amounts of wealth left relatively unrestrained by the bail package, that amount, standing alone, cannot reasonably assure that she would appear before the Court. Nor is the Court's conclusion altered by the fact that a number of third parties have pledged to support her bond; the amount of wealth that she would retain were she to flee, in addition to contingent assets and future income streams that are not accounted for in the bail package, would plausibly enable her to compensate them, in part or in full, for their losses. And while the Defendant argues that she has procured "significant loans on the basis of a negative pledge" over a property and that \$4 million is invested in an "illiquid hedge fund that could only be liquidated with considerable difficulty," see Def. Reply at 6, these arguments do not alter the Court's ultimate conclusion that the financial package does not meaningfully mitigate the possibility of flight. + +The proposed conditions also provide that the Defendant would be released to the custody of a family member, who would serve as the Defendant's third-party custodian under 18 U.S.C. § 3142(c)(1)(3)(i); that the Defendant would be placed in home confinement with GPS monitoring and that her travel would be restricted to the Southern and Eastern Districts of New York and would be limited to appearances in Court, meetings with counsel, medical visits, and upon approval by the Court or Pretrial Services; that she would be under the strict supervision of Pretrial Services; and that she would surrender all travel documents. Id. at 2-3. Furthermore, the Defendant would have on-premises security guards who would prevent her from leaving the residence at any time without prior approval by the Court or Pretrial Services and who would escort her when she is authorized to leave. Id. at 3. + +None of these conditions would reasonably assure the Defendant's appearance. Here, too, the Court's original determination applies with equal force. As the Court noted at the original hearing, the Defendant has demonstrated an extraordinary capacity to evade detection, "[e)ven in the face of what the Defense has acknowledged to be extreme and unusual efforts to locate her." Tr. at 87:4-87:19. Indeed, regardless of whether the Defendant sought to evade the press, rather than law enforcement, in the months leading up to her arrest, her sophistication in evading detection reveals the futility of relying on any conditions, including GPS monitoring, restrictive home confinement, and private security guards, to secure her appearance. See Tr. at 87:4-88:2. As other courts have observed, "home detention with electronic monitoring does not prevent flight; at best, it limits a fleeing defendant's head start." United States v. Zarger, No. 00- CR-773-S-1 (JG), 2000 WL 1134364, at \*I (E.D.N.Y. Aug. 4, 2000). Furthermore, while the Defendant now represents that she would be released to the custody of a family member, who would serve as the Defendant's third-party custodian under 18 U.S.C. § 3142(c)(1)(B)(i), and that she secured a residence in the Eastern District of New York, see Def. Mot. at 3, that does not outweigh the other significant factors weighing in favor of detention. And finally, the Defendant's argument that private security guards could ensure her appearance at future proceedings runs afoul of the Bail Reform Act, which the Second Circuit has held "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." United States v. Boustani, 932 F.3d 79, 82 (2d Cir. 2019). As in Boustani, the Defendant in the present case would be detained regardless of her wealth, and "if a similarly situated defendant of lesser means would be detained, a wealthy defendant cannot avoid detention by relying on his personal funds to pay for private detention." Id. + +In light of the above, the Court again concludes that the Government has shown by a preponderance of the evidence that the defendant presents a risk of flight and that the Defendant's proposed conditions are insufficient to reasonably assure her appearance. The presumption in favor of detention, the weight of the evidence, and the history and characteristics of the Defendant all support that conclusion, and none of Defendant's new arguments change the Court's original determination. + +# D. The Defendant's conditions of confinement do not justify release + +Lastly, the Court is unpersuaded by the Defendant's argument that the conditions of her confinement are uniquely onerous, interfere with her ability to participate in her defense, and thus justify release. See Def. Mot. at 35-38. Indeed, the Defendant does not meaningfully dispute that she has received "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." Gov't Opp'n at 29. To the extent that the Defendant has concerns regarding some of the measures taken by BOP, including a recent lockdown due to COVID-19 that curtailed in-person legal visitations, the Defendant provides no authority to conclude that this, standing alone, violates her constitutional right to participate in her defense. And while the Court acknowledges the Defendant's concerns regarding the conditions of her confinement, the Defendant has failed to provide any basis to conclude that release is warranted on those grounds—even after the Court has determined that she continues to pose a flight risk.3 + +3 The Court will continue to ensure that the Defendant has the ability to speak and meet regularly with her attorneys and to review all necessary discovery materials to prepare for her defense. Defense counsel shall confer with the Government on any specific requests. To the extent they are not reasonably accommodated, an application may be made to the Court. + +Finally, as the Court expressed at the initial bail hearing, it has deep concerns about the spread of COVID-19 at BOP facilities, including at the MDC. Indeed, in recent weeks, the incidence of COVID-19 among the inmate population where the Defendant is housed is truly alarming. See COVID-19: Coronavirus, Fed. Bureau of Prisons, https://www.bop.gov/ coronavirus/ (last visited Dec. 28, 2020) (noting that the MDC currently has 99 inmates and 11 staff members who have tested positive for COVID-19). It could be argued that in the face of this, only those defendants who pose a danger to the community ought to be detained pending trial. If that were the law and in light of the increasing positivity rate, the Court would not hesitate to reopen the detention hearing and release the Defendant on bail since the Government rests none of its arguments on dangerousness. But that is not the law. Moreover, as the Court found at the initial bail hearing, the Defendant has no underlying health conditions that put her at heightened risk of health impacts were she to contract COVID. The pandemic, including increasing positivity numbers in the MDC, is not a basis for release in this case where the Court finds that the Defendant poses a substantial and actual risk of flight and that no combination of conditions could reasonably assure her appearance. + +# E A hearing is unnecessary + +Having carefully reviewed the parties' arguments, the Court determines that a hearing is unnecessary and that it can resolve the motion on the papers. The briefing from both sides comprehensively lays out the parties' respective arguments For the reasons stated above, none of the new information has a material bearing on the Court's determination that the Defendant poses a flight risk. Indeed, many of the reasons that the Court provided at the July 14, 2020 hearing continue to apply with equal, if not greater, force. The Court need not hold another + +hearing to evaluate Maxwell's motion, and it declines to do so. *See United States v. Raniere*, No. + +18-CR-2041 (NGG) (VMS), 2018 WL 6344202, at \*2 n.7 (E.D.N.Y. Dec. 5, 2018). + +**IV. Conclusion** + +Defendant Ghislaine Maxwell's renewed motion for release on bail, Dkt. No. 97, is + +DENIED. + +SO ORDERED. + +Dated: December 28, 2020 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00083752/EFTA00083752.metadata.json b/marker2/ds9/EFTA00083752/EFTA00083752.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..be25f0a8043fc8c9cb41a30f1e084081e4becbd9 --- /dev/null +++ b/marker2/ds9/EFTA00083752/EFTA00083752.metadata.json @@ -0,0 +1,1025 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083752.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 22, + "chars": 42782, + "elapsed_seconds": 4.74, + "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": "I. 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b/marker2/ds9/EFTA00083774/EFTA00083774.md @@ -0,0 +1,234 @@ +# Exhibit A + +# COMPOSITE EXHIBIT A + +## NON-PROSECUTION AGREEMENT AND ADDENDUM + +IN RE: INVESTIGATION OF JEFFREY EPSTEIN + +### NON-PROSECUTION AGREEMENT + +IT APPEARING 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 with 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 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, 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(O, 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 nob contendere) to the indictment as currently pending against hint in the 15th Judicial Circuit in and for Palm Beach County (Case No. 2006-d-009495A/100CW charging one (1) count of solicitation of prostitution, in violation of FL Stet § 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 term(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 be paid 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 end/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 terms, nor arty 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 eny 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, [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 and agrees to comply with them. + +> R. ALEXANDER ACOSTA UNITED STATES ATTORNEY + +Dated: By: + +Dated: + +Dated: + +Dated: + +illIPPRILy + +GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN + +LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR 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 tmdmstands the conditions of this Non-Prosecution Agreement and agrees to comply with them. + +> R. ALEXANDER ACOSTA UNITED STATES ATTORNEY + +Dated: By: + +Dated; + +Dated: 7/2-41°7 + +Dared: + +ASSISTANT U.S. ATTORNEY + +JEFFREY EPSTEIN + +LILLY ANN SANCHE7, ESQ. ATTORNEY FOR JEFFREY EPSTEIN + +ERALD EFCOU"R71IESQ. OUNSEL TO )FFFREY EPSTEIN + +By signing this agreement, Epstein uststs 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 UN/TED STATES ATTORNEY + +Dated: BY: + +ASSISTANT U.S. ATTORNEY + +Dated: + +JEFFREY EPSTE/N + +Dated: + +Dated 61-oi a?-- + +GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTMN + +ESQ. ATTORNEY FOR JEFFREY EPSTEIN IN RE: + +#### INVESTIGATION OF + +JEFFREY EPSTEIN + +#### ADDENDUM TO 71IE NON-PROSECUTION AGREEMENT + +IT APPEARING that the parties sea to clarify certain provisions of page 4, paragraph 7 of the Non-Prosecution Agreement (hereinafter "paragraph Tr), that agreement is modified as follows: + +7A. The United Stales 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-party prior to the final designation of the attorney representative. 7E. The parties 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. + +Dated: /DAD 47 + +Dated: / rill- + +Dated: + +Dated: + +R. ALEXANDER. ACOSTA UNITED STATES ATTORNEY + +By: fis—rAftehia4A-- FAuccfr + +ASSISTA U.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 + +Dated: 10/30/07 + +By: Jeffrey H. Howard FAUSA +~~[REDACTED]~~ +ASSISTANT U.S. ATTORNEY + +Dated: \_\_\_\_\_ + +\_\_\_\_\_ +JEFFREY EPSTEIN + +Dated: 10/29/07 + +Gerald Lefcourt +GERALD LEFCOURT ESQ. +COUNSEL TO JEFFREY EPSTEIN + +Dated: \_\_\_\_\_ + +\_\_\_\_\_ +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 + +Dated: 10/30/07 + +By: + +*[Handwritten signature]* +**ALEXANDER ACOSTA** +**FAUSA** +**ASSISTANT U.S. ATTORNEY** + +Dated: \_\_\_\_\_ + +\_\_\_\_\_ +JEFFREY EPSTEIN + +Dated: \_\_\_\_\_ + +\_\_\_\_\_ +GERALD LEFCOURT, ESQ. +COUNSEL TO JEFFREY EPSTEIN + +Dated: 10-29-07 + +\_\_\_\_\_ +LILLY ANN SANCHEZ, ESQ. +ATTORNEY FOR JEFFREY EPSTEIN + +Doc-07-07 04:55pm From-Fowler-White Burnett + +3657820001 + +T-966 P.003/004 F-976 + +**Affirmation** + +I, Jeffrey B. 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b/marker2/ds9/EFTA00083790/EFTA00083790.md @@ -0,0 +1,106 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x + +20 Cr. 330 (AJN) + +#### MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL + +Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 + +Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 + +Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 + +Attorneys for Ghislaine Maxwell + +### INTRODUCTION + +Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. + +As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in United States for 30 years, has strong family ties and the support of friends and family residing in this country. She wants nothing more than to remain in the United States under whatever conditions the Court deems necessary so that she can effectively prepare for trial and vigorously defend against the 25-year-old charges in the Indictment. Ms. Maxwell has already proposed an expansive and, to our knowledge, unprecedented set of bail conditions that would reasonably assure her appearance. (See Dkt. 97.) In light of the Court's denial of that application (see Dkt. 106), Ms. Maxwell now proposes two additional bail conditions to supplement the extraordinarily restrictive bail package she has already offered. + +- First, Ms. Maxwell will renounce her French and British citizenship to eliminate any opportunity for her to seek refuge in those countries, if the Court so requires. +- Second, Ms. Maxwell will have her and her spouse's assets—excluding funds earmarked for living expenses, for legal fees and other expenses necessary to defend her against the criminal charges in this case and related civil lawsuits and for taxes—placed in a new account that will be monitored by a retired federal District Court judge and former United States Attorney who will function as asset monitor and will have co-signing authority over the account. + +The former condition goes well beyond the extradition waivers that the Court deemed insufficient and should satisfy any concerns the Court may have that Ms. Maxwell may try to seek a safe haven in France or the United Kingdom. (See id. at 11-13). As a non-citizen, Ms. Maxwell will not be able to avail herself of any protections against extradition that may apply to citizens of those countries. The latter condition will restrain Ms. Maxwell's assets so they cannot be used for flight or harboring her outside of the jurisdiction of this Court. This should satisfy the Court's concern that the proposed bond was not fully secured and left assets unrestrained that could be used for such purposes. (See id. at 17-18). + +In addition, since the last bail application, Ms. Maxwell has submitted twelve pretrial motions that raise substantial legal and factual issues that may result in the dismissal of some or all of the charges against her. Ms. Maxwell referenced some of these motions in her initial bail application (see Dkt. 18 at 19) but was not in a position to fully articulate them until she had the chance to review the discovery and research the legal issues in advance of the motion deadline of January 25. These motions significantly call into question the strength of the government's case against Ms. Maxwell and the underlying justification for continued detention. + +Ms. Maxwell has already been denied a fair chance in the court of public opinion. She has been maligned by the media, which has perpetuated a false narrative about her that has poisoned any open-mindedness and impartiality of a potential jury. She has been relentlessly attacked with vicious slurs, persistent lies, and blatant inaccuracies by spokespeople who have neither met nor spoken to her. She has been depicted as a cartoon-character villain in an attempt to turn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined and welcomes the opportunity — to face her accusers at trial and clear her name. The additional proposed bail conditions should quell any concerns that she would try to flee. The Court should therefore grant bail under the proposed conditions so that Ms. Maxwell can adequately prepare for trial. + +#### The Proposed Additional Bail Conditions Will Reasonably Assure Nis. \ la kV% CH'S Appearance in Court + +As set forth above, Ms. Maxwell now proposes two additional restrictions that eliminate any means or opportunity that she may have to leave the country. The Court should therefore reconsider its earlier ruling and grant bail under the proposed conditions. See United States v. Rowe, No. 02 CR. 756 LMM, 2003 WL 21196846, at \*1 (S.D.N.Y. May 21, 2003) ("[A] release order may be reconsidered even where the evidence proffered on reconsideration was known to the movant at the time of the original hearing."); see also United States v. Petrov, No. I 5-CR-66- LTS, 2015 WL 11022886, at \*3 (S.D.N.Y. Mar. 26, 2015) (noting "Court's inherent authority for reconsideration of the Court's previous bail decision"). + +# A. Renunciation of Foreign Citizenship + +To demonstrate her commitment to abide by her conditions of release and to provide further assurance to the Court that she will not attempt to leave the country, Ms. Maxwell is willing to formally renounce her foreign citizenships in France and the United Kingdom. Should the Court feel this drastic condition is necessary, the required documents will be submitted to the appropriate authorities. Moreover, as a standard condition of bail, all of Ms. Maxwell's passports will be surrendered to the government and no further application will be made. + +If the Court deems it a necessary condition of release, Ms. Maxwell will formally commence the procedure to renounce her foreign citizenship. The requisite paperwork is in the process of being completed. Renunciation of UK citizenship can be accomplished immediately upon granting of bail. The process of renouncing her French citizenship, while not immediate, may be expedited. + +Citizenship is a precious and priceless asset. Ms. Maxwell's decision to give up citizenship from the county of her birth and the country of her upbringing demonstrates her earnestness to abide by the conditions of her release and underscores that she has no intention to flee and reflects her deep need to communicate freely with counsel to prepare for her defense. Her renunciation of foreign citizenship obviates the Court's concerns about the validity of waivers of extradition. (See Dkt. 106 at 13). Ms. Maxwell will have no ability to contest extradition from France or the United Kingdom on the basis of citizenship, which removes any incentive the Court and government believe she may have to seek refuge in those countries. + +# B. Restraint and Monitoring of Assets + +In denying bail, the Court noted that the bond was not fully secured, and that Ms. Maxwell and her spouse would still have several million dollars in unrestrained assets that could be used to facilitate her flight from the country. (See id. at 17-18). To assuage any concerns that those assets would be available to finance flight to and shelter in a foreign country, Ms. Maxwell has taken steps to create a monitorship that will place meaningful restraints on the assets that are not used to secure the bond, while still allowing Ms. Maxwell to pay for her legal defense, for her spouse to pay for daily living expenditures and for payment of taxes. + +# 1. New Account + +All assets of Ms. Maxwell and her spouse, with the exception of money currently held in escrow for legal fees and related defense expenses and the funds contained in the bank account in the name of Ms. Maxwell's spouse ("the Personal Account")', will be deposited in a newly created account ("the New Account") to be overseen by an asset monitor appointed pursuant to order of the Court. The New Account will contain all of Ms. Maxwell's and her spouse's remaining cash and other liquid assets, including any proceeds that result from the pending sale + +1The Personal Account is identified as Account Ion page 9 of the Financial Report annexed to Ms. Maxwell's Renewed Bail Application. (See Dkt. 97, Exhibit 0.) + +of Ms. Maxwell's London house and any other assets, excluding salary, hereinafter acquired. The asset manager will approve the financial institution at which the New Account is created and must approve and co-sign any expenditure from the New Account, with the exception of disbursements for Ms. Maxwell's legal fees in connection with the ongoing criminal and civil litigation and for payment of taxes, which will not require authorization. No illiquid assets may be sold, conveyed or transferred without approval of the asset monitor. + +#### 2. Other Assets + +The only funds that will not be included in the New Account are (I) the money currently held in escrow by Ms. Maxwell's attorneys, which will be used exclusively for her defense; and (2) the roughly \$450,000 in the Personal Account which her spouse will use only for living expenses. The asset monitor shall regularly receive information regarding activity of the Personal Account, including the account balance, on a weekly basis. The asset monitor must also receive five-day advance notice of any check, on-line payment, or transfer of finds in any amount exceeding \$5,000, and the reason for such payment. Ms. Maxwell's spouse agrees to be bound by these restrictions and reporting requirements. + +The asset monitor shall report to Pretrial Services any possible non-compliance or disbursement in violation of the terms and conditions specified above. + +# 3. Selected Asset Monitor + +The Honorable William S. Duffey, Jr., a retired federal District Court judge and the former United States Attorney for the Northern District of Georgia, has agreed to undertake the position of asset monitor. (Judge Duffey's bio is attached as Exhibit A.) Judge Duffey has extensive experience evaluating and monitoring funds held in and disbursed from financial + +accounts and will be entrusted with the authority to oversee the assets of Ms. Maxwell and her spouse, as described above. + +Restraining Ms. Maxwell's assets that are not used to secure the bond and placing them under the supervision of a former federal District Court judge eliminates any concern that such funds could be used to violate the terms of release. + +#### IL Ms. Maxwell's Pretrial Motions Raise Substantial Legal and Factual Issues That Could Result in Dismissal of Some or All of the Charges Against Her + +In addition to the new conditions proposed above, the numerous substantive pretrial motions now before the Court amply challenge the purported strength of the government's case. Ms. Maxwell's pretrial motions raise serious legal issues that could result in dismissal of charges, if not the entire indictment. Among the dozen submissions are motions to dismiss the superseding indictment for breach of the non-prosecution agreement, for pre-indictment delay, and for being based on improperly obtained evidence in violation of Ms. Maxwell's constitutional rights under the Fifth and Sixth the Amendments. Other motions seek dismissal of the Mann Act charges as being time-barred and the perjury charges as based on non-perjurious statements. These motions are substantial with a likelihood of success on the merits. These motions cast substantial doubt on the alleged strength of the government's case and warrant granting bail on the conditions proposed. + +## III. The Court Should Grant Bail + +Under the Bail Reform Act of 1984, a defendant must be released on personal recognizance or unsecured personal bond unless the judicial officer determines "that such release will not reasonably assure the appearance of the person as required or will endanger the safety of any other person or the community." 18 U.S.C. § 3142(b). The enhanced bail package proposed by Ms. Maxwell contains financial burdens and a combination of restrictions that reasonably + +assure her appearance as required. Before preventive detention may be ordered under § 3142(e), the Court is obliged to determine both whether the defendant is likely to flee the jurisdiction if released, and whether any conditions of release will be reasonably certain to guard against this propensity to flee. The Court expressed concerns and denied bail without indicating what conditions would be reasonably certain to assure Ms. Maxwell's appearance. Ms. Maxwell is no danger to the community and not alleged to have been involved in ongoing criminal activity. To say that there are absolutely no conditions flies in the face of cases where non-United States citizens with no ties to the district, let alone the country, were released on lesser conditions for alleged criminality ongoing up to or within hours of the time of arrest, in contrast to 26-year-old claims alleged against Ms. Maxwell.' + +The additional conditions set forth above, which supplement the exceptional bail package previously proposed, are sufficient to address the hypothetical risk of flight and secure Ms. Maxwell's presence at trial. The financial magnitude of the proposed bonds, the collateral pledged to secure the bonds, the stringent requirements of home detention, the renunciation of foreign citizenship and monitoring of assets contained in a special account from which no funds can be withdrawn without the approval and signature of a retired federal District Court judge and former United States Attorney are conditions that amply satisfy the concerns expressed by the government and the Court. These cnditions are unique and unprecedented. They profoundly + +2 See Dkt. 97 at 34 (case-comparison chart in the Renewed Motion for Bail); cf. People v. Dominique Strauss-Kahn, 02526/201 I(S.Ct. N.Y. County). Strauss-Kahn, a French citizen with no ties to the United States, was arrested on a Paris-bound flight at JFK minutes before takeoff and later charged with several counts of sexual assault, including felony charges punishable up to 25 years imprisonment, for sexual assault and attempted rape of a Manhattan hotel housekeeper on the day of his arrest. The accusations were corroborated by semen containing Strauss-Kahn's DNA on the accuser's uniform. The New York State Supreme Court granted bail in the amount of \$ I million cash, 24 hour home detention electronic monitoring ankle bracelet, and private 24/7 security guards. After surrendering his French passport and posting an additional \$5 million bail bond, Strauss-Kahn was placed under house arrest in a residence in Manhattan. See https://www.theguardian.comAvorld/20 Ill may/20/dominiquc-strauss-kahn-ncw-yorkapartment. + +affirm Ms. Maxwell's earnestness in seeking bail to properly prepare her defense, not to flee. + +The Court should grant bail to Ghislaine Maxwell. + +### CONCLUSION + +The proposed additional conditions of release—renunciation of foreign citizenship and restraint and monitoring of assets by a retired District Court judge—enhance the already extraordinarily restrictive bail conditions proposed in Ms. Maxwell's Renewed Motion for Bail. + +In combination, these conditions satisfy the Bail Reform Act and reasonably assure Ms. + +Maxwell's appearance at trial. To deny Ms. Maxwell bail when such extraordinary and restrictive conditions are available would be a miscarriage of justice. + +Dated: February 23, 2021 + +Respectfully submitted, + +goat C. Sitagn. + +Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 + +Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 + +Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 \ No newline at end of file diff --git a/marker2/ds9/EFTA00083790/EFTA00083790.metadata.json b/marker2/ds9/EFTA00083790/EFTA00083790.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5022416289e2d3fc00c80d145cb595085f25c0e2 --- /dev/null +++ b/marker2/ds9/EFTA00083790/EFTA00083790.metadata.json @@ -0,0 +1,615 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083790.pdf", + "engine": { + "marker_major": "2", + "marker_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": 16023, + "elapsed_seconds": 1.26, + "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 + ], + [ + 281.7991943359375, + 71.28 + ], + [ + 281.7991943359375, + 99.7330322265625 + ], + [ + 68.544, + 99.7330322265625 + ] + ] + }, + { + "title": "MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S \nTHIRD MOTION FOR RELEASE ON BAIL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 133.416, + 345.87 + ], + [ + 479.59716796875, + 345.87 + ], + [ + 479.59716796875, + 375.7330322265625 + ], + [ + 133.416, + 375.7330322265625 + ] + ] + }, + { + "title": "INTRODUCTION", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 255.204, + 96.38999999999999 + ], + [ + 356.9654541015625, + 96.38999999999999 + ], + [ + 356.9654541015625, + 111.9735107421875 + ], + [ + 255.204, + 111.9735107421875 + ] + ] + }, + { + "title": "The Proposed Additional Bail Conditions Will Reasonably Assure Nis. \\ la kV% CH'S \nAppearance in Court", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 525.708, + 71.28 + ], + [ + 525.708, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + }, + { + "title": "A. 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Other Assets", + "heading_level": null, + "page_id": 5, + "polygon": [ + [ + 105.26399999999998, + 236.51999999999998 + ], + [ + 213.21560668945312, + 236.51999999999998 + ], + [ + 213.21560668945312, + 251.853515625 + ], + [ + 105.26399999999998, + 251.853515625 + ] + ] + }, + { + "title": "3. Selected Asset Monitor", + "heading_level": null, + "page_id": 5, + "polygon": [ + [ + 105.26399999999998, + 539.46 + ], + [ + 265.3486328125, + 539.46 + ], + [ + 265.3486328125, + 555.6035614013672 + ], + [ + 105.26399999999998, + 555.6035614013672 + ] + ] + }, + { + "title": "IL Ms. Maxwell's Pretrial Motions Raise Substantial Legal and Factual Issues \nThat Could Result in Dismissal of Some or All of the Charges Against Her", + "heading_level": null, + "page_id": 6, + "polygon": [ + [ + 68.544, + 208.17000000000002 + ], + [ + 492.6166076660156, + 208.17000000000002 + ], + [ + 492.6166076660156, + 237.603515625 + ], + [ + 68.544, + 237.603515625 + ] + ] + }, + { + "title": "III. 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Present via video was EVA's attorney . Also present via video was Assistant United States Attorneys , and , along with Detective and Special Agent + +The above listed individuals met over video conference with EVA and her counsel to introduce EVA to the team that was investigating the captioned case. EVA expressed her memory of experiences that happened a long time ago was not the best. EVA expressed her willingcess to cooperate with the investigation and to meet on another date dcd time to be interviewed. + +limmtgammon 31/22/2321 m Now York, Now York, Unttod Stator. G Other Illtdoo)) + +This document contains neither recommendations nor conclusions or the FBI. 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Present via video was Assistant United States Attorneys and , along with Detective and Special Agent + +The above listed individuals met over video conference with to introduce to the team that was investigating the captioned case. was suggested to obtain counsel. When announced that counsel was expensive, she was advised she could obtain court appointed counsel. spontaneously stated she had never seen "them" do anything but she thought JEFFREY EPSTEIN went a little crazy. + +kmmtgammon 02/01/2021 m New York, Now York, Unttod Stator. G Other Illtdoo)) + +This document contains neither recommendations nor conclusions or the FBI. 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Also present for this interview was s attorney Tamara Giwa. After being advised of the identity of the above listed individuals and the nature of the interview, provided the following information: + +is from, and currently lives in California. When she was about 28 years old (in 1996) she moved to New man and she moved to be with him. When through an employment agency. York. At the time she was dating a she arrived she looked for work learned of this employment agency through a newspaper ad. Through this agency she was connected with JEFFREY EPSTEIN. gets hired and works for EPSTEIN She worked for them the entire time before she goes back to sometime around the summer of 2002. noted that it for 6 years. California, was after 9/11. + +After finished high school she attended in and worked in fashion in Los Angeles. She wanted to continue York but worked as an executive assistant instead. Los Angeles fashion in New + +first interviewed at the employment agency and then was sent to "JE EPSTEIN". The job was assistant to the legal counsel. During.the interview she met with two lawyers. was then sent to GHISLAINE MAXWELL and then sent to EPSTEIN. After this got the job. + +For the MAXWELL interview, waited for her in the office. The receptionist tells to go downstairs to do the interview in the town car because MAXWELL was rushed. They drove around while she was being interviewed and then was dropped back at the office to be interviewed by EPSTEIN. + +MAXWELL was the office manager of 457 Madison Avenue at the time as + +Investigammon 13/28/2323 File# 5CD-NY-3C27571 Now York, Now York, Untted Stator, Other Illtdoo at Conference)) Date drafted 02/02/2021 + +This document contains neither recommendations nor conclusions of the FBI. It is the moony of the FBI and is loaned to your agency; it and its contents am not to he distributed outside your agency. + +ComthwdionofFD-302of (U) Interview of 10/28/2020 ,page 2 of 7 + +IIIIIIIII understood. MAXWELL conducts a basic interview asking about 's experience and asked if her relationship didn't work out would she stay in New York. + +For the interview conducted by EPSTEIN, was tired from waiting all day. It was a short interview and she was hired the next day. + +Her job responsibilities were paper filing for the attorneys and sending faxes. reported to JEFF SCHANTZ for about the first 6 months. + +MAXWELL's assistant called in sick one day and stepped in to help MAXWELL out that day. The assistant's name was MIRIAM; she was French. After this, MAXWELL picked up as her permanent assistant. then worked at 457 Madison for both MAXWELL and the lawyers. + +would have to deal with lots of phone calls working for MAXWELL. She would connect MAXWELL with others, kind of like an operator. Each morning, MAXWELL would tell a list of things to do such as booking appointments, phone calls and purchasing books. EPSTEIN had just purchased the island which had much to do with helping making calls for it. ostly dealt with MAXWELL for this but sometimes EPSTEIN. + +states there was another assistant 1 street address and they also had "runners" to pick up purchases. does not recall their names. + +During the time was working for MAXWELL, she believed MAXWELL's roll was an estate manager. She would prep the properties. When MAXWELL was in the office she was like an office manager but she got her direction from EPSTEIN. At one point EPSTEIN and MAXWELL were a couple. understood that because they would sometimes arrive together or it would be obvious that they spent the weekend together. They acted like a couple in the office. + +'s first impression of MAXWELL was that she liked her. She was someone that could look up to. She was pretty, spoke 5 languages, charismatic, a wealthy woman. She had lots of needs and was retty demanding. It was a very busy job and very fast paced. was constantly dealing with furnishing of the different properties, credit card receipts, auctioning and purchases. The island was the main project because + +Continuation of FD-302 of ( U ) Interview of ,On 10/28/2020 m g, 3 of 7 + +EPSTEIN bought it and started it from scratch. would prepare the properties such as house stuff, cleaning, making sure bagels were there and making sure it was stocked with jelly and bread. + +They tried to have all properties ready by Thursday so when EPSTEIN traveled on the weekends all of the properties were ready. MAXWELL and EPSTEIN traveled a lot together during this time period. MAXWELL also traveled separately sometimes. + +'s first impressions of EPSTEIN were that he was casual for someone with that much money. He would wear slippers and sweatshirts. He was not too personable and not really friendly. EPSTEIN would come into the office, usually on a daily basis when he was in New York. There was almost never small talk between and EPSTEIN. + +would connect MAXWELL on phone calls with her mother, brothers and mostly friends. She would also make calls for facials, hair and doctor appointments. never went to other EPSTEIN properties. She went to the house on 71st street a few times. At the house she would meet RICH BARNETT (security) and (the house keeper). went on a tour there. + +was hired by "Epstein & Co.". That was the name on her checks at first. The new names on her checks would either be "Epstein Investments", "NES" or "Financial Strate Group". Over time, her salary did not reall increase that much. did not receive gifts. They would fly to California on occasion to see her family. EPSTEIN gave MM tickets to see The Lion King on Broadway with her husband. would get a bonus at Christmas time. + +was asked about the rules with MAXWELL. she signed a non-disclosure not to talk to media or press. states that + +MAXWELL stopped coming into the office shortly before left the job. She had known that MAXWELL had started dating another man towards the end. was still reporting to her around this time. had started working out of MAXWELL's home towards the end (the 65t street townhouse). This only happened about 1-2 times. While there, 's responsibilities didn't change much. The employees had a separate entrance to the office which was on the ground floor. + +Continuation of FD-302 of (U) Interview of 10/28/2020 ,Pas, 4 of 7 + +was not really involved with organizing the travel for MAXWELL and EPSTEIN; MAXWELL and the pilots would organize that. It would be very rare for to be in communication with the pilots. Just in terms of wheels up, would speak to the ilot LARRY VISOSKI or EPSTEIN's driver JOJO. VISOSKI would tell the wheels up time so that would tell JOJO what time to pick them up in the car. Sometimes MAXWELL would call about wheels up. MAXWELL had a separate driver. + +The people handling house stuff was a husband (driver) and a wife (GIRLIE) who was a maid. IGOR was another driver for MAXWELL. would talk with MAXWELL's drivers about wheels up and down. Typically, MAXWELL and EPSTEIN only traveled to one of his homes. Weather had a lot to do with where they would travel. did not discuss with them who was going on these trips. Either MAXWELL or EPSTEIN would coordinate other aspects of their travel. + +Sometimes MAXWELL would fly commercially. She would either stay behind or go a day early. They traveled with other people. Sometimes people would hop rides with EPSTEIN. EPSTEIN's assistant may have had more to do with these arrangements. has booked commercial flights for other people such as (an assistant to MAXWELL), family members and other employees. + +did not recall who gave her the non-disclosure agreement; she was not sure if it was MAXWELL or the attorneys or someone else. did not remember having a discussion about it. + +recalled the travel agency she used was "Shopper's Travel". They were located in New York. For the most part they were used for commercial flights. Sometimes they were used for mileage points. knew there were other agencies used, but this was the one she remembered. + +would hear directly from MAXWELL about travel. + +ecalled EPSTEIN's receptionists listed below: + +- MICHELLE HEALY was there when first started. +- was there when ESPINOSA left from what she remembered. + +recalled EPSTEIN's assistants listed below: + +Continuation of FD-302 of ( U ) Interview of a 10/28/2020 page 5 of 7 + +- It +- MAURENE, whose last name did not recall. +- SUE ANN, whose last name id not recall. +- LESLEY GROFF was there when left. + +and LESLEY were on a friendly level as they socialized outside of the office. They were friends who talked about their personal lives. + +If MAXWELL wanted to talk with EPSTEIN, would have to ask where he was and where she should call. + +and LESLEY would talk about what to order for lunch and would coordinate on some things. Both LESLEY and did similar jobs. did not talk with LESLEY about the work they did. + +LESLEY's role was to "bridge the line" and connect EPSTEIN to those he wanted to talk with. LESLEY was a message taker who made appointments and phone calls. LESLEY had common office assistant duties. + +was MAXWELL's assistant. did not recall the timeline of when came around. traveled with MAXWELL. pers ssistant, which was different from assistant. also walked MAXWELL's dog. When MAXWELL came into the office, came into the office with her. also worked out of MAXWELL's house. A lot of the time, MAXWELL and were together. was more of a being an executive was more of a "purse carrier" and personal assistant who + +There were other assistants MAXWELL employed but could not recall their names; there was a lot coming and going. was not always introduced to them. + +was asked if she heard about EPSTEIN donating money and she replied yes. was not sure where she heard this. came to know EPSTEIN as a generous person who donated to charities, science, and the arts. recalled Interlochen and Juilliard. Interlochen was a a place EPSTEIN went or had an office there or donated an office in his name. This was in the beginning stages of working there. + +was asked if she was aware of EPSTEIN and/or MAXWELL traveling to Interlochen and she did not recall anything specific. + +for a visit; she was visiting LESLEY. extra cash and she thought she was paid. did recall seeing EPSTEIN around 2004/2005 when she went back worked in the office for would have been paid in cash because she technically was not employed with them. + +Continuation of FD-302 of ( U ) Interview of on 10/28/2020 ipage 6 of 7 + +interest to EPSTEIN; there were friend's daughters and/or sons that went there. + +was asked if she knew of young people in EPSTEIN and MAXWELL's orbit and she replied that she considered herself young at 28 years old. never saw anyone who looked younger than herself, other than They were "all virtually the same age". + +was asked if she had interaction with EPSTEIN and MAXWELL outside of the office and she replied that it was close to zero. Maybe on occasion she interacted with them outside the office, but her interactions were mostly in the office. + +Looking back, did not notice anything odd. Knowing what she knows from the media, "it's shocking" to + +left EPSTEIN's employ around 2002. had been considering going back to California for a while. When told MAXWELL she was going back to California, MAXWELL was upset she was leaving. left on good terms. + +was paid around \$50,000 a year; she did not feel that she was overpaid. There were perks in working for EPSTEIN. EPSTEIN paid for her to have a physical trainer. had found her own trainer and he paid for the trainer. EPSTEIN paid for her hair cut every once in a while. EPSTEIN always had the best lunch/food; he had a chef bring food, especially if he was working in the office. was there when EPSTEIN hired ADAM PERRY LANG; she did not recall if there was a chef before him. + +In or around 2007/2008, California. was dating at the time not get the job. get the job because it had a job interview with MAXWELL in was interviewing to work for TED WAITT, who MAXWELL It was a project manager position. did thought MAXWELL had said it was ok she did not was labor intensive. + +Continuation of FD-302 of ( U ) Interview of a 10/28/2020 , page 7 of 7 + +has been approached at her home, employer's office, via her cell phone by CBS, ABC, and other media. does not take the calls. has not given other statements outside of this interview. \ No newline at end of file diff --git a/marker2/ds9/EFTA00083803/EFTA00083803.metadata.json b/marker2/ds9/EFTA00083803/EFTA00083803.metadata.json new file mode 100644 index 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Also present for this interview was LOUTHAN's attorneys Jay Musoff and Brandon Zamudio. After being advised of the identity of the above listed individuals and the nature of the interview, LOUTHAN provided the following information: + +LOUTHAN grew up in Scotland. He went to high school at "Millfield" school which was located in Somerset (south of England). LOUTHAN did not attend college. LOUTHAN started working as a PA in New York in 1979. He then moved on to work in production management and now works as a producer. He has a home in Hollywood but spends lots of time in Europe. He is currently in Los Angeles. + +LOUTHAN first met SH:SLAiNE MAXWELL at Millfield school in the early to mid-1970's. LOUTHAN WaS not that close with her but he knew of her. She was well known because of her status and she would often have helicopters pick her up from school. LOUTHAN left for New York after finishing school and didn't have contact with her for many years after that. + +He began to know her socially at some point by seeing her at events. They would say hello to each other and joke about school. LOUTHAN did not have much knowledge of the details of her life at this time. This was around late 2001. + +During the summer of 2016, MAXWELL reached out to LOUTHAN. LOUTHAN had been dating someone that MAXWELL knew named . MAXWELL asked LOUTHAN about and if she was involved with EPSTEIN. This call was about and was not about LOUTHAN. MAXWELL wanted to know if she was involved with an investigation or with EPSTEIN. MAXWELL asked LOUTHAN to talk to about it. LOUTHAN dodged this cuestion. He tells + +New York, New York, Untted States I, Other (Video Invesugammon 31/14/2321 at Conference)) + +This document contains neither recommendations nor conclusions of the FBI. It is the moony of the 1:B1 and is loaned to your agency; it and its contents am not to be distributed outside your agency. + +Continuation of FD-302 of (U) Interview of GUY LOUTHAN o, 01/14/2021 " cc 2 of 2 + +MAXWELL that he no longer is dating and he doesn't know anything about that situation. MAXWELL asks LOUTHAN to reach out to .. + +This phone call was a blast from the past for LOUTHAN and he was shocked that MAXWELL called him. It was unusual for MAXWELL to call him. LOUTHAN felt that maybe EPSTEIN was in trouble again and that's why MAXWELL was calling him. + +Sometime after this call LOUTHAN calls to tell her that MAXWELL called him. was shocked and told LOUTHAN not to talk to her. LOUTHAN does not think he ever spoke to MAXWELL after this. + +LOUTHAN started dating in the summer of 2015. He had already known her for about 3-5 years prior to that. He would see her out and about but every time he would see her she was always dating someone else. He was originally introduced to her by friends. They dated for about a year or less. LOUTHAN and still talk regularly. + +LOUTHAN had known that knew MAXWELL and EPSTEIN but they really didn't discuss them. She was clear that she did not like MAXWELL or EPSTEIN but they did not go into details on why. It was 's tone that would let LOUTHAN know she did not like them. If their names came up, would turn white and sometimes stammer. never told LOUTHAN how she met MAXWELL. LOUTHAN knew they met a while back and possibly in London. + +LOUTHAN wasn't entirely aware there was a case but he knew that something was going on. At the time, LOUTHAN thought that EPSTEIN had been acquitted. had given LOUTHAN very few details of this case. She was sensitive about it so LOUTHAN did not talk about it. has not really talked about any detail regarding her and EPSTEIN and MAXWELL. + +After receiving a phone call from Detective , LOUTHAN called tells LOUTHAN that she's involved in the EPSTEIN case and she herself had given an interview and that LOUTHAN can mention her name. + +MAXWELL may have introduced LOUTHAN to EPSTEIN briefly on one occasion at an event in London in the early 2O00's. 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After being advised of the identity of the interviewing Agents and the nature of the interview, CALLOWAY provided the following information: + +CALLOWAY is currently living in. Scotch Plains New Jersey. He works for Sysco food distributor. CALLOWAY went to culinary school and used to be a chef. + +CALLOWAY was employed by jEFFREY EPSTEIN from about the winter of 2006 to January/ February 2009. He got the job through a head hunter that he knew. At some point he meets GHISLAINE MAXWELL at her house and she asks him some food questions. At some point CALLOWAY goes to EPSTEIN's office. EPSTEIN conducts a short interview and asks about his background. He asks CALLOWAY what would he make if the girls got fat. CALLOWAY states that he would make healthy food. He says that he figured EPSTEIN was talking about his daughters. Shortly thereafter CALLOWAY gets the job. + +Prior to these meetings, CALLOWAY had never met either EPSTEIN or MAXWELL. To CALLOWAY's knowledge he was replacing the previous chef who left for family reasons. + +MAXWELL and interviewed CALLOWAY. CALLOWAY did a tasting menu for MAXWELL and at 9 East 71 street. CALLOWAY was working in New York City at the time. EPSTEIN interviewed CALLOWAY alone. + +CALLOWAY's job responsibilities included being in charge of grocery shopping and making lunches and dinners. CALLOWAY would leave the meals in the fridge for the maid and the driver (LYN and JOJO). CALLOWAY was told there would be travel involved with the job. When. EPSTEIN was in town CALLOWAY would arrive at the house around 6:30-7:03 AM to prepare the food. + +Now York, Now York, Untted Stator, Other Illtdoo Investigation on 39/13/2323 at Conference)) + +This document contains neither recommendations nor conclusions of the FBI. It is the moony of the FBI 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 LANCE CALLOWAY .On 09/10/2020 ,page 2 of 4 + +When CALLOWAY was on the island he was on call the whole time. CALLOWAY went to the ranch twice but didn't really work there. CALLOWAY went to Paris once. CALLOWAY never went to West Palm Beach. CALLOWAY would prepare snacks for the plane. + +In New York City CALLOWAY would normally spend a few hours inside the house. Most of the food prep that CALLOWAY would do would be in the basement kitchen. He would then bring the food up to the first floor kitchen. CALLOWAY would not hang in the front with RICHARD the property manager. + +EPSTEIN would have a lot of visitors. In retrospect there was a lot of females coming through. They looked to be 18 or in their early 20's. CALLOWAY would have no interaction with them. CALLOWAY would stay to himself. EPSTEIN would have visitors in the morning. Then around 11:00 AM, JOJO would drive EPSTEIN to his office. At that point CALLOWAY would leave. + +IGOR would be there but mostly in the gym. + +At the island CALLOWAY replaced CATHY and MILES ALEXANDER because they went back to South Africa. After about a year CALLOWAY took over as island manager. While there, he would prepare food for and MAXWELL and sometimes other girls that he did not know. + +While on the plane, CALLOWAY would mainly hang out in the cockpit area. The foods that he prepared were generally self-served. CALLOWAY states that he did not see anything abnormal on the plane. + +ADAM PERRY LANE used to be a chef for EPSTEIN. + +While CALLOWAY was living on the island he learned that there was an investigation into EPSTEIN. He then started looking for a new job in New Jersey. He eventually left. + +DARREN INDYKE (EPSTEIN's attorney) told CALLOWAY that if someone approaches him with something to not accept it because he could be getting served. + +CATHY and MILES ALEXANDER may have told CALLOWAY why EPSTEIN was getting investigated but he was not sure. EPSTEIN was very polite to CALLOWAY. He + +Continuation of FD-302 of RD Interview of LANCE CALLOWAY a 09/10/2020 page 3 of 4 + +only got upset with him once over a meal. + +It was an unwritten rule that CALL WAY was to stay out of sight. KATHY may have told this to CALLOWAY, but and JOJO may have also. + +CALLOWAY did not have many dealings with MAXWELL. He did one dinner for her at her house. She would travel to the island a handful of times. She called CALLOWAY and yelled at him once. + +would text CALLOWAY when to go to the island. + +CALLOWAY would have to go to DARREN INDYKE or RICH for the big purchases. CALLOWAY would mostly go to EPSTEIN for assignments. + +It was an unwritten rule to take care of and EPSTEIN. + +CALLOWAY spent a lot of time with IGOR. + +CALLOWAY would stay with the pilots mostly on the plane in the cockpit. + +told CALLOWAY that she was from North Carolina. That's about how in depth they got in conversation. + +IGOR, the body guard and personal trainer, was very friendly. He stayed in the gym for most of the day in New York City. + +CALLOWAY thinks that about 3a of his way through working for EPSTEIN he learned of the investigation. This was approximately around 2008. CALLOWAY stayed on the island for a bit while EPSTEIN was away. + +CALLOWAY had no other conversations or instructions about the investigation and who not to talk to. CALLOWAY is not sure how he found out what EPSTEIN was in trouble for. He may have found out from the news. + +BRICE and may have come to the island to explain what was going on. CALLOWAY was to take pictures of the island and email EPSTEIN while he was away. + +CALLOWAY eventually finds a job in New Jersey while EPSTEIN was still in jail. CALLOWAY gave his notice to BRICE. He is told to leave the island almost right away. EPSTEIN calls CALLOWAY and is upset. CALLOWAY never speaks to EPSTEIN again. + +Continuation of FD-302 of RD Interview of LANCE CALLOWAY a 09/10/2020 mg, 4 of 4 + +Sometime later CALLOWAY texted MAXWELL one time by accident. CALLOWAY texted with the pilots. Eventually he stops all communication with them. + +The Daily Mail showed up at CALLOWAY's house recently when EPSTEIN got arrested and again when MAXWELL was arrested. CALLOWAY has had no other law enforcement contact or civil contact. + +and JOJO would take care of the guests. + +On the island about every hour EPSTEIN would take a girl down to his master bedroom. 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After being advised of the identity of the interviewing Agents and the nature of the interview, provided the following information: + +met EPSTEIN at 17 years old. She recalls it was 2002 and it was warm. out. She was asked to give him dance inspired work cuts which morphed into massages in her underwear. This happened about 3-6 times for the first few years. These morphed into sexual arrangements. He controlled a lot of her life. EPSTEIN asked that not go to college and make different career choices. He kept her from. going back to school. He asked to introduce him. to other friends of hers. + +The first meeting of EPSTEIN started when was coming out of ballet class in New York "Steps on Broadway". Someone asked if she wanted to give EPSTEIN dance inspired work outs. does not recall this person's name but she was tall, blonde and pretty. + +goes to EPSTEIN's house about the next day. She talked with the woman who gave her directions to his house. She meets them at the house. There was a cleaning staff and doorman at the house. met PRINCE ANDREW and a brunette there. She waited in the lobby area. EPSTEIN either met her downstairs or in the gym. No one else was in the gym. It was just a flirtatious work out at first. He asks for to come back the next day and pays her \$100. + +is not sure if they exchanged numbers. The original woman she dealt with may have handled that. Additional meetings were scheduled by either EPSTEIN or his assistants. His assistant's name was . After the first 1-2 sessions with EPSTEIN they turned into massage sessions. The + +:mem:gam:cm 12/15/2020 at New York, New York, Untted States (Phone) + +This document contains neither recommendations nor conclusions or the FBI. It is the property of the FIlland 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 12/15/2020 ins 2 of 2 + +sexual activities started between the 2 -4th session. + +saw EPSTEIN around 2010 after he got out of jail. The first 3-4 years she saw him a lot. After that it slowed down to less than once a month. During the massage it would range anywhere from masturbation to penetration. EPSTEIN always wanted to know what was doing with dance and her professional life. They would talk about . Then in the massage room things heated up. He would tell what to do. Then he would push her around to get him to do what he wanted to do. He would continue to pay The girl would call and say \$100 for massage with clothes on and \$300 for massage with clothes off. + +Sometimes EPSTEIN would pay more if she was well behaved. He paid for auditions. He would pay directly for these auditions. He would send to hair salons and to get clothes. + +Sometimes there were other girls in the room. Once there was a girl named who was a tall blonde. This was his "main + +A number of different people called but she does not know the names. + +EPSTEIN asked her to go to Paris which she did not. EPSTEIN sent to London and Florida for auditions. She did not see him in Florida. His driver may have picked her up. EPSTEIN was trying to court a friend of at the time. The driver may have been following them around while they were down in Florida. saw him at a distance a few times. + +turned 18 on . She was born in Sexual encounters with EPSTEIN happened prior January 2004. + +IIIIII met JEAN-LUC, FREDRICK PACKIE and PRINCE ANDREW. She also met other unknown persons. She met (the she spoke about earlier), LESLIE, BELLA and a little blonde South African girl. does not know their ages. + +At the time first met EPSTEIN she had just moved to New York with no money. 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Also present via video was Assistant United States Attorney , Detective and Special Agent . After being advised of the identities of the above listed individuals and the nature of the interview, provided the following information: + +was born in Manhattan. She grew up in the upper east side of Manhattan and finished her associates degree. She currently cuts hair for a living and lives in + +met JEFFRE.Y EPSTEIN when she was in high school. She came back from boarding school and met a girl named who introduced her to EPSTEIN. This was around her senior year 2003-2004. At the time was attending Evangel Christian. Private High School. was going with another girl named tells that she goes to an older guy to give him. a massage . He may or may not and that would be it. + +went to EPSTEIN's residence about 9 times between 2004 and 2005 and stopped going before she finished high school. + +The first time she went she recalls going in with thinks was there in the massage room. EPSTEIN was lying down and on the phone. They all started to massage him and then they left alone. EPSTEIN then . He says "you can get your money". EPSTEIN walks out. gets money from his house lady, a Filipino woman. + +then waited for a call because gave them her phone number. LESLEY or the house lady would call. met LESLEY. She would call the majority of the times. She would say "EPSTEIN wants to see you, can you coma". + +On one occasion told LESLEY she couldn't go because she had to stay after school and couldn't come before 5 PM. LESLEY says to let her know if she can leave early. LESLEY never asked how old was. + +After the first visit would go by herself or with or + +New York, New York, Untted States (, Other (Video Invesugammon 13/39/2323 m conference)) + +This document contains neither recommendations nor conclusions of the FBI. It is the moony of the 1:B1 and is loaned to your agency; it and its contents am not to be distributed outside your agency. + +Continuation of FD-302 of (U) Interview of ,o, 10/09/2020 mg, 2 of 3 + +with a friend + +When went with she had left early that day. She took the bus home with to do a project. They went to mother's apartment and dropped off their stuff then went to EPSTEIN's. came to the house but did not go into the massage room. + +recalls bringing a childhood friend of hers named once. Someone had suggested to to bring a friend. EPSTEIN asked to bring more people. He asked for girls age or younger. had told EPSTEIN that she was 16 years old when she first met him. EPSTEIN's cleaning lady knew age and knew what school she went to and knew when she was graduating. She knew when she got out of school. All the girls were the same age. started to see EPSTEIN but not with + +LESLIE asked on the phone if her friend her and how old she was. They were interested in to ask about had said to young girls. was in school with . LESLEY called that he wants + +went there about 9 times and it was generally the same thing each time. It was a massage and EPSTEIN would and Sometimes he would get more physical depending on his mood. For example he would jump off the table, come behind and When he was done he usually just got up and walked out. The money would always come from the cleaning lady. She got paid \$200. She may have gotten paid \$300-\$350 when she brought + +felt like it was a competition for money between her friends. They would sometimes get calls to come separately. + +EPSTEIN gave a purse as a gift once. The gift was given to by the cleaning lady. sells the purse around the holiday time. never received anything else from EPSTEIN. + +had a nokia phone back then. Her phone number may have been\_ • + +No other persons were ever in the massage room other than friends. never discussed what happened in the massage room with either LESLEY or the cleaning lady. + +EPSTEIN's house was on either on 71 street or 73 street near 5th Avenue near the park. never saw EPSTEIN outside of his house. + +Continuation of FD-302 of ( U ) Interview of .on 10/09/2020 m g, 3 of 3 + +blonde hair. said "that's Ghislaine". was invited to a dinner party at EPSTEIN's house. She was told it would be a fun foot party. couldn't go and didn't talk personal details. + +Photos were never taken of + +The second time see's MAXWELL at the house she just said hello. + +partner is the reason why she stopped seeing EPSTEIN. She had told him that she was massaging an older guy . He said that he does not want her seeing this man anymore. recalls that she started seeing EPSTEIN around when she was 16-17 years old. At 18 she had stopped seeing him. + +For about a month or two they called to ask to come back. She ignored the phone calls. + +never talked to law enforcement about EPSTEIN. + +told a few classmates pieces of what she was doing with EPSTEIN but never the whole truth. + +About two years after seeing EPSTEIN, tells her mother about what happened. + +never talked to reporters about EPSTEIN. + +told that EPSTEIN was mean to her one time. + +started going to the island with EPSTEIN which finds out later. \ No newline at end of file diff --git a/marker2/ds9/EFTA00083818/EFTA00083818.metadata.json b/marker2/ds9/EFTA00083818/EFTA00083818.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5c180b283c8343ea00917568892c4200baaeadf7 --- /dev/null +++ b/marker2/ds9/EFTA00083818/EFTA00083818.metadata.json @@ -0,0 +1,160 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083818.pdf", + "engine": { + "marker_major": "2", + "marker_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": 5182, + "elapsed_seconds": 1.1, + "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 + ], + [ + 387.4266357421875, + 49.41 + ], + [ + 387.4266357421875, + 62.10113525390625 + ], + [ + 189.108, + 62.10113525390625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 90 + ], + [ + "Line", + 42 + ], + [ + "Text", + 14 + ], + [ + "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", + 93 + ], + [ + "Line", + 45 + ], + [ + "Text", + 13 + ], + [ + "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", + 52 + ], + [ + "Line", + 25 + ], + [ + "Text", + 13 + ], + [ + "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/EFTA00083818" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083818/_page_0_Picture_3.jpeg b/marker2/ds9/EFTA00083818/_page_0_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..eace184d80c073ccabb2162c04a04a827ddec2bb --- /dev/null +++ b/marker2/ds9/EFTA00083818/_page_0_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:71164f70af7f35f6591e3219400de8560fdc8a7890dd90185c6d4422080af07f +size 4312 diff --git a/marker2/ds9/EFTA00083821/EFTA00083821.md b/marker2/ds9/EFTA00083821/EFTA00083821.md new file mode 100644 index 0000000000000000000000000000000000000000..6bba4caf00b12f6a11a07cf9414b48998d8fcb0e --- /dev/null +++ b/marker2/ds9/EFTA00083821/EFTA00083821.md @@ -0,0 +1,11 @@ +![](_page_0_Picture_3.jpeg) + +Dmeoremm 02/23/202: + +EVA DUBIN was given an introductory meet with the case team over video conference. present via Present via video was EVA's attorney video was Assistant United States Attorneys , and , along with Detective Special Agent Also and + +The above listed individuals met over video conference with EVA and her counsel to introduce EVA to the team that was investigating the captioned case. EVA expressed her memory of experiences that happened a long time ago was not the best. EVA expressed her willingcess to cooperate with the investigation and to meet on another date ecd time to be interviewed. + +Investigation on 31 /22/2321 m New York, New York, United States I, Other Illtdeo)) + +This document contains neither recommendations nor conclusions Mille FBI. 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Present via video was Assistant United States Attorneys and , along with Detective and Special Agent + +The above listed individuals met over video conference with to introduce to the team that was investigating the captioned case. was suggested to obtain counsel. When announced that counsel was expensive, she was advised she could obtain court appointed counsel. spontaneously stated she had never seen "them" do anything but she thought JEFFREY EPSTEIN went a little crazy. + +Invesugammon 02/01/2021 at New York, New York, United States I, Other Illtdeo)) + +This document contains neither mommendations nor conclusions or the FBI. 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I did not mean to imply that you leaked anything. I am sure you did not. But from the information leaked, it is apparent that someone at the facility did. Please include the source of the leak in your investigation. + +Bruce A. Barket, Esq. + +Barket Epstein Kearon Aldea & LoTurco, LLP + +666 Old Country Road , Ste. 700 + +Garden City, NY 11530 + +(516) 745 1500 [P1 (516) 745 1245 [F] + +www.barketepstein.com + +This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, please notify us immediately by telephone or email and immediately delete this message and all its attachments + +From: (si rr a: + +Sent: Thursday, July 25, 2019 9:50 AM + +To: Bruce Barket + +Cc: + +Subject: Re: Fwd: Jeffrey Epstein/Nicholas Tartaglione + +Good morning Bruce, + +Please be advised that this matter is currently the subject of an open investigation, and, thus, I am limited in what I can discuss at this time. I have not shared any information with the press or the public, and I am not aware of any other MCC staff doing so either. As this is an open investigation, no information can be shared with outside parties until the investigation is complete. Once the investigation is concluded, I will be able to provide you more information. + +I have reminded MCC administrators to caution staff that they are not to retaliate against your client or any inmate. Please let me know if you have any further questions or concerns. + +Thank you, + +>> > Bruce Barket > 7/24/2019 11:30 PM >> > + +This comes on the heels of our complaints to the Court. It seems someone in your facility has leaked false information about Nick. + +Garden City, NY 11530 + +Begin forwarded message: + +From: Tracy Connor + +Date: July 24, 2019 at 11:08:48 PM EDT + +To: + +Subject: Jeffrey Epstein/Nicholas Tartaglione + +Hello, + +Trying to co ' story that says your client was questioned about a possible attack on Jeffrey Epstein at the MCC. I'm a . Can you call? + +Tracy Connor + +Executive editor + +Join Beast Inside, our new membership program, to get more of the journalism you trust and love. \ No newline at end of file diff --git a/marker2/ds9/EFTA00083824/EFTA00083824.metadata.json b/marker2/ds9/EFTA00083824/EFTA00083824.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a61297c0a3e2f0a1d61826b3d471b24918ee387a --- /dev/null +++ b/marker2/ds9/EFTA00083824/EFTA00083824.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083824.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2617, + "elapsed_seconds": 1.3, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 87 + ], + [ + "Line", + 39 + ], + [ + "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", + 33 + ], + [ + "Line", + 15 + ], + [ + "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/EFTA00083824" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083826/EFTA00083826.md b/marker2/ds9/EFTA00083826/EFTA00083826.md new file mode 100644 index 0000000000000000000000000000000000000000..b7bb874c7f65aa75aacfda57358d69ae332d6413 --- /dev/null +++ b/marker2/ds9/EFTA00083826/EFTA00083826.md @@ -0,0 +1,75 @@ +From: + +To: "Bloom, Suzanne Jaffe" + +Cc: "Hud ens, Johanna Rae". M b' + +Subject: RE: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to + +Date: Wed, 24 Jul 2019 18:32:25 +0000 + +Attachments: 2019-07-09,\_presentment.pdf 2019-07-09,\_initial\_conference.pdf; 2019-07- 15,\_bail\_hearing.pdf + +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, + +Ori inal Messa e + +From: + +Sent: Tuesday, July 23, 2019 14:55 + +To: Bloom, Suzanne Jaffe + +Cc: Hud ens Johanna Rae ; alMIN>; + +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 yo ext week. Given our continued discussions, and the possibility of a voluntary interview wit e 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 aa- + +Sent: Monday. July 22.2019 12:32 + +To: + +Cc: Hudgens, Johanna Rae + +Subject: SDNY Grand Jury Subpoena Dated July 5, 2019 issued ti + +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. + +We look forward to hearing back from you regarding the above. Many thanks. + +Best, Suzanne + +Suzanne Jaffe Bloom + +Partner + +Winston & Strawn LLP + +200 Park Avenuecx-apple-data-detectors://0/1> 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. 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. \ No newline at end of file diff --git a/marker2/ds9/EFTA00083826/EFTA00083826.metadata.json b/marker2/ds9/EFTA00083826/EFTA00083826.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..eb601fb714cd2f17a414985a249178759de740c9 --- /dev/null +++ b/marker2/ds9/EFTA00083826/EFTA00083826.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083826.pdf", + "engine": { + "marker_major": "2", + "marker_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": 4569, + "elapsed_seconds": 1.11, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 39 + ], + [ + "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", + 64 + ], + [ + "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/EFTA00083826" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083828/EFTA00083828.md b/marker2/ds9/EFTA00083828/EFTA00083828.md new file mode 100644 index 0000000000000000000000000000000000000000..be679062f04be7f9ec5356a6cf215e4dc6e524c6 --- /dev/null +++ b/marker2/ds9/EFTA00083828/EFTA00083828.md @@ -0,0 +1,1013 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x + +4 JEFFREY EPSTEIN, + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +UNITED STATES OF AMERICA, + +v. + +Defendant. + +Before: + +x + +New York, N.Y. + +19 Cr. 490(RMB) + +Conference + +July 8, 2019 1:20 p.m. + +HON. HENRY B. PITMAN, + +APPEARANCES + +GEOFFREY S. BERMAN United States Attorney for the Southern District of New York + +BY: es Attorneys + +STEPTOE & JOHNSON, LLP Attorneys for Defendant BY: REID H. WEINGARTEN + +MARTIN G. WEINBERG Attorney for Defendant + +MARC FERNICH Attorney for Defendant + +Also Present: + +Special Agent Detective FBI , NYPD + +Magistrate Judge + +4 5 6 7 MR. : Good afternoon, your Honor. For the government, , and With us are Special Agent of the F.B.I. and Detective , NYPD task force officer. + +8 THE COURT: Okay. + +9 10 11 MR. WEINGARTEN: Good afternoon, your Honor. For Jeffrey Epstein, Reid Weingarten from the law firm of Steptoe & Johnson. + +12 13 14 15 MR. WEINBERG: Good afternoon, your Honor. Martin Weinberg. I'm an attorney from Boston, Massachusetts; and, with your Honor's permission, I will be filing a pro hac vice to represent Mr. Epstein. + +16 THE COURT: Okay. + +17 18 MR. FERNICH: Good afternoon, your Honor. Marc Fernich, New York, New York, also for Mr. Epstein. + +19 20 21 THE COURT: All right. I have spoken to Judge Berman. The matter has been referred to me for the initial appearance, arraignment, and bail. + +22 23 24 25 Mr. Epstein, my name is Magistrate Judge Pitman. The purpose of this proceeding is to inform you of certain rights that you have, to inform you of the charges against you, to consider whether counsel should be appointed for you, and to + +(Case called) + +THE DEPUTY CLERK: Counsel, please state your name for the record. + +4 MR. : Yes, your Honor. The defendant was arrested on Saturday, July 6, at approximately 5:30 p.m. + +5 THE COURT: Thank you. + +6 7 8 9 10 Mr. Epstein, you have the right to remain silent. You are not required to make any statements. Even if you have made any statements to the authorities, you need not make any further statements. Anything you do say can be used against you. + +11 12 13 14 15 You have the right to be released, either conditionally or unconditionally, pending trial unless I find that there are no conditions or combination of conditions that would reasonably assure your presence in court and the safety of the community. + +16 17 18 19 You have the right to be represented by counsel during all court proceedings, including this one, and during all questioning by the authorities. If you cannot afford an attorney, I will appoint one to represent you. + +20 21 22 23 24 25 It is my understanding that you are being represented by retained counsel. I want to advise you that the right to the appointment of counsel is an ongoing right that you possess throughout these proceedings. If at any time you are unable to continue with retained counsel for financial reasons, you can apply to the court at any time for the appointment of counsel. + +decide under what conditions, if any, you should be released. + +Can I have the date and time of arrest, please? + +4 THE COURT: Mr. Epstein, you are charged in an indictment in two counts. + +5 6 Count One charges you with a sex trafficking conspiracy in violation of Title 18 United States Code § 371. + +7 8 9 Count Two charges with you with the substantive offense of sex trafficking in violation of Title 18 United States Code § 1591. + +10 11 Mr. Weingarten, are you going to be lead counsel here today? + +12 MR. WEINGARTEN: Yes, your Honor. + +13 14 THE COURT: Mr. Weingarten, have you received a copy of the indictment? + +15 MR. WEINGARTEN: Yes, your Honor. + +16 THE COURT: Have you reviewed it with your client? + +17 MR. WEINGARTEN: Yes, your Honor. + +18 THE COURT: Do you waive its reading? + +19 MR. WEINGARTEN: Yes, your Honor. + +20 THE COURT: Mr. Epstein, how do you plead? + +21 THE DEFENDANT: Not guilty, your Honor. + +22 23 24 25 THE COURT: Because the defendant has been indicted, there will be no preliminary hearing, and that takes us to the question of bail. In that regard, I have received the Pretrial Services report. I have also received a letter from the + +Do you understand that? + +THE DEFENDANT: Yes, your Honor. + +4 5 THE COURT: I will hear from the government first, and then I will hear from defense counsel. + +6 MR. : Yes, your Honor. + +7 8 9 The government intends to seek detention, and I am happy to explain the reasons why. Would the court prefer that i speak from the table or from the podium? + +10 THE COURT: Whatever your pleasure is. + +11 12 13 14 15 16 17 MR. : Your Honor, the defendant poses an extraordinary risk of flight and danger presented by him. Given the charges and the characteristics of the defendant, he simply cannot reasonably be expected to appear in court if he is granted bail. Accordingly, the government joins the recommendation of Pretrial Services that the defendant be detained pending trial for a number of reasons. + +18 19 20 21 22 Starting with the conduct alleged, the defendant is charged with trafficking minors for sex acts, as the court explained, in violation of 18 United States Code E. 591, and is charged with a count of conspiracy to traffic minors for sex acts in violation of 18 U.S.C. 371. + +23 24 25 In particular, the indictment charges that the defendant engaged in a years-long scheme to sexually abuse underage girls, paying minor girls to themselves be abused, and + +government dated July 8, 2019. + +I take it all counsel have the same documents? + +MR. WEINGARTEN: Yes, your Honor. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +also paying certain victims to recruit other girls to be subject to the defendant's sexual abuse. + +The indictment alleges that the defendant undertook this conduct at at least two locations, including his mansion in Manhattan and his estate in Palm Beach, Florida. In both locations, 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 contact with the victims' genitals. These victims, who were often particularly vulnerable, were as as 14, and the defendant knew he was abusing underage girls. The indictment further alleges that the defendant perpetrated these crimes by working with others, including employees and associates who facilitated these abusive encounters. + +Regarding the defendant himself, your Honor, he is extraordinarily wealthy, mobile, and unattached to the Southern District of New York. He maintains at least six residences in the United States and abroad, including the ownership of a private island in the U.S. Virgin Islands and a residence in Paris, France. Among other things, the defendant owns two private jets and routinely uses them to travel abroad. He is a man of nearly infinite means, your Honor; and, as set forth in our submission, he has tremendous incentives to use those means to flee prosecution. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +The government notes as an initial matter that this is a presumption case because sex trafficking is charged; and, moreover, each of the four factors to be considered in the detention analysis strongly militates towards pretrial detention. + +So starting with the nature and seriousness of the offense, as previously discussed, the nature and circumstances of the crime are the most serious crime that this court sees. The defendant is alleged to have spent years sexually abusing minors in multiple locations and with dozens of victims. + +The seriousness of the charge is also reflected in the potential penalties, which include up to 45 combined years of incarceration on Counts One and Two, and the likelihood of a substantial period of incarceration is supported by the fact that the government's evidence is strong. There are multiple individual identified victims in the indictment, numerous specified overt acts, and dozens of overall victims alleged. + +In order to protect the privacy of the victims, your Honor, I'm not going to go into detail about particular victims, but we can say that information provided by victims has been detailed, it has been credible, and it has been corroborated by other witnesses and contemporaneous documents and records, including from a recent search of the defendant's Manhattan mansion, as I will discuss further in a moment. + +Separately, your Honor, in just the last 36 hours, + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +that is, post charge, we have been contacted by multiple attorneys and several additional individuals who have identified themselves as victims and are interested in speaking with the government, none of whom the government has previously spoken with. + +Your Honor, the defendant is 66 years old. He is charged with appalling crimes, and those charges are supported by significant evidence, including victim and witness testimony and damning record evidence. He faces the very real prospect of spending the rest of his life in prison. He has every motivation in the world to flee, and he has the means to do it. + +And I will note for the court that this is a case where the government has really put its money where its mouth is on the risk of flight. This district took extraordinary efforts to maintain the covert status of its investigation for many months due to the risk of flight of the defendant -- not a single media report, not a single public statement, no appeals for victims to come forward because of precisely the flight risks we are discussing now. + +Turning to the characteristics of the defendant, your Honor, some individuals who face significant charges lack the means to flee. Not this defendant. As set forth in the government's submission, in the defendant's most recent sex offender registration, he lists six residences worth tens or hundreds of millions of dollars, including a residence abroad. + +4 5 6 7 8 9 10 11 12 13 14 The defendant has refused to answer any questions about his income or assets for the Pretrial Services report, so the scope of his wealth and his assets remains entirely concealed to the government and to the court. But the defendant certainly has access to endless means to flee, including two private jets. He has no meaningful family ties, and any argument that his properties would keep him in the United States ignores his ability to simply leave those properties behind in favor of moving beyond the reach of U.S. authorities to live off his extensive wealth abroad, extensive wealth, I should add, that the court doesn't even have any accounting of. He travels abroad extensively, has a residence in France, and all of those factors further contribute to the risk of flight. + +15 16 17 18 19 20 21 With respect to danger and obstruction, again, this is a presumption case, and not only is the defendant charged with the sexual abuse of minors, he has previously pled guilty to solicitation of an underage girl. This court knows that defendants are routinely detained in this district when facing such charges and that this is not an unusual position for the government to take. + +22 23 24 25 It is further concerning that there are credible allegations from the prior investigation that the defendant or his agents engaged in witness tampering and harassment, and in fact there is evidence that he was contemplating pleading + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +guilty to that kind of offense in Florida. Those allegations include verbal harassment, evasion of legal process, and forcing off the road the father of an individual relevant to that investigation. + +THE COURT: Can you elaborate on that last point about forcing somebody off the road? + +MR. : Your Honor, what we have is the record evidence from an underlying civil dispute in Florida that discusses this incident and discusses it in the context of a potential plea of the defendant to obstruction or harassment charges. The government sets before this court that if the defendant was willing to undertake such measure simply as a result of an investigation, the potential for dangerous and obstructive activity in an indicted case is alarming and very real. + +Despite having been previously convicted of a sex offense involving an underage victim and being a registered sex offender, the defendant has continued to maintain a vast trove of lewd photography of -looking women or girls at his mansion. Your Honor, pursuant to judicially authorized warrants, law enforcement agents searched his home on Saturday and found at least hundreds, and perhaps thousands, of sexually suggestive photographs of nude females, many of whom appear to be underage. + +I also want to note that the search revealed specific + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +evidence from his home consistent with victim accounts. Ever the room where the abuse occurred, your Honor, the massage room, was still set up in the same way it was 15 years ago, with a massage table and sex paraphernalia. + +And with respect to the photographs + +THE COURT: When you say the evidence was consistent with victim accounts, is it limited to the massage table and massage room or is there something else? + +MR. : Descriptions of the massage room and the massage table, that's correct, your Honor. + +THE COURT: Okay. All right. + +MR. : With respect to the photographs, your Honor, some of those were found in a locked safe which also held electronic disks with labels that included the words Miscellaneous Nudes 1" and "Girl Pics Nude." + +Your Honor, this is not an individual who has left his past behind. He is a continuing danger to the community and an extraordinary risk of flight and, for those reasons, the government joins the pretrial recommendation that the defendant be detained pending trial. + +THE COURT: All right. Thank you. + +Mr. Weingarten. + +MR. WEINGARTEN: Thank you, your Honor. I will use the podium, if that's okay. + +THE COURT: That's fine. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +MR. WEINGARTEN: So your Honor, I would like to start by providing some context, and then I'm going to make a suggestion as to how we proceed. + +The beginning here is 2005 in Florida. That's when an allegation was received by the local police that Mr. Epstein was engaged in sexual conduct for money, prostitution. Thereafter, there was a very sophisticated three-year investigation by law enforcement, including locals and feds, into Mr. Epstein's conduct. Numerous girls were interviewed, employees were interviewed, and it is fair to say that a significant segment of the law enforcement community in Florida thought what we had in hand was simple prostitution. There was no coercion. There were no threats. There was no violence. And it is also fair to say that a significant portion of the law enforcement community in Florida believed that a local misdemeanor was the appropriate sanction. + +Now, it is also -- + +THE COURT: Did you represent Mr. Epstein in the Florida investigation? + +MR. WEINGARTEN: No, but I'm familiar with the records. + +THE COURT: All right. + +MR. WEINGARTEN: It is also true that there was a contrary view largely taken by the feds, and what ensued was a complex set of discussions and negotiations and finally an + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +agreement, an agreement that was consummated and agreed to all the way up to main justice at a very, very high level. + +The agreement involved a plea in state court to soliciting an underaged girl, which would require registration, compensation paid to alleged victims, and an NPA from the feds, in other words, a declination by the federal government, an agreement that was approved all the way up in main justice and it sure seemed like a global solution at the time to everyone involved, including my client. + +What happened since then? Mr. Epstein continued a life of success, generosity, creativity and, more important, a law-abiding life from 2008 forward. How do we know? Because when you are in registration the way he is, every single night his whereabouts are known. There is constant reporting, constant monitoring, and absolutely, to our knowledge, no complaints by anybody from that moment forward about his conduct until we have arrived in court here. + +Now, what has happened in court from that moment? There have been lawsuits, many of them ludicrous, dismissed out of hand. But when something like this happens, a lot of stuff comes out of the woodwork, and there were lawsuits that Mr. Epstein settled also in the normal course. + +There was one particular litigation that leads to this occasion, and that is, under the Crime Victims Rights Act, that act simply says that victims have a right to be consulted by + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +the United States, and there are alleged victims in this case who complain that they were not, and there has been extensive litigation in the Southern District of Florida before Judge Marra on that very subject. In fact, the judge concluded that the prosecutors from the Southern District of Florida did not adequately notify some of the victims about the ongoing discussions and the consummation of the deal and, in particular, the NPA. The United States took the position that they had no responsibility to do so, that they had treated the victims properly, and that matter continues to this day. + +The consequences of that matter are overwhelming, because the judge suggested, I think three times, that the NPA, the declination, could be voided. And we think about that for a second. So a defendant negotiates what he thinks is a global solution with the feds. He does his time -- + +THE COURT: Does the nonprosecution agreement in Florida -- the nonprosecution agreements in the Southern District routinely say they are limited to the Southern District of New York. + +MR. WEINGARTEN: Obviously -- + +THE COURT: Is there a similar provision in the Florida agreement? + +MR. WEINGARTEN: I don't want to misstate. It is not before me. It is obviously going to be an important part of the pretrial motions. What is for sure is that there was - + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +the negotiation with the Southern District included negotiations with main justice. What's also true is the investigation extended into the Southern District of New York and elsewhere in terms of girls being interviewed. + +So obviously your question is relevant and will be part of the pretrial litigation for sure. But what matters here and for now is there certainly was a belief that there was a global solution based upon the facts on the ground. + +THE COURT: Have you seen the Florida nonprosecution agreement? + +MR. WEINGARTEN: Yes. + +THE COURT: And -- + +MR. WEINGARTEN: I don't have it before me. I don't want to make a specific representation and not be completely accurate. + +THE COURT: Okay. All right. Go ahead. + +MR. WEINGARTEN: The consequences of this are huge in that if in fact there is a negotiation with a defendant, the defendant does his time, the defendant pays his victim, and the defendant spends ten years on the registration list and prosecutors don't adequately notify the victims, how in the world can that deal be undone? Every prosecutor in the world has to oppose that possibility. No defense attorney in their right mind would negotiate a deal with that potential consequence. + +So this is a huge problem for the department and what 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 solution ensues, and I suggest the solution that ensued is this indictment. To us, this indictment is essentially a do-over. The allegations are from 2002 to 2005. This is old stuff. This is ancient stuff. This is the very stuff that was investigated by the feds in Florida, a sophisticated three-year investigation. Two of the alleged victims in this indictment are from Florida. The indictment here tracks the conduct that was investigated in Florida back before the agreement was reached. Obviously we need to get discovery to find out just how inextricably linked the investigation back in Florida is with what's going on here. We do know we are talking about ancient conduct. We do know we are talking about facts that are from 2002 to 2005, facts that were known to the United States prosecutors before they entered into the NPA, the declination. This is essentially a redo. That's how it feels to us. And if we are correct, that should chill the blood of every defense attorney who negotiates a deal with the United States. + +20 21 22 23 24 25 In addition, we have the central allegation here is trafficking, and obviously it is useful and relevant to make inquiry as to why the trafficking law was passed. It is to cover abhorrent conduct, where girls are kidnapped, they are fooled, they are forced to come usually to unfamiliar places, work in brothels where they service 15, 20 guys in a + +4 5 6 7 I remember an occasion when the Attorney General Eric Holder and I think Director Comey had a press conference establishing this as a law enforcement priority. Every sensible person in the world would think that this is the exact right thing law enforcement should do. + +8 9 10 11 12 13 14 This is not this case. There was no violence. There was no coercion. There was no intimidation. There is no deception. The bottom line, if you take a fair look at the facts of this case as alleged and in the record, you may come to the conclusion there was prostitution involved and maybe a lot of it, but that doesn't mean that the person involved is pedophile, a rapist or, heaven knows, a trafficker. Just -- + +15 16 THE COURT: Well, if the women involved were under 18, isn't that rape? + +17 MR. WEINGARTEN: My understanding -- + +18 19 THE COURT: Legally they are incapable of consent, are they not? + +20 MR. WEINGARTEN: Well, it could be statutory rape. + +21 22 23 24 But what I am talking about is trafficking and why the statute was passed, and obviously the statute was passed to protect women from the horrors that occur in such settings, and that is light years removed to what happened in this case. + +25 So what about bond? I would suggest that the + +day. They can't leave or else their families are threatened. This is dreadful conduct. + +traditional issues that we look at, the issues involved, let's start with that, we believe we have extremely powerful motions relating to the government seeking two bites at the apple and for due process reasons, double jeopardy reasons, we don't think that will stand. We also think fundamentally what's at issue here is not trafficking. That's not why the statute was passed. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +The risk to others, what we have here is at least ten years post incarceration in the State of Florida of conduct that has never been challenged by anyone until now. The registration requirements are onerous. He is under constant surveillance. Law enforcement knows, if they choose to look, exactly where he is at any time. + +The risk of flight, what is true is from the moment of Judge Marra's litigation in the Southern District of Florida, the defendant knew that there would be challenges to the NPA. From 2013 on, there were representations made in court that that challenge was ongoing, and the defendant never sought to flee, never anticipated a time when he would flee, continued to live his law-abiding life. So the risk of flight, I think, is dramatically overstated in the government's presentation. + +I think the traditional remedies that the court finds appropriate in case after case -- a large cash bond; passport relinquished; waiving extradition; a bracelet on; some form of supervision that is adequate to guarantee his appearance, it + +4 5 6 7 Because we have not had an opportunity to see our client until today and because we have just received the government's submission, what we would like to do is have the opportunity to sit down and put together a bail package, a coherent bail package in writing and provide it to the court. + +8 I would point out on the obstruction allegation + +9 10 11 THE COURT: Let me ask you this -- sorry to interrupt you -- do you want to adjourn the detention hearing? Under the statute, you have up to three days. + +12 13 14 MR. WEINGARTEN: What I would like is to have until the end of the week to provide something in writing, a specific recommendation in writing. + +15 16 THE COURT: So you want to adjourn a determination of bail? + +17 MR. WEINGARTEN: Yes. + +18 19 20 THE COURT: Is there any objection to that from the government? The defendant is detained in the interim under 3142(f). + +21 MR. WEINGARTEN: Right. + +22 23 24 MR. : Your Honor, we certainly don't object if the defendant is consenting to detention with leave to make a further application. + +25 I think the government would like at least a brief + +will be child's play to find that; bonds from other people, surety bonds from other people. + +opportunity to respond to some of those points, to the extent that the defense is arguing that Mr. Epstein should be granted bail as a general matter and the court is going to consider those arguments. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +THE COURT: Well, the court always considers the parties' arguments. + +But let me just come back to Mr. Weingarten for a minute. Mr. Weingarten, under the Bail Reform Act you are entitled to a continuance of three days, which I guess would take us to Thursday. + +MR. WEINGARTEN: Right. + +THE COURT: The other alternative, I guess, if you want to de facto extend that three days is consent to detention without prejudice. + +MR. WEINGARTEN: We estimated that by Thursday we could get you something in writing and then appear back before you at your convenience. + +THE COURT: Okay. Do you want to schedule it -- well, I think Thursday's proceedings right now would be in front of Judge Berman unless he wants to send it back to me for bail, but do you want to put this down for detention hearing on Thursday? + +MR. WEINGARTEN: Can I make one point that I don't want to forget that I think is extremely important? + +THE COURT: Go ahead. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +MR. WEINGARTEN: The last thing we did today was refuse to answer questions. What we said at Pretrial is heaven forbid we make a mistake, and in terms of assets, we wanted to be precise. So there was no refusal. There was a request for time to supplement. That was accepted. And that's part of the reason we want to sit down and make sure we get our information correct to provide to the court. + +THE COURT: All right. + +MR. WEINGARTEN: Can I make one other point? + +THE COURT: Sure. + +MR. WEINGARTEN: In terms of the obstruction, I think it is such a significant part of our argument that the conduct at issue is ancient. It is from 2002 to 2005. So obviously if the defendant is a threat to obstruct justice, the court needs to take that into account. The allegations raised -- and I just read them briefly because we just got the government's letter -- relate to negotiations between the feds and the defendant. Back when the Southern District of Florida was attempting to find an appropriate remedy, there were discussions going back and forth: Can we squeeze you into this statute? And it didn't work, and it didn't work because there is no factual basis. That is the reference to the alleged obstruction. Not obstructive acts. Instead, the feds in Florida agreed to the plea to the state offense because there was no appropriate statute that covered conduct that was + +4 MR. WEINGARTEN: Yes. + +5 6 7 THE COURT: All right. Is there any objection to that from the government? I think under the statute he is entitled to three days. + +8 MR. : That is, of course, fine, your Honor. + +9 10 11 I think we would like just a very brief opportunity to respond to some of those arguments so that they don't sort of hang with the court for three days unresponded to. + +12 THE COURT: All right. Go ahead. + +13 14 15 MR. : Just very briefly, your Honor, I think a lot of that discussion was entirely orthogonal to the issues here. + +16 17 18 19 But just very briefly, with respect to the charges here, there is simply no force required for underage victims. A grand jury has properly returned an indictment, and these are fact issues that are being presented in large part. + +20 21 22 23 24 25 Certainly the concept of child prostitution is, frankly, offensive and not recognized in federal law. The idea that children can consent to sex and be prostitutes is beyond the realm of federal law which contemplates trafficking, which is what has been charged here. Mr. Weingarten is free to argue to a jury that trafficking minors was only statutory rape or + +proveable. That is the answer to the obstruction issue. + +THE COURT: All right. So you want to adjourn the detention hearing until Thursday? + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +that those victims weren't treated as badly as the parade of horribles he has in mind. But for now the question is whether the defendant's attendance can be assured. + +And with respect to the nonprosecution agreement + +THE COURT: I'm not sure I would refer to something as only statutory rape. The use of the word "only" before "statutory rape" I'm not sure sits well. But go ahead. + +MR. : And I agree, your Honor. + +With respect to the actual substance, the Southern District of Florida has represented in public filings that the nonprosecution agreement was limited to the Southern District of Florida, and we can litigate that in a motion to dismiss, but it is simply not relevant here. + +With respect to the statute of limitations, Mr. Weingarten says that the conduct is old. He did not say that that it is beyond the statute of limitations because it is not. + +And, finally, it is not the same conduct. Some of the conduct overlaps. Some of the conduct does not. And in particular, one of the two counts of the indictment is predicated exclusively on New York victims. + +So for all of those reasons, we just ask the court to consider those responses as it awaits the defendant's filings later this week. + +MR. WEINGARTEN: Can I just make one point to clarify? + +4 + +5 THE COURT: All right. + +6 + +7 + +8 + +9 10 11 The defendant is detained at least until the continuation of the detention hearing pursuant to 18 United States Code 3142(f). + +12 13 14 I have been advised by Judge Berman that he wants to see counsel right after these proceedings. Judge Berman's courtroom is 17B. So counsel and Mr. Epstein should go to 178. + +15 All right. Anything else from the government? + +16 17 18 MR. : Your Honor, ordinarily we would ask to exclude speedy trial time, but I think because we are going directly to Judge Berman, we have no such application. + +19 THE COURT: Mr. Weingarten, anything else? + +20 MR. WEINGARTEN: No, thank you, your Honor. + +21 THE COURT: Mr. Weingarten, anything else? + +22 MR. WEINGARTEN: No, your Honor. + +23 THE COURT: All right. Thank you all. + +24 oOo + +25 + +THE COURT: Go ahead. + +MR. WEINGARTEN: On the statutory rape thing, I had t senior moment. There is no statutory rape because there is no penetration, and that is the answer to that question. + +We will set this down for a detention hearing on Thursday, July 11, for the continuation of the detention hearing. 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Conference + +9 Before: + +10 11 HON. RICHARD M. BERMAN District Judge + +12 + +13 + +14 + +15 16 GEOFFREY S. BERMAN United States Attorney for the Southern District of New York + +17 + +18 Assistant United States Attorneys + +19 20 21 REID H. WEINGARTEN MARTIN G. WEINBERG MARC FERNICH Attorneys for Defendant + +22 Also Present: + +23 24 25 - Special Agent FBI - NYPD KEYANA POMPEY - Probation Officer LEA HARMON - Probation Officer + +x New York, N.Y. July 8, 2019 2:00 p.m. + +APPEARANCES + +2 THE COURT: Good afternoon. + +3 4 5 6 7 I think I'm pretty much up to speed as to where you are in the sense that I am aware that you have been before Magistrate Judge Pitman earlier this morning and up to some few minutes ago for purposes of presentment, arraignment, and some preliminary discussion of bail. Is that accurate? + +9 10 11 12 13 MR. : That's correct, your Honor. I don't want to speak for defense counsel, but my understanding is they expect to put in some sort of written submission and return to argue the rest of the bail hearing on Thursday before Judge Pitman at 2:00. That is, if your Honor refers the bail hearing to Judge Pitman on that basis as well. + +14 15 16 THE COURT: I might just take that bail application before me. We'll figure out a time when that would be comfortable for all of you. How is that? + +17 18 MR. WEINGARTEN: That's fine with the government, your Honor. + +19 20 21 22 23 24 25 THE COURT: I have a few items on my list. I want to make mention, I'm sure Magistrate Judge Pitman did, of our presumption of innocence. Even though in some of these discussions, and probably more so when we get to bail, it may sound like we are talking about merits of the case, it's important that we underscore that the presumption of innocence pertains to Mr. Epstein, now and until such time, if it comes, + +1 2 that there is a guilty determination by a jury or by the Court, that he is presumed to be innocent. + +3 4 5 6 7 I did have these questions. One has to do with persons who are categorized as victims. I want to get some assurance from the U.S. Attorney's office that they have been notified about this case and that you will keep them abreast of developments in this case. + +9 10 11 MR. : Yes, your Honor, we are acutely aware of our obligations to the victims in this case. We have notified them and we expect to continue to do so as the case moves forward. + +12 13 14 15 16 17 18 THE COURT: Second, for my background, I am aware that there are certain conditions that attach to Mr. Epstein's sex offender status resulting from his Florida state prosecution in or about 2008. One result is that under New York law - correct me if I'm wrong about any of this -- he is considered to be at high risk of committing another sex crime with minors. Is that a fair characterization of his sex offender status? + +19 20 21 22 23 MR. : Your Honor, as the government set forth in its submission to Judge Pitman, and we copied this Court, it is our understanding that the defendant is a tier 3 sex offender in New York and that that is characterized as high-risk individual. + +24 25 THE COURT: The question that I have is what are the implications, if any, of the search conducted by the U.S. + +1 2 3 4 5 Attorney's office over the weekend of Mr. Epstein's residence on East 71st Street for the terms and conditions of his sex offender status, if any? Are there any consequences or relationship between what was uncovered and what he is obliged to do? + +6 MR. : May I have one moment, your Honor? + +7 THE COURT: Yes. + +8 9 10 11 12 13 14 15 16 MR. : Your Honor, in response to that question, at the outset I should say that we don't have particular interaction with state authorities with respect to those types of notifications. We are, I would say, in the early stages of reviewing those materials. With respect to the defendant's obligations or potential consequences in the New York State system, we certainly will notify whichever authorities are appropriate. I don't think that we have a role other than that. + +17 18 19 20 I will say that they are extremely concerning with respect to bail here, with respect to the conduct here, and expect we will get into that more in our submissions and bail argument. + +21 22 THE COURT: By the way, if defense counsel wants to jump in at any point, feel free to do that? + +23 24 MR. WEINGARTEN: On that, we have not seen the pictures. + +25 THE COURT: I haven't either. + +1 2 3 4 MR. WEINGARTEN: I understand. It is our expectation that they are ancient, that they are pre his spending time in prison, and/or they are erotic pictures of adults who voluntarily engaged in that conduct. + +5 6 7 THE COURT: I have a question about the Southern District of Florida nonprosecution agreement dated probably in 2008 -- is that correct? + +9 THE COURT: Is that a public document? + +10 11 MR. WEINGARTEN: It is, your Honor. It's been publicly filed in connection with other civil litigation. + +12 13 14 THE COURT: Does that agreement bear on in any way the search and results of the search that were conducted at Mr. Epstein's townhouse over the weekend? + +15 16 17 18 MR. : Not in ways that I am aware of now, your Honor. Again, we are very much in progress on the search. We will continue to consider any other implications beyond this case as we continue to review those materials. + +19 20 21 22 23 24 25 On a separate note, your Honor, I want to add the government noted it is aware of its victim obligations. In terms of notification, we have made notification to individuals that we are in particular aware of. We also have listed a phone number for victims to be in touch with the FBI, with the U.S. Attorney's office. We have also put a website up and have asked victims to be in touch with us through those sources as + +MR. : It's dated in 2007, your Honor. + +1 well. That is just to round out the notification that the U.S. 2 Attorney's office has made. + +3 MR. WEINGARTEN: May I be heard briefly on that? + +4 THE COURT: Sure. + +5 MR. WEINGARTEN: For us, your Honor, the NPA is the 6 center of the universe for everything, search included, because 7 the NPA was the result of an extensive 3-year investigation by 8 law enforcement in Florida. In essence, the Feds made Mr. 9 Epstein plead to a state offense and they declined prosecution 10 federally, and that is translated in the NPA. Mr. Epstein did 11 his time, Mr. Epstein is on the registration list, and Mr. 12 Epstein paid the alleged victims. + +13 As I am sure you have noted from the indictment, that 14 conduct too is an ancient history. That conduct is 2002 to 15 2005. It is our belief that this is basically a re-do. This 16 is basically the Feds today, not happy with what happened in 17 the decision that led to the NPA, redoing the same conduct that 18 was investigated 10 years ago and calling it, instead of 19 prostitution, calling it sex trafficking. We think that is the 20 heart of everything, and that will be the centerpiece of our 21 defense, at least legally. + +22 THE COURT: My understanding of what the government is 23 asserting is that the episodes that occurred in Manhattan were 2.1 not included in the nonprosecution agreement in Florida and 25 that there is a separate basis not only for a sex trafficking + +2 3 4 5 6 7 MR. WEINGARTEN: We have had good conversations with the prosecutors, and we like and respect them. We are looking forward to getting discovery. We are interested to see whether the prosecutors in Florida, who are now under severe criticism 10 years later, steered the alleged victims to New York, whether or not they violated their responsibilities under the NPA. + +9 10 THE COURT: Whether the federal prosecutors in Florida violated their terms and conditions? + +11 MR. WEINGARTEN: That will certainly be germane. + +12 THE COURT: Is that the point? + +13 MR. WEINGARTEN: Yes. + +14 THE COURT: Got it. + +15 16 MR. : Your Honor, if I could very briefly respond to those points? + +17 THE COURT: Sure. + +18 19 20 21 22 23 MR. : I expect this will be briefed and argued on Thursday. I don't intend to go into extensive details about that. I just want to flag for the Court that defense counsel is saying that this conduct is ancient. What he is not saying is it is beyond the statute of limitations, because it is not. + +24 25 Second, the allegation that this is some kind of a conspiracy within the Department of Justice is just false. + +1 2 3 There is no evidence to support that. The investigation was begun and conducted entirely separate from any other district. It began in the Southern District of New York. + +4 5 6 7 9 10 Certainly there is evidence that was gathered that is consistent with and even overlapping with the prior investigation. But as the Court noted, in particular an entire count of this indictment is with respect to New York victims. And that is before we even get to the fact that the nonprosecution agreement does not bind the Southern District of New York. + +11 12 THE COURT: I was going to ask you about that too. Now that you have mentioned the topic, explain that, would you. + +13 14 15 16 17 18 MR. : Yes, your Honor. I do expect that we can brief this, but the short version is that this prosecution is not precluded by the nonprosecution agreement entered into by the defendant in the Southern District of Florida. That agreement expressly referred to that federal district. It didn't purport to bind any other office or district. + +19 20 21 22 23 24 25 It is well-settled in the Second Circuit that a plea agreement in one U.S. Attorney's office does not bind another unless otherwise stated. That is even if, based on case law, the agreement refers generally to "the government." Again, additionally, as set forth in the indictment returned by the grand jury, the substantive count alleges acts occurring in New York and alleges New York-based victims. + +1 2 3 4 5 That is in spite of the fact that the Southern District is not bound, is not a signatory to, and otherwise has no connection to the NPA. And there is no evidence that we have come across that the Southern District of New York was consulted, asked, involved, notified as far as we have seen. + +6 7 For those reasons and others I'm sure we will brief, we don't think the NPA applies to us. + +9 THE COURT: Yes. + +10 11 12 13 14 15 16 17 MR. WEINBERG: I have been one of Mr. Epstein's counsel through the CVRA litigation which started in 2008 and continues. In fact, our briefing is today. The NPA provided him with immunity for any offenses arising from a joint FBI/grand jury/U.S. Attorney investigation that led to a decision by Mr. Epstein to plead to a higher state offense than the state prosecutors contemplated. He went to jail, signed an agreement, and has lived up to its terms 100 percent. + +18 19 20 21 22 23 24 25 We have seen in the paperwork of the CVRA, in the Southern District of Florida, in writing at docket 205-2 the government's motion to dismiss CVRA, urging that the witnesses there go to the Southern District of New York and essentially try to motivate them to prosecute for the very same conduct, in other words, the conduct that Mr. Epstein was immunized, including travel between two states, telephonic communications between two states. Florida immunized him for the same travel + +MR. WEINBERG: If I may reply briefly, your Honor? + +2 In addition, the Department of Justice reviewed the 3 NPA on several occasions in 2008 and essentially confirmed that 4 the exercise of discretion shown in Florida was appropriate. 5 But the most important thing is that there was communication 6 between the prosecutors in Florida, perhaps through prosecutors 7 in Georgia that took over the case because the Florida 8 prosecutors were recused as a result of Judge Marrah's 9 decisions in the CVRA case. + +10 We know the government is relying in part on evidence 11 that was generated by the Southern District of Florida case 12 back in 2007. They have talked about message pads, telephone 13 records. They are the same message pads and telephone records 14 that reflect conduct that was exclusively 15, 16, 17 years ago. 15 So we do have a principal position that we will put to the 16 Court at the appropriate time regarding the legality of this 17 prosecution and whether or not it is appropriately barred. + +18 I can say as a criminal defense lawyer of 45 years, 19 when there is an interstate wire, mailing, travel, and there is 20 one district that is conducting an investigation, you negotiate 21 with that district and count on the Department of Justice to 22 what it does every day decade after decade after decade, which 23 is not to go to the second jurisdiction that received the mail 2.1 that was sent from the immunizing jurisdiction and have a 25 prosecution on the very same conduct. We will be briefing + +2 THE COURT: Do you anticipate that there is going to 3 be any discussion here about the legality of the NPA? + +4 MR. WEINBERG: Not the legality of the NPA. I th\_-k 5 the discussion here is going to be about its scope. + +6 THE COURT: From the defense, yes. You don't think 7 you expect to hear anything from the government, for example? + +8 MR. WEINBERG: In the Southern District case, the CVRA 9 case, maybe two weeks ago the Northern District of Georgia 10 prosecutors, who are proxy for the Southern District of 11 Florida, filed the submission before District Judge Marrah in 12 the CVRA case totally supporting the constitutionality and 13 legality of the NPA, their discretion to enter into it, and 14 that there absolutely has never been a charge that Mr. Epstein 15 ever did anything other than fully perform his end as a citizen 16 who is expecting the benefits of a contract that he lived up 17 to. + +18 THE COURT: I thought there had been some contention 19 that the way that the victims vis-a-vis the Florida NPA were 20 dealt with or not dealt with was one basis for attacking the 21 legality of that arrangement. + +22 MR. WEINBERG: The petitioners are vigorously and have 23 vigorously for many years challenged, many years starting quite 2.1 frankly after Mr. Epstein performed his obligations to go to 25 jail and challenged it, claiming that there was no consultation + +2 3 4 5 6 7 The Department of Justice at the time did not believe the CVRA extended absent a federal charge. The predicate is a federal crime that harms a victim. The petitioners have vigorously asserted a different position. Judge Marrah, in a summary judgment motion, agreed with the petitioners as to the fault of the government in not conferring. The issue of remedy is before Judge Marrah at the present time, your Honor. + +9 THE COURT: Okay. + +10 MR. : Your Honor, if I may very briefly? + +11 THE COURT: Yes. + +12 13 14 15 16 17 18 19 20 MR. : The crux of the defense argument here I think cuts precisely the other way. They are arguing that the Southern District of Florida has sort of sent up a flag that these prosecutions could be undertaken elsewhere. That's true. The Southern District of Florida has argued in papers that they believed, the Southern District of Florida believed, that the nonprosecution agreement was limited to that district. They have said that out loud and in public and in their positions in filing. + +21 22 23 24 25 So certainly this investigation was not shoveled to the Southern District of New York from anywhere else, including the Department of Justice. We expect that the nonprosecution agreement will not be an impediment, in particular because the defendant certainly did not lack for sophisticated counsel in + +1 2 3 negotiating that agreement, which again did not include the Southern District of New York. We don't expect that to be any impediment at all here. + +4 THE COURT: Got it. + +5 6 7 This is a small item. In the pretrial services report which was prepared today -- how many, if more than one, passports does Mr. Epstein have? + +8 9 10 MR. WEINGARTEN: Mr. Epstein reported today one. 1. others were rescinded. As we understand it, there is one effective passport today. + +11 12 I would like to make one other point about the pretrial that is extremely important. + +13 THE COURT: Go ahead. + +14 15 MR. WEINGARTEN: The way it reads is that we have refused to provide information about income and assets. + +16 17 18 19 THE COURT: I didn't really read it that way myself. I thought it was incomplete in some places and I thought it could be beefed up, so to speak. But I imagine that in the bail application those matters may be dealt with. + +20 MR. WEINGARTEN: Exactly. + +21 22 23 24 25 THE COURT: For Mr. : In your letter you describe some obstruction or harassment, witness tampering, alleged, by Mr. Epstein. That, I take it, is going to be included in any response or any bail submission made by the government? + +1 2 3 4 5 MR. : Your Honor, I think we addressed that in our initial submission. To the extent defense counsel has a response to it, we will evaluate that response and see whether additional submission from the government is required or appropriate. + +6 7 THE COURT: I think that's it for me in terms of questions that I might have had. + +9 10 11 There is, of course, a conspiracy charge here, one of the two counts. It may be early in your investigation to know. Do you anticipate that there may be other defendants in this proceeding? + +12 13 14 MR. : Your Honor, we don't expect any imminent superseding indictments in this case. It certainly is possible down the road. + +15 16 17 18 19 20 21 22 MR. WEINGARTEN: May I make one point, your Honor? These obstruction allegations we find very nettlesome and bothering. My understanding is that the Feds and Mr. Epstein's attorneys back in the early 2000s, or 2007 and 8, when they were negotiating were looking desperately for an appropriate statute. They finally settled on a state statute that Mr. Epstein pled to. We all know how unusual that is. There was some consideration of a federal statute, including obstruction. + +23 24 25 So lawyers in good faith were having discussions back and forth whether or not they could squeeze Mr. Epstein's conduct into a particular statute, and they concluded they + +1 2 couldn't because the facts didn't fit. That is my understanding of how those obstruction discussions arose. + +3 THE COURT: Got it. + +4 5 6 7 8 9 10 In terms of bail application, it would be helpful, and maybe this is your anticipation, to file written submissions. If you could do that. What I'm getting to is Thursday afternoon is not a good time, in my opinion. I would prefer to do it, if you would go along with this, Monday morning at, say, 9:30. That would give everybody more time to make these submissions and to study them. Is that agreeable? + +11 MR. WEINGARTEN: Yes. + +12 MR. WEINBERG: Yes. + +13 14 15 THE COURT: Why don't we say Monday at 10:00. Have you arranged written submissions on any time schedule with Magistrate Judge Pitman? + +16 17 MR. : May we have just a moment, your Honor, with defense counsel? + +18 19 20 THE COURT: Yes, would you. And also determine if one party or the other is going first and that the other is responding or they are simultaneous. + +21 MR. Yes, your Honor. Thank you. + +22 (Pause) + +23 24 25 MR. : Your Honor, the government is prepared to rely on its initial submission at least for its first argument. I expect defense counsel will respond to that + +1 2 and propose a package. Then the government would like an opportunity to reply to that submission. + +3 4 5 6 7 9 The parties would be happy to make those deadlines Thursday and Saturday respectively. However, we are also happy to back that up a little bit if the Court prefers not to receive the government's submission over the weekend. We could do an earlier deadline on Thursday for defense and a late Friday deadline for the Court from the government, depending on what the Court prefers. + +10 11 THE COURT: I was going to propose defense Thursday at noon. Is that okay to get your submission in? + +12 MR. WEINBERG: We can do that, your Honor. + +13 THE COURT: Thanks. + +14 And if you could respond Friday by 5:00 p.m. + +15 MR. : We will, your Honor. Thank you. + +16 17 18 19 THE COURT: Then we can have oral presentations. I take it everybody wants to have oral presentations in addition to the written. I'll set aside as much time as we need on the 15th at 10:00. + +20 21 I ask the government if there is a speedy trial issue or application that takes us to Monday at 10:00 a.m. + +22 23 24 25 MR. : Yes, your Honor. The government asks that speedy trial time be excluded until Monday. We do expect to begin the process of working on producing discovery, to include discussions with defense counsel about a protective + +1 2 3 4 order. I think, frankly, the outcome of that will be effected by the coming week. But we do expect to have those conversations and therefore request that speedy trial time be excluded until Monday. + +5 6 7 9 THE COURT: I am going to find under 18 United States Code 3161 that the request for adjournment, joined in by both sides, to and including Monday the 15th at 10:00 a.m., is appropriate and warrants exclusion of the adjourned time from speedy trial calculations. + +10 11 12 13 14 15 16 17 I further find that the exclusion is designed to prevent any possible miscarriage of justice to facilitate these proceedings and, initially at least, so that counsel has time to prepare written bail submission and to guarantee effective representation of and preparation by counsel for both sides. Thus, the need for exclusion and the ends of justice outweigh the interests of the public and the defendant in a speedy trial pursuant to 18 U.S.C. section 3161(h) (7)(A) and (B). + +18 Does anybody want to add anything to today's session? + +19 20 MR. : Your Honor. May we have one more moment with defense counsel? + +21 THE COURT: Sure. + +22 (Pause) + +23 24 MR. : Nothing from the government. Your + +25 THE COURT: Defense? + +2 THE COURT: Nice to see you all. 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a/marker2/ds9/EFTA00083870/EFTA00083870.md b/marker2/ds9/EFTA00083870/EFTA00083870.md new file mode 100644 index 0000000000000000000000000000000000000000..cf7eb7ec46c2210b2845ed93ff5431dc7048ad66 --- /dev/null +++ b/marker2/ds9/EFTA00083870/EFTA00083870.md @@ -0,0 +1,49 @@ +**From:** [REDACTED] +**To:** "Daniel J. Kaiser" [REDACTED] +[REDACTED] "William H. Kaiser" [REDACTED] +**Cc:** [REDACTED] + +**Subject:** RE: Epstein case, SDNY +**Date:** Fri, 26 Jul 2019 03:37:49 +0000 + +Dan, Kimberly, + +Following up on our discussions regarding [REDACTED] we were wondering if you have time for a brief call tomorrow, or if not, at your earliest convenience next week? We don't expect to take long but do want to be quickly in touch when you're available. + +thank you, + +[REDACTED] + +Assistant U.S. Attorney +Southern District of New York +[REDACTED] + +--- + +**From:** Daniel J. Kaiser <[REDACTED]> +**Sent:** Sunday, July 14, 2019 08:05 +**To:** [REDACTED] +**Cc:** [REDACTED] William H. Kaiser [REDACTED] [REDACTED] +[REDACTED] +**Subject:** Re: Epstein case, SDNY + +Thanks to all of you for handling the meeting with [REDACTED] so professionally. We greatly appreciate it. + +Dan + +Daniel J. Kaiser +Kaiser Saurborn & Mair, P.C. + +[REDACTED] + +On Jul 14, 2019, at 12:09 AM, [REDACTED] > wrote: + +Team – following up on our meeting yesterday, I wanted to make sure you all have the contact info for our full team. My colleagues [REDACTED] and [REDACTED] are also working on the case, and they're copied here and we're all reachable at these email addresses or by phone anytime at: + +[REDACTED] + +We greatly appreciated being willing to talk with us, and I expect we'll be in touch again in the coming weeks. And of course if anything comes up that you want to reach out to us about, please don't hesitate at all. + +thank you, + +Assistant U.S. Attorney id of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00083870/EFTA00083870.metadata.json b/marker2/ds9/EFTA00083870/EFTA00083870.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..816a5f444bf1e225a00b2a25e7b224c8099aa7ec --- /dev/null +++ b/marker2/ds9/EFTA00083870/EFTA00083870.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083870.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1581, + "elapsed_seconds": 5.5, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 50 + ], + [ + "Text", + 38 + ], + [ + "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", + 11 + ], + [ + "Line", + 6 + ], + [ + "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/EFTA00083870" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083872/EFTA00083872.md b/marker2/ds9/EFTA00083872/EFTA00083872.md new file mode 100644 index 0000000000000000000000000000000000000000..c016336d6a8fc82ef098f954471ae198743a9e08 --- /dev/null +++ b/marker2/ds9/EFTA00083872/EFTA00083872.md @@ -0,0 +1,47 @@ +To: "Daniel J. Kaiser' + +Cc: "William H. Kaiser" + +Subject: Re: Epstein case, SDNY + +Date: Fri, 26 Jul 2019 10:39:00 +0000 + +I am at a charity function all day with limited service. Can we do Monday at 12? + +Sent from my iPhone + +On Jul 26, 2019, at 5:33 AM, Daniel J. Kaiser < > wrote: + +I am in Boston for a deposition but can speak between 1:00 and 2:00 if that works. My cell is Dan + +Dan Daniel J. Kaiser Kaiser Saurborn & Mair, P.C. + +On Jul 25, 2019, at 11:38 PM > wrote: + +Dan, Kimberly, + +Following up on our discussions regarding, we were wondering if you have time for a brief call tomorrow, or if not, at your earliest convenience next week? We don't expect to take long but do want to be quickly in touch when you're available. + +thank you, + +Assistant U.S. Attorney id of New York + +From: Daniel J. Kaiser 4I &gt; + +Sent: Sunday, July 14, 2019 08:05 + +Thanks to all of you for handling the meeting with n professionally. We greatly appreciate it. + +Dan + +Daniell. Kaiser Kaiser Saurborn & Mair, P.C. + +On Jul 14, 2019, at 12:09 AM, wrote: + +Team — following up on our meeting yesterday, I wanted to make sure you all have the contact info for our full team. My colleagues ancl are also working on the case, and they're copied here and we're all reachable at these email addresses or by phone anytime at: + +We greatly appreciated being willing to talk with us, and I expect we'll be in touch again in the coming weeks. And of course if anything comes up that you want to reach out to us about, please don't hesitate at all. + +thank you, + +Assistant U.S. Attorney MM. New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00083872/EFTA00083872.metadata.json b/marker2/ds9/EFTA00083872/EFTA00083872.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fb315ab36078382d76a81d6ba7af61bc13ff56b6 --- /dev/null +++ b/marker2/ds9/EFTA00083872/EFTA00083872.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083872.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1576, + "elapsed_seconds": 1.01, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 28 + ], + [ + "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", + 31 + ], + [ + "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/EFTA00083872" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083874/EFTA00083874.md b/marker2/ds9/EFTA00083874/EFTA00083874.md new file mode 100644 index 0000000000000000000000000000000000000000..90438d99eb6df143c2047d58d40088c5a6707311 --- /dev/null +++ b/marker2/ds9/EFTA00083874/EFTA00083874.md @@ -0,0 +1,99 @@ +**To:** [REDACTED] + +**Cc:** Kimberly Lerner <[REDACTED]>, "William H. Kaiser" <[REDACTED]>, + +[REDACTED] + +**Subject:** Re: Epstein case, SDNY + +**Date:** Fri, 26 Jul 2019 17:35:44 +0000 + +--- + +I should be able to speak at 3:30. Call my cell [REDACTED]. + +Dan + +Daniel J. Kaiser +Kaiser Saurborn & Mair, P.C. + +[REDACTED] + +On Jul 26, 2019, at 1:34 PM, [REDACTED] > wrote: + +Dan, + +We actually need to speak briefly today – the agents unfortunately are in a meeting right now, but could we speak when you're finished with your depo this afternoon? We should be able to do any time after about 3:30. And we can have another call with everyone on Monday if you think that would be useful after we chat. + +thanks, + +[REDACTED] + +--- + +**From:** Daniel J. Kaiser [REDACTED] > + +**Sent:** Friday, July 26, 2019 13:29 + +**To:** Kimberly Lerner [REDACTED] > + +**Cc:** [REDACTED] >; William H. Kaiser [REDACTED] + +**Subject:** Re: Epstein case, SDNY + +[REDACTED] Are we on for a Monday call? Dan + +Dan + +Daniel J. Kaiser +Kaiser Saurborn & Mair, P.C. + +[REDACTED] + +On Jul 26, 2019, at 6:39 AM, Kimberly Lerner 4 > wrote: + +I am at a charity function all day with limited service. Can we do Monday at 12? + +Sent from my iPhone + +On Jul 26, 2019, at 5:33 AM, Daniel J. Kaiser wrote: + +M: I am in Boston for a deposition but can speak between 1:00 and 2:00 if that works. My cell is Dan + +Dan Daniell. Kaiser Kaiser Saurborn & Mair, P.C. + +On Jul 25, 2019, at 11:38 PM wrote: + +Dan, Kimberly, + +Following up on our discussions regarding , we were wondering if you have time for a brief call tomorrow, or if not, at your earliest convenience next week? We don't expect to take long but do want to be quickly in touch when you're available. + +thank you, + +Assistant U.S. Attorney Southern District of New York + +From: Daniel J. Kaiser + +Sent: Sunday, July 14, 2019 08:05 + +To + +Cc: William H. Kaiser + +Subject: Re: Epstein case, SONY + +Thanks to all of you for handling the meeting with so professionally. We greatly appreciate it. + +Dan + +Daniell. Kaiser Kaiser Saurborn & Mair, P.C. + +On Jul 14, 2019, at 12:09 AM, wrote: + +Team — following up on our meeting yesterday, I wanted to make sure you all have the contact info for our full team. My colleagues and are also working on the case, and they're copied here and we're all reachable at these email ad resses or y p one anytime at: + +We greatly appreciated being willing to talk with us, and I expect we'll be in touch again in the coming weeks. And of course if anything comes up that you want to reach out to us about, please don't hesitate at all. + +thank you, + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00083874/EFTA00083874.metadata.json b/marker2/ds9/EFTA00083874/EFTA00083874.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..15c3e4c7be2bd3093dca77f714ed033f4567e5ae --- /dev/null +++ b/marker2/ds9/EFTA00083874/EFTA00083874.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083874.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2618, + "elapsed_seconds": 5.4, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Text", + 48 + ], + [ + "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", + 60 + ], + [ + "Line", + 29 + ], + [ + "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", + 21 + ], + [ + "Line", + 10 + ], + [ + "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/EFTA00083874" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083877/EFTA00083877.md b/marker2/ds9/EFTA00083877/EFTA00083877.md new file mode 100644 index 0000000000000000000000000000000000000000..1d19c8634ea3dc291ff0a77f1d9ccca90f29c2ab --- /dev/null +++ b/marker2/ds9/EFTA00083877/EFTA00083877.md @@ -0,0 +1,35 @@ +From: aNIMIW To: air , Lisa Bloom ck Fudali "Colleen Mullen" + +Subject: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) + +Date: Mon, 05 Aug 2019 22:52:00 +0000 + +Attachments: + +Hi Ms.M + +Thank you for taking the time to speak with our firm on Friday, August 2, 2019, regarding our clients, + +ho believe they were assaulted by Epstein in or around June 2004. + +We have confirmed our clients' availability for interviews wit ice. Ms. • available for an inperson interview on August 26, 2019, or August 27, 2019. Ms ho is located in is available for an interview via video confe ably the week of Augus . ease confirm whether your office is available to meet with Ms. n those dates and whether we can arrange a video conference for Ms. + +Ad diii • • idiscussed in our call, we have attached two PDF files for your review which contain pictures of Ms. d Ms om 2004. If possible, please confirm whether our clients are in any of the photograp s seized from pstein's home. + +Thank you. We look forward to hearing from you soon. + +Best regards, + +Teri Gibbs + +![](_page_0_Picture_14.jpeg) + +Notice To Recipient: This e-mail is meant for only the mended 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 copykig of this e-mail is strictly prohibited. Please notify us immediately of the error by retum e-mail and please delete this message end any and ell 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 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. marketing. or recommendrig to another party any transaction or matter addressed herein. \ No newline at end of file diff --git a/marker2/ds9/EFTA00083882/EFTA00083882.metadata.json b/marker2/ds9/EFTA00083882/EFTA00083882.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..15d43426480f8018fa2e90212380e8fdb50e0f03 --- /dev/null +++ b/marker2/ds9/EFTA00083882/EFTA00083882.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083882.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1991, + "elapsed_seconds": 0.86, + "image_assets": [ + "_page_0_Picture_14.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 27 + ], + [ + "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/EFTA00083882" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083882/_page_0_Picture_14.jpeg b/marker2/ds9/EFTA00083882/_page_0_Picture_14.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..f896685ded141656259788248f702a340b5feea8 --- /dev/null +++ b/marker2/ds9/EFTA00083882/_page_0_Picture_14.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:d568bf080f69663b36239f82cf182c0d1172f32b6635226e236b0254af1bc4dd +size 13150 diff --git a/marker2/ds9/EFTA00083883/EFTA00083883.md b/marker2/ds9/EFTA00083883/EFTA00083883.md new file mode 100644 index 0000000000000000000000000000000000000000..79c3ac3c3f694520ade6fa49070e93b9582e7a8d --- /dev/null +++ b/marker2/ds9/EFTA00083883/EFTA00083883.md @@ -0,0 +1,55 @@ +Cc + +Subject: RE: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) + +Date: Mon, 05 Aug 2019 23:04:38 +0000 + +Inline-Images: image00 1 jpg + +' trial — at least in theorybut definitely go ahead and schedule. + +Froni + +Sent: Monday, August 05, 2019 19:03 + +To: (NY) (FBI) + +Cc: Ic a; + +Subject: FW: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) + +Team, + +Are you available for interviews on 8/26 and 8/27? Regarding the photos (attached), we can discuss next time we talk. Thanks. + +From: Teri Gibbs + +Sent: Monday, August 5, 2019 6:52 PM + +To: + +Cc: < => + +Lisa Bloom <= >; Arick Fudali Colleen Mullen + +4 + +Subject: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) + +Hi Ms. + +Thank you for taking the time to speak 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 our Ms s available for an inperson interview on August 26, 2019, or August 27, 2019. Ms. ho is loca is available for an interview via video confe ably the week of August 26th. Please confirm whether your office is available to meet with Min those dates and whether we can arrange a video conference for Ms. + +Additional) as discussed in our call, we have attached two PDF files for your review which contain pictures of Ms. d Ms. from 2004. If possible, please confirm whether our clients are in any of the pho ed fr tein's home. + +Thank you. We look forward to hearing from you soon. + +| | | +|---------------|---------------| +| | | + +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 duplicates of this message from your system. Thank you in advance for your cooperation. + +IRS Crcular 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 0) avoiding penalties under the Internal Revenue Code or (a) promoting. marketing. or recommending to another party any transaction or matter addressed herein. \ No newline at end of file diff --git a/marker2/ds9/EFTA00083883/EFTA00083883.metadata.json b/marker2/ds9/EFTA00083883/EFTA00083883.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6cbd42bbae33047dea9ea2cc7bf7eaa0d58f5e72 --- /dev/null +++ b/marker2/ds9/EFTA00083883/EFTA00083883.metadata.json @@ -0,0 +1,88 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083883.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2546, + "elapsed_seconds": 1.46, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 92 + ], + [ + "Line", + 38 + ], + [ + "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", + 13 + ], + [ + "Line", + 7 + ], + [ + "Text", + 3 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00083883" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083885/EFTA00083885.md b/marker2/ds9/EFTA00083885/EFTA00083885.md new file mode 100644 index 0000000000000000000000000000000000000000..46336bdbc7d015b12bdce8e982be1fdb234fbfd4 --- /dev/null +++ b/marker2/ds9/EFTA00083885/EFTA00083885.md @@ -0,0 +1,23 @@ +From: ' y, To:" " (FBI)" W Cc: "I + +Subject: RE: RE: sisters meeting / new subpoena + +Date: Mon, 15 Jul 2019 22:19:42 +0000 + +Importance: Normal + +A quick update on this — I've asked Stan to propose a few possible times later this week for an interview wither so will let everybody know what he proposes. + +thanks, + +From: 1 Sent: Saturday, July 13, 2019 16:48 To: ( ) ; I ‹ > Subject: RE:IIM sisters meeting / new subpoena + +Two quick things —first, we'd like to set up a meeting for this coming week with who previously worked with Epstein, and possibly her younger sister as well. I don't believe they were underage victims of Epstein, but they apparently have useful information and also may have been victims of coercive sexual encounters with Epstein and/or his associates. Any days or times this week you would snots be available for that? + +Separately, there have now been two stories in the Times where a publicist, Mr. R. Couri Hay, has been referenced as having recently been told by Epstein about Epstein's prior conduct. Can we please try to contact him? Can issue him a subpoena, attached, if he doesn't want to be interviewed informally. + +(Here's the latest reference to him: "Just three months ago, as federal prosecutors were closing in with new charges, Mr. Epstein had a conversation with R. Couri Hay, a publicist, about continuing to improve his reputation. Mr. Epstein asserted that what he was convicted of did not constitute pedophilia, said Mr. Hay, who declined to represent him. The girls he had sex with were "tweens and teens," Mr. Epstein told him.") + +thanks, + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00083885/EFTA00083885.metadata.json b/marker2/ds9/EFTA00083885/EFTA00083885.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cb6a8c7bba0e802e345fcc14f90bafc3abe260ec --- /dev/null +++ b/marker2/ds9/EFTA00083885/EFTA00083885.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083885.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1647, + "elapsed_seconds": 0.62, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 66 + ], + [ + "Line", + 31 + ], + [ + "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/EFTA00083885" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083886/EFTA00083886.md b/marker2/ds9/EFTA00083886/EFTA00083886.md new file mode 100644 index 0000000000000000000000000000000000000000..982ed2ddfd9debfaf947b1c1de5890d3cc0a60de --- /dev/null +++ b/marker2/ds9/EFTA00083886/EFTA00083886.md @@ -0,0 +1,103 @@ +From: To: Jeff Pagliuc Cc: Nicole Simmons + +Subject: RE: Maxwell + +Date: Mon, 15 Jul 2019 20:18:39 +0000 + +Importance: Normal + +Jeff, + +We haven't spoken to Mark and hadn't heard from you that our call was canceled. Why don't you all let us know when you want to reschedule for, and with whom, and we'll go from there. + +thanks, + +From: Jeff Pagliuc. + +Sent: Monday, July 15, 2019 16:15 + +To: + +Cc: Nicole < + +Subject: Re: Maxwell + +Sorry I missed your call. I had to travel to North Carolina over the weekend to assist with some family issues. I am on my way back to Denver now. I have a court appearance in Aspen, Colorado tomorrow and should have quite a bit of phone availability during the drive. + +I assume Mark updated you on our status and am happy to discuss further when I am available. + +Jeff + +On Jul 9, 2019, at 7:36 PM, wrote: + +Jeff, + +You're absolutely correct and I'm sorry for the delay. Attached please find the form proffer letter, as discussed. And it is on our calendar to have a call on this Thursday the 11th, 4 p.m. your time (and 6 p.m. our time). Please let us know if it would be useful to chat in the interim—we're happy to, if so—and we look forward to being in touch soon. + +thank you, + +From: Jeff Pagliuca + +Sent: Tuesday, July 09, 2019 18:56 + +To: + +Cc: Nicole Simmons + +I expect you all have been busy in the last few days. When we spoke yesterday I understood that you would be sending a form proffer letter for my review. I would like to discuss the document with my client as soon as possible to keep the process moving. When you get a chance please send the draft and I will hopefully be in a position to discuss a potential proffer metting during our next call which I think is scheduled for 7-11 at 4pm my time. + +Best Regards, + +Jeff + + + +Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. + +ISO East 10th Avenue Denver, Colorado 80203 Main 303.831.7364 FX 303.832.2628 + +www. m aw.com + +CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain information that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its attachments without reading or saving it in any manner. Thank you + +From: ) [mailto: + +Sent: Sunday, July 7, 2019 1:46 PM + +To: Jeff Pagliuca + +Cc: Nicole Simmons; + +Subject: RE: Maxwell + +Jeff, + +Thanks for speaking with me this afternoon. I've copied my colleagues, you have everyone's contact information. and so that + +In terms of scheduling a call tomorrow, we are going to be tied up in the morning, and the afternoon is a bit uncertain given that we are not sure yet of the timing of the presentment for Mr. Epstein. I think it would make sense to plan for a call at 4, and we can let you know if we need to reschedule, if that's alright with you. + +Attached is the subpoena for Ms. Maxwell. The indictment is currently under seal, but we anticipate that it will be unsealed tomorrow morning and publicly available. Please let us know tomorrow if you have any difficulty and we can certainly send you a copy. + +Thanks very much, and looking forward to discussing further tomorrow. + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 + +From: Jeff Pagliuca Sent: Sunday, July 7, 2019 3:09 PM To: Cc: Nicole Simmons < Subject: Maxwell + +Dear M, + +It was a pleasure talking to you today. As we discussed, I am authorized to accept service of the subpoena for testimony issued to Ms. Maxwell by the Grand Jury, SDNY. I expect that we will need to coordinate a mutually convenient time to either appear or proffer, either in advance or in lieu of any testimony. + +I will be in court tomorrow morning and afternoon, so I have a small window to discuss the matter- probably between 11am and noon and then again at around 4pm my time which is 2 hrs. earlier than the East Coast. My staff will attempt to obtain a copy of the Epstein indictment as soon as it is publicly available. In my experience this can sometimes be difficult so If it is not an inconvenience perhaps you could email the indictment along with the subpoena and waiver. + +Best Regards, + +Jeff + +Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue + + Denver, Colorado 80203 Main 303.831.7364 FX 303.832.2628 .00 + +CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain information that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its attachments without reading or saving it in any manner. Thank you + + \ No newline at end of file diff --git a/marker2/ds9/EFTA00083886/EFTA00083886.metadata.json b/marker2/ds9/EFTA00083886/EFTA00083886.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9d6a3af914bfe7bde5bf6c2e9fb29ceee9bde9ea --- /dev/null +++ b/marker2/ds9/EFTA00083886/EFTA00083886.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083886.pdf", + "engine": { + "marker_major": "2", + "marker_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": 5500, + "elapsed_seconds": 1.28, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "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", + 81 + ], + [ + "Line", + 41 + ], + [ + "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", + 58 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00083886" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083889/EFTA00083889.md b/marker2/ds9/EFTA00083889/EFTA00083889.md new file mode 100644 index 0000000000000000000000000000000000000000..1b33293ddc9ccbc0ebead3b9385904ba5cb05796 --- /dev/null +++ b/marker2/ds9/EFTA00083889/EFTA00083889.md @@ -0,0 +1,62 @@ +**To:** [REDACTED] + +[REDACTED] + +**Subject:** FW: SDNY investigation (re: Epstein) + +**Date:** Tue, 16 Jul 2019 17:17:15 +0000 + +**Importance:** Normal + +**Inline-Images:** image001.png; image002.jpg + +Should we do this at 5:00? Or [REDACTED] if you want, [REDACTED] and I can do it at 4:30 – totally happy to wait until you can join if you want, but if you don't care, likely won't be super exciting and we can cover. Your call. + +--- + +**From:** Christian Everdell <[REDACTED]> + +**Sent:** Monday, July 15, 2019 22:33 + +**To:** [REDACTED] >; Mark S. Cohen <[REDACTED]> + +**Cc:** [REDACTED] + +**Subject:** RE: SDNY investigation (re: Epstein) + +Thanks for the email, [REDACTED]. We appreciate your willingness to meet with us. If you can make the time, I think it would be useful to have an introductory meeting tomorrow. Let us know what time works best for you. + +Regards, + +Chris + +Christian Everdell + +COHEN & GRESSER LLP + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +New York | Seoul | Paris | Washington DC | London + +![](_page_0_Picture_150.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. Thank you. + +PRIVACY: A complete copy of our privacy policy can be viewed at [REDACTED] + +--- + +**From:** [REDACTED] + +**Sent:** Monday, July 15, 2019 7:57 PM + +Following up on my very brief conversation with Chris earlier this afternoon, and the voicemail you left earlier, thanks for getting in touch regarding your representation of Ms. Maxwell. I understand you'll be in our neighborhood tomorrow afternoon; we can make ourselves available to meet, but will that have been enough time for you to speak with your client? Let us know what you think would be best to proceed, and we'll figure out next steps. + +thanks, + +M + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00083889/EFTA00083889.metadata.json b/marker2/ds9/EFTA00083889/EFTA00083889.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a6b56e94e17095920534b65c817fa2449ef13456 --- /dev/null +++ b/marker2/ds9/EFTA00083889/EFTA00083889.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083889.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2272, + "elapsed_seconds": 7.72, + "image_assets": [ + "_page_0_Picture_150.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Text", + 53 + ], + [ + "Line", + 33 + ], + [ + "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 + } + }, + { + "page_id": 1, + "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/EFTA00083889" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083889/_page_0_Picture_150.jpeg b/marker2/ds9/EFTA00083889/_page_0_Picture_150.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..2f5c3fc03f51e634a83f97778ce07b898e7af14d --- /dev/null +++ b/marker2/ds9/EFTA00083889/_page_0_Picture_150.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:884f8eb0a07b0010c34e2c63a1e44ba297cd2b5fad36eff77a1a6c333b9693cc +size 1140 diff --git a/marker2/ds9/EFTA00083891/EFTA00083891.md b/marker2/ds9/EFTA00083891/EFTA00083891.md new file mode 100644 index 0000000000000000000000000000000000000000..a99e28824dd1d5753b840b97de043094fbc70ea6 --- /dev/null +++ b/marker2/ds9/EFTA00083891/EFTA00083891.md @@ -0,0 +1,17 @@ +![](_page_0_Picture_3.jpeg) + +Date of entry 07/29/20)9 + +Pursuant to an arrest warrant issued in the Southern District of New York, Special Agents and Task Force Officers of the Federal Bureau of Investigation located and arrested JEFFREY EPSTEIN at Teterboro Airport in New Jersey. + +On or about July 6, 2019, at approximately 5:30PM, EPSTEIN's plane with tail number N212JE landed in Teterboro, New Jersey, arriving from Paris, France. + +Customs and Border Protection (CBP) agents and processed EPSTEIN coming back into the United States. Once EPSTEIN cleared US Customs, EPSTEIN was introduced to FBI Special Agent and Task Force Officer, Detective . EPSTEIN was informed that a federal arrest warrant had been issued for him regarding sex trafficking of minors and conspiracy to commit sex trafficking. EPSTEIN was read his rights, which he in turn asked to speak with his lawyer before questioning. EPSTEIN was taken into FBI custody at approximately 6:12PM. EPSTEIN was transported to , New York, New York for arrest processing by Special Agent , Special Agent and Task Force Officer, , before being transported to the Metropolitan Correctional Center for safe keeping until his initial appearance on July 8, 2019. + +Also present to assist with the arrest was Special Agent Special Agent , Special Agent , CBP Agent , CBP Supervisory Agent , and CBP Supervisory Agent . The arrest operation was supervised by Supervisory Special Agent and NYPD Lieutenant + +Arrest warrant, Advice of Rights, arrest paperwork, and receipt for property are all attached in a 1A. + +Investigation on 07/06/2019 at Teterboro, New Jersey, 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. \ No newline at end of file diff --git a/marker2/ds9/EFTA00083891/EFTA00083891.metadata.json b/marker2/ds9/EFTA00083891/EFTA00083891.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..77084ac20de899734c817a5634d7a4eb04447228 --- /dev/null +++ b/marker2/ds9/EFTA00083891/EFTA00083891.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083891.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1842, + "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 + ], + [ + 390.5003662109375, + 49.41 + ], + [ + 390.5003662109375, + 62.4552001953125 + ], + [ + 189.108, + 62.4552001953125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 82 + ], + [ + "Line", + 38 + ], + [ + "Text", + 12 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00083891" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083891/_page_0_Picture_3.jpeg b/marker2/ds9/EFTA00083891/_page_0_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..10029eb8f59798236293202a76adec2cffb21c5c --- /dev/null +++ b/marker2/ds9/EFTA00083891/_page_0_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:3137c628bcf149980f49d7435c2ef13472e55e81aaa0999d12f7f02342912a65 +size 4492 diff --git a/marker2/ds9/EFTA00083892/EFTA00083892.md b/marker2/ds9/EFTA00083892/EFTA00083892.md new file mode 100644 index 0000000000000000000000000000000000000000..927d27d0ed191e8949f7b527265a0e5f0ea35b19 --- /dev/null +++ b/marker2/ds9/EFTA00083892/EFTA00083892.md @@ -0,0 +1,17 @@ +From: "Min aNIMIE> + +To: "a (NY) (FBI)" On Jul 26, 2019, at 7:54 PM, 'aNIMIN> wrote: + +> Hi =1, + +> Would you please send me the 302 regarding Epstein's arrest, including whatever statements he made? + +> Thanks, \ No newline at end of file diff --git a/marker2/ds9/EFTA00083892/EFTA00083892.metadata.json b/marker2/ds9/EFTA00083892/EFTA00083892.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a445d5ea4788a341b13706914d5415bba05bbd34 --- /dev/null +++ b/marker2/ds9/EFTA00083892/EFTA00083892.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083892.pdf", + "engine": { + "marker_major": "2", + "marker_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": 348, + "elapsed_seconds": 0.62, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Text", + 13 + ], + [ + "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/EFTA00083892" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083893/EFTA00083893.md b/marker2/ds9/EFTA00083893/EFTA00083893.md new file mode 100644 index 0000000000000000000000000000000000000000..7890da0c428f017135911cb8b872c6aa53035ca2 --- /dev/null +++ b/marker2/ds9/EFTA00083893/EFTA00083893.md @@ -0,0 +1,341 @@ +To: + +Subject: Epstein Accuser Says Dershowitz Is Using Fees To Bully Her + +Date: Wed, 31 Jul 2019 09:28:11 +0000 + +![](_page_0_Picture_4.jpeg) + +;,,l\_aw360 White + +Collar WHITE COLLAR + +Wednesday, July 31, 2019 Follow Law360 + +## TOP NEWS + +## Epstein Accuser Says Dershowitz Is Using Fees To Bully Her + +An alleged Jeffrey Epstein victim has said that right-wing personality Michael Cemovich's request to compel her to pay costs in a Second Circuit appeal is an attempt by Cernovich and Harvard Law School professor Alan Dershowitz to intimidate her, prompting Cernovich to apologize and distance himself from the professor. + +&lotion attached I Read full article » + +### Rakoff Gives 5 Months To Jeweler Tipped By Ex-S&P Analyst + +A French jeweler who traded on an inside tip from former Standard & Poor's analyst Sebastian Pinto-Thomaz was sentenced to five months in prison Tuesday by Manhattan U.S. District Judge Jed S. Rakoff, who rejected his bid for no prison in part because he later took a second tip. + +Read full article » + +### Binary Options Boss Defends Lying To Clients In \$145M Fraud + +An Israeli binary options executive on trial for her alleged role in a \$145 million investment scam took the stand Tuesday to tell a Maryland federal jury that she may have lied to clients about her name and her experience in financial markets, but she never misled investors about the financial product. + +Read full article » + +### 5th Circ. Vacates 1912/ -Year Sentence Over 'Plain' Mistake + +The Fifth Circuit vacated Monday the 19%-year sentence of a Mexican businessman who participated in a \$14 million Ponzi scheme, finding a lower court's "plain" mistake raised his offense level by one point and skewed the sentencing guidelines. + +Opinion attached I Read full article » + +## British Art Broker Gets 4 To 12 Years In Prison For \$10M Theft + +A confessed high-dollar art swindler was sentenced in New York state court on Tuesday to at least four years in state prison for stealing at least \$10 million from his clients in a scheme involving paintings by Pablo Picasso and Marc Chagall. + +Read full article » + +# SECURITIES + +![](_page_0_Picture_27.jpeg) + +;'''.,Law360 Pro Say Podcast + +Listen to our new podcast here + +#### LAW FIRMS + +Arent Fox + +Baker Botts + +Baker Donelson + +Baker McKenzie + +Blackstone Chambers + +Boies Schiller + +Cotsirilos Tighe + +Dechert + +Dentons + +Desai Law Firm PC + +Dewey & LeBoeuf + +Erskine Chambers + +Fisher Phillips + +Fountain Court Chambers + +Greenberg Traurig + +Hogan Lovells + +Jones Day + +Kaufman Dolowich + +Latham & Watkins + +Linklaters + +A convicted New Jersey fraudster who served prison time for impersonating representatives of the defunct Dewey & LeBoeuf LLP and a bank violated his probation by concealing his high-paid executive job at a Massachusetts information technology firm, according to a federal court filing Monday. + +Petition attached I Read full article » + +# Engine Maker's Ex-CEO Pleads Not Guilty In \$25M Fraud Case + +The former CEO of an Illinois-based alternative-energy engine maker pled not guilty Tuesday to charges that he and two other company executives engaged in an accounting fraud scheme that inflated company revenues by \$25 million. + +Read full article » + +# No New Trial For Convicted Life Time Fitness Trader + +An Illinois federal judge on Tuesday rejected a California trader's bid for an acquittal or a new trial after a jury had convicted him of participating in a conspiracy to trade Life Time Fitness Inc. stock before the gym chain announced an impending take-private acquisition, ruling that the government had sufficiently proved the charge. + +Order attached' Read full article » + +# Ex-IT Firm CEO To Pay \$2.9M SEC Judgment In Fraud Case + +The former CEO of bankrupt IT company Quadrant 4 System Corp. has agreed to pay \$2.9 million to resolve the U.S. Securities and Exchange Commission's suit alleging he embezzled millions out of the company and filed false financial statements to cover it up. + +2 documents attached I Read full article » + +# Dubai Watchdog Fines Abraaj \$315M For Deceiving Clients + +The Dubai Financial Services Authority slapped a \$315 million fine on two Abraaj Group companies Tuesday — the largest penalty it's ever imposed saying the defunct private equity firm misused investors' money and then tried to cover it up. + +Read full article » + +## FCPA + +# Micronesian Transportation Official Gets 112/ Years For Bribery + +A Micronesian government official was sentenced to a year and a half in prison for his role in a bribery and money laundering scheme to secure engineering project contracts for a U.S. firm with the Pacific island nation, the U.S. Department of Justice announced Tuesday. + +Read full article » + +# PUBLIC INTEGRITY + +## Chicago Area Ex-Teamsters Head Admits Extortion Scheme + +A former Teamsters regional leader admitted Tuesday in Illinois federal court that he extorted a business for at least \$325,000 through threats of work stoppages and filing false labor and tax documents. + +1 document attached I Read full article » + +# CYBERSECURITY + +#### Analysis + +# Hacker Arrest Provides Rare Insight Into Capital One Breach + +Court filings accusing a Seattle software engineer of stealing the personal data of 106 million Capital One consumers — one of the largest bank data breaches ever — reveal a rare amount of detail about the historic hack into the credit-card issuer's rented cloud computing server. + +Post & Schell + +Randazza Legal Group + +Redgrave LLP + +Robbins Russell + +Sanford Heisler + +Vogel Law Firm + +White & Case + +White and Williams + +Zhong Lun Law Firm + +## COMPANIES + +ABB Asea Brown Boveri Ltd. + +Amazon.com Inc. + +American Express Co. + +Capital One Financial Corp. + +Equifax Inc. + +Ethics & Compliance Initiative + +GitHub Inc. + +Hitachi Ltd. + +International Brotherhood of Teamsters + +KPMG International + +LVMH Group + +Life Time Fitness Inc. + +London Stock Exchange Group PLC + +Power Solutions International Inc. + +S&P Global Inc. + +Shire PLC + +Sotheby's + +The Abraaj Group + +The Valspar Corporation + +Trelleborg AB + +Trimble Inc. + +Twitter Inc. + +USG Corp. + +## GOVERNMENT AGENCIES + +Arizona Supreme Court + +Federal Bureau of Investigation + +Federal Election Commission + +New York Attorney General's Office + +Securities and Exchange Commission + +Serious Fraud Office + +Solicitors Regulation Authority + +U.S. Attorney's Office + +U.S. Court of Appeals for the Fifth Circuit + +U.S. Court of Appeals for the Second Circuit + +#### SFO Defends Talks With ENRC Lawyer In £70M Suit + +A former lawyer for Eurasia Natural Resources Corp. had been given permission to tell the Serious Fraud Office that senior managers had allegedly paid bribes and were suspected of corruption, the agency said as it hit back at the mining company's lawsuit challenging the investigation. + +Read full article » + +#### INTELLECTUAL PROPERTY + +#### Texas Man Guilty Of Conspiracy In China Trade Secrets Case + +A Houston man accused of helping a Chinese manufacturer steal trade secrets from a U.S. drilling company was convicted Monday of one count of conspiracy and acquitted of two other counts. + +Read full article » + +#### EXPERT ANALYSIS + +### Effective Compliance Programs Look Beyond DOJ Guidance + +Emphasis on adherence to the recently issued U.S. Department of Justice guidance on corporate ethics and compliance programs is well-intended but might be diverting focus away from developing the programs and protocols necessary to yield lasting change, says Patricia Hamed of the Ethics & Compliance Initiative. + +Read full article » + +## LEGAL INDUSTRY + +## Global 20: Baker McKenzie + +Baker McKenzie LLP has spent the past year helping clients navigate multibillion-dollar transactions that span continents, including Japanese giant Hitachi's \$11 billion purchase of a Swiss power grid business, landing the firm on Law360's Global 20 list for the ninth year in a row. + +Read full article » + +## Senate OKs Greenberg Vet In Race To Confirm 19 Judges + +The U.S. Senate confirmed three new judges — including a Greenberg Traurig attorney — for Arizona, Texas and North Dakota district courts Tuesday in the first round of a wave of President Donald Trump's judicial picks Republicans want to clear before leaving for recess at week's end. + +Read full article » + +## Ex-Trump Adviser Returns To Baker Donelson Via Alliance + +A recently departed policy adviser to President Donald Trump has returned to Baker Donelson, inking a strategic alliance to work for the law firm in Washington, D.C., a Tuesday announcement said. + +Read full article » + +## Ex-Ogletree Lawyers Abandon Push To Take Over Bias Suit + +Two female attorneys who sought to take the helm of a suit accusing employment law giant Ogletree Deakins Nash Smoak & Stewart PC of systemic sex discrimination after the original plaintiff was forced into arbitration have dropped their claims, according to a California federal court filing. + +Read full article » + +U.S. District Court for the District of Hawaii + +U.S. District Court for the District of Maryland + +U.S. District Court for the District of New Jersey + +U.S. District Court for the Eastern District of Pennsylvania + +U.S. District Court for the Northern District of Illinois + +U.S. District Court for the Northern District of Texas + +U.S. District Court for the Southern District of New York + +U.S. District Court for the Western District of Washington + +U.S. Senate + +Attorney regulatory authorities in the U.K. have referred Baker McKenzie LLP to the country's disciplinary tribunal over allegations the firm allowed a thenpartner in London to sully a 2012 internal sexual assault investigation, documents made public Tuesday show. + +Read full article + +### White & Williams Slams 'Small-Bore' Claims In Atty Bias Suit + +White and Williams LLP fired back Tuesday against a May lawsuit from one of its attorneys alleging a culture of rampant racial and gender bias in the workplace, writing off the claims as a "catalogue of small-bore grievances" that failed to show any actual discrimination. + +Read full article » + +#### Jones Day Pro Bono Work 'Was A Fiasco,' Ex-Clients Claim + +Two Orange County mobile home owners say Jones Day provided pro bono legal services that were "a fiasco" and ultimately left them homeless, according to a suit filed in California state court. + +Read full article + +### Dentons To Combine With Heavyweight New Zealand Firm + +Dentons and leading New Zealand law firm Kensington Swan intend to combine, they said Tuesday, allowing both to expand their presence in the Australasian region and connect clients to a greater range of legal experts. + +Read full article + +### JOBS + +Search full listings or advertise your job opening + +Mid-sized White Plains firm seeks municipal government associate KLR Davis White Plains, New York + +elite lit boutique // mid level assoc Schoen Legal Search New York, New York + +Not sum if your firm subscribes? 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software engineer of stealing the personal data of 106 million Capital One consumers — one of the largest bank data breaches ever — reveal a rare amount of detail about the historic hack into the credit-card issuer's rented cloud computing server. + +Read full article » + +## DNC Loses Election Hack Suit Against Trump, Russia + +A New York federal judge on Tuesday dismissed the Democratic National Committee's lawsuit against the Trump campaign, WikiLeaks, the Russian Federation and others over a preelection email hack, finding no viable claim against Russia pursuant to the Foreign Sovereign Immunities Act and that everyone else is protected on First Amendment grounds. + +Order attached I Read full article » + +## NY Officials OK Conditional Pause On Trump Tax Returns + +New York officials said Tuesday they would temporarily defer any congressional request for President Donald Trump's state tax returns once a federal judge decides whether to dismiss Trump's attempt to block a state law that could let Congress see his returns. + +1 document attached I Read full article 0 + +## British Art Broker Gets 4 To 12 Years In Prison For \$10M Theft + +A confessed high-dollar art swindler was sentenced in New York state court on Tuesday to at least four years in state prison for stealing at least \$10 million from his clients in a scheme involving paintings by Pablo Picasso and Marc Chagall. + +Read full article » + +# Rakoff Gives 5 Months To Jeweler Tipped By Ex-S&P Analyst + +A French jeweler who traded on an inside tip from former Standard & Poor's analyst Sebastian Pinto-Thomaz was sentenced to five months in prison Tuesday by Manhattan U.S. District Judge Jed S. Rakoff, who rejected his bid for no prison in part because he later took a second tip. + +Read full article » + +![](_page_0_Picture_27.jpeg) + +Listen to our new podcast here + +#### LAW FIRMS + +Akerman + +Arent Fox + +Baker Botts + +Baker Donelson + +Baker McKenzie + +BakerHostetler + +Ballard Spahr + +Banner Witcoff + +Berger Montague + +Boies Schiller + +Buschel & Gibbons + +Cassin & Cassin + +Cohen Milstein + +Consovoy McCarthy + +Covington & Burling + +Dentons + +Desai Law Firm PC + +Drinker Biddle + +Duval & Stachenfeld + +Fisher Phillips + +Coogi, an apparel company that's suing the Brooklyn Nets over specialedition jerseys, is arguing that it has "every right" to benefit from its connection to the late Brooklyn rapper Notorious B.I.G. + +1 document attached I Read full article » + +#### MEDIA & ENTERTAINMENT + +#### Epstein Accuser Says Dershowitz Is Using Fees To Bully Her + +An alleged Jeffrey Epstein victim has said that right-wing personality Michael Cemovich's request to compel her to pay costs in a Second Circuit appeal is an attempt by Cemovich and Harvard Law School professor Alan Dershowitz to intimidate her, prompting Cemovich to apologize and distance himself from the professor. + +Motion attached I Read full article 0 + +#### SECURITIES & WHITE COLLAR + +### Mobileye Defendants Can't Duck SEC's Insider Trading Claims + +Two men must face the U.S. Securities and Exchange Commission's insider trading allegations after a New York federal judge denied them a quick victory Monday in the suit over trades connected to Intel's \$15.3 billion acquisition of Israeli tech company Mobileye. + +1 document attached I Read full article » + +#### Network 1 Ducks Claims It Misled Investors In Longfin Offering + +Network 1 escaped a securities fraud class action that claims the investment bank made misleading statements that caused the stock price of a shuttered fintech corporation, Longfin, to skyrocket in late 2017. + +Order attached I Read full article » + +# Cancer Biotech Oasmia Hid Deals From Investors, Suit Says + +Investors for Swedish cancer biotechnology firm Oasmia launched a proposed class action lawsuit in New York federal court Monday, alleging the company actively concealed a number of deals involving entities owned by the biotech's founder and a former board member. + +Complaint attached I Read full article » + +#### BANKING + +## Investors Get OK For \$10.9M Forex Deal With Citigroup, MUFG + +A New York federal judge gave investors the go-ahead on Monday for their \$10 million settlement with Citigroup and a smaller deal with MUFG Bank Ltd. that would resolve claims that the banks participated in a scheme to rig foreign exchange markets. + +1 document attached I Read full article » + +# PERSONAL INJURY & MEDICAL MALPRACTICE + +# Eagles Guitarist's Widow Won't Give Up Info, Hospital Says + +A New York City hospital accused of causing the death of Eagles guitarist Glenn Frey has told a state judge that the wrongful death suit filed by his widow should be dismissed for her failure to comply with a discovery request seeking production of band contracts. + +Motion attached I Read full article » + +Jones Day + +Katten Muchin + +Kaufman Dolowich + +Kriss & Feuerstein + +Levi & Korsinsky + +Linklaters + +McCulley McCluer + +McDermott Will + +Mitchell Silberberg + +Ogletree Deakins + +Paul Hastings + +Paul Weiss + +Peiffer Wolf + +Pierce Bainbridge + +Pomerantz LLP + +Post & Schell + +Powley & Gibson + +Randazza Legal Group + +Redgrave LLP + +Robbins Geller + +Rosen Law Firm PA + +Sanford Heisler + +Schneider Wallace + +Schwartz Levine PLLC + +SeegerWeiss + +Shaub Ahmuty + +Shearman & Sterling + +Shulman Rogers + +Stroock & Stroock + +Sullivan & Cromwell + +Vogel Law Firm + +White & Case + +White and Williams + +Winston & Strawn + +Zhong Lun Law Firm + +#### COMPANIES + +ABB Asea Brown Boveri Ltd. + +AT&T Inc. + +Alexandria Real Estate Equities Inc. + +Amazon.com Inc. + +American Express Co. + +Bank of America Corp. + +Beacon Capital Partners LLC + +Boy Scouts of America + +Jumia Technologies investors began sparring in New York federal court Monday over who should represent the proposed class in the suit alleging the African e-commerce platform led them astray ahead of its initial public offering. + +3 documents attached I Read full article » + +# PRIVATE EQUITY + +## Dubai Watchdog Fines Abraaj \$315M For Deceiving Clients + +The Dubai Financial Services Authority slapped a \$315 million fine on two Abraaj Group companies Tuesday — the largest penalty it's ever imposed saying the defunct private equity firm misused investors' money and then tried to cover it up. + +Read full article » + +# PE Shop Collects \$4.3B For Health Care, Tech Investments + +Welsh Carson Anderson & Stowe said Tuesday it has clinched its latest private equity fund after securing \$4.3 billion from limited partners, with plans to focus on investments in health care and technology. + +Read full article » + +# REAL ESTATE & DEVELOPMENT + +# Real Estate Rumors: Axpo, Reading, Moody Bible Institute + +Swiss energy company Axpo is reportedly leasing 8,443 square feet in New York, the City of Reading, Pennsylvania, is said to be considering purchasing a 50-acre industrial site and Moody Bible Institute is reportedly looking to sell a large portion of its downtown Chicago campus. + +Read full article » + +# NYC Real Estate Week In Review + +Paul Weiss, Ballard Spahr and Stroock were among the law firms that helped with the largest New York City real estate deals that hit public records last week, with three large Manhattan transactions leading the way. + +Read full article » + +# PEOPLE + +# McDermott Brings 2 New Partners To New York Office + +McDermott Will & Emery LLP has boosted the corporate practices at its New York office with two new partners, one specializing in restructuring, the other in real estate. + +Read full article » + +# EXPERT ANALYSIS + +#### Opinion + +#### #MeToo Defendant Bankruptcies Can Delay, Not Deny, Justice + +Institutional defendants facing sexual abuse claims are increasingly using bankruptcy filings to freeze litigation, and those representing survivors need to be aware of the different rules, deadlines and discovery procedures in the new venue to ensure their clients' claims are not lost, says Michelle Tuegel of Seeger Weiss. + +Read full article » + +# LEXIS PRACTICE ADVISOR + +# How NYC's New Tenant Protection Law Will Affect Owners + +Citigroup Inc. + +Democratic National Committee Equifax Inc. + +First Republic Bank + +Fordham University + +GitHub Inc. + +Hitachi Ltd. + +Intel Corp. + +KPMG International + +LVMH Group + +LexisNexis Group + +MetLife Inc. + +Mount Sinai Hospital + +NASDAQ OMX Group Inc. + +Nike Inc. + +RELX PLC + +S&P Global Inc. + +Shire PLC + +Sotheby's + +The Abraaj Group + +The Valspar Corporation + +Trimble Inc. + +Twitter Inc. + +USG Corp. + +United Surgical Partners International Inc. + +Vornado Realty Trust + +Wells Fargo & Co. + +Welsh Carson Anderson & Stowe + +#### GOVERNMENT AGENCIES + +Arizona Supreme Court + +Federal Bureau of Investigation + +Federal Election Commission + +Internal Revenue Service + +New York Attorney General's Office + +Securities and Exchange Commission + +Solicitors Regulation Authority + +U.S. Attorneys Office + +U.S. Court of Appeals for the Fifth Circuit + +U.S. Court of Appeals for the Second Circuit + +U.S. District Court for the Central District of California + +U.S. District Court for the Eastern District of New York + +U.S. District Court for the Eastern District of Pennsylvania + +U.S. District Court for the Northern District of Texas + +provides rent-regulated tenants with protections not seen before in recent memory, says YuhTyng Patka of Duval & Stachenfeld. + +Read full article » + +# LEGAL INDUSTRY + +# Global 20: Baker McKenzie + +Baker McKenzie LLP has spent the past year helping clients navigate multibillion-dollar transactions that span continents, including Japanese giant Hitachi's \$11 billion purchase of a Swiss power grid business, landing the firm on Law360's Global 20 list for the ninth year in a row. + +Read full article » + +#### Senate OKs Greenberg Vet In Race To Confirm 19 Judges + +The U.S. Senate confirmed three new judges — including a Greenberg Traurig attorney — for Arizona, Texas and North Dakota district courts Tuesday in the first round of a wave of President Donald Trump's judicial picks Republicans want to clear before leaving for recess at week's end. + +Read full article » + +# Ex-Trump Adviser Returns To Baker Donelson Via Alliance + +A recently departed policy adviser to President Donald Trump has returned to Baker Donelson, inking a strategic alliance to work for the law firm in Washington, D.C., a Tuesday announcement said. + +Read full article » + +# Ex-Ogletree Lawyers Abandon Push To Take Over Bias Suit + +Two female attorneys who sought to take the helm of a suit accusing employment law giant Ogletree Deakins Nash Smoak & Stewart PC of systemic sex discrimination after the original plaintiff was forced into arbitration have dropped their claims, according to a California federal court filing. + +Read full article » + +# Baker McKenzie Accused Of Mishandling Sex Assault Claim + +Attorney regulatory authorities in the U.K. have referred Baker McKenzie LLP to the country's disciplinary tribunal over allegations the firm allowed a thenpartner in London to sully a 2012 internal sexual assault investigation, documents made public Tuesday show. + +Read full article » + +# White & Williams Slams 'Small-Bore' Claims In Atty Bias Suit + +White and Williams LLP fired back Tuesday against a May lawsuit from one of its attorneys alleging a culture of rampant racial and gender bias in the workplace, writing off the claims as a "catalogue of small-bore grievances" that failed to show any actual discrimination. + +Read full article » + +# Jones Day Pro Bono Work 'Was A Fiasco,' Ex-Clients Claim + +Two Orange County mobile home owners say Jones Day provided pro bono legal services that were "a fiasco" and ultimately left them homeless, according to a suit filed in California state court. + +Read full article » + +# Dentons To Combine With Heavyweight New Zealand Firm + +Dentons and leading New Zealand law firm Kensington Swan intend to combine, they said Tuesday, allowing both to expand their presence in the Australasian region and connect clients to a greater range of legal experts. + +Read full article » + +U.S. District Court for the Southern District of New York + +U.S. District Court for the Western District of Washington + +U S House of Representatives + +U.S. Senate + +U.S. Supreme Court + +United Nations + +music industry copyright associate Schoen Legal Search New York, New York + +Intellectual Property Assistant Knobbe Martens Olson & Bear, LLP New York, New York + +NYC\*Corp\*Assoc•Mid-sized\*Lifestyle Schoen Legal Search NYC, New York + +Banktcy Boutique Counsel/Partner Schoen Legal Search NYC, New York + +Real Estate Associate Hunton Andrews Kurth LLP New York, New York + +Paralegal, IP Litigation Baker & McKenzie New York, New York + +Junior Level Construction Associate Duane Morris New York, New York + +M&A Associate Perkins Cole LLP New York, New York + +Mid-sized NY LF seeks add'tl up-andcoming partners PB \$1M+ Schoen Legal Search New York, New York + +Stellar mid-sized firm seeks outstanding mid level m&a atty Schoen Legal Search NYC, New York + +elite lit boutique // mid level assoc Schoen Legal Search New York, New York + +Litigation Funding Business Developer North America Deminor Recovery Services New York, New York + +ECVC Associate Attorney Perkins Cole LLP New York, New York + +Summer Program 2020 Hunton Andrews Kurth LLP New York, New York + +Not sure if your firm subscribes? 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0000000000000000000000000000000000000000..2ebe142036abab310be6cd13c2ee10e54b8f053a --- /dev/null +++ b/marker2/ds9/EFTA00083902/EFTA00083902.md @@ -0,0 +1,19 @@ +To: + +Subject: Re: Epstein Oath Return + +Date: Thu, 01 Aug 2019 19:07:14 +0000 + +Thanks! Could you please put a copy in the second production folder? + +Sent from my iPhone + +On Aug 1, 2019, at 1:13 PM, [Contractor] < > wrote: + +Hi guys, + +In the process of comparing sub oena returns with the FBI, the ave us an Oath roduction that I do not believe we previously had. It is saved here: + +air + +raraiegai speciaust United States Attorney's Office Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00083902/EFTA00083902.metadata.json b/marker2/ds9/EFTA00083902/EFTA00083902.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ce68e8a0be07d1ab83b322373ae9276d9efb5f25 --- /dev/null +++ b/marker2/ds9/EFTA00083902/EFTA00083902.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083902.pdf", + "engine": { + "marker_major": "2", + "marker_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": 466, + "elapsed_seconds": 0.57, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 16 + ], + [ + "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/EFTA00083902" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083903/EFTA00083903.md b/marker2/ds9/EFTA00083903/EFTA00083903.md new file mode 100644 index 0000000000000000000000000000000000000000..830e8753c7656c7a8e661e49cce86f2c34528cbb --- /dev/null +++ b/marker2/ds9/EFTA00083903/EFTA00083903.md @@ -0,0 +1,15 @@ +To + +Subject: RE: U.S. V EPSTEIN, JEFFREY + +Date: Thu, 01 Aug 2019 15:15:05 +0000 + +Received, thank you I + +From + +Sent: Thursday, August 1, 2019 7:41 AM + +To: + +Subject: U.S. V EPSTEIN, JEFFREY \ No newline at end of file diff --git a/marker2/ds9/EFTA00083903/EFTA00083903.metadata.json b/marker2/ds9/EFTA00083903/EFTA00083903.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6af400d8dc4c67db789e5458a663982eb2351cf0 --- /dev/null +++ b/marker2/ds9/EFTA00083903/EFTA00083903.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083903.pdf", + "engine": { + "marker_major": "2", + "marker_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": 187, + "elapsed_seconds": 0.48, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 20 + ], + [ + "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/EFTA00083903" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083904/EFTA00083904.md b/marker2/ds9/EFTA00083904/EFTA00083904.md new file mode 100644 index 0000000000000000000000000000000000000000..50d951bfdd7af11486f3cd8f783a52cd10e3c943 --- /dev/null +++ b/marker2/ds9/EFTA00083904/EFTA00083904.md @@ -0,0 +1,13 @@ +To: + +Subject: Epstein Oath Return + +Date: Thu, 01 Aug 2019 17:13:35 +0000 + +Hi guys, + +In the process of comparing subpoena returns with the FBI, they gave us an Oath production that I do not believe we previously had. It is saved here: + +Thanks, + +Paralegal Specialist United States Attorney's Office Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00083904/EFTA00083904.metadata.json b/marker2/ds9/EFTA00083904/EFTA00083904.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5ff8049f05a146f884b98dbca9d04b622483e26a --- /dev/null +++ b/marker2/ds9/EFTA00083904/EFTA00083904.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083904.pdf", + "engine": { + "marker_major": "2", + "marker_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": 326, + "elapsed_seconds": 0.57, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 12 + ], + [ + "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/EFTA00083904" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083905/EFTA00083905.md b/marker2/ds9/EFTA00083905/EFTA00083905.md new file mode 100644 index 0000000000000000000000000000000000000000..c8048792f0ca477fe9ee1bde0ec8b3a7bba73248 --- /dev/null +++ b/marker2/ds9/EFTA00083905/EFTA00083905.md @@ -0,0 +1,89 @@ +From: ' < To: "cl aiNYS)" < (USANYS)" + +Subject: FW: Thank you + +Date: Fri, 26 Jul 2019 20:05:05 +0000 + +From: Sent: Friday, July 26, 2019 4:03 PM To: Bruce Barket < Cc: Subject: Re: Thank you + +Hi Bruce, + +I was on my way out the door, but notified medical and psych staff of the below. I also asked that he be ready tomorrow morning for your visit. + +Thank you, + +>> > Bruce Barket > 7/26/2019 3:56 PM >> > Nick's parents just left him and described him as nearly incoherent. + +Said he is as bad as he has ever been. + +I want to see him tomorrow at 8:00 but I am hoping someone can check on him tonight + +Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 + +On Jul 26, 2019, at 3:38 PM, wrote: + +Bruce, + +Thanks for the kind words. We are happy to help. Have a great weekend. + +>> > Bruce Barket < > 7/26/2019 8:15 AM > » + +I am not shy about complaining so I figure I should also acknowledge the good work done. I met with Nick last night and he told me that you personally checked in on him and swapped out his books. Thank you. + +Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP 666 Old Country Road , Ste. 700 Garden City, NY 11530 + +[REDACTED] + +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:** [REDACTED] [mailto: [REDACTED]] +**Sent:** Thursday, July 25, 2019 9:50 AM +**To:** Bruce Barket +**Cc:** [REDACTED]; [REDACTED] +**Subject:** Re: Fwd: Jeffrey Epstein/Nicholas Tartaglione + +Good morning Bruce, + +Please be advised that this matter is currently the subject of an open investigation, and, thus, I am limited in what I can discuss at this time. I have not shared any information with the press or the public, and I am not aware of any other MCC staff doing so either. As this is an open investigation, no information can be shared with outside parties until the investigation is complete. Once the investigation is concluded, I will be able to provide you more information. I have reminded MCC administrators to caution staff that they are not to retaliate against your client or any inmate. Please let me know if you have any further questions or concerns. + +Thank you, + +[REDACTED] + +> > > Bruce Barket <[REDACTED]> 7/24/2019 11:30 PM > > > + +This comes on the heels of our complaints to the Court. It seems someone in your facility has leaked false information about Nick. + +Bruce Barket + +Barket, Epstein, Kearon, Aldea & LoTurco + +666 Old Country road + +Garden City, NY 11530 + +[REDACTED] + +Begin forwarded message: + +**From:** Tracy Connor <[REDACTED]> + +**Date:** July 24, 2019 at 11:08:48 PM EDT + +**To:** [REDACTED] + +**Subject:** Jeffrey Epstein/Nicholas Tartaglione + +Hello, + +Trying to confirm this NBC story that says your client was questioned about a possible attack on Jeffrey Epstein at the MCC. I'm at [REDACTED]. Can you call? + +Tracy Connor + +Executive editor + +[REDACTED] + +![](_page_1_Picture_171.jpeg) + +**Join [Beast Inside](#), our new membership program, to get more of the journalism you trust and love.** \ No newline at end of file diff --git a/marker2/ds9/EFTA00083905/EFTA00083905.metadata.json b/marker2/ds9/EFTA00083905/EFTA00083905.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6acfe362ec3e725a6577ada0e65973c65abf04fe --- /dev/null +++ b/marker2/ds9/EFTA00083905/EFTA00083905.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083905.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3455, + "elapsed_seconds": 9.08, + "image_assets": [ + "_page_1_Picture_171.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 74 + ], + [ + "Line", + 33 + ], + [ + "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": "surya", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Text", + 55 + ], + [ + "Line", + 38 + ], + [ + "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/EFTA00083905" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083905/_page_1_Picture_171.jpeg b/marker2/ds9/EFTA00083905/_page_1_Picture_171.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..93dd78dd5265c97333ecf7d267f2e2c67b7b2a7e --- /dev/null +++ b/marker2/ds9/EFTA00083905/_page_1_Picture_171.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:5317cc6f1acfa782e2636ba661218eb41a1c70093c5de9b568f6cb6cd3da5382 +size 952 diff --git a/marker2/ds9/EFTA00083907/EFTA00083907.md b/marker2/ds9/EFTA00083907/EFTA00083907.md new file mode 100644 index 0000000000000000000000000000000000000000..de35cfd2b0de6a1791bf476b790666eb95362b39 --- /dev/null +++ b/marker2/ds9/EFTA00083907/EFTA00083907.md @@ -0,0 +1,49 @@ +From: 'S" + +To: "Moyer, Thomas" + +Cc: "Moyne, Parvin" "Benjamin, James" + +, Andrew Stemmer + +Subject: RE: Deutsche Bank Production + +Date: Thu, 01 Aug 2019 00:34:46 +0000 + +Tom, + +Received, thanks. Following up on our previous conversation (and copying Andrew since I think we discussed this with him), could you please let us know the current status on us being able to meet with someone (or someones) who can talk with us in general terms about the nature of Epstein's accounts and their activities? Also, do you have a sense — or if not, do you know when you'll have a sense — of what the overall production volume is likely to be, and the approximate timeline for complete production? The answer may be that you're not sure yet, which would be understandable, but we wanted to check. + +thanks, + +From: Moyer, Thomas - + +Sent: Tuesday, July 30, 2019 15:49 + +To: + +Cc: Moyne, Parvin Benjamin, James c + +Subject: Deutsche Bank Production + +On behalf of our client, Deutsche Bank, the link below contains an additional production of documents in response to your July 11, 2019 subpoena. Also attached is the accompanying cover letter for today's production. The password to access these materials is the same as it was for the previous submissions. For your convenience, I will recirculate it momentarily under separate cover. + +Please do not hesitate to reach out if you have any questions. + +Regards, + +Tom + +## Citrix Attachments Expires January 26, 2020 + +DB-SDNY-Prod0O4.zip 67.L MB + +Download Attachments + +AKIN GUMP STRAUSS HAUER & FELD LLp + +2001 K Street N.W. Washington, DC 20006 I USA I Direct i I Internal= + +Fax: akingump.com I No + +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. \ No newline at end of file diff --git a/marker2/ds9/EFTA00083907/EFTA00083907.metadata.json b/marker2/ds9/EFTA00083907/EFTA00083907.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9e5e093ee76393a816ef8b5eaa89e19d65326687 --- /dev/null +++ b/marker2/ds9/EFTA00083907/EFTA00083907.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083907.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1880, + "elapsed_seconds": 1.18, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Citrix Attachments Expires January 26, 2020", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 45.9, + 617.22 + ], + [ + 410.9778747558594, + 617.22 + ], + [ + 410.9778747558594, + 632.3340759277344 + ], + [ + 45.9, + 632.3340759277344 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 33 + ], + [ + "Text", + 24 + ], + [ + "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", + 16 + ], + [ + "Line", + 8 + ], + [ + "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/EFTA00083907" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083909/EFTA00083909.md b/marker2/ds9/EFTA00083909/EFTA00083909.md new file mode 100644 index 0000000000000000000000000000000000000000..5491cbe56e7a178ad8703d9e77511e94b3303b59 --- /dev/null +++ b/marker2/ds9/EFTA00083909/EFTA00083909.md @@ -0,0 +1,33 @@ +To: ' + +Cc: ' + +Subject: RE: SDNY investigation + +Date: Thu, 01 Aug 2019 03:02:40 +0000 + +I write to follow up on our conversation the week before last regardin Is there a good time to talk early next week about the status of your discussions with him, and when we can schedule a time to speak with him directly? + +you, + +From: + +Sent: rtr ay u y + +To: + +Cc: + +Subject: RE: SDNY investigation /- + +Arthur, + +Following up on our phone conversation a few minutes ago, thank you for being in touch and advising us of your representation an connection with his receipt of a grand jury subpoena, which is attached. So you have contact info for our full team, we're all reachable anytime at the copied emails or by phone at: + +As we discussed on the phone, I understand you'll need to have the opportunity to speak with him further, and so it's fine for us to speak mid-next week. And as I also mentioned, we don't currently have any reason to believe that has done anything wrong; we would like to speak with him about his knowledge of and interactions with Jeffrey Epstein, particularly in connection with recent statements he has made to the press about comments Epstein made to him about Epstein's prior conduct. + +Please let us know if any additional information would be helpful, and we look forward to being in touch with you next week. + +thank you, + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00083909/EFTA00083909.metadata.json b/marker2/ds9/EFTA00083909/EFTA00083909.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4753d6c143548df811c378c183809b35249dd5f8 --- /dev/null +++ b/marker2/ds9/EFTA00083909/EFTA00083909.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083909.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1390, + "elapsed_seconds": 0.91, + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00083909" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083910/EFTA00083910.md b/marker2/ds9/EFTA00083910/EFTA00083910.md new file mode 100644 index 0000000000000000000000000000000000000000..f463f9d521fbd38f403286dcda0029902759fac1 --- /dev/null +++ b/marker2/ds9/EFTA00083910/EFTA00083910.md @@ -0,0 +1,11 @@ +From: + +To:' . aNIMIE' + +Subject: Epstein + +Date: Thu, 01 Aug 2019 13:39:54 +0000 + +I'll have the reports tomorrow but I have a preliminary of the interviews + +Sent from my iPhone \ No newline at end of file diff --git a/marker2/ds9/EFTA00083910/EFTA00083910.metadata.json b/marker2/ds9/EFTA00083910/EFTA00083910.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ee12ada16a10c715b2f794860afb5ef85c80de3c --- /dev/null +++ b/marker2/ds9/EFTA00083910/EFTA00083910.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083910.pdf", + "engine": { + "marker_major": "2", + "marker_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": 174, + "elapsed_seconds": 0.37, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "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/EFTA00083910" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083911/EFTA00083911.md b/marker2/ds9/EFTA00083911/EFTA00083911.md new file mode 100644 index 0000000000000000000000000000000000000000..ddd8a310d24b055a26ccaf2db87fc30e60ffc014 --- /dev/null +++ b/marker2/ds9/EFTA00083911/EFTA00083911.md @@ -0,0 +1,17 @@ +## Unable to Respond + +June 01. 2019 + +T-Mobile / MetroPCS Tracking ID: 2321537 + +Target Identifier(s): + +T-Mobile / MetroPCS is unable to respond to your legal demand for the following reasons: + +The target telephone number is not associated with a T-Mobile or MetroPCS subscriber during the date range identified in the legal demand. + +AT&T # + +T-Mobile Law Enforcement Relations Phone: Fax: + +Email: \ No newline at end of file diff --git a/marker2/ds9/EFTA00083911/EFTA00083911.metadata.json b/marker2/ds9/EFTA00083911/EFTA00083911.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..46c2a6498e82df2d5cd205da5211543553470276 --- /dev/null +++ b/marker2/ds9/EFTA00083911/EFTA00083911.metadata.json @@ -0,0 +1,86 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083911.pdf", + "engine": { + "marker_major": "2", + "marker_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": 394, + "elapsed_seconds": 0.72, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Unable to Respond", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 208.84499999999997, + 76.2042236328125 + ], + [ + 389.0149841308594, + 76.2042236328125 + ], + [ + 389.0149841308594, + 101.16241455078125 + ], + [ + 208.84499999999997, + 101.16241455078125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 26 + ], + [ + "Line", + 13 + ], + [ + "Text", + 11 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00083911" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083912/EFTA00083912.md b/marker2/ds9/EFTA00083912/EFTA00083912.md new file mode 100644 index 0000000000000000000000000000000000000000..9a0732d5647d7314e715d024feff7c479dbd06e4 --- /dev/null +++ b/marker2/ds9/EFTA00083912/EFTA00083912.md @@ -0,0 +1,13 @@ +## Secured Message Reply + +From: Matthew Goldsmith To: Recipients ca , Date: 07124,2019 08:13:41 PM GMT Subject: Your LERT Case case packet feed "anal' Response vnomppsecure Attachments: ematzip + +Attached is your case response for case packet titled 'email" + +LERT comments: The target MON was with T-Mobile between 10/07/2002 - 11/22/2012. You may contact them ate Thank you + +Thanks, LERT Team + +This email was sent using elert-email-service + +Reply \ No newline at end of file diff --git a/marker2/ds9/EFTA00083912/EFTA00083912.metadata.json b/marker2/ds9/EFTA00083912/EFTA00083912.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..997294685df261c2b4908bff3e90a3b595f2d185 --- /dev/null +++ b/marker2/ds9/EFTA00083912/EFTA00083912.metadata.json @@ -0,0 +1,82 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083912.pdf", + "engine": { + "marker_major": "2", + "marker_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": 446, + "elapsed_seconds": 0.53, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Secured Message Reply", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 0.0, + 140.377 + ], + [ + 1003.9992065429688, + 140.377 + ], + [ + 1003.9992065429688, + 155.08900000000003 + ], + [ + 0.0, + 155.08900000000003 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 30 + ], + [ + "Line", + 14 + ], + [ + "Text", + 7 + ], + [ + "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/EFTA00083912" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083913/EFTA00083913.md b/marker2/ds9/EFTA00083913/EFTA00083913.md new file mode 100644 index 0000000000000000000000000000000000000000..3162f86f535de7b965f886c189e80d3b044d5244 --- /dev/null +++ b/marker2/ds9/EFTA00083913/EFTA00083913.md @@ -0,0 +1,25 @@ +**BUSINESS RECORDS DECLARATION** + +Request for information regarding: + +[REDACTED] + +) +) +) + +**DECLARATION OF** + +Alyssa Anderson + +I, Alyssa Anderson, declare: + +1. 1. I am a Custodian of Records for Oath Holdings Inc. ("Oath") (formerly Yahoo Holdings, Inc.), located in Sunnyvale, California. I am authorized to submit this declaration on behalf of Oath. I make this declaration pursuant to the Federal Rules of Evidence Rule 902(11) and the California Code of Evidence section 1561 and in response to a subpoena dated December 19, 2018 ("the request"). I have personal knowledge of the following facts, except as noted, and could testify competently thereto if called as a witness. +2. 2. Attached hereto are true and correct copies of the following data pertaining to the user accounts identified in the request: (1) the user profile, as produced by the Yahoo Account Management Tool and (2) the dates, times, and Internet protocol addresses for logins and authentication events (if any), as produced by the Yahoo Login Tracker Tool. Oath's servers record this data automatically at the time, or reasonably soon after, it is entered or transmitted, and this data is kept in the course of this regularly conducted activity and was made by regularly conducted activity as a regular practice. Oath may not require or verify user information because it offers many of its services to users for free. +3. 3. To the extent any document attached hereto contained information that exceeded the scope of the request, is protected from disclosure, or is otherwise not subject to production, such information has been redacted or otherwise removed. + +I declare under penalty of perjury under the laws of the United States of America and the State of California that the foregoing is true and correct. + +DATED: January 15, 2019 + +![]() \ No newline at end of file diff --git a/marker2/ds9/EFTA00083913/EFTA00083913.metadata.json b/marker2/ds9/EFTA00083913/EFTA00083913.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..01f5a1e4f58432c27f075a82867fcb8f3895365f --- /dev/null +++ b/marker2/ds9/EFTA00083913/EFTA00083913.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083913.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1820, + "elapsed_seconds": 6.46, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "BUSINESS RECORDS DECLARATION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 206.24400000000003, + 52.650000000000006 + ], + [ + 404.532, + 52.650000000000006 + ], + [ + 404.532, + 64.80000000000001 + ], + [ + 206.24400000000003, + 64.80000000000001 + ] + ] + }, + { + "title": "DECLARATION OF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 351.9, + 88.28999999999999 + ], + [ + 457.164, + 88.28999999999999 + ], + [ + 457.164, + 101.25 + ], + [ + 351.9, + 101.25 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 26 + ], + [ + "Text", + 19 + ], + [ + "SectionHeader", + 4 + ], + [ + "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/EFTA00083913" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083914/EFTA00083914.md b/marker2/ds9/EFTA00083914/EFTA00083914.md new file mode 100644 index 0000000000000000000000000000000000000000..41575f0e268e923d503266f59af549e751179445 --- /dev/null +++ b/marker2/ds9/EFTA00083914/EFTA00083914.md @@ -0,0 +1,3 @@ +## YAHOO! ACCOUNT MANAGEMENT TOOL + +Login Name: littlestjeff GUID: 3DNS3FBDXA2C72WVMAMSXS4JHU Properties Used: Mail Yahoo Mail Name: littlestjeff@yahoo.com Alternate Communication Channels: jeevacation@gmail.com unverified 1 Verified Registration IP address: 208.14.24.156 Account Created (reg): Sun Feb 6 17:18:53 2000 GMT Other Identities: littlestjeff jeffrey.epstein Full Name Mr jeffrey epstein Addressl: 457 madison av e Address2: City: new york State, territory or province: NY Country: United States Zip/Postal Code: 10019 Phone: Time Zone: et Business Name: Business Address: Business City: Business State: Business Country: us Business Zip: Business Phone: Business Email: Account Status: Active \ No newline at end of file diff --git a/marker2/ds9/EFTA00083914/EFTA00083914.metadata.json b/marker2/ds9/EFTA00083914/EFTA00083914.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fd5075f75ca73c5147538cfd027dffa01e18d85b --- /dev/null +++ b/marker2/ds9/EFTA00083914/EFTA00083914.metadata.json @@ -0,0 +1,82 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083914.pdf", + "engine": { + "marker_major": "2", + "marker_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": 704, + "elapsed_seconds": 0.26, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "YAHOO! 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ACCOUNT MANAGEMENT TOOL + +Login Name: jeeproject GUID: UTUZHOMWKDGHXAXIBISCKY7A34 Properties Used: Mail Yahoo Mail Name: jeeproject@yahoo.com Alternate Communication Channels: jeevacation@gmail.com Verified 1 2125333739 Verified Registration IP address: 64.132.93.8 Account Created (reg): Mon Apr 2 14:00:24 2001 GMT Other Identities: jeeproject (Yahoo! Mail) jeffrey.newyork Full Name Mr Jeffrey Epstein Addressl: Address2: City: New York State, territory or province: NY Country: United States Zip/Postal Code: 10022 Phone: Time Zone: et Business Name: Business Address: 457 Madison Ave. 4th Floor Business City: New York Business State: NY Business Country: us Business Zip: 10022 Business Phone: 212-750.9895 Business Email: Account Status: Active \ No newline at end of file diff --git a/marker2/ds9/EFTA00083915/EFTA00083915.metadata.json b/marker2/ds9/EFTA00083915/EFTA00083915.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..13557bb06cd9d4dbfbb24a60232d6cc26b68a2cc --- /dev/null +++ b/marker2/ds9/EFTA00083915/EFTA00083915.metadata.json @@ -0,0 +1,82 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083915.pdf", + "engine": { + "marker_major": "2", + "marker_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": 760, + "elapsed_seconds": 0.25, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "YAHOO! 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August 1.2019 7:24 PM To: Subject: FW: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to + +Ori inal Messa e + +I'd suggest a call for late Monday afternoon, if that works. + +Original Message + +From: Bloom, Suzanne Jaffe aa Sent: Thursday. August 1.2019 7:20 PM To: Cc: Hud ens, Johanna Rae Subject: Re: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to + +Hi all. Thanks again for your time yesterday. Just checking in to see when you'd like to continue our conversation. Please let us know what would work best for you. + +Many thanks, Suzanne + +Suzanne Jaffe Bloom + +Partner + +Winston & Strawn LLP 200 Park Avenue New York, NY 10166-4193 + +Bio VCard I Email + +On Jul 30 2019, at 1:54 PM mailto: > 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 ct >> + +Sent: Tuesda Jul 30 2019 13:22 + +To: mailto: + +Bloom Suzanne Jaffe + +Cc: 1 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 + +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 + +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] [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]>> + +Subject: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to [REDACTED] [REDACTED] + +Hi [REDACTED]. 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 + +We look forward to hearing back from you regarding the above. Many thanks. + +Best, Suzanne + +Suzanne Jaffe Bloom + +Partner + +Winston & Strawn LLP + +200 Park Avenue New York, NY 10166-4193 + +Bio VCardI 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. 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. \ No newline at end of file diff --git a/marker2/ds9/EFTA00083916/EFTA00083916.metadata.json b/marker2/ds9/EFTA00083916/EFTA00083916.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ea659db321a48946cc0128f40eb1d693ce163514 --- /dev/null +++ b/marker2/ds9/EFTA00083916/EFTA00083916.metadata.json @@ -0,0 +1,144 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083916.pdf", + "engine": { + "marker_major": "2", + "marker_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": 6440, + "elapsed_seconds": 10.63, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 33 + ], + [ + "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", + 78 + ], + [ + "Line", + 38 + ], + [ + "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": "surya", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Text", + 50 + ], + [ + "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": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "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/EFTA00083916" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083920/EFTA00083920.md b/marker2/ds9/EFTA00083920/EFTA00083920.md new file mode 100644 index 0000000000000000000000000000000000000000..b6e3d140c496a346168b6e5d36d80d1f35b549e5 --- /dev/null +++ b/marker2/ds9/EFTA00083920/EFTA00083920.md @@ -0,0 +1,31 @@ +To: + +Cc: + +Subject: Deutsche Bank Production + +Date: Fri, 02 Aug 2019 22:09:56 +0000 + +Attachments: 2019.08.02\_DB\_Submission\_to\_SDNY.pdf; Attachments.html + +On behalf of our client, Deutsche Bank, the link below contains an additional production of documents in response to your July 11, 2019 subpoena. Also attached is the accompanying cover letter for today's production. The password to access these materials is the same as it was for the previous submissions. For your convenience, I will recirculate it momentarily under separate cover. + +Please do not hesitate to reach out if you have any questions. + +Regards, + +## Citrix Attachments Expires January 29, 2020 + +DB-SDNY-Prod005.zip 219.8 MB + +Download Attachments + +Thomas Moyer uses Citrix Files to share documents securely. + +AKIN GUMP STRAUSS HAUER & FELD LLF, + +2001 K Street N.W. j Washington, DC 20006 j USA Direct: +1202.887.4528 i Internal: 24528 + +fl + +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. \ No newline at end of file diff --git a/marker2/ds9/EFTA00083920/EFTA00083920.metadata.json b/marker2/ds9/EFTA00083920/EFTA00083920.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b8ee13dcf75e783712a0397d9b24c50cf25749d7 --- /dev/null +++ b/marker2/ds9/EFTA00083920/EFTA00083920.metadata.json @@ -0,0 +1,82 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083920.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1168, + "elapsed_seconds": 1.03, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Citrix Attachments Expires January 29, 2020", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 45.9, + 386.37 + ], + [ + 410.9678649902344, + 386.37 + ], + [ + 410.9678649902344, + 402.0840759277344 + ], + [ + 45.9, + 402.0840759277344 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Line", + 23 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00083920" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083921/EFTA00083921.md b/marker2/ds9/EFTA00083921/EFTA00083921.md new file mode 100644 index 0000000000000000000000000000000000000000..973809aad5ca635543ca818f97170dcb3c15b175 --- /dev/null +++ b/marker2/ds9/EFTA00083921/EFTA00083921.md @@ -0,0 +1,40 @@ +![](_page_0_Picture_2.jpeg) + +August 2, 2019 + +## CONFIDENTIAL PURSUANT TO FED. R. CRIM. P. 6(e) + +## V►A **ELECTRONIC DELIVERY** + +![](_page_0_Picture_6.jpeg) + +**U.S. Attorney's Office Southern District of New York 1 Saint Andrew's Plaza New York, NY 10007** + +**Re: July 11, 2019 Subpoena to Deutsche Bank** + +**Dear** + +**On behalf of our client, Deutsche Bank AG, New York Branch and its affiliates ("Deutsche Bank" or the "Bank"), we write in further response to the grand jiffy subpoena dated July 11, 2019 (the "Subpoena"). This letter and the enclosed document production represent the fifth submission in our client's rolling response to the Subpoena.** + +**Enclosed with this letter is an encrypted file labeled DB-SDNY-PROD005 containing documents responsive to items 1 and 3 of the Subpoena. Specifically, the enclosed production includes certain additional "Know Your Customer" records for Jeffrey Epstein-affiliated accounts (labeled DB-SDNY-0002515 through 0002894), and account statements for Jeffrey Epstein's custody account (labeled DB-SDNY-0001711 through 0002514). The decryption password for the production will be provided by separate email. As we have discussed, we continue to collect relevant information related to the Subpoena, and expect to make additional productions shortly.** + +**Because we are producing these materials pursuant to a grand jury subpoena, it is our understanding that this production will be treated as confidential consistent with Federal Rule of Criminal Procedure 6(e). Notwithstanding the confidentiality of the enclosed materials and information, should you receive any request for disclosure of such information, pursuant to the Freedom of Information Act or otherwise, we ask to be notified in a timely fashion and given the opportunity to object to such disclosure. Further, should you determine to disclose any materials to any third party, we ask to be given reasonable advance notice in order to allow us to pursue any** + +August 2, 2019 + +[REDACTED] + +Page 2 + +available remedies. In such event, we request that you contact the undersigned by email or telephone rather than rely on regular mail or facsimile transmission to provide such notice. Please advise us if you object to or disagree with the foregoing requests. + +For the avoidance of doubt, no response or document provided in response to the Subpoena shall be construed as a waiver of any applicable privilege or doctrine available to Deutsche Bank under state or federal law. If it were found that production of any of the enclosed materials constitutes disclosure of otherwise privileged matters, such disclosure would be inadvertent. By the production of such documents, [REDACTED] does not intend to waive and has not waived the attorney-client privilege or any other protections. + +Please do not hesitate to contact us at (212) 872-1076 or [pmoyne@akingump.com](mailto:pmoyne@akingump.com) if you have any questions. We look forward to continuing to work with you in a cooperative manner. + +Sincerely, + +![]()Parvin D. Moyne +James J. 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Although I will have access to email durin m absence, my responses may be dela ed. For ur ent matters, please contact the other AUSA(s) on the case, or AUSA or \ No newline at end of file diff --git a/marker2/ds9/EFTA00083924/EFTA00083924.metadata.json b/marker2/ds9/EFTA00083924/EFTA00083924.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..33268e8041db7946d91542327a6e3055fb421bda --- /dev/null +++ b/marker2/ds9/EFTA00083924/EFTA00083924.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083924.pdf", + "engine": { + "marker_major": "2", + "marker_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": 383, + "elapsed_seconds": 0.33, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 14 + ], + [ + "Line", + 7 + ], + [ + "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/EFTA00083924" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083925/EFTA00083925.md b/marker2/ds9/EFTA00083925/EFTA00083925.md new file mode 100644 index 0000000000000000000000000000000000000000..fe6172aa536dc9d2fd7319a9f86743eea867fae7 --- /dev/null +++ b/marker2/ds9/EFTA00083925/EFTA00083925.md @@ -0,0 +1,93 @@ +To: + +Cc: + +Subject: RE: Brief Exhibits + +Date: Sat, 27 Feb 2021 02:23:35 +0000 + +Attachments: Brief Exhibits.zip + +Of course — it's attached. Thanks! + +From: + +Sent: Friday, February 26, 2021 9:22 PM + +To: Cc: + +Subject: RE: Brief Exhibits + +Thanks Would you please unencrypt the zip? We're going to be sending it to the Court. + +From USANYS) [Contractor] + +Sent: Friday, February 26, 2021 9:20 PM + +To: (USANYS) + +Cc: Bohrer, William (USANYS) [Contractor] >; + +Subject: RE: Brief Exhibits + +Absolutely! Zip of the exhibits is attached; the password is + +If you'd like the zip unencrypted or under a different name, please let me know — it's easy for me to change. Thanks, all! + +From: + +Sent: Friday, February 26, 2021 9:11 PM + +To + +C + +Subject: RE: Brief Exhibits + +Thanks,— can you please send us a zip of the exhibits? Thanks! + +From: + +Sent: Friday, February 26, 2021 7:31 PM + +To: + +Cc: + +Subject: RE: Brief Exhibits + +From Sent• n a e rua : + +To Cc + +Su ject: : Brie x i its + +Can you please make sure the metadata is scrubbed from the current versions of the exhibits? (I know we made some changes since you sent this email). + +Thanks, + +From: Sent: Friday, February 26, 20215:46 PM + +To: Cc: + +Subject: RE: Brief Exhibits + +Hi, all! I've stamped the first versions of Exhibit 5 and 7 as Confidential, and redacted the second versions of Exhibits 5 and 7; all Exhibits are saved here scrubbed metadata where possible as well. Thanks so much! Please let me know if there's anything else I can help out with where I can. + +From: Sent: Friday, February 26, 2021 4:57 PM + +To: Cc: + +Su ject: Brie Ex i its + +Thanks so much for helping out. The exhibits for the brief are located here: + +There should be two versions of each of Exhibit 5 and 7. The version that says confidential should be stamped with confidential, no redactions. The version that says redboxed just needs the redactions to be applied. The title can be Exhibit 5 (Redacted). + +Can you also please scrub the exhibits for metadata and shrink the file size of exhibits where possible? + +Please let us know if you have any questions. + +Thanks, + +United States Attorney's Office Southern District of New York One St. Andrew's Plaza 07 \ No newline at end of file diff --git a/marker2/ds9/EFTA00083925/EFTA00083925.metadata.json b/marker2/ds9/EFTA00083925/EFTA00083925.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..98ccf94a35dc782ea96e098e0585e4c95507fe42 --- /dev/null +++ b/marker2/ds9/EFTA00083925/EFTA00083925.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083925.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2156, + "elapsed_seconds": 1.56, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "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", + 63 + ], + [ + "Line", + 31 + ], + [ + "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", + 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/EFTA00083925" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083928/EFTA00083928.md b/marker2/ds9/EFTA00083928/EFTA00083928.md new file mode 100644 index 0000000000000000000000000000000000000000..e6c4c0b29d178a68f2c7771af001adb062a435f7 --- /dev/null +++ b/marker2/ds9/EFTA00083928/EFTA00083928.md @@ -0,0 +1,58 @@ +From: + +To: + +Subject: + +Date: Friday, November 30, 2018 4:01:53 PM + +From: + +Sent: Tuesday, March 8, 2016 12:28 PM + +To: + +Cc: + +Subject + +If you haven't already seen it, the Es2it reported today on Jeffrey Epstein's continued relationships with young women. + +httol/oagesix com/2016/03/08/jeffrey-eosteins-east-side-mansion-houses-russianplaymates/ + +Best, + +Pete + +From: Peter Skinner + +Sent: Monday, February 29, 2016 10:13 PM + +To: Amanda Kramer + +Cc: + +Subject: e + +am adding o this email chain as well. As we mentioned earlier today, is one of the lead attorneys on the case and knows both and the facts very well. Please include'. in any follow-up that you may. + +Best, + +From: + +Date: Monday, February 29, 2016 at 10:03 PM + +To: + +Thank you again for meeting with us today. We very much appreciate your time. I am attaching the following documents for your review: + +- 1. Complaint in the defamation case against Ghislaine Maxwell (just today, Judge Sweet denied Maxwell's motion to dismiss today); +- 2. Declarations that filed in the CVRA case; +- 3. The Rule 56.1 statement recently filed in the CVRA case; +- 4. The redacted 302 + +Please let us know what other information we can provide or if you have any further questions. + +Best, + +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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Please let me know if you need any further info. Good luck! + +From: + +Sent: , , + +To + +Subject: A question regarding a very old case + +- I saw that you were the AUSA who worked on a case several years ago against Jeffrey Epstein involving the lease of a former embassy. Do you remember anything about the case that you might be willing to share? + +Assistant U.S. Attorney + +West Palm Beach, FL 33401 \ No newline at end of file diff --git a/marker2/ds9/EFTA00083930/EFTA00083930.metadata.json b/marker2/ds9/EFTA00083930/EFTA00083930.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b4919c93b5cfeaa49fbc9452312901ea3df24926 --- /dev/null +++ b/marker2/ds9/EFTA00083930/EFTA00083930.metadata.json @@ -0,0 +1,50 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083930.pdf", + "engine": { + "marker_major": "2", + "marker_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": 542, + "elapsed_seconds": 0.82, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 19 + ], + [ + "Text", + 18 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00083930" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083931/EFTA00083931.md b/marker2/ds9/EFTA00083931/EFTA00083931.md new file mode 100644 index 0000000000000000000000000000000000000000..de8f908e4191be164913295417e6fd5a21c73bdd --- /dev/null +++ b/marker2/ds9/EFTA00083931/EFTA00083931.md @@ -0,0 +1,39 @@ +From: + +To: + +Subject: FW: Contact Info Daniel Siad (from Brunel) + +Date: Thursday. December 6. 2018 1:40:33 PM + +Attachments: 20160502 11111123 resiied tog + +FYI + +From: + +Sent: Tuesday, May 3, 2016 12:02 PM + +To: + +Cc: + +Subject: Fwd: Contact Info Daniel Siad (from Brunel) + +Yesterday I spoke of Daniel Siad, whom describes as a "scout" or recruiter of girls and/or women for J. Epstein. Attached to this incoming email from Brunel is the contact information he has for Siad. + +Best regards, + +From: + +To: + +Sent: 5/3/2016 11:13:15 A.M. Eastern Daylight Time + +Subj: (no subject) + +Sont from my Samsung Galaxy smartphone. + +![](_page_1_Picture_3.jpeg) + +CONFIDENTIAL \ No newline at end of file diff --git a/marker2/ds9/EFTA00083931/EFTA00083931.metadata.json b/marker2/ds9/EFTA00083931/EFTA00083931.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..680c2e3d405fd4c9c39ec2c868b552894bbfc668 --- /dev/null +++ b/marker2/ds9/EFTA00083931/EFTA00083931.metadata.json @@ -0,0 +1,78 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083931.pdf", + "engine": { + "marker_major": "2", + "marker_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": 650, + "elapsed_seconds": 2.14, + "image_assets": [ + "_page_1_Picture_3.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Text", + 23 + ], + [ + "Line", + 22 + ] + ], + "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": [ + [ + "Picture", + 2 + ], + [ + "Text", + 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/EFTA00083931" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083931/_page_1_Picture_3.jpeg b/marker2/ds9/EFTA00083931/_page_1_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..5b4860d70093213ad3758ea68775656d0e986c64 --- /dev/null +++ b/marker2/ds9/EFTA00083931/_page_1_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:2d3c72d227e190c1ee4355417185ac8791d05a753dafa4a756f8bea00814fed4 +size 237753 diff --git a/marker2/ds9/EFTA00083933/EFTA00083933.md b/marker2/ds9/EFTA00083933/EFTA00083933.md new file mode 100644 index 0000000000000000000000000000000000000000..504b58af298d94ac8919e7c46561203722861f0b --- /dev/null +++ b/marker2/ds9/EFTA00083933/EFTA00083933.md @@ -0,0 +1,765 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x + +Plaintiff, + +-against- + +GHISLAINE MAXWELL, + +Defendant. + +Case No.: 15-cv-07433-RWS + +\*\*CONFIDENTIAL\*\* + +x + +Continued Videotaped Deposition of GHISLAINE MAXWELL, the Defendant herein, taken pursuant to subpoena, was held at the law offices of Boies, Schiller & Flexner, LLP, 575 Lexington Avenue, New York, New York, commencing July 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. + +MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 + +1 + +2 APPEARANCES: + +3 On Behalf of the Plaintiff: + +4 BOIES SCHILLER & FLEXNER, LLP + +333 Main Street 5 Armonk, New York 10504 + +BY: DAVID BOIES, ESQUIRE + +6 + +7 + +8 BY: MEREDITH SCHULTZ, ESQUIRE + +BOIES SCHILLER & FLEXNER,LLP + +Fort Lauderdale, Florida 33301 + +SIGRID McCAWLEY, ESQUIRE + +9 SANDRA PERKINS, PARALEGAL + +10 + +FARMER JAFFE WEISSING EDWARDS FISTOS & + +11 LEHRMAN, + +12 Fort Lauderdale, Florida 33301 + +BY: BRAD EDWARDS, ESQUIRE + +13 + +14 PAUL G. CASSELL ES UIRE + +15 at ace ity, to + +16 + +J. STANLEY POTTINGER PLLC + +17 + +South Salem, New York 10590 + +18 BY: STAN POTTINGER, ESQUIRE + +19 + +On Behalf of Defendant: + +20 + +HADDON MORGAN FOREMAN 21 Attorneys for Defendant + +22 Denver, Colorado 80203 + +BY: JEFFREY S. PAGLIUCA, ESQUIRE + +23 LAURA A. MENNIGER, ESQUIRE + +24 + +Also Present: + +25 + +1 + +2 THE VIDEOGRAPHER: This is DVD No. + +3 1, Volume II, of the continued video + +4 recorded deposition of Ghislaine Maxwell + +5 in the matter against + +6 Ghislaine Maxwell, in the United States + +7 District Court, Southern District of New + +8 York. + +9 This deposition is being held at + +10 New York, New + +11 York, on July 22, 2016 at approximately + +12 9:04 a.m. + +13 My name is Rodolfo Duran. I am the + +14 legal video specialist. The court + +15 reporter is Leslie Fagin, and we are + +16 both in association with Magna Legal + +17 Services. + +18 Will counsel please introduce + +19 themselves. + +20 MR. BOIES: This is David Boies, of + +21 Boies, Schiller & Flexner, counsel for + +22 plaintiff. + +23 MS. SCHULTZ: Meredith Schultz, + +24 from Boies Schiller & Flexner, counsel + +25 for plaintiff. + +1 + +2 MR. EDWARDS: Brad Edwards, also 3 representing the plaintiff, + +4 + +5 MR. POTTINGER: Stan Pottinger, 6 also representing the plaintiff. + +7 MR. CASSELL: Paul Cassell, from 8 Salt Lake City, Utah, also representing + +9 + +10 MR. PAGLIUCA: Jeff Pagliuca and 11 Laura Menninger, on behalf of Ms. 12 Maxwell. + +13 And Ms. McCawley has also entered 14 the room, and we have an assistant from 15 Boies Schiller from the Fort Lauderdale 16 office here today as well today. + +17 THE VIDEOGRAPHER: Will the court 18 reporter please swear in the witness. + +19 GHI SLAINE MAXWEL L, 20 called as a witness, having been duly 21 sworn by a Notary Public, was 22 examined and testified as follows: + +23 EXAMINATION BY + +24 MR. BOIES: + +25 Q. Good morning, Ms. Maxwell. When + +1 G. Maxwell - Confidential + +2 MR. PAGLIUCA: Why don't we both + +3 stop making speeches. + +4 BY MR. BOIES: + +5 Q. Ms. Maxwell, let me use the term 6 that your lawyer used of sexual activities. + +7 We've been talking about intercourse and + +8 we've been talking about oral sex. + +9 Did you engage in any sexual 10 activities with Mr. Epstein other than sexual 11 intercourse and oral sex? + +12 MR. PAGLIUCA: Objection to form 13 and foundation. + +14 A. Can you ask the question again, 15 please? + +16 Q. Sure. + +17 Did you engage in any sexual 18 activities with Mr. Epstein other than what 19 you have referred to as sexual intercourse 20 and oral sex? + +21 A. No. + +22 Q. Did you engage in any sexual 23 activities with anyone other than Mr. Epstein 24 at his home in New York? + +25 MR. PAGLIUCA: Objection to form + +1 G. Maxwell - Confidential + +2 and foundation. + +3 A. No. + +4 Q. As you understand the term sexual 5 activities, what does that encompass? + +6 A. In what context are you asking? + +7 I'm not sure I understand the question. + +8 "Sexual activities" meaning kissing or 9 something? + +10 Q. Kissing, touching with hands or 11 mouths or other parts of your body. + +12 A. That would form sexual activity + +13 Q. Using sexual activity in that 14 sense, did you engage in sexual activities 15 with anyone other than Mr. Epstein at his 16 home in New York? + +17 MR. PAGLIUCA: Objection to form 18 and foundation. + +19 A. No. + +20 Q. Whenever I use the term sexual 21 activities, I will be using it in the way we 22 just defined it. Do you understand that? + +23 A. Yes. + +24 Q. Did you engage in sexual activities 25 with anyone other than Mr. Epstein at Mr. + +1 G. Maxwell - Confidential + +2 Epstein's home in Palm Beach? + +3 MR. PAGLIUCA: Objection to form + +4 and foundation. + +5 A. I did. + +6 Q. With whom? + +7 A. I don't actually have a name. + +8 Q. Did you know the name at the time? + +9 A. At the time I did. + +10 Q. When was this? + +11 A. Sometime in the '90s, the late '90s + +12 and early 2000s. + +13 Q. Was there more than one person with + +14 whom you engaged in sexual activities other + +15 than Mr. Epstein at Mr. Epstein's home in + +16 Palm Beach? If the question is unclear, I + +17 will rephrase it. + +18 A. Yes. + +19 Q. How many people other than + +20 Mr. Epstein were there with whom you engaged + +21 in sexual activities at Mr. Epstein's home in + +22 Palm Beach? + +23 A. A few. + +24 Q. How many? + +25 A. I don't have a number. + +1 G. Maxwell - Confidential + +2 Q. Approximately? + +3 A. A few. + +4 Q. More than ten? + +5 A. A few is a few. + +6 Q. Is a few more than ten? + +7 A. A few is not more than ten. + +8 Q. Is a few more than five, as you use 9 the term? + +10 A. No. + +11 Q. So it would be fewer than five 12 people? + +13 A. It's a few people. + +14 Q. But I'm saying, I'm trying to get 15 an understanding of what you mean by a few? + +16 A. I understand that. + +17 Q. And as you use the term few, can 18 that include more than five people? + +19 A. I just said it's five or less and 20 it's a few. I'm not prepared to characterize 21 a number because I just don't have a number. + +22 Q. Do you remember the names of any of 23 the people with whom you engaged in sexual 24 activities at Mr. Epstein's home in Palm 25 Beach? + +1 G. Maxwell - Confidential + +2 MR. PAGLIUCA: Objection to form 3 and foundation. + +4 A. I do not. + +5 Q. Can you describe any of the people 6 with whom you engaged in sexual activities at 7 Mr. Epstein's home in Palm Beach? + +8 MR. PAGLIUCA: Objection to form 9 and foundation. + +10 A. The description that I have is 11 somebody who is roughly my age, and I recall 12 a blond and I recall a brunette, and that's 13 pretty much what I recall. + +14 Q. And the people that you recall as 15 people with whom you engage in sexual 16 activities at Mr. Epstein's home in Palm 17 Beach, male or female or both? + +18 A. Female. + +19 Q. Where in Mr. Epstein's home in Palm 20 Beach were you when you engaged in sexual 21 activities with the females that you have 22 referred to? + +23 MR. PAGLIUCA: Objection to form 24 and foundation. + +25 A. Master bedroom. + +1 G. Maxwell - Confidential 2 only area that the witness was precluded 3 from talking about in the first 4 deposition. So that's where we're at. + +5 MR. BOIES: I think that directly 6 misreads the judge's order, including 7 where it says: Defendant is ordered to 8 answer questions relating to defendant's 9 own sexual activity with or involving 10 Jeffrey Epstein, with or involving 11 plaintiff, with or involving underage 12 females, involving or including massage 13 with individuals defendant knew to be or 14 believed might become known to Epstein. + +15 MR. PAGLIUCA: All of it is 16 preceded by the word sexual activity. + +17 MR. BOIES: I think your point of 18 view is an interesting one, but we will 19 see what the judge rules on it. + +20 BY MR. BOIES: + +21 Q. The women that you have described 22 as joining you and Mr. Epstein in three-way 23 sexual activities, were these people who you 24 believed were professional masseuses? + +25 MR. PAGLIUCA: Objection to form + +1 G. Maxwell - Confidential + +2 and foundation. + +3 A. No. + +4 Q. Did any of the women that you have + +5 said engaged with you and Mr. Epstein in + +6 three-way sexual activities give Mr. Epstein + +7 massages? + +8 MR. PAGLIUCA: Objection to form + +9 and foundation. + +10 A. I don't know. + +11 Q. Did any of them give you massages? + +12 A. No. + +13 Q. Did you engage in any sexual + +14 activities with either of these two people + +15 that you've identified as the blond and the + +16 brunette in the Virgin Islands? + +17 MR. PAGLIUCA: Objection to form + +18 and foundation. Asked and answered. + +19 A. No. + +20 Q. Were they ever in the Virgin + +21 Islands? + +22 MR. PAGLIUCA: Objection to form + +23 and foundation. + +24 A. No. + +25 Q. Did you ever see any of the women + +1 G. Maxwell - Confidential + +2 with whom you and Mr. Epstein engaged in + +3 three-way sexual activities outside of Mr. + +4 Epstein's Palm Beach home? + +5 A. Not that I recall. + +6 Q. Had you met either of them prior to + +7 the time that you and Mr. Epstein engaged in + +8 the three-way sexual activities with them? + +9 A. I don't recall. + +10 Q. Had you met them before the date, + +11 is what I'm asking you? + +12 MR. PAGLIUCA: You already asked + +13 that and she answered it. + +14 A. I don't recall. + +15 Q. When you and Mr. Epstein were + +16 engaged in sexual activity that included + +17 these other women, were any devices or sex + +18 toys used as part of the sexual activity? + +19 A. No. + +20 Q. Were you ever involved in sexual + +21 activities in Mr. Epstein's Palm Beach house + +22 that included the use of sex toys or any kind + +23 of mechanical or other device? + +24 MR. PAGLIUCA: Objection to form + +25 and foundation. + +1 G. Maxwell - Confidential + +2 A. No. + +3 Q. Were you ever involved in sexual + +4 activities in any of Mr. Epstein's properties + +5 other than Palm Beach that included the use + +6 of sex toys or any kind of mechanical or + +7 other device? + +8 A. No. + +9 Q. Were you aware of the presence of + +10 sex toys or devices used in sexual activities + +11 in Mr. Epstein's Palm Beach house? + +12 MR. PAGLIUCA: Objection to form + +13 and foundation. + +14 A. No, not that I recall. + +15 Q. Were you aware that there were sex + +16 toys or devices used in sexual activities in + +17 Mr. Epstein's New York house? + +18 A. No. + +19 Q. Were you aware that there were sex + +20 toys or devices used in sexual activities in + +21 Mr. Epstein's property in the Virgin Islands? + +22 MR. PAGLIUCA: Objection to form + +23 and foundation. + +24 A. No. + +25 Q. Were you aware whether or not there + +1 G. Maxwell - Confidential + +2 were sex toys or devices used in sexual + +3 activities in Mr. Epstein's property in the 4 Virgin Islands? + +5 MR. PAGLIUCA: Objection to form 6 and foundation. + +7 A. No. + +8 Q. Do you know whether Mr. Epstein 9 possessed sex toys or devices used in sexual 10 activities? + +11 MR. PAGLIUCA: Objection to form 12 and foundation. + +13 A. No. + +14 Q. Did you ever assist Mr. Epstein in 15 obtaining sex toys or devices used in sexual 16 activities? + +17 MR. PAGLIUCA: Objection to form 18 and foundation. + +19 A. No. + +20 Q. In the 1990s and 2000s, did you 21 ever have possession of or use sex toys or 22 devices used in sexual activities? + +23 A. No. + +24 Q. Did you, in the 1990s and 2000s, 25 engage in sexual activities other than + +1 G. Maxwell - Confidential 2 intercourse with women other than what you 3 have testified to already? + +4 MR. PAGLIUCA: First of all, I 5 object to the form and foundation and 6 it's also outside of the court's order 7 because it's unclear as you question, 8 and I specifically direct you to the 9 last line of the court's order: Sexual 10 activity of third parties who bear no 11 knowledge or relation to key events, 12 individuals or locations in this case. + +13 MR. BOIES: This simply asks yes or 14 no, and I think that it is an 15 appropriate question given some of the 16 witness' prior answers, but there is no 17 point in debating it, because if you 18 instruct her not to answer, the judge 19 will decide whether it's appropriate. + +20 MR. PAGLIUCA: I'm just telling you 21 if you tie it to something in this case, 22 I will let her answer. + +23 MR. BOIES: Are you instructing her 24 not to answer? + +25 MR. PAGLIUCA: Yes, unless you tie + +1 G. Maxwell - Confidential + +2 it to something in the case. + +3 MR. BOLES: I think it's tied, but + +4 if you instruct her not to answer, it + +5 goes into the -- + +6 MR. PAGLIUCA: Meat grinder. + +7 BY MR. BOIES: + +8 Q. At any time in any of Mr. Epstein's 9 properties, did you engage in sexual 10 activities with any woman other than when you 11 had three-way sexual activities with + +12 Mr. Epstein? + +13 MR. PAGLIUCA: Object to the form. + +14 A. Can you repeat the question? + +15 Q. At any time, in any of Mr. + +16 Epstein's properties, did you engage in 17 sexual activities with any woman other than 18 when you had three-way sexual activities with 19 Mr. Epstein? + +20 MR. PAGLIUCA: Same objection. + +21 A. No. + +22 Q. Other than yourself and the blond 23 and brunette that you have identified as 24 having been involved in three-way sexual 25 activities, with whom did Mr. Epstein have + +1 G. Maxwell - Confidential + +2 sexual activities? + +3 MR. PAGLIUCA: Objection to form + +4 and foundation. + +5 A. I wasn't aware that he was having + +6 sexual activities with anyone when I was with 7 him other than myself. + +8 Q. I want to be sure that I'm clear. + +9 Is it your testimony that in the 1990s and + +10 2000s, you were not aware that Mr. Epstein + +11 was having sexual activities with anyone + +12 other than yourself and the blond and + +13 brunette on those few occasions when they + +14 were involved with you? + +15 A. That is my testimony, that is + +16 correct. + +17 Q. Do you remember testifying earlier + +18 today that Mr. Epstein had, on a number of + +19 occasions, tried to have you join in + +20 three-way sexual activities with women other + +21 than the blond and brunette that you + +22 identified? + +23 MR. PAGLIUCA: Objection to form + +24 and foundation. + +25 A. I don't know who he was wanting me + +1 G. Maxwell - Confidential + +2 to have a three-way with. It was in general + +3 he wanted to have a three-way. It was + +4 nothing specific talked about. + +5 Q. Is it your testimony that other + +6 than the blond and brunette that you have + +7 referred to, you don't know of any particular + +8 person with whom he wanted you and he to have + +9 sex with? + +10 A. Correct. + +11 Q. But he talked to you generally + +12 about wanting to do that? + +13 A. Correct. + +14 Q. And it is your testimony that you + +15 believed that you were the only person that + +16 he was having sex with or engaging in sexual + +17 activities with other than on these few + +18 occasions, this blond and brunette, is that + +19 correct? + +20 MR. PAGLIUCA: Object to the form. + +21 Asked and answered. + +22 A. That's what I said. + +23 Q. Is that still what you say? + +24 A. Yeah, that is still what I say. + +25 Q. Do you know the reporter by the + +1 G. Maxwell - Confidential + +2 ever see + +3 A. I don't recall ever seeing her. + +4 Q. Did ever engage in any 5 sexual activity with you? + +6 A. No. + +7 Q. Did ever engage in any 8 sexual activity with Mr. Epstein? + +9 A. I wouldn't know. I would assume 10 not, but I don't know. + +11 Q. Do you have any reason to believe 12 that Mr. Epstein engaged in any sexual 13 activity with + +14 MR. PAGLIUCA: Objection to form 15 and foundation. + +16 A. I wouldn't know. + +17 Q. Did you ever give a massage to 18 anyone other than Mr. Epstein at any of Mr. 19 Epstein's properties? + +20 A. First of all, I never said I gave 21 Mr. Epstein a massage. + +22 Q. I will ask that question if you 23 want, but I was focusing on people other than 24 Mr. Epstein right now. + +25 A. I don't give massages. + +1 G. Maxwell - Confidential + +2 Q. Let's just tie that down. It is + +3 your testimony that you've never given + +4 anybody a massage? + +5 A. I have not given anyone a massage. + +6 Q. You never gave Mr. Epstein a + +7 massage, is that your testimony? + +8 A. That is my testimony. + +9 Q. You never gave a + +10 massage is your testimony? + +11 A. I never gave a + +12 massage. + +13 Q. Did you, or to your knowledge, + +14 Mr. Epstein pay for to go to + +15 Thailand? + +16 MR. PAGLIUCA: Objection to form + +17 and foundation. + +18 A. I am not aware. + +19 Q. Do you know whether + +20 went to Thailand? + +21 A. I have no knowledge of anything + +22 like that. + +23 Q. Did you ever give anyone + +24 instructions as to how to give a massage? + +25 MR. PAGLIUCA: Objection to form + +1 G. Maxwell - Confidential + +2 closed. + +3 If there are questions that I have 4 instructed the witness not to answer and 5 it later turns out the judge disagrees 6 with my characterization, we will be 7 back to revisit it, but we are done as 8 far as I'm concerned. + +9 MR. BOIES: The deposition is not 10 closed. There are a number of 11 instructions not to answer. I think it 12 is a fair point that if the court were 13 14 15 16 17 to conclude that none of the questions that have been instructed need to be answered, we're not going to be continuing the deposition, barring some additional information coming to light. + +18 19 MR. 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December 6. 2018 1:40:33 PM Attachments: 20160402 193623 resved + +FYI + +From: + +Sent: Tuesday, May 3, 2016 12:02 PM + +To: + +Cc: + +Subject: Fwd: Contact Info Paniel Siaci(from I + +Yesterday I spoke of Paniel Six( whom describes as a "scour or recruiter of girls and/or women for J. Epstein. Attached to this incoming email from is the contact information he has for F7:1I + +Best regards, + +Stan + +From: + +To: + +Sent: 5/3/2016 11:13:15 A.M. Eastern Daylight Time + +Subj: (no subject) + +Sent from my Samsung Galaxy smartphone. + +Daniel Siad + +Phone Numbers + +Mobile: +33633582532 + +Other: +32489336992 + +Email Addresses + +Email: photographtv.daniel@ gmail.com + +Notes \ No newline at end of file diff --git a/marker2/ds9/EFTA00083956/EFTA00083956.metadata.json b/marker2/ds9/EFTA00083956/EFTA00083956.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6a6378331c4528692754c5f2b1d25f4dcf4c15b2 --- /dev/null +++ b/marker2/ds9/EFTA00083956/EFTA00083956.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083956.pdf", + "engine": { + "marker_major": "2", + "marker_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": 709, + "elapsed_seconds": 1.03, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 50 + ], + [ + "Line", + 22 + ], + [ + "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", + 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/EFTA00083956" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083958/EFTA00083958.md b/marker2/ds9/EFTA00083958/EFTA00083958.md new file mode 100644 index 0000000000000000000000000000000000000000..03f40ffffddf107964f17acc2d4639b058a2481f --- /dev/null +++ b/marker2/ds9/EFTA00083958/EFTA00083958.md @@ -0,0 +1,39 @@ +From: ' To: (USANYS)" Cc: ' + +Subject: Re: SDNY Investigation + +Date: Wed, 03 Mar 2021 17:52:55 +0000 + +Yes + +Sent from my iPhone + +On Mar 3, 2021, at 12:38 PM, (USANYS) < > wrote: + +I actually just realized I have something from 10 to 11:30. Can you guys do 11:30 instead? + +Begin forwarded message: + +From: " (USANYS)" < Date: March 3, 2021 at 12:37:00 PM EST To: Nicolas CASSART Cc: ' , Nicolas BOULAY Subject: RE: SDNY Investigation + +Thanks very much for your quick reply. That time works for us and I will send a WebEx invite. If you are not able to use WebEx, please let me know. + +Best, + +From: Nicolas CASSART Sent: Wednesday, March 03, 2021 12:19 PM To: (USANYS) Cc: BOULAY Subject: RE: SDNY Investigation Nicolas + +HIM, My patner Nicolas Boulay (copied) and I would be available this coming Friday at 17 :00, our time. Can you send a teams invitation ? best + +De: (USANYS) Envoye : mercredi 3 mars 2021 17:23 A: Nicolas CASSART > + +Hi Nicolas, + +I hope this email finds you well. Together with my colleagues AUSA and AUSA (both copied), I am one of the federal prosecutors handling the ongoing investigation regarding Jeffrey Epstein and the prosecution of Ghislaine Maxwell. We are hoping to find a time to speak with you this week. Are you available for a call tomorrow or Friday? Please let us know some times that work for you. + +Thanks very much, and looking forward to speaking with you. + +Best, + +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/EFTA00083958/EFTA00083958.metadata.json b/marker2/ds9/EFTA00083958/EFTA00083958.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c6876c23c196618281e8c84f6f6f3a70e96780e6 --- /dev/null +++ b/marker2/ds9/EFTA00083958/EFTA00083958.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083958.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1497, + "elapsed_seconds": 0.8, + "image_assets": [], + 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Epstein Arrest Seizure Items + +Date: Tue, 16 Jul 2019 15:45:52 +0000 + +Importance: Normal + +Embedded: Undeliverable:\_Epstein\_Arrest\_Seizure\_Items.msg; Undeliverable:\_Epstein\_Arrest\_Seizure\_Items(1).msg + +I received bounce-back messages for two att.net emails in response to the below (attached), so just want to make sure, Marty, that you were able to receive the email at your firm email address. Thanks. + +From: + +Sent: Tuesday, July 16, 2019 11:42 + +To: 'Martin G. Weinberg' < >; 'Marc Fernich' + +Cc: 'Marty Weinberg' c a>, + +Subject: RE: Epstein Arrest Seizure Items + +Hi Marty, + +In reverse order, we're not prepared to make any generalized representations regarding any communications within the Department in its entirety, but I note for your reference that the Southern District of Florida apparently recused itself in or about March 2019, and it was only at that point, to my knowledge, that the Northern District of Georgia became involved in the CVRA case. As we have noted, our investigation had been active for several months at that time. And we will further discuss your other communications-related questions and get back to you. + +Regarding the review of electronic devices, we'll discuss internally whether we're in a position to specifically describe our review and screening process, but certainly it would be helpful in the first instance for you to provide the list of attorneys and/or firms that could implicate privilege. You can simply send that list to us—unless you have concerns that even the identities of those attorneys and firms would disclose privileged information, though I think ideally the case team would benefit from having that information as further protection against any taint. + +thanks, + +From: Martin G. Weinberg < + +Sent: Tuesday, July 16, 2019 08:31 + +To: >; 'Marc Fernich' a> 'Martin Weinberg' < MI> + +Cc: 'Marty Weinberg' < + +First, the seizure of various phones and computer-type devices from Mr Epstein and his residence. I would like to discuss the protocol for any search of the devices with the purpose of protecting the confidentiality of a vast amount of attorney-client and work product privileged communications that are within these devices. Can we schedule a call? I have assembled a preliminary list of attorneys. If the matter has been delegated to a taint prosecutor, and without waiving rights to contest the process, I would like to send the list of attorneys to that taint prosecutor. + +Second, yesterday [REDACTED] stated that there had been no communications with the SD Fla. That is not surprising since they are recused. Would you inform the defense whether there has been a similar absence of any contact with the ND Ga prosecutors (in particular [REDACTED] or with Main Justice (eg CEOS or others)? I would also want to explore with you an agreement on preserving emails, texts, voicemessages, documents that would be relevant to the genesis of the SDNY investigation given the issues that we have raised regarding the NPA. I am not by this email seeking their discovery (a future issue), only an agreement on their preservation. + +Thanks + +Marty + +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:** [REDACTED] [mailto: [REDACTED]] + +**Sent:** Monday, July 15, 2019 8:35 PM + +**To:** Marc Fernich <[REDACTED]> + +**Cc:** Marty Weinberg <[REDACTED]>; Martin Weinberg <[REDACTED]>; + +[REDACTED]; [REDACTED] <[REDACTED]>; [REDACTED] + +<[REDACTED]> + +**Subject:** RE: Epstein Arrest Seizure Items + +Marc, + +Circling back on this, I'll ask the agents to bring the cash and other personal effects seized from Mr. Epstein to the hearing on Thursday, unless it is important to receive them before then, in which case please let me know and I'll try to arrange that. With respect to the electronic devices, we've obtained a warrant to search them and so will be retaining them as evidence. + +thanks, + +[REDACTED]. + +--- + +**From:** Marc Fernich <[REDACTED]> + +**Sent:** Thursday, July 11, 2019 15:54 + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** Marty Weinberg <[REDACTED]>; Martin Weinberg <[REDACTED]>; + +[REDACTED] + +**Subject:** Epstein Arrest Seizure Items + +I'm having trouble reaching Agent [REDACTED] to coordinate pickup of the cellphone and other items seized upon Epstein's arrest. She said she'd be out in the field, but I don't hear from the intermediary agent — identity unknown — who was + +Thanks a lot. + +Marc Fernich, Esq. + +![](_page_2_Picture_3.jpeg) + +Sent from my iPhone + +On Jul 9, 2019, at 3:26 PM, > wrote: + +Marc, + +It is the right number, so feel free to follow up later, but I can also give you her cell number which is + +thanks, + +From: Marc Fernich <-> + +Sent: Tuesday, July 09, 2019 14:56 + +To: + +Cc: Marty Weinberg < ; Martin Weinberg < >; + +Subject: Re: U.S. v. Epstein, 19 Cr. 490 (RMB), Government bail memorandum + +Sorry to trouble again. No answer or VM pickup at that number. I'll try again later so long as it's the right number. Can you confirm? Many thanks. + +Marc Fernich, Esq. + +![](_page_2_Picture_18.jpeg) + +![](_page_2_Picture_19.jpeg) + +![](_page_2_Picture_20.jpeg) + +![](_page_2_Picture_21.jpeg) + +![](_page_2_Picture_22.jpeg) + +![](_page_2_Picture_23.jpeg) + +![](_page_2_Picture_24.jpeg) + +![](_page_2_Picture_25.jpeg) + +Sent from my iPhone + +On Jul 9, 2019, at 2:45 PM, ) < > wrote: + +Apologies for the delay on this, and thanks for following up. The best way to coordinate this is to contact the case agent directly – I just spoke to her so she'll be expecting your call. They're running around, so if you reach out and aren't able to connect today please let me know, but hopefully we can get it coordinated. The contact is Special Agent [REDACTED], and she can be reached at [REDACTED]. + +thanks, + +[REDACTED]. + +--- + +**From:** Marc Fernich <[REDACTED]> +**Sent:** Monday, July 08, 2019 15:40 +**To:** [REDACTED] <[REDACTED]> +**Subject:** Re: U.S. v. Epstein, 19 Cr. 490 (RMB), Government bail memorandum + +[REDACTED], + +One of your agents told Marty the case agent would return Epstein's phone, the cash and other items taken from his person upon arrest. Marty's returning to Boston shortly. Can you arrange for me to take possession of those items? + +Thanks, + +Marc + +Marc Fernich, Esq. + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +Sent from my iPhone + +On Jul 8, 2019, at 10:53 AM, [REDACTED] <[REDACTED]> wrote: + +Marc, + +Wanted to send this to you as well in case your co-counsel can't receive it in the Court. Please let me know if it would be helpful to get a hard copy – I'm copying two of our paralegals who can bring you (or co-counsel) a copy; I'll be unreachable for the next hour or so. + +thank you, + +[REDACTED] + +--- + +**From:** [REDACTED] +**Sent:** Monday, July 08, 2019 10:43 +**To:** [REDACTED] > +**Cc:** [REDACTED] >; +[REDACTED]; 'Martin Weinberg' <[REDACTED]>; [REDACTED] +<[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] + +To the Chambers of Judge Pitman: + +In advance of the expected bail argument in the above-captioned case, in connection with the presentment and arraignment referred by Judge Berman, attached please find a memorandum from the government on the issue of detention. Defense counsel is copied, as is the chambers of Judge Berman at their request. + +Thank you, + +Assistant U.S. Attorney Southern District of New York + + \ No newline at end of file diff --git a/marker2/ds9/EFTA00083961/EFTA00083961.metadata.json b/marker2/ds9/EFTA00083961/EFTA00083961.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9038fc4bb7c691ba9b7a3ea8e7798afd8ce62fbb --- /dev/null +++ b/marker2/ds9/EFTA00083961/EFTA00083961.metadata.json @@ -0,0 +1,188 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083961.pdf", + "engine": { + "marker_major": "2", + "marker_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": 7724, + "elapsed_seconds": 11.92, + "image_assets": [ + "_page_2_Picture_3.jpeg", + "_page_2_Picture_18.jpeg", + 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b/marker2/ds9/EFTA00083961/_page_2_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:24053082608e16ee5c2d20ee61d12ea15f6667a6a5f41172d3498932b490a9b5 +size 4779 diff --git a/marker2/ds9/EFTA00083966/EFTA00083966.md b/marker2/ds9/EFTA00083966/EFTA00083966.md new file mode 100644 index 0000000000000000000000000000000000000000..32c493bfaaa1e9902feb67fc5bc989854510845c --- /dev/null +++ b/marker2/ds9/EFTA00083966/EFTA00083966.md @@ -0,0 +1,77 @@ +**From:** "[REDACTED]" +**To:** "[REDACTED]", "[REDACTED]" +**Subject:** RE: SDNY investigation (re: Epstein) +**Date:** Tue, 16 Jul 2019 18:02:14 +0000 +**Importance:** Normal +**Inline-Images:** image001.png; image002.jpg + +--- + +I think we're fine to meet any time, and I can join. 5 would be better though. + +--- + +**From:** [REDACTED] +**Sent:** Tuesday, July 16, 2019 2:01 PM +**To:** [REDACTED] +**Subject:** RE: SDNY investigation (re: Epstein) + +Bumping this, they just called me again. Thoughts? + +--- + +**From:** [REDACTED] +**Sent:** Tuesday, July 16, 2019 13:17 +**To:** [REDACTED] +**Subject:** FW: SDNY investigation (re: Epstein) + +Should we do this at 5:00? Or [REDACTED] if you want, [REDACTED] and I can do it at 4:30 – totally happy to wait until you can join if you want, but if you don't care, likely won't be super exciting and we can cover. Your call. + +--- + +**From:** Christian Everdell [REDACTED] +**Sent:** Monday, July 15, 2019 22:33 +**To:** [REDACTED]; Mark S. Cohen <[REDACTED]> +**Cc:** [REDACTED] +**Subject:** RE: SDNY investigation (re: Epstein) + +Thanks for the email, [REDACTED]. We appreciate your willingness to meet with us. If you can make the time, I think it would be useful to have an introductory meeting tomorrow. Let us know what time works best for you. + +Regards, + +Chris + +Christian Everdell + +COHEN & GRESSER LLP + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +![](_page_0_Picture_133.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 at: + +From: + +Sent: Monday, July 15, 2019 7:57 PM + +To: Christian Everdell• Mark S. Cohen + +Cc: + +Subject: RE: SDNY investigation (re: Epstein) + +Chris, Mark, + +Following up on my very brief conversation with Chris earlier this afternoon, and the voicemail you left earlier, thanks for getting in touch regarding your representation of Ms. Maxwell. I understand you'll be in our neighborhood tomorrow afternoon; we can make ourselves available to meet, but will that have been enough time for you to speak with your client? Let us know what you think would be best to proceed, and we'll figure out next steps. + +thanks, + +Assistant U.S. Attorney + +Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00083966/EFTA00083966.metadata.json b/marker2/ds9/EFTA00083966/EFTA00083966.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..daa63a966dd00759813f3b797fd03eb62024f8ae --- /dev/null +++ b/marker2/ds9/EFTA00083966/EFTA00083966.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083966.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2744, + "elapsed_seconds": 5.75, + "image_assets": [ + "_page_0_Picture_133.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 32 + ], + [ + "Text", + 30 + ], + [ + "PageFooter", + 4 + ], + [ + "Picture", + 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", + 37 + ], + [ + "Line", + 19 + ], + [ + "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/EFTA00083966" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083966/_page_0_Picture_133.jpeg b/marker2/ds9/EFTA00083966/_page_0_Picture_133.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..9c00894c5d5aca20b77e6745f052258fad16b98c --- /dev/null +++ b/marker2/ds9/EFTA00083966/_page_0_Picture_133.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:bc0d70f9ba87d2fa2e83b0ef6409a98bbefba484138086fdfb5135a4bd734a43 +size 1234 diff --git a/marker2/ds9/EFTA00083968/EFTA00083968.md b/marker2/ds9/EFTA00083968/EFTA00083968.md new file mode 100644 index 0000000000000000000000000000000000000000..0d07aa7f96ca1d335cf485c2e1a7cba98eddc9c4 --- /dev/null +++ b/marker2/ds9/EFTA00083968/EFTA00083968.md @@ -0,0 +1,43 @@ +From: + +To: + +Cc: + +Subject: RE: St. Thomas airstrip employees + +Date: Mon, 22 Jul 2019 21:32:36 +0000 + +Awesome, thanks and sounds good. Let us know if you need subpoenas from us, or if anything else on our end would be helpful. + +From: + +Sent: Monday, July 22, 2019 17:30 + +To: + +Cc: + +Subject: RE: St. Thomas airstrip employees + +Already on it. Saw the articles. We've already connected with St. Thomas to get the ball rolling. + +From: + +Sent: Monday, July 22, 2019 4:13 PM + +To: + +Cc: + +Subject: RE: St. Thomas airstrip employees + +Multiple workers at the airstrip on St. Thomas have been quotes in two recent articles saying they repeatedly saw Epstein fly in with girls they believed were minors — see here, for example: + +https://www.insideccom/airport-workers-say-they-saw-jeffrey-epstein-traveling-with-teens-2019-7 + +Would it be possible to interview employees there to see if we can identify those folks (who are anonymous in the article) and get additional info? I think could be through leads or your folks, whatever is preferable for your unit. This could be relevant not just for the current case but in connection with a potential search warrant there, which I understand some of your folks have been asking about. + +thanks, + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00083968/EFTA00083968.metadata.json b/marker2/ds9/EFTA00083968/EFTA00083968.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4297b51cbc6eaeae23955683cc57c18fcf296c66 --- /dev/null +++ b/marker2/ds9/EFTA00083968/EFTA00083968.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083968.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1275, + "elapsed_seconds": 1.01, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Line", + 29 + ], + [ + "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/EFTA00083968" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083969/EFTA00083969.md b/marker2/ds9/EFTA00083969/EFTA00083969.md new file mode 100644 index 0000000000000000000000000000000000000000..036199db4548984011178feb90a6bc04a682143f --- /dev/null +++ b/marker2/ds9/EFTA00083969/EFTA00083969.md @@ -0,0 +1,64 @@ +# Prtitebr 'fates !Strict alattrt SOUTHERN DISTRICT OF NEW YORK + +TO: MR. R. COURI HAY + +### GREETINGS: + +WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before the GRAND JURY of the people of the United States for the Southern District of New York, at the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the following date, time and place: + +Appearance Date: July 31, 2019 Appearance Time: 10:00 a.m. + +to testify and give evidence in regard to an alleged violation of : + +18 U.S.C. §§ 1591, 2421, 2422, 2423, 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 Advice of Rights + +Failure to attend and produce any items hereby demanded will constitute contempt of court and will subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law. + +DATED: New York, New York + +July 15 2019 + +(.4 EY S. BE AN United States Attorney for the Southern District of New York + +![](_page_0_Picture_15.jpeg) + +A. nited Slates Attorneys ne St. Andrew's Plaza New York, New York 10007 + +![](_page_0_Picture_17.jpeg) + +#### Advice of Rights + +- I. You may refuse to answer any question if a truthful answer to the question would tend to incriminate you. +- 2. Anything that you do say may be used against you by the grand jury or in a subsequent legal proceeding. +- 3. If you have a lawyer, the grand jury will permit you a reasonable opportunity to step outside the grand jury room to consult with your lawyer if you so desire. +- 4. If you would like a lawyer but do not have funds to retain one, you may make an application to the United States Magistrate Judge who will decide whether to appoint a lawyer to represent you. + +![](_page_2_Picture_0.jpeg) + +#### U.S. Department of Justice + +United States Attorney Southern District of New York + +The Silvio J. MoUo Building One Saint Andrew's Plaza New York, New York 10007 + +July 15, 2019 + +## 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. 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. + +Moreover, if you intend to disclose the existence of this subpoena 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, + +GEOFFREY S. BERMAN United States Attorney + +Assistap ed-State Attorneys \ No newline at end of file diff --git a/marker2/ds9/EFTA00083969/EFTA00083969.metadata.json b/marker2/ds9/EFTA00083969/EFTA00083969.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..aabcef0dd5ea684ade027e1ed1ef65465f0ac9c9 --- /dev/null +++ b/marker2/ds9/EFTA00083969/EFTA00083969.metadata.json @@ -0,0 +1,285 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083969.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3056, + "elapsed_seconds": 1.05, + "image_assets": [ + "_page_0_Picture_15.jpeg", + "_page_0_Picture_17.jpeg", + "_page_2_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Prtitebr 'fates 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Kaiser" <[REDACTED]> +**To:** Kimberly Lerner <[REDACTED]> +**Cc:** [REDACTED], "William H. Kaiser" +[REDACTED] + +**Subject:** Re: Epstein case, SDNY +**Date:** Fri, 26 Jul 2019 17:28:47 +0000 + +[REDACTED]: Are we on for a Monday call? Dan + +Dan + +Daniel J. Kaiser +Kaiser Saurborn & Mair, P.C. +[REDACTED] + +On Jul 26, 2019, at 6:39 AM, Kimberly Lerner <[REDACTED]> wrote: + +I am at a charity function all day with limited service. Can we do Monday at 12? + +Sent from my iPhone + +On Jul 26, 2019, at 5:33 AM, Daniel J. Kaiser <[REDACTED]> wrote: + +[REDACTED]: I am in Boston for a deposition but can speak between 1:00 and 2:00 if that works. My cell is [REDACTED]. Dan + +Dan +Daniel J. Kaiser +Kaiser Saurborn & Mair, P.C. +[REDACTED] + +On Jul 25, 2019, at 11:38 PM, [REDACTED] > wrote: + +Following up on our discussions regarding [REDACTED] we were wondering if you have time for a brief call tomorrow, or if not, at your earliest convenience next week? We don't expect to take long but do want to be quickly in touch when you're available. + +thank you, + +[REDACTED] + +Assistant U.S. Attorney +Southern District of New York + +[REDACTED] + +--- + +**From:** Daniel J. Kaiser <[REDACTED]> + +**Sent:** Sunday, July 14, 2019 08:05 + +**To:** [REDACTED] + +**C:** [REDACTED] William H. Kaiser <[REDACTED]> + +<[REDACTED]> + +**Subject:** Re: Epstein case, SDNY + +Thanks to all of you for handling the meeting with [REDACTED] so professionally. We greatly appreciate it. + +Dan + +Daniel J. Kaiser + +Kaiser Saurborn & Mair, P.C. + +[REDACTED] + +On Jul 14, 2019, at 12:09 AM, [REDACTED] > wrote: + +Team – following up on our meeting yesterday, I wanted to make sure you all have the contact info for our full team. My colleagues [REDACTED] and [REDACTED] are also working on the case, and they're copied here and we're all reachable at these email addresses or by phone anytime at: + +[REDACTED] + +We greatly appreciated [REDACTED] being willing to talk with us, and I expect we'll be in touch again in the coming weeks. And of course if anything comes up that you want to reach out to us about, please don't hesitate at all. + +thank you, + +[REDACTED] + +Assistant U.S. Attorney +Southern District of New York + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00083972/EFTA00083972.metadata.json b/marker2/ds9/EFTA00083972/EFTA00083972.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..07b1edea402f2024e49e7371782190a51a00e3f5 --- /dev/null +++ b/marker2/ds9/EFTA00083972/EFTA00083972.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083972.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2203, + "elapsed_seconds": 6.4, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Text", + 32 + ], + [ + "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 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Text", + 46 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00083972" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083974/EFTA00083974.md b/marker2/ds9/EFTA00083974/EFTA00083974.md new file mode 100644 index 0000000000000000000000000000000000000000..cbfb8f9f4d4182cebda88875a52855fc40a2103f --- /dev/null +++ b/marker2/ds9/EFTA00083974/EFTA00083974.md @@ -0,0 +1,98 @@ +**From:** [REDACTED] +**To:** "Daniel J. Kaiser" [REDACTED] >, Kimberly Lerner [REDACTED] > +**Cc:** "William H. Kaiser" [REDACTED] >, +[REDACTED] +**Subject:** RE: Epstein case, SDNY +**Date:** Fri, 26 Jul 2019 17:33:21 +0000 + +--- + +Dan, + +We actually need to speak briefly today – the agents unfortunately are in a meeting right now, but could we speak when you're finished with your depo this afternoon? We should be able to do any time after about 3:30. And we can have another call with everyone on Monday if you think that would be useful after we chat. + +thanks, +[REDACTED] + +--- + +**From:** Daniel J. Kaiser <[REDACTED]> +**Sent:** Friday, July 26, 2019 13:29 +**To:** Kimberly Lerner <[REDACTED]> +**Cc:** [REDACTED] William H. Kaiser ; [REDACTED] +[REDACTED] +**Subject:** Re: Epstein case, SDNY + +[REDACTED] Are we on for a Monday call? Dan + +Dan + +Daniel J. Kaiser +Kaiser Saurborn & Mair, P.C. + +On Jul 26, 2019, at 6:39 AM, Kimberly Lerner <[REDACTED]> wrote: + +I am at a charity function all day with limited service. Can we do Monday at 12? + +Sent from my iPhone + +On Jul 26, 2019, at 5:33 AM, Daniel J. Kaiser [REDACTED] > wrote: + +[REDACTED]: I am in Boston for a deposition but can speak between 1:00 and 2:00 if that works. My cell is [REDACTED]. Dan + +Dan +Daniel J. Kaiser +Kaiser Saurborn & Mair, P.C. +[REDACTED] + +[REDACTED] + +Page: 212-350-3060 + +On Jul 25, 2019, at 11:38 PM, [REDACTED] > wrote: + +Dan, Kimberly, + +Following up on our discussions regarding [REDACTED], we were wondering if you have time for a brief call tomorrow, or if not, at your earliest convenience next week? We don't expect to take long but do want to be quickly in touch when you're available. + +thank you, + +[REDACTED] + +Assistant U.S. Attorney +Southern District of New York + +[REDACTED] + +--- + +**From:** Daniel J. Kaiser <[REDACTED]> + +**Sent:** Sunday, July 14, 2019 08:05 + +**To:** [REDACTED] + +**Cc:** [REDACTED]; William H. Kaiser <[REDACTED]> + +**Subject:** Re: Epstein case, SDNY + +Thanks to all of you for handling the meeting with [REDACTED] so professionally. We greatly appreciate it. + +Dan + +Daniel J. Kaiser +Kaiser Saurborn & Mair, P.C. + +[REDACTED] + +On Jul 14, 2019, at 12:09 AM, [REDACTED] > wrote: + +Team – following up on our meeting yesterday, I wanted to make sure you all have the contact info for our full team. My colleagues [REDACTED] and [REDACTED] are also working on the case, and they're copied here and we're all reachable at these email addresses or by phone anytime at: + +[REDACTED] + +We greatly appreciated [REDACTED] being willing to talk with us, and I expect we'll be in touch again in the coming weeks. And of course if anything comes up that you want to reach out to us about, please don't hesitate at all. + +[REDACTED] + +![](_page_2_Picture_1.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00083974/EFTA00083974.metadata.json b/marker2/ds9/EFTA00083974/EFTA00083974.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a2beb5534c1edb5bbb4a1ef39907a710053c2f2f --- /dev/null +++ b/marker2/ds9/EFTA00083974/EFTA00083974.metadata.json @@ -0,0 +1,120 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083974.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2791, + "elapsed_seconds": 6.94, + "image_assets": [ + "_page_2_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Text", + 44 + ], + [ + "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", + 53 + ], + [ + "Text", + 48 + ], + [ + "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": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 5 + ], + [ + "Line", + 3 + ], + [ + "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/EFTA00083974" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083974/_page_2_Picture_1.jpeg b/marker2/ds9/EFTA00083974/_page_2_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..4ac3820b526e639bf1635742ef2b56d626faeaff --- /dev/null +++ b/marker2/ds9/EFTA00083974/_page_2_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:3880e68a89463792ade46af98e502c4211060db858139719bb95d809a5906e84 +size 1231 diff --git a/marker2/ds9/EFTA00083977/EFTA00083977.md b/marker2/ds9/EFTA00083977/EFTA00083977.md new file mode 100644 index 0000000000000000000000000000000000000000..213498a2a85ec86d597373d46c602e027b8eac04 --- /dev/null +++ b/marker2/ds9/EFTA00083977/EFTA00083977.md @@ -0,0 +1,99 @@ +To: "Daniel J. Kaiser" + +Cc: Kimberl Lemer + +Subject: RE: Epstein case, SDNY + +Date: Fri, 26 Jul 2019 18:36:36 +0000 + +"William H. Kaiser" + +Thanks very much, we should be able to call you then (and I'll let you know if for some reason that changes). Thanks again. + +From: Daniel J. Kaiser + +Sent: Friday, July 26, 2019 13:36 + +To: + +Cc: Kimberly Lerner a; William H. Kaiser < + +u•Ject: Re: Epstein case DNY + +I should be able to speak at 3:30. Call my cel + +Dan + +Daniell. Kaiser + +Kaiser Saurborn & Mair, P.C. + +On Jul 26, 2019, at 1:34 PM wrote: + +Dan, + +We actually need to speak briefly today — the agents unfortunately are in a meeting right now, but could we speak when you're finished with your depo this afternoon? We should be able to do any time after about 3:30. And we can have another call with everyone on Monday if you think that would be useful after we chat. + +thanks, + +From: Daniel J. Kaiser + +Sent: Friday, July 26, 2019 13:29 + +To: Kimberly Lerner + +: William H. Kaise + +Dan + +Daniel J. Kaiser +Kaiser Saurborn & Mair, P.C. + +On Jul 26, 2019, at 6:39 AM, Kimberly Lerner <[REDACTED]> wrote: + +I am at a charity function all day with limited service. Can we do Monday at 12? + +Sent from my iPhone + +On Jul 26, 2019, at 5:33 AM, Daniel J. Kaiser <[REDACTED]> wrote: + +[REDACTED] I am in Boston for a deposition but can speak between 1:00 and 2:00 if that works. My cell is [REDACTED] +Dan + +Dan +Daniel J. Kaiser +Kaiser Saurborn & Mair, P.C. + +On Jul 25, 2019, at 11:38 PM [REDACTED] > wrote: + +Dan, Kimberly, + +Following up on our discussions regarding [REDACTED] we were wondering if you have time for a brief call tomorrow, or if not, at your earliest convenience next week? We don't expect to take long but do want to be quickly in touch when you're available. + +thank you, + +[REDACTED] +Assistant U.S. Attorney +Southern District of New York + +--- + +**From:** Daniel J. Kaiser <[REDACTED]> + +**Sent:** Sunday, July 14, 2019 08:05 + +**To:** [REDACTED] + +Dan + +Daniell. Kaiser Kaiser Saurborn & Mair, P.C. + +On Jul 14, 2019, at 12:09 AM, > wrote: + +Team — following up on our meeting yesterday, I wanted to make sure you all have the contact info for our full team. My colleagues and are also working on the case, and they're copied here and we're all reachable at these email addresses or by phone anytime at: + +We greatly appreciated being willing to talk with us, and I expect we'll be in touch again in the coming weeks. And of course if anything comes up that you want to reach out to us about, please don't hesitate at all. + +thank ou, + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00083977/EFTA00083977.metadata.json b/marker2/ds9/EFTA00083977/EFTA00083977.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4c1b298001f862334c54ca352a2d098f26ba10d0 --- /dev/null +++ b/marker2/ds9/EFTA00083977/EFTA00083977.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083977.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2587, + "elapsed_seconds": 5.56, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 31 + ], + [ + "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", + 53 + ], + [ + "Text", + 47 + ], + [ + "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": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Line", + 14 + ], + [ + "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/EFTA00083977" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083980/EFTA00083980.md b/marker2/ds9/EFTA00083980/EFTA00083980.md new file mode 100644 index 0000000000000000000000000000000000000000..ee754e4ed0f0ce3066ef30e4c3e6cfd8f7b80aa9 --- /dev/null +++ b/marker2/ds9/EFTA00083980/EFTA00083980.md @@ -0,0 +1,25 @@ +To: + +Cc: + +Subject: financial exhibits + +Date: Wed, 29 Sep 2021 00:08:19 +0000 + +Importance: Normal + +Attachments: October 1999 FTC Slint.pdf; JPM-SDNY-00005512.tif; JPM-SDNY-00001937.tif + +Hi team, + +Could you please mark the following exhibits from the JP Morgan subpoena returns? I just have the JP Morgan bates ranges — I don't know the corresponding discovery bates numbers. + +- JPM-SDNY-00001937 (financial entity account application for Financial Trust Company) (attached) +- JPM-SDNY-00036863 through JPM-SDNY-00036869 (1999 account statement for Financial Trust Company) (attached) +- JPM-SDNY-00005512 (2002 wire transfer record) (attached) (please pull and mark the full 9 page document JP + +end I have been discussing one additional financial transaction from 2007, and we'll let you know as soon as we can whether we decide to offer those records. + +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/EFTA00083980/EFTA00083980.metadata.json b/marker2/ds9/EFTA00083980/EFTA00083980.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9b04dfad2731937ed23b4507f002e1e4968537e3 --- /dev/null +++ b/marker2/ds9/EFTA00083980/EFTA00083980.metadata.json @@ -0,0 +1,62 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083980.pdf", + "engine": { + "marker_major": "2", + "marker_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": 967, + "elapsed_seconds": 0.67, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 44 + ], + [ + "Line", + 22 + ], + [ + "Text", + 12 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00083980" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083981/EFTA00083981.md b/marker2/ds9/EFTA00083981/EFTA00083981.md new file mode 100644 index 0000000000000000000000000000000000000000..ca497db48ca24ef20edc601bec636b3700022cd6 --- /dev/null +++ b/marker2/ds9/EFTA00083981/EFTA00083981.md @@ -0,0 +1,195 @@ +10 Morgan Guaranty Trust Company of New York 1999 345 Park Avenue. New York, NY 10154-1002 + +Account Number FINANCIAL TRUST COMPANY, INC. + +### Gift Processing + +The holiday season will soon be here. If you plan to make securities gifts this year, please notify us before December 1, 1999. This will provide us with sufficient time to process your request and meet the year-end deadline. + +JPMorgan + +Confidential Page 1 of 7 + +# Asset Account Portfolio + +October I - October 31, 1999 + +### Table of Contents + +| | Page | +|----------------------|------| +| Portfolio Summary | 2 | +| Cash and Short Term | 3 | +| Trade Activity | 4 | +| Account Transactions | 5 | + +## Account Officers + +Service Specialist: SCOTT/DENCKER + +FINANCIAL TRUST COMPANY, INC. C/O AMERICAN YACHT HARBOR 6100 RED HOOK, QUARTERS #2 ST THOMAS US VIRGIN ISLDS 00802 + +## Overview + +# Portfolio Summary + +| | Market Value USD
Oct 31 | Tax
Cost USD | Estimated Annual
Income USD | Yield
% | +|------------------------------|----------------------------|---------------------|--------------------------------|------------| +| Cash & Short Term | 6,700,000.00 | 6,700,000.00 | 361,800.00 | 5.4 | +| Total | 6,700,000.00 | 6,700,000.00 | 361,800.00 | 5.4 | +| Accrued Income | 75,196.71 | | | | +| Total Portfolio Value | 6,775,196.71 | | | | + +## Asset Allocation + +![](_page_1_Figure_11.jpeg) + +as of January 1 1999 + +| Currency | Ditching* Ren | +|----------|---------------| +| AST | 13.7603 | +| BEF | 40.3399 | +| DEM | 1.9558 | +| ESP | 166.386 | +| FIM | 5.9457 | +| FRF | 6.5596 | +| IEP | 0.7875 | +| ITL | 1,936.2700 | +| LUF | 40.3399 | +| NLG | 2.2037 | +| PTE | 200.4820 | + +Account Number: [REDACTED] +FINANCIAL TRUST COMPANY, INC. + +**Asset Account Portfolio** +October 01, 1999 - October 31, 1999 + +**Cash and Short Term** + +**Summary by Maturity** + +| | Current Market Value
USD | Estimated Annual Income
USD | +|--------------------|------------------------------------|---------------------------------------| +| Less Than 3 Months | 6,700,000.00 | 361,800.00 | +| Total | 6,700,000.00 | 361,800.00 | + +Current yield is displayed for instruments with no maturity and YTM on market is displayed for instruments that mature. + +**Cash and Short Term by Type** + +| Description
Cusip/S&P/Moody's Rating | Currency | Quantity | Unit Cost
Adjusted
Original | Market
Price | Tax Cost
Adjusted
Original | Market Value USD
Accrued Interest USD | Unrealized
Gain/Loss USD | Estimated
Annual
Income USD | Current
Yield/
YTM % | +|-----------------------------------------------------|----------|-----------|-----------------------------------|-----------------|----------------------------------|--------------------------------------------------------|------------------------------------|------------------------------------------|----------------------------| +| Short Term by Maturity | | | | | | | | | | +| J P MORGAN INSTITUTIONAL PRIME MONEY
MARKET FUND | USD | 6,700,000 | 1.00 | 1.00 | 6,700,000.00 | 6,700,000.00 | | 361,800.00 | 5.40 | +| 7-Day Annualized Yield: 5.34%
[REDACTED] | | | | | | 75,196.71 | | | | +| Total Cash and Short Term | | | | | 6,700,000.00 | 6,700,000.00 | 0.00 | 361,800.00 | 5.40 | + +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. + +10 Morgan Guaranty Trust Company of New York 1999 345 Park As enue, New York, NY 10154-1002 + +Account Number Asset Account Portfolio FINANCIAL TRUST COMPANY, INC. October 01, 1999 - October 31, 1999 + +# Trade Activity + +JPMorgan + +Page 4 of 7 + +## Realized Gain/Loss Summary + +Short Term Gain/Loss + +Long Term Gain/Loss + +Note: S incicates Short Term Realized Gain/Loss + +L indicates Long Term Realized Gain/Loss + +Amount USD + +0.00 0.00 + +## Trade Activity by Type + +| Trade | Semement | | | | | | | +|-------|---------------|----------|--------------------------------------|----------|--------------|-----------|-------------------------------| +| Date | Date | Type | DeacriptIon | Currency | Ottantlry | Pncellnit | Marker Coat/Proceeda | +| | | | | | | | Tax Cost DeWitt Osa USD | +| | Oct 1 Oct 1 | Purchase | J P MORGAN INSTITUTIONAL PRIME MONEY | USD | 20,000,000 | | 1.00 - 20,000,000.00 | +| Oct 4 | Oct 4 | Purchase | J P MORGAN INSTITUTIONAL PRIME MONEY | USD | 5,000,000 | 1.00 | - 5,000,000.00 | +| | Oct 19 Oct 19 | Sale | J P MORGAN INSTITUTIONAL PRIME MONEY | USD | - 18,300,000 | 1.00 | 18,300,000.00 - 18,300,000.00 | + +10 Morgan Guaranty Trust Company of New York 1999 345 Park A% num New York, NY 10154-1002 + +Account Number FINANCIAL TRUST COMPANY, INC. October 01, 1999 - October 31, 1999 + +Asset Account Portfolio + +# Account Transactions + +JPMorgan + +Page 5 of 7 + +## Cash Activity Summary + +| Beginning Balance Credits | Amount INS Penne/ USD .00 | Amount year !ODOM USD' | +|-------------------------------|---------------------------|------------------------| +| Sales. Matunbes, Redemptions | 18,300,000.00 | 18,300,000.00 | +| Miscellaneous Receipts Debits | 25,000,000.00 | 25,000,000.00 | +| Purchases of Securities | - 25,000,000.00 | - 25,000,000.00 | +| Miscellaneous Disbursements | - 18,300,000.00 | - 18,300,000.00 | +| Ending Balance | .00 | | + +Year to date information is calculated on a calendar year basis. + +## Activity by Date + +| Settlement Date | Type | Quantity | Description | Amount USD | +|-----------------|---------------|------------|-------------------------------------------------------------------------------------------------------------------------|-----------------| +| Oct 1 | Purchase | 20,000,000 | J P MORGAN INSTITUTIONAL PRIME MONEY MARKET FUND
J.P.MORGAN SECURITIES INC AS AGENT
@ 1.00
TRADE DATE 10/01/99 | - 20,000,000.00 | +| Oct 1 | Misc. Receipt | | FUNDS TRANSFERRED TO BRKRG
AC# [REDACTED] (PRN) FROM
BRKRG AC# [REDACTED] (PRN) | 20,000,000.00 | + +10 Morgan Guaranty Trust Company of New York 1999 345 Park As enue, New York, NY 10154-1002 + +Account Number Asset Account Portfolio FINANCIAL TRUST COMPANY, INC. October 01, 1999 - October 31, 1999 + +JPMorgan + +Page 6 of 7 + +## Activity by Date + +| Settlement Date | Type | Quantity | Description | Amount USD | +|-----------------|--------------------|--------------|-------------------------------------------------------------------------------------------------------------------------|-----------------| +| Oct 4 | Purchase | 5,000,000 | J P MORGAN INSTITUTIONAL PRIME MONEY MARKET FUND
J.P.MORGAN SECURITIES INC AS AGENT
@ 1.00
TRADE DATE 10/04/99 | - 5,000,000.00 | +| Oct 4 | Misc. Receipt | | FUNDS TRANSFERRED TO BRKRG
AC# ██████████ (PRN) FROM
BRKRG    AC# ██████████ (PRN) | 5,000,000.00 | +| Oct 19 | Sale | - 18,300,000 | J P MORGAN INSTITUTIONAL PRIME MONEY MARKET FUND
J.P.MORGAN SECURITIES INC AS AGENT
@ 1.00
TRADE DATE 10/19/99 | 18,300,000.00 | +| Oct 19 | Misc. Disbursement | | TRANSFERRED BY WIRE TO
BEAR STEARNS
FAO GHISLAINE MAXWELL | - 18,300,000.00 | + +continued + +Account Number: [REDACTED] +**FINANCIAL TRUST COMPANY, INC.** + +**Asset Account Portfolio** +October 01, 1999 - October 31, 1999 + +**In Case of Errors or Questions About Your Electronic Transfers.** + +Telephone us at 1 (800) 576-6221 or write us at 500 Stanton Christiana Road, 1/OPS, Newark, DE 19713-2107 as soon as you can, if you think your statement is wrong or if you need more information about a transfer on the statement. We must hear from you no later than 60 days after we sent you the FIRST statement on which the error or problem appeared. (1) Tell us your name and account number. (2) Describe the error or the transfer you are unsure about, and explain as clearly as you can why you believe it is in error or why you need more information. (3) Tell us the dollar amount of the suspected error. If you contact us orally, you must send us your complaint or question in writing within 10 business days in order to preserve your rights. We will investigate your complaint and will correct any error promptly. If we take more than 10 business days to do this (20 days for purchases using VISA Check Card or for international transactions), we will credit your account for the amount you think is in error, so that you will have the use of money during the time it takes us to complete our investigation. + +**In case of errors or questions about your statement, including your line of credit.** + +If you think that your statement is incorrect or if you need more information about a transaction on your statement including a line of credit transaction, you must write to us on a separate sheet describing the error and send it to: J.P. Morgan, Private Client Services, 345 Park Avenue, New York, NY 10154-1002. We must hear from you no later than 60 days after the statement on which the error or problem appeared is sent. You can telephone us at 1-800-576-6221 but doing so will not preserve your rights. + +In your letter, please provide the following information: (1) your name and account number; (2) the dollar amount of the suspected error; and (3) 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 J.P. Morgan Funds or The J.P. Morgan Institutional Funds or The American Century Funds** + +The J.P. Morgan, J.P.Morgan Institutional, and American Century mutual funds are distributed by Funds Distributor, Inc. J.P. Morgan Investment Management Inc. and American Century Investment Management serve as investment advisors to their respective fund families. Shares of the funds are not bank deposits and are not guaranteed by any bank, government entity, or the FDIC. Return and share price will fluctuate and redemption value may be more or less than 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. 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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/EFTA00083988/EFTA00083988.metadata.json b/marker2/ds9/EFTA00083988/EFTA00083988.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b6f9ea9dbc09c6e128c71da86bb3e79bf98d1c81 --- /dev/null +++ b/marker2/ds9/EFTA00083988/EFTA00083988.metadata.json @@ -0,0 +1,115 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083988.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1454, + "elapsed_seconds": 0.67, + "image_assets": [ + "_page_0_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Asset Account Portfolio Page Sof 9", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 266.904, + 80.565 + ], + [ + 722.4708862304688, + 80.565 + ], + [ + 722.4708862304688, + 93.61590576171875 + ], + [ + 266.904, + 93.61590576171875 + ] + ] + }, + { + "title": "Activity by Date", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 15.048, + 157.855 + ], + [ + 103.75750732421875, + 157.855 + ], + [ + 103.75750732421875, + 171.61590576171875 + ], + [ + 15.048, + 171.61590576171875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 30 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 3 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "Table", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00083988" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00083988/_page_0_Picture_2.jpeg b/marker2/ds9/EFTA00083988/_page_0_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..992896f1ac99ee0c1b663b9b60bdde862d6cb1cb --- /dev/null +++ b/marker2/ds9/EFTA00083988/_page_0_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:cfe3cd14a4b942e02d9fb63da3a73a68af751381604a64b79a58fd92c028f085 +size 10652 diff --git a/marker2/ds9/EFTA00083989/EFTA00083989.md b/marker2/ds9/EFTA00083989/EFTA00083989.md new file mode 100644 index 0000000000000000000000000000000000000000..7d105d892fe68c5fa8c27f94c79f52eaa7eab93d --- /dev/null +++ b/marker2/ds9/EFTA00083989/EFTA00083989.md @@ -0,0 +1,129 @@ +J.P. Morgan Entity Account Application + +J.P.Morgan + +A. Entity Information + +Type of Business INVESTMENTS + +Date of Incorporation/Organization 11/06/1998 + +Country of Incorporation/Organization VIRGIN ISLANDS (U.S.) + +Primary Authorized Contact Person DARREN INDYKE + +Phone + +Mailing Address + +City ST THOMAS + +Country VIRGIN ISLANDS - Zip 00802 + +The following fields are required for Brokerage and IM Accounts: + +Gross Annual + +Ravenue (\$) \$0.00m + +Total Assets (\$) \$0.00m + +Liquid Net Worth + +(Investable assets) (\$) \$0.00m + +Total + +Net Worth (\$) \$0.00m + +B. Account Information + +Title of account/Name of business: FINANCIAL TRUST COMPANY INC, C/O AMERICAN YACHT HARBOR + + Corporation      Partnership      PIC/PHC      Sole Proprietorship      Check if applicable + Foundation      Limited Liability Company      Limited Liability Partnership      Not for profit + + +I have applied to open the following accounts: + + Checking Account      Money Market Deposit Account/Savings      Investment Management/Third Party Manager (discretionary) + Asset/Brokerage      Asset/Custody + + +I hereby apply for a Line of Credit linked to my Asset Account Yes No (if Yes, a U-1 form will be required) + +Each account I open is subject to the security interest provisions in the Agreement (defined below) and is pledged as Collateral for all my Obligations. + +C. Ownership Information + +Is this a privately held operating company in which any one person or entity has 25% or more of the ownership interest? + + Yes (complete owner information below) + + No + +Controlling Owner (Primary) + +Jeffrey Eastein + +% of Ownership + +100% + +Controlling Owner + +% of Ownership + +Date of Birth: + +01-26-19 5 3 + +Date of Birth: m m - d d - y y y y + +Passport Number + +Controlling Owner + +% of Ownership + +Passport Number + +% of Ownership + +Date of Birth: + +m m - d d - y y y y + +Date of Birth: m m - d d - y y y y + +Passport Number + +Passport Number + +D. Authorized Persons for Information Access + +The following individuals are authorized to inquire about and receive all information about my accounts and transactions, including access to account information made available on J.P. Morgan websites: + +Name RICH KAHN, HARRY BELLER + +Name + +E. Brokerage Information (required for Brokerage accounts only) + +By checking the box below I consent to the electronic delivery of all information including, but not limited to, communications, prospectuses, and marketing and sales documents relating to my securities activity for all investment products including both registered and unregistered offerings. + + I may be notified by e-mail regarding the above + + Mail Address: + +[Redacted] + +My objective for this account (check one): Capital Preservation Income Generation Capital Appreciation +Speculative or aggressive investments that may generate higher returns but may be riskier than other investments because I may lose all or part of my investment (check one): Are permitted in this account: Are not permitted in this account +Primary source of income: Investments Operating income Other + +Please indicate the number of years of personal trading experience for the authorized party(s) on this account: + +Stocks 20 Bonds 20 Commodities 20 Foreign Exchange 20 Emerging Markets 20 Options 20 + +I currently have brokerage accounts with the following firms: \ No newline at end of file diff --git a/marker2/ds9/EFTA00083989/EFTA00083989.metadata.json b/marker2/ds9/EFTA00083989/EFTA00083989.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..23ea07d99964743fbf7ce6cedd87532016473d60 --- /dev/null +++ b/marker2/ds9/EFTA00083989/EFTA00083989.metadata.json @@ -0,0 +1,197 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083989.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3301, + "elapsed_seconds": 20.96, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "J.P. 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New York, NY 10154-1002 + +Account Number JEFFREY EPSTEIN + +![](_page_0_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 | 5 | +| Account Transactions | 6 | + +## Account Officers + +Service Specialist: RILEYIHORNBECKER + +0000000000 00 0000 000 000000020 000000 JEFFREY E EPSTEIN C/O FINANCIAL TRUST COMPANY ATTN: JEANNE BRENNAN + +![](_page_0_Picture_13.jpeg) + +GOVERNMENT EXHIBIT 504 52 20 Cr. 330 (AIN) + +Confidential Treatment Requested by JPMorgan Chase + +Account Number [REDACTED] +JEFFREY EPSTEIN + +**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_1_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 | + +09 + +Account Number + +JEFFREY EPSTEIN September 01, 2002 - September 30. 2002 Asset Account Portfolio Page 3 of 9 + +JPMorgan Chase Bank + +![](_page_2_Picture_3.jpeg) + +# Cash and Short Term + +# Summary by Maturity + +| | Current Market Value | Estimated Annual Income | +|--------------------|-----------------------------|--------------------------------| +| | USD | USD | +| Cash | 957.08 | 12.44 | +| Less Than 3 Months | 6,837,730.16 | 109,403.68 | +| Total | 6,838,687.24 | 109,416.12 | + +Current yield is displayed for instruments with no maturity and YTM on market is displayed for instruments that mature. + +## Cash and Short Term by Type + +| Description | | Linn Cost atSISS | Tax Cost Current | | Estimated | CLIMIlt | +|-------------------------|----------|------------------|---------------------------------------|--------------|------------|---------| +| Cus'pSSP Moody's Raring | Currency | Quantity | | | | | +| | | Original | Market Aquaria Madre( Value USO Price | Unroahse4 | Annual | | +| | | | | Don/Loss USD | Income USD | | +| | | | Accrued Interest USO Original | | | % | + +### 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 Annuakzed Yield: 1.27% + +### Short Term by Maturity + +J P MORGAN TM 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-Da Annualized Yield: 1.52% + +Confidential Treatment Requested by JPMorgan JPM-SDNY-00005507 Chase + +Account Number [REDACTED] +JEFFREY EPSTEIN + +**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 345 Park Avenue. New York, NY 10154-1002 + +Account Number JEFFREY EPSTEIN + +# Trade Activity + +Asset Account Portfolio September 01, 2002 - September 30, 2002 + +![](_page_4_Picture_3.jpeg) + +Page 5 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 | Semement | | | | | | | +|---------------|------------|----------------------------------|----------|-------------|---------|-------------------|----------------------| +| Care | Clare Type | OeungifIon | Currency | Quantify | P/1OVUM | Name CostoProcels | | +| | | | | | | | Tax COW Gainless 050 | +| 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 | - 5,000,000 | 1.00 | 5,000,000.00 | - 5,000,000.00 | + +09 2002 + +Account Numbe + +JEFFREY EPSTEIN September 01, 2002 - September 30, 2002 Asset Account Portfolio Page Got 9 + +JPMorgan Chase Bank 345 Park Avenue. New York, NY 10154-1002 + +![](_page_5_Picture_3.jpeg) + +# Account Transactions + +## Cash Activity Summary + +| Beginning Balance Credits Dividends | Amount1MS Penod USD .00 21,093 46 | Amount Year to Date 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 | | | | | +|------------|----------|----------|------------------------------------------------------------------------------------------------|------------| +| are | Type | Quantity | Descnplton | 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 \$798,956.29 AS OF 09/01/02 | | + +09 JPMorgan Chase Bank + +2002 345 Park Avenue, Nen York, NY 10154-1002 + +![](_page_6_Picture_2.jpeg) + +Account Number JEFFREY EPS + +### Asset Account Portfolio Page 7 of 9 + +September 01, 2002 - September 30, 2002 + +## 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 51.00 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 + +09 + +Account Numbe + +JEFFREY EPSTEIN September 01, 2002 - September 30, 2002 + +JPMorgan Chase Bank + +![](_page_7_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 + +Account Number [REDACTED] +JEFFREY EPSTEIN + +Asset Account Portfolio +September 01, 2002 - September 30, 2002 + +**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. 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b/marker2/ds9/EFTA00083999/EFTA00083999.md @@ -0,0 +1,195 @@ +Account Number FINANCIAL TRUST COMPANY, INC. + +### Gift Processing + +The holiday season will soon be here. If you plan to make securities gifts this year, please notify us before December 1, 1999. This will provide us with sufficient time to process your request and meet the year-end deadline. + +Morgan Guaranty Trust Company of New York 345 Park Avenue, New York, NY 10154-1002 JPMorgan + +Confidential Page 1 of 7 + +# Asset Account Portfolio + +October I - October 3 I, 1999 + +## Table of Contents + +| | Page | +|----------------------|------| +| Portfolio Summary | 2 | +| Cash and Short Term | 3 | +| Trade Activity | 4 | +| Account Transactions | 5 | + +### Account Officers + +Service Specialist SCOTT/DENCKER + +FINANCIAL TRUST COMPANY, INC. C/O AMERICAN YACHT HARBOR + +> GOVERNMENT EXHIBIT SOS 52 20 Cr. 330 (MN) + +Confidential Treatment Requested by JPMorgan Chase + +## Overview + +# Portfolio Summary + +| | Market Value USD
Oct 31 | Tax
Cost USD | Estimated Annual
Income USD | Yield
% | +|------------------------------|----------------------------|---------------------|--------------------------------|-------------| +| Cash & Short Term | 6,700,000.00 | 6,700,000.00 | 361,800.00 | 0.00 | +| Total | 6,700,000.00 | 6,700,000.00 | 361,800.00 | 0.00 | +| Accrued Income | 75,196.71 | | | | +| Total Portfolio Value | 6,775,196.71 | | | | + +## Asset Allocation + +![](_page_1_Figure_11.jpeg) + +as of January 1, 1999 + +| Currency | Exchange Rate | +|----------|---------------| +| AST | 13.7603 | +| BEF | 40.3399 | +| OEM | 1.9558 | +| ESP | 166.386 | +| FIM | 5.9457 | +| FRF | 6.5596 | +| I EP | 0.7875 | +| ITL | 1,936.2700 | +| LUF | 40.3399 | +| NLG | 2.2037 | +| PTE | 200.4820 | + +## Cash and Short Term + +### Summary by Maturity + +| | Current Market Value
USD | Estimated Annual Income
USD | +|--------------------|-----------------------------|--------------------------------| +| Less Than 3 Months | 6,700,000.00 | 361,800.00 | +| Total | 6,700,000.00 | 361,800.00 | + +Current yield is displayed for instruments with no maturity and YTM on market is displayed for instruments that mature. + +### Cash and Short Term by Type + +| 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 INSTITUTIONAL PRIME MONEY
MARKET FUND | USD | 6,700,000 | 1.00 | 1.00 | 6,700,000.00 | 6,700,000.00 | | 361,800.00 | 5.40 | +| 7-Day Annualized Yield: 5.34%
[REDACTED] | | | | | | | | | | +| Total Cash and Short Term | | | | 6,700,000.00 | 6,700,000.00 | 0.00 | 361,800.00 | 5.40 | | + +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. + +Account Number. FINANCIAL TRUST COMPANY, INC. October 01, 1999 - October 31, 1999 + +Morgan Guaranty Trust Company of New York 345 Park Avenue, New York, NY 10154-1002 JPMorgan + +# Asset Account Portfolio Page 4 of 7 + +# Trade Activity + +# Realized Gain/Loss Summary + +Short Term Gain/Loss + +Long Term Gain/Loss + +Note: S indicates Short Term Realized Gain/Loss + +indicates Long Term Realized Gain/Loss + +Amount USD + +0.00 0.00 + +# Trade Activity by Type + +| Ttade | Settlement | | | | | | | +|-------|---------------|----------|--------------------------------------|----------|--------------|-----------|-------------------------------| +| Date | Date | Type | Description | Currency | Quantity | PriedUnit | Markel CosvPmeeeds | +| | | | | | | | Tax Cost Gain/Loss (GO | +| | Oct 1 Oct 1 | Purchase | J P MORGAN INSTITUTIONAL PRIME MONEY | USD | 20,000,000 | | 1.00 - 20,000,000.00 | +| Oct 4 | Oct 4 | Purchase | J P MORGAN INSTITUTIONAL PRIME MONEY | USD | 5,000,000 | 1.00 | - 5,000,000.00 | +| | Oct 19 Oct 19 | Sale | J P MORGAN INSTITUTIONAL PRIME MONEY | USD | - 18,300,000 | 1.00 | 18,300,000.00 - 18,300,000.00 | + +Account Number FINANCIAL TR , INC. + +# Account Transactions + +Morgan Guaranty Trust Company of New York + +345 Park Avenue, New York, NY 10154-1002 JPMorgan + +Asset Account Portfolio Page 5 of 7 + +October 01, 1999 - October 31, 1999 + +### Cash Activity Summary + +| Beginning Balance Credits | Amount OWs Period USD .00 | Amount Yee, to DAN USD' | +|--------------------------------|---------------------------|-------------------------| +| Sales, Maturities, Redemptions | 18,300,000.00 | 18,300,000.00 | +| Miscellaneous Receipts Debits | 25,000,000.00 | 25,000,000.00 | +| Purchases of Securities | - 25,000,000.00 | - 25,000,000.00 | +| Miscellaneous Disbursements | - 18,300,000.00 | - 18,300,000.00 | +| Ending Balance | .00 | | + +'Year to date information is calculated on a calendar year basis. + +## Activity by Date + +| Sottlomonr | | | | | +|------------|---------------|------------|------------------------------------------------------------------------------------------------------------------|-----------------| +| ano | Type | Quantity | °nun:Aron | Amount USO | +| Oct 1 | Purchase | 20,000,000 | J P MORGAN INSTITUTIONAL PRIME MONEY MARKET FUND J.P.MORGAN SECURITIES INC AS AGENT (22 1.00 TRADE DATE 10/01/99 | - 20,000,000.00 | +| Oct 1 | Misc. Receipt | | FUNDS TRANSFERRED TO BRKRG | 20,000,000.00 | +| | | | (PRN) FROM | | + +Account Number. FINANCIAL TR , • Morgan Guaranty Trust Company of New York + +345 Park Avenue, New York, NY 10154-1002 JPMorgan + +### Asset Account Portfolio Page 6 of 7 + +October 01, 1999 - October 31, 1999 + +### Activity by Date + +| Settlement | | | | | +|------------|--------------------|--------------|-------------------------------------------------------------------------------------------------------|----------------| +| Date | Type | | | | +| | | Ousn0ty | Description | Amount USD | +| Oct 4 | Purchase | 5,000,000 J | P MORGAN INSTITUTIONAL PRIME MONEY MARKET FUND J.P.MORGAN SECURITIES INC AS AGENT TRADE DATE 10/04/99 | - 5,000,000.00 | +| Oct 4 | Misc. Receipt | | ERRED TO BRKRG BRKRG | 5,000,000.00 | +| Oct 19 | Sale | 18,300,000 J | P MORGAN INSTITUTIONAL PRIME MONEY MARKET FUND J.P.MORGAN SECURITIES INC AS AGENT TRADE DATE 10/19199 | 18,300,000.00 | +| Oct 19 | Misc. Disbursement | | TRANSFERRED BY VV1RE TO BEAR STEARNS FAO GHISLAINE MAXWELL | 18,300,000.00 | + +continued + +Account Number: [REDACTED] +**FINANCIAL TRUST COMPANY, INC.** + +**Asset Account Portfolio** +October 01, 1999 - October 31, 1999 + +Page 7 of 7 + +**In Case of Errors or Questions About Your Electronic Transfers.** + +Telephone us at 1 (800) 576-6221 or write us at 500 Stanton Christiana Road, 1/CPS, 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 craily, you must send us your complaint or question in writing within 10 business days in order to preserve your rights. We will investigate your complaint and will correct any error promptly. If we take more than 10 business days to do this (20 days for purchases using VISA Check Card or for international transactions), we will credit your account for the amount you think is in error, so that you will have the use of money during the time it takes us to complete our investigation. + +**In case of errors or questions about your statement, including your line of credit.** + +If you think that your statement is incorrect or if you need more information about a transaction on your statement including a line of credit transaction, you must write to us on a separate sheet describing the error and send it to: J.P. Morgan, Private Client Services, 345 Park Avenue, New York, NY 10154-1002. We must hear from you no later than 60 days after the statement on which the error or problem appeared is sent. You can telephone us at 1-800-576-6221 but doing so will not preserve your rights. + +In your letter, please provide the following information: (1) your name and account number; (2) the dollar amount of the suspected error; and (3) 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 J.P. Morgan Funds or The J.P. Morgan Institutional Funds or The American Century Funds** + +The J.P. Morgan, J.P.Morgan Institutional, and American Century mutual funds are distributed by Funds Distributor, Inc. J.P. Morgan Investment Management Inc. and American Century Investment Management serve as investment advisors to their respective fund families. Shares of the funds are not bank deposits and are not guaranteed by any bank, government entity, or the FDIC. 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+[Redacted Account Numbers Box] + +[Redacted Account Numbers Box] + +[Redacted Account Numbers Box] + +[Redacted Account Numbers Box] + +[Redacted Account Numbers Box] + +[Redacted Account Numbers Box] + +[Redacted Account Numbers Box] + +[Redacted Account Numbers Box] + +[Redacted Account Numbers Box] + +[Redacted Account Numbers Box] + +**GOVERNMENT +EXHIBIT +506** +S2 20 Cr. 330 (AJN) + +![](_page_1_Picture_39.jpeg) + +Department of the Treasury +Internal Revenue Service +HOLTSVILLE NY 00501 + +Date of this notice: +Taxpayer Identifying Number +Form: + +MAY 22, 2000 + +Tax Period: + +For assistance you may call us at: + +1-800-829-1040 + +[REDACTED] + +Or you may write to us at the address shown at the left. If you write, be sure to attach the bottom part of this notice. + +AIR GHISLAINE INC +[REDACTED] + +NOTICE OF ACCEPTANCE AS AN S-CORPORATION + +YOUR ELECTION TO BE TREATED AS AN S-CORPORATION WITH AN ACCOUNTING PERIOD OF DECEMBER IS ACCEPTED. THE ELECTION IS EFFECTIVE BEGINNING JAN. 28, 2000, SUBJECT TO VERIFICATION IF WE EXAMINE YOUR RETURN. + +IF YOUR EFFECTIVE DATE IS NOT AS REQUESTED, IT WILL HAVE BEEN CHANGED FOR ONE OF TWO REASONS. EITHER YOUR ELECTION WAS MADE AFTER THE 15TH DAY OF THE THIRD MONTH OF THE TAX YEAR TO WHICH IT APPLIES, BUT BEFORE THE END OF THAT TAX YEAR, OR THE ELECTION WHEN SUBMITTED WAS INCOMPLETE, AND REQUESTED INFORMATION WAS RECEIVED AFTER THE FILING PERIOD. IN EITHER CASE, YOUR ELECTION IS INVALID FOR THE TAX YEAR REQUESTED AND HAS THEREFORE, BEEN TREATED AS THOUGH IT WERE MADE FOR THE NEXT TAX YEAR. + +PLEASE KEEP THIS NOTICE IN YOUR PERMANENT RECORDS AS VERIFICATION OF YOUR ACCEPTANCE AS AN S-CORPORATION. + +IF YOU HAVE ANY QUESTIONS ABOUT THIS NOTICE OR THE ACTIONS WE HAVE TAKEN, PLEASE WRITE TO US AT THE ADDRESS SHOWN ABOVE. IF YOU PREFER, YOU MAY CALL US AT THE IRS TELEPHONE NUMBER LISTED IN YOUR LOCAL DIRECTORY. AN EMPLOYEE THERE MAY BE ABLE TO HELP YOU; HOWEVER, THE OFFICE AT THE ADDRESS SHOWN ON THIS NOTICE IS MOST FAMILIAR WITH YOUR CASE. + +IF YOU WRITE TO US, PLEASE PROVIDE YOUR TELEPHONE NUMBER AND THE MOST CONVENIENT TIME FOR US TO CALL SO WE CAN CONTACT YOU TO RESOLVE YOUR INQUIRY. PLEASE RETURN THE BOTTOM PART OF THIS NOTICE TO HELP US IDENTIFY YOUR CASE. + +THANK YOU FOR YOUR COOPERATION. + +To make sure that IRS employees give courteous responses and correct information to taxpayers, a second IRS employee sometimes listens in on telephone calls. + +Keep this part for your records + +Overlay 5 Form 8489 (Rev 8-9) + +Return this part to us with your check or inquiry + +Your telephone number [ ] Best time to call [ ] + +[REDACTED] + +[REDACTED] 00 000000 + +261 + +INTERNAL REVENUE SERVICE +HOLTSVILLE NY 00501 + +AIR GHISLAINE INC +[REDACTED] 150 + +FOR ASSISTANCE CALL US AT: I-BOB-029-1040 + +OR WRITE TO THE ADDRESS SHOWN AT THE TOP LEFT. + +IF YOU WRITE, ATTACH THE STUB Of THIS ROTICE. + +WE ASSIGNED YOU AN EMPLOYER IDENTIFICATION NUMBER (EIN) + +Thank you for your Form SS-4, APPlication for Employer Identification Number (EIN). We assigned you (IN 13-4109791. This EIN will identify your business account, tax returns, and documents, oven if you have ne employees. Please keep thif notice in your permanent records. + +Use your complete name and EIN as shown above on all federal tax forms, Paymonto, and related correspondonce. If YOU use, any variation in your name or EIS, it may cameo o delay in processing. incorrect infatuation in your accoont, or clues you to be 'reignitd sere than one EIN. + +Sewed on the information shown on your Fero SS-4, you must file the following florets) by tho date we show. + +Form 1120 02/15/2001 + +Your assigned tax cloweificetion io based on information obtained free your Form SS-4. It is not a legal doterminotion of your tax classification and is not binding on the IRS. If you want a determination en your tax classification. you may seek • Private latter ruling from the IRS under the procedures set forth in Rev. Proc. 9B-11, 1948-1 I.R.B. 7 (or the superceding revenue precodure for the year at ). + +If you need help in determining what your tax year is, you can get Publication S30, Accounting Periods and Methods, at your local IRS office. + +If you have questions about the fora\* shown or the data they are duo, you may cell us at 1-A00-B29-1040 or write to us at the address shown above. + +If you're required to deposit for iimoloyaent taxes (Forms 941, 943, 940. 945, CT-1, or 1142). excise taxes (Fors 720). or income taxes (Form 1120), me will vend en initial wooly of Fodarol Tex Deposit (FTD) coueon books within six weeks. You can use the enclosed coupons if you neod to make a deposit before you receive your supply. + +Start your business off right - pay your taxes the easy way. Pay through the Electronic Federal Tax Payment System (EFTPS). For information about EFTPS. call 1-800-021-3676 and request Publication 966, EFTPS Answers to the Most Ccawonly slaked Questions. + +# The Morgan Account + +Month / Date / Year (CHECK ONE BELOW) + Social Security No. / Tax ID No. / Passport no. + +Account title + +Account type Account number + Account type Account number + BAC # + +All Accountholders/Signers must sign this Signature Form exactly as the checks/instructions will be signed. + +![]() + +# The Morgan Account + +Month / Date / Year (CHECK ONE BELOW) + Social Security No. / Tax ID No. / Passport no. + +Account type Account number + Account type Account number + BAC # + +All Accountholders/Signers must sign this Signature Form exactly as the checks/instructions will be signed. + +![]()**Application: Corporate/Other Organization Resolutions** + +1. Harry Bella, the Secretary (or other authorized officer) of Air Chiefers, Inc. (the "Organization") duly organized under the laws of the State of Morgan and is considered to be a complete copy of resolutions adopted by the Board of Directors of the Organization by unauthorized written consent or at a meeting held on 18th day September 2006 at which a quotum of the Board of Directors was present and voting and that these resolutions have not been rescinded or modified and are now in full force and effect. + +**A. Authorized signers** + +In this space, please list, by names or titles, the persons authorized to sign or act parsum to the resolutions indicated below (signers must be identified in each resolution as passed). Also, each signer may act singly only as that use is created out below and the word "only" is written in, which means that any two signers must act jointly. + +Ghishaire Marwell, Personnel Singly + +Print Name and Title (if any) or Title Only Manner of Signing + +Harry Bella, Secretary Singly + +Print Name and Title (if any) or Title Only Manner of Signing + +Print Name and Title (if any) or Title Only Manner of Signing + +Print Name and Title (if any) or Title Only Manner of Signing + +Print Name and Title (if any) or Title Only Manner of Signing + +Print Name and Title (if any) or Title Only Manner of Signing + +\*A photo copy of a current Driver's License or Passport and social security number are required for each signer listed above. Please check the line to the left of any one or more of the following resolutions which have been adopted. If the line to the left of any particular lettered subdivision is not checked, that resolution has not been adopted. + +**B. Banking and custody** + +X 1. RESOLUTION, that the individuals identified above are authorized to enter into drivers and custody accounts with JPMorgan Chase Benk, N.A. or a Morgan Affiliate (individually or collectively, "Morgan") and any successors or assigns designating Morgan as a depository of the funds and custodian of the accounts of the Organization and to act on behalf of the Organization as all respects regarding the Organization's banking and custody accounts with Morgan as they in their discretion determine. + +**C. Investment management** + +X 2. RESOLUTION, that the persons specified above are authorized, in the name and on behalf of the Organization to execute an investment management agreement designating Morgan as the Organization's investment manager, to deliver or modify any asset allocation guideline, market, or other instruction, and to act on behalf of the Organization in all respects regarding the Organization's investment management accounts with Morgan. + +**D. Brokerage** + +X 3. RESOLUTION, that those persons identified above are authorized in the name and on behalf of the Organization to execute a brokerage agreement with J.P. Morgan Securities Inc. and any successors or assigns to particular or margin or in herewise and therefore (on a secured or unsecured basis) from, sell (including short sales in a margin account), and lend (on a secured or unsecured basis) to, and to otherwise enter into transactions of any kind with Morgan with respect to value and all securities and financial instruments whatsoever in which Morgan may deal, broker or act as evaluatory from time to time, to enter into any derivative or transactions with respect to the foregoing, including over the counter equity derivatives and structured transactions (including, but not limited to options, swaps, collect, caps and floors), to pledge any funds or instruments for the purpose of securing the Organization's obligations with respect to the foregoing, to establish and operate one or more brokerage or other accounts in connection with the foregoing activities and transactions, and, to act on behalf of the Organization in all respects regarding the Organization's brokerage accounts. + +**E. Credit** + +X 4. RESOLUTION, that those persons specified above are authorized in the name and on behalf of the Organization to borrow from time to time from Morgan same of passey, for partial or time and upon terms as may to them in their discretion seem advisable, to execute notes or other obligations to evidence brokerages, to enter into agreements with respect to borrowings, to discount with Morgan any bills or notes receivable held by the Organization upon such terms as they may deem proper to apply for and establish letters of credit and to execute applications, agreements, mast receipts and all other documents in connection therewith to execute and deliver, in their discretion, any guarantee, indemnity agreement or undertakings deemed necessary or advisable to enter out the purpose and any it of the foregoing resolutions, to pledge any of the assets or property of the Organization, for the purpose of securing any of the foregoing transactions or any transaction entend into by any other entity or person, and, to endorse securities and/or to issue appropriate powers of attorney documents or assignments in furtherance discretif. + +JPMorgan Use Only Title AIR GENERALING INC. S/N CAS +CS150105/06 + +![](_page_4_Picture_56.jpeg) + +→ pages + +11/15/04 + +**The Morgan Account +Application: Corporate/Other Organization Resolutions** + +**F. General** + +**X 5. RESOLVED**, that those individuals should filed in above, acting as the enamer specified therein, are authorized to delegate the authority granted under the foregoing resolutions to any other person by written appointment selected to Morgan and any such appointment shall remain in full force and effect until Morgan shall receive written notice to the contrary from the Organization. + +**X 6. RESOLVED**, that any transaction of the type notified by the preceding resolutions which has been taken are hereby in all respects approved, confirmed and confirmed; and + +**X 7. RESOLVED**, that any resolution certified to Morgan by the Secretary, or other duly appointed officer of the Organization shall remain in full force and effect until Morgan shall receive certification of a sull response resolution and noting, superseding or revoking it. + +**X 8. RESOLVED**, Any persons authorized to act by the preceding resolutions may utilize the wells to provided by Morgan (the "Sinc") via the Internet 24 hours a day, seven days a week to act in the manner indicated in this resolution provided the functionality is available via the Sinc Transactions requiring more than one signature to complete will not be available via the Sinc. Sinc usage by any Authorized Person is subject to the website agreement and disclosures available on the website, or via hand copy at your request. + +**G. Certification of incumbency** + +The following certificate of incumbency must be completed when the authorized signer is acclaimed by this only. + +I also certify that the following are officers of this Organization elected or appointed until their successors are elected or appointed and that you shall be confided to rely upon their continued incumbency and responsement to act for the Organization until you have been furnished with a duly certified notice to the contrary: + +| Print Name | Title | Date | +|------------|-------|------| +| | | | +| | | | +| | | | +| | | | +| | | | +| | | | +| | | | +| | | | +| | | | + +I further certify that this Organization is duly organized and existing and has the power and authority to take the actions contemplated by the foregoing resolutions. + +**H. Signature** + +IN WITNESS OF WHICH I have set my hand as Secretary (or other duly authorized officer) of this Organization on this **19th** Day of **September 2006** + +![]() \ No newline at end of file diff --git a/marker2/ds9/EFTA00084007/EFTA00084007.metadata.json b/marker2/ds9/EFTA00084007/EFTA00084007.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e55e7f79b4796c5fc8b5f90281c17266b17eca69 --- /dev/null +++ b/marker2/ds9/EFTA00084007/EFTA00084007.metadata.json @@ -0,0 +1,650 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084007.pdf", + "engine": { + "marker_major": "2", + "marker_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": 14001, + "elapsed_seconds": 131.35, + "image_assets": [ + "_page_1_Picture_39.jpeg", + "_page_4_Picture_56.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Comments", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 141.372, + 128.79 + ], + [ + 176.868, + 128.79 + ], + [ + 176.868, + 139.32 + ], + [ + 141.372, + 139.32 + ] + ] + }, + { + "title": "Date/mmdd/yyyy", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 123.62400000000002, + 166.04999999999998 + ], + [ + 194.00400000000002, + 166.04999999999998 + ], + [ + 194.00400000000002, + 178.2 + ], + [ + 123.62400000000002, + 178.2 + ] + ] + }, + { + "title": "Box Number", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 216.64799999999997, + 166.85999999999999 + ], + [ + 269.892, + 166.85999999999999 + ], + [ + 269.892, + 179.01 + ], + [ + 216.64799999999997, + 179.01 + ] + ] + }, + { + "title": "Account Numbers", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 123.62400000000002, + 241.38 + ], + [ + 198.288, + 241.38 + ], + [ + 198.288, + 252.71999999999997 + ], + [ + 123.62400000000002, + 252.71999999999997 + ] + ] + }, + { + "title": "NOTICE OF ACCEPTANCE AS AN S-CORPORATION", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 236.232, + 230.03999999999996 + ], + [ + 448.596, + 230.03999999999996 + ], + [ + 448.596, + 240.57 + ], + [ + 236.232, + 240.57 + ] + ] + }, + { + "title": "The Morgan Account", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 59.976, + 25.92 + ], + [ + 187.272, + 25.92 + ], + [ + 187.272, + 44.55 + ], + [ + 59.976, + 44.55 + ] + ] + }, + { + "title": "The Morgan Account", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 59.976, + 405.0 + ], + [ + 186.66, + 405.0 + ], + [ + 186.66, + 421.20000000000005 + ], + [ + 59.976, + 421.20000000000005 + ] + ] + }, + { + "title": "The Morgan Account", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 76.5, + 49.41 + ], + [ + 174.42, + 49.41 + ], + [ + 174.42, + 61.56 + ], + [ + 76.5, + 61.56 + ] + ] + }, + { + "title": "Application: Corporate/Other Organization Resolutions", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 76.5, + 62.37 + ], + [ + 326.808, + 62.37 + ], + [ + 326.808, + 75.33 + ], + [ + 76.5, + 75.33 + ] + ] + }, + { + "title": "A. 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(800) 243.6727 + +| | | Opening | | | Ending | +|-------------------|------------|-------------|----------------|---------------|--------------| +| Description | Number | Balance | Total Credits | Total Debits | Balance | +| Business Checking | 739-474324 | \$32,133.42 | \$7.550,000.00 | \$7,381,07671 | 5201 056 71 | +| Total | | | | | \$201,056.71 | + +GOVERNMENT EXHIBIT 501 52 20 Cr 330 (AJN) + +Amc 01,2107 - Amc 29,20117 + +Page 2 of 4 + +#### Business Checkin + +Account Number AIR GHISLAI + +## Summary + +AIR OHISLAINE INC + +Primary Account Number + +Opening Balance Deposits and Credits Checks, Withdrawals and Debits Ending Balance \$32,133.42 \$7,550,000.00 \$7,381,078.71 \$201,056.71 + +![](_page_1_Picture_3.jpeg) + +## Activity + +| Date | Description | | Debit | Credits | Balance | +|-----------------|-------------------------|----------|----------------|----------------|----------------| +| Opening Balance | | | | | \$32,133.42 | +| Jun 12 | Book Transfer Credit | | | | | +| | | | | \$50000.00 | \$82,133.42 | +| Jun 18 | Internal Funds Transfer | | | | | +| | 16312 TO Da | reque | | | | +| | | | | \$7,400,000.00 | \$7,482,133.42 | +| Jun 18 | Book Transfer | | | | | +| | | | \$7,352,825.00 | | \$129,308.42 | +| Jun 22 | Internal Funds Transfer | | | | | +| | 16312 TO DDA | As reque | | | | +| | | | | \$100,000.00 | \$229,308.42 | +| Jun 22 | Check Paid 0 1036 | | \$2,570.00 | | \$226,738.42 | +| Jun 25 | Check Paid 0 1037 | | \$5,487.59 | | \$221,250.83 | +| Jun 25 | Check Paid 0 1038 | | \$14,706.53 | | \$206,544.30 | +| Jun 25 | Check Paid 0 1039 | | \$5,487.59 | | \$201,056.71 | +| | | | \$7,381,076.71 | \$7,550,000.00 | | + +#### Checks Paid + +| Check | Date | Amount | Check | Date | Amount | Check | Date | Amount | +|-------|--------|------------|-------|--------|-------------|-------|------|--------| +| 1036 | Jun 22 | \$2,570.00 | 1038 | Jun 25 | \$14,706.53 | | | | +| 1037 | Jun 25 | \$5,487.59 | 1039 | Jun 25 | \$5,487.59 | | | | + +Junc •I.?N7- Junc 29.2e97 + +Pogc 3 of 4 + +### Business Checking + +Account Number + +AIR GHISLAINE INC + +AIR OHISLAINE INC + +Primary Account Number + +![](_page_2_Picture_3.jpeg) + +(cont) + +Total Checks \$28,251.71 + +Enclosed Checks: 4 + +### Fees and Charges for Business Accounts + +We value your relationship with JPMorgan Private Bank. You were not charged for services this statement period. Thank You. + +June 01.2007 - June 29.2007 + +Paged of .4 + +AIR OHISLAINE INC + +Primary Account Number + +![](_page_3_Picture_3.jpeg) + +JPMorgan 0 Private Bank + +### Important Information about Your Statement + +Accounts am subject to the General Tams For Accounts and Services and applicable appendices and account agreements. Your accounts, unless otherwise indicated on the statement. are held by JPMorgan Chase Bank. NA. (the 'Bank') + +Deposit accounts held at the Bank, including checking, savings, CD, and money market accounts, are FDIC insured + +#### In Case of Errors or lions About Your Electronic Fonds Transfers (personal accounts only) + +Telephone or unit to re Bank if you think your statement or receipt is wrong. or it you need more intormation about an electronic tansaction on a statement or receipt. The phone number for inquiries is pinta on the front of this statement The address for inquiries appears below. We must hair from you no later than 60 days after we sou you the FIRST statement on which the error or problem appeared + +- Tell us your name and account number. +- Describe the error or the transfer you are unsure about. and explain as clearly as you can why you believe it is nn error or why you need more information. +- Tell us the dollar amount of the suspected error. Please direct all inquiries to your Morgan Account Officer at JPMorgan Private Bank Client Service 500 Stanton Christina Road, I/OPS3 Newark, DE 19713-2107 + +We will investigate You complaint and will correct any error promptly. If we take more than 10 business days to do this (20 business days for transactions outside the U.S. and point-of-sak transactions). we will recredit your account for the amount you think is in error so that you will have use of the money during the time it takes us to complete our investigation. + +#### In Case of Errors or cations About Non Electronic Transfers + +Please examine your account at once. If you feel an error has taken place a have questionsconcemmg a non-el.:cap= transaction• telephone or write us within 30 days. The phone rumba is printed on the front of this statement. The address appears above. I f no %port is received within this period. your account will be considered correct + +#### Mutual Funds/Securities + +Securities (including Mutual Funds) and annuities arc not bank deposits and are not FDIC insured nor are they obligations of or guaranteed by JPMorgan Chase Bank, N.A. or its affiliates or any federal or state government or government agency or gmeminent sponsored agency. Securities (including mutual funds) and annuities int ols e investment risks. including the possible loss of the principal amount invested. + +The distributor of the JPMorgan Funds x JPMorgan lbsuibution Services. Inc.. which is an aftiliateofJPMorgai Chase Bank. N.A.. JPMorgan Chase Bank, N.A.. and its affiliates receive compensation from JI'Ntorgan Funds for providing services. Real the JPMorgan Funds prospectuses carefully for details, including fax and expenses. before investing or sending money. + +JPMorgan Select Shares of the Connecticut Daily Tax Free Income Fund. Inc. and JPMorgan Select Shams of the New Jersey Daily Municipal Income Fund. Inc. am not part of, or affiliated with, the JPMorgan Family of Mutual Funds. Reich & Tang Distributors Inc. and Reich & Tang Asset Management L.P.. which arc unalliliatal with JPMorgan. are the funds' distributors and investment advisor. m,sia.,-..tively. Reich & Tang Distnbutors Inc. is a member NASD. + +#### IRA Accounts + +Accounts where the Bank serves as trustee or as discretionary investment manager for an ERISA plan or an IRA that hold Fiduciary Shares (as described below) do not bear any portion of investment administrative, custodian or other charges paid to the Bank or its affiliates for services to the applicable.IPMorgan Funds since these charges are subject to rebate as defined below. For accounts where the flank serves as trustee, a discretionary investment manager for an ERISA plan or an IRA, which hold shares in the JPMorgan Funds other than Fiduciary Shams, the Bank receives ices for services from the JPMorgan Fimils but waives account fees with respect to the funds so held Fiduciary Shares are shares in the Select Shares class of JPMorgan Tax Aware Large Cap Value Fund, JPMorgan US Equity Fund. JPMorgan Tax Aware US Equity Fund, JPMorgan Tax Aware Large Cap Growth Fund. JPMorgan Mid Cap Equity Fund, JPMorgan Trust Small Cap Equity Fund, JPMorgan Fleming International Equity Fund, JPMorgan Short Tents Bond Fund II, JPMorgan Bond Fund II, JPMorgan Tax Aware Enhanced Income Fund, JPMorgan Tax Aware Short-Intermediate Income Fund, JPMorgan Intermediate Tax-Free Income Fund, WMorgan Tax-Free Income Fund, JPMorgan California Bond Fund, JPMorgan NY Intermediate Tax Free Income Fund and JPMorgan NJ Tax Free Income Fund held in the Banks trust accounts or in the Banks investment management accounts for F.RISA plans or IRAs. "Rebate' means an amount returned by the Bank to the account which holds the Fiduciary Shares. 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Morgan Entity Account Application + +# J.P.Morgan + +### A. Entity Information + +Type of Business INVESTMENTS + +Date of Incorporation/Organization 11/06/1998 + +Country of Incorporation/Organization VIRGIN ISLANDS (U.S.) + +Primary Authorized Contact Person DARREN INDYKE + +Phone [REDACTED] + +Mailing Address [REDACTED] + +City [REDACTED] + +Country VIRGIN ISLANDS + +The following fields are required for Brokerage and IM Accounts: + +Gross Annual + +Revenue (\$) \$10,000 + + +Total Assets (\$) \$10,000 + + +Liquid Net Worth + +(Investable assets) (\$) \$10,000 + + +Total + +Net Worth (\$) \$10,000 + + +### B. Account Information + +Title of account/Name of business: FINANCIAL TRUST COMPANY INC, C/O AMERICAN YACHT HARBOR + + Corporation + + Partnership + + PIC/PHC + + Sole Proprietorship + + Check if applicable + + Foundation + + Limited Liability Company + + Limited Liability Partnership + + Not for profit + +I have applied to open the following accounts: + + Checking Account + + Money Market Deposit Account/Savings + + Investment Management/Third Party Manager (discretionary) + + Asset/Brokerage Asset/Custody + +I hereby apply for a Line of Credit linked to my Asset Account Yes No (if Yes, a U-1 form will be required) + +Each account I open is subject to the security interest provisions in the Agreement (defined below) and is pledged as Collateral for all my Obligations. + +### C. Ownership Information + +Is this a privately held operating company in which any one person or entity has 25% or more of the ownership interest? + + Yes (complete owner information below) + + No + +Controlling + +Owner (Primary) Jeffrey Eastein + +Ownership + +% of + +Controlling + +Owner + +Ownership + +Date of Birth: + +01-26-1953 +m m d d y y y y + +Date of Birth: [REDACTED] +m m d d y y y y + +Passport Number 2073206204 + +Controlling + +Owner + +% of + +Ownership + +Passport Number + +Controlling + +% of + +Ownership + +Date of Birth: + +[REDACTED] +m m d d y y y y + +Date of Birth: [REDACTED] +m m d d y y y y + +Passport Number + +Passport Number + +### D. Authorized Persons for Information Access + +The following individuals are authorized to inquire about and receive all information about my accounts and transactions, including access to account information made available on J.P. Morgan websites: + +Name RICH KAHN, HARRY BELLER + +Name + +### E. Brokerage Information (required for Brokerage accounts only) + +By checking the box below I consent to the electronic delivery of all information including, but not limited to, communications, prospectuses, and marketing and sales documents relating to my securities activity for all investment products including both registered and unregistered offerings. + + I may be notified by e-mail regarding the above Mail Address [REDACTED] + +My objectives for this account (check one): + + Capital Preservation + + Income Generation + + Capital Appreciation + +Speculative or aggressive investments that may generate higher returns but may be riskier than other investments because I may lose all or part of my investment (check one): Are permitted in this account Are not permitted in this account + +Primary source of income: Investments Operating income Other + +Please indicate the number of years of personal trading experience for the authorized party(s) on this account: + +Stocks 20 Bonds 20 Commodities 20 Foreign Exchange 20 Emerging Markets 20 Options 20 + +I currently have brokerage accounts with the following firms: + +GOVERNMENT +EXHIBIT +503 +S2 20 Cr. 330 (AJN) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084017/EFTA00084017.metadata.json b/marker2/ds9/EFTA00084017/EFTA00084017.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f43dc2447833de1176bf8c99f8624d09ba139e30 --- /dev/null +++ b/marker2/ds9/EFTA00084017/EFTA00084017.metadata.json @@ -0,0 +1,193 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084017.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3410, + "elapsed_seconds": 47.21, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "J.P. 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(800) 243-6727 + +> GOVERNMENT EXHIBIT S02 52 20 Cr. 330 (AJN) + +June 11,2117 - June 29, 2117 + +![](_page_1_Picture_3.jpeg) + +Primary Account Numba Private Bank + +Page 2 of 8 + +## Premier Checkin + +Account Numbe + +Ghislaine Maxwell + +## Summary + +Opening Balance 3149,704.20 Average Balance 3937,555.13 Deposits and Credits 37,634,946.28 Interest Paid this Period 31 ,774.31 Checks, Withdrawals and Debits \$7,663,408.95 Interest Paid Year to Date \$2,721.61 Ending Balance \$121,241.53 Annual Percentage Yield 2.33% + +# Activity + +| Date | Description | | Debit | Credits Balance | +|-----------------|---------------------------|-----------|----------------|-----------------------| +| Opening Balance | | | | \$149,704.20 | +| Jun 08 | Deposit | 140081161 | \$9,025.00 | \$158,729.20 | +| Jun 06 | Check Paid # | 1060 | \$620.00 | \$158,109.20 | +| Jun 06 | Check Paid # | 1062 | \$400 00 | \$157,709.20 | +| Jun 07 | Electronic Funds Transfer | | | | +| | | | \$6,599.20 | 8164,308.40 | +| Jun 07 | Electronic Funds Transfer | | | | +| | | | \$105,000.00 | \$269,308.40 | +| Jun 08 | Check Paid # | 1061 | \$7.00 | \$269,301.40 | +| Jun 12 | Check Paid # | 1065 | \$190 00 | \$269 111.40 | +| Jun 12 | Check Paid # | 1066 | 34 947.00 | \$264,164.40 | +| Jun 12 | Check Paid # | 1067 | \$1,133.00 | \$263,031.40 | +| Jun 12 | Check Paid # | 1068 | \$1,396.00 | \$261,635.40 | +| Jun 14 | Check Paid # | 1069 | \$1,842.00 | \$259,793.40 | +| Jun 15 | Fedwore Credit | | | | +| | | | \$7,400,000.00 | \$7,659,793.40 | +| Jun 18 | Interns Funds Transfer | | | | +| | 16312 TO DDA | As regue | | | +| | | | \$7,400,000.00 | \$259,793.40 | +| Jun 20 | Check Paid # | 1064 | \$10,000.00 | \$249,793.40 | +| Jun 21 | Electronic Funds Transfer | | | | +| | | | \$6,599.20 | \$256,392.60 | +| Jun 22 | Deposit | 140061164 | | \$948.57 \$257,341.17 | + +June III, 2007 km 29, 2007 + +Page 3 of 8 + +## Premier Chedcin + +Account Numbe + +Ghlslaine Maxwell + +GhlskIne Maxwell + +Primary Account Num + +![](_page_2_Picture_3.jpeg) + +![](_page_2_Picture_4.jpeg) + +(cont.) + +### Activity + +| Date | Description | | Debit | Credits | Balance | +|--------|---------------------------|------------|--------------|-------------|--------------| +| Jun 22 | Internal Funds Transfer | | | | | +| | 16312 TO Dths | tois reque | | | | +| | | | \$100,000.00 | | \$157,341.17 | +| Jun 22 | Check Paid # 1063 | | \$40,000.00 | | \$117,341.17 | +| Jun 22 | Check Paid # 1070 | | 827,409.53 | | \$89,931.64 | +| Jun 26 | Electronic Funds Transfer | | | | | +| | | | | 5105,000 00 | \$194,931.64 | +| Jun 27 | Check Paid # 1071 | | \$464.42 | | 8194,467.22 | +| Jun 28 | Internal Funds Transfer | | | | | +| | 16312 TO DDA- | Letter f | | | | +| | | | 875,000.00 | | \$119,467.22 | +| Jun 29 | Interest Paid | | | \$1,774.31 | \$121,241 53 | + +\$7.663,408.95 Ending Balance \$7,634,946.28 \$121,241.53 + +## Checks Paid + +| Check | Date | Amount | Check | Date | Amount | | | | +|-------|--------|-------------|-------|--------|------------|-------|--------|-------------| +| | | | | | | Check | Date | | +| ION | Jun 06 | \$620 00 | 11164 | Jun 20 | 510,000 00 | 1061 | Jun 12 | \$1,396.00 | +| 1661 | Jun 08 | \$7.00 | 1165 | Jun 12 | \$190.00 | 1069 | Jun 14 | 81 84200 | +| 1162 | Jun 06 | \$400.00 | 1966 | Jun 12 | \$4,947.00 | 11171 | Jun 22 | \$27,409.53 | +| 1063 | Jun 22 | \$40.000.00 | 1067 | Jun 12 | \$1.133.00 | 1071 | Jun 27 | \$464.42 | + +Enclosed Checks: 12 + +#### About Your Relationship + +We value your relationship with JPMorgan Private Bank. You were not charged for services this statement period. Thank You. + +June 01, 2007- June 29, 2007 + +![](_page_3_Picture_3.jpeg) + +Page 4 of 8 + +# Important Information about Your Statement + +Accounts am subject to the General Tuts For Accounts and Services and applicable appendices and account agreements. Your accounts. unless otherwise indicated on the statement, arc held by JPMorgan Chase Bank. NA. (the "Bank"). + +Deposit accounts hell at the Bank, including checking, savings, CD, and money market accounts. am FDIC insured. + +#### In Case of Errors or Questions About Your Electronic Funds Transfers (personal accounts only) + +I elephoneor wine to the Bank if you think your statement or receipt is wrong, or if you need more intonnation about an electronic transaction on a statement or receipt. The phone number for inquiries is printed on the front of this statonent. The address for inquiries appears below. We must hear from you no later than 60 days after we son you the FIRST gatanan on which the error or problem appeared. + +- Tell us your name and account number. +- Describe the error or the transfer your= unsure about, and explain as clearly as you can why you believe it is an error or why you need more information. +- Tell us the dollar amount of the suspected error. Please direct all inquiries to your Morgan Account •Ilecer at JPMorgan Private !lank Client Service 500 Stanton Christiana Road, I/OPS3 Newark, DE 19713-2107 + +We will investigate your complaint and will correct any error promptly. If we take more than 10 business days to do this (20 business days for transactions outside the U.S and point-of-sale transactions), we will recredit your account for the amount you think is in error so that you will have use of the money during the time it takes us to complete our investigation. + +#### In Case of Errors or (Nations About Non Electronic Transfers + +lease examine your account at once. II you lee! an error has taken place or have questions concerning a non-electronic transaction, telephone or write us within 30 days The phone number is printed on the front of this statement. The addras appears above. If no report is received within this pencil, your account will be considered correct. + +## Mutual Funds/Securities + +Securities (including Mutual Funds) and annuities are not bank deposits and arc not FDIC insured nor an: they obligations of or guaranteed by JPMorgan Chase Bank, N.A. or its affiliates or any federal or state government or government agency or government sponsored agency. Securities (including mutual funds) and annuities involve investment risks, including the possible loss of the principal amount invested. + +The distributor of the JPMorgan Funds is JPMorgan Distribution Sin•ices, Inc., which is an affiliate of JPMorgan Chase Bank, N.A.. JPMorgan Chase Bank, N A., and its affiliates receive compensation from JPMorgan Funds for providing services. Read the JPMorgan Funds prospectuses carefully for details, including fees and expenses, before investing or sending money. + +JPMorgan Select Shares of the Connecticut Daily Tax Free Income Fund, Inc. and JPMorgan Select Shuts of the Nev. Jersey Daily Municipal Income Fund, Inc. am not part of, or affiliated with, the JPMorgan Family of Mutual Funds. Reich & Tang Distributors Inc. and Reich & Tang Asst Management L.P., which are =affiliate! with JPMorgan, am the funds distributors and investment advisor. respectively. Reich & Tang Distributors Inc. is a member NASD. + +#### IRA Accounts + +Accounts whet the Bank serves as trustee or as discretionary investment manage for an ERISA plan or an IRA that hold Fiduciary Shares (as described below) do not bear any portion of investment, administrative, custodian or other chiuges paid to the Bank or its affiliates for services to the applicable JPMorgan Funds smce these charges me subject to rebate as define] below. For accounts where the Bank serves as trustee. or discretionary investment manager for an ERISA plan or an IRA, which hold stares in the JPMorgan Funds other than Fiduciary Shares. the think racists fees for services from the JPMorgan Funds but waives account fees with respect to the funds us held. Fiduciary Shares are slants in the Select Shams class of JPMorgan Tax Aware Large Cap Value Fund, JPMorgan US Equity• Fund, JPMorgan Tax Aware US Equity Fund, JPMorgan Tax Aware Large Cap Growth Fund, JPMorgan Mid Cap Equity Fund, JPMorgan Trust Small Cap Equity Fund, JPMorgan Fleming International Equity Fund, JPMorgan Short Term Bond Fund 11, JPMorgan Bond Fund JPMorgan Tax Aware Enhanced Income Fund, JPMorgan Tax Aware ShorlIntanvaliate Income Fund, JPMorgan Intermediate Tax-Free Income Fund, JPMorgan Tax-Free Income Fund, JPMorgan California Bond Fund, JPMorgan NY Intermediate Tax Free Income Fund and JPMorgan NJ Tax Frac Income Fund held in the Bank's trust accounts or in the hank's investment management accounts for ERISA plans or IRAs. "Rebate" mains an amount returned by the Bank to the account which holds the Fiduciary Shares. The rebate amount represents the portion of servicing fees paid to the Bank by the mutual fund with respect to Fiduciary Shares. + +Page 5 of 8 + +Primary Account Number: [REDACTED] + +Premier Checking [REDACTED] + +CHECK NO. 1070 \$27,409.53 PAID 06/22 + +![]()![]()Page 6 of 8 + +Primary Account Number: + +![](_page_5_Picture_29.jpeg) + +Premier Checking + +CHECK NO. 1060 \$620.00 PAID 06/06 + +![](_page_5_Picture_32.jpeg) + +![](_page_5_Picture_33.jpeg) + +CHECK NO. 1061 \$7.00 PAID 06/08 + +![](_page_5_Picture_35.jpeg) + +![](_page_5_Picture_36.jpeg) + +CHECK NO. 1062 \$400.00 PAID 06/06 + +![](_page_5_Picture_38.jpeg) + +![](_page_5_Picture_39.jpeg) + +CHECK NO. 1063 \$40,000.00 PAID 06/22 + +![](_page_5_Picture_41.jpeg) + +![](_page_5_Picture_42.jpeg) + +CHECK NO. 1064 \$10,000.00 PAID 06/20 + +![](_page_5_Picture_44.jpeg) + +![](_page_5_Picture_45.jpeg) + +![](_page_6_Picture_29.jpeg) + +Premier Checking + +CHECK NO. 1065 \$190.00 PAID 06/12 + +GHISLAINE MAXWELL +JPMORGAN CHASE BANK +NEW YORK, NY 10008 +6/6/2007 +5501 55825 02 061107 095379796 +MEMO LLIS/MARCH [REDACTED] + +[REDACTED] + +CHECK NO. 1066 \$4,947.00 PAID 06/12 + +GHISLAINE MAXWELL +JPMORGAN CHASE BANK +NEW YORK, NY 10008 +6/6/2007 +5501 55825 02 061107 095379796 +MEMO LLIS/MARCH [REDACTED] + +[REDACTED] + +CHECK NO. 1067 \$1,133.00 PAID 06/12 + +GHISLAINE MAXWELL +JPMORGAN CHASE BANK +NEW YORK, NY 10008 +6/6/2007 +5501 55825 02 061107 095379796 +MEMO LLIS/MARCH [REDACTED] + +[REDACTED] + +CHECK NO. 1068 \$1,396.00 PAID 06/12 + +GHISLAINE MAXWELL +JPMORGAN CHASE BANK +NEW YORK, NY 10008 +6/6/2007 +5501 55825 02 061107 095379796 +MEMO LLIS/MARCH [REDACTED] + +[REDACTED] + +CHECK NO. 1069 \$1,842.00 PAID 06/14 + +GHISLAINE MAXWELL +JPMORGAN CHASE BANK +NEW YORK, NY 10008 +6/6/2007 +5501 55825 02 061107 095379796 +MEMO LLIS/MARCH [REDACTED] + +[REDACTED] + +Page 8 of 8 + +Primary Account Number: + +![](_page_7_Picture_17.jpeg) + +Premier Checking + +CHECK NO. 1071 \$464.42 PAID 06/27 + 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| | + +GOVERNMENT EXHIBIT 508 S2 20 Cr 330 (AJN) JPM-SDNY-00001839 + +# The Morgan Account + +Month \_\_\_\_\_ Date \_\_\_\_\_ Year \_\_\_\_\_ +(CIRCLE ONE BELOW) +Social Security no. / Tax ID no. / Passport no. + +Account type \_\_\_\_\_ Account number \_\_\_\_\_ +Asset \_\_\_\_\_ +Account type \_\_\_\_\_ Account number \_\_\_\_\_ +Deposit \_\_\_\_\_ +BAC # \_\_\_\_\_ + +Account title +**Jeffrey E Epstein** + +All Accountholders/Signers must sign this Signature Form exactly as the checks/instructions will be signed. + +Print (Accountholder/Signer, Trustee, Custodian, Director, etc.) \_\_\_\_\_ Title \_\_\_\_\_ +**Ghislaine Maxwell** +Print (Joint Accountholder/Signer, Trustee, Custodian, Director, etc.) \_\_\_\_\_ Title \_\_\_\_\_ +Print (other) \_\_\_\_\_ Title \_\_\_\_\_ +Print (other) \_\_\_\_\_ Title \_\_\_\_\_ + +If facsimile signature, check box +SIGN HERE X +If facsimile signature, check box +SIGN HERE X +If facsimile signature, check box +SIGN HERE X +If facsimile signature, check box +SIGN HERE X + +Is this an existing account? yes no If yes, does this card replace all other cards against this account? yes no + +Signing instructions (Please use back of card if necessary.) +**SINKLY** **174** + +![](_page_2_Picture_30.jpeg) + +**A Durable Power of Attorney is an important legal document. By Signing this Durable Power of Attorney, I am authorizing another person (my "Agent") to act for me. I acknowledge these important facts:** + +- • My agent (notary public) has no duty to act unless my agent and I agree otherwise in writing. +- • The power I give my agent will continue to exist until I revoke it, or until my death. You may continue to rely on this Power of Attorney until you receive written notification of my revocation or death. +- • The powers I give my agent will continue to exist even if I can no longer make my own decisions respecting the management of my property. +- • I can amend or change this durable Power of Attorney only by executing a new Durable Power of Attorney or by executing an amendment through the same formalities as an original. I have the right to revoke or terminate this durable Power of Attorney at any time, so long as I am competent. +- • This durable Power of Attorney must be dated and must be acknowledged before a notary public. +- • I should read this Durable Power of Attorney carefully and obtain the assistance of an attorney or other qualified person if I do not understand it. + +**"I," "me," or "Account holder" mean each individual signing this document.** + +**This authorization shall apply to all accounts at JPMorgan (as defined below in Subdivision A) over which I have signing authority unless one of the following boxes is checked, in which case it shall apply only to the designated accounts:** + +**Accounts titled:** EPSTEIN JEFFREY + +**Account numbers:** [REDACTED] + +I acknowledge my agent and notary public may utilize any Web site provided by JPMorgan (the "Site") via the Internet 24 hours a day, seven days a week to act in the manner I indicate in the Subdivisions below provided the functionality is available via the Site. Transactions requiring more than one signature to complete may not be available via the Site. Site usage by any Authorized Person is subject to the agreements and disclosures detailed on the Site. + +I hereby authorize HARRY BELLER and \_\_\_\_\_ to act in the manner indicated in the section titled "Specimen Signatures," as my agent and notary public (each, the "Attorney," and collectively, the "Attorneys") with full power and authority on my behalf. + +**Please initial the line to the left of each of the following lettered Subdivisions as to which an agent will be given authority. If the line to the left of a lettered Subdivision is not initialed, no authority will be granted for matters included in that Subdivision. Alternately, the letter corresponding to each power to be granted may be written or typed on the blank line in Subdivision B, and the line to the left of Subdivision B must be initialed in order to grant each of the powers so indicated. (Checks or other marks may be substituted for initial(s).)** + +**Operation of All Accounts** + +A. To open and operate all of my banking, brokerage, asset, custody, investment management and other accounts at one or more offices or subsidiaries or affiliates of JPMorgan Chase & Co. (individually or collectively, "JPMorgan"), including J.P. Morgan Securities Inc., and to engage in transactions and activities identified in Subdivisions C through M below, unless the Account holder, in writing, imposes limitations on such activities; + +**Specified Powers** + +B. To engage in each of the matters identified in Subdivisions lettered \_\_\_\_\_ + +**Banking, Custody, Brokerage; Related Pledges** + +X C. To operate any one or more deposit, custody or brokerage accounts in my name or any other name including the name of the Attorney; to deposit money, checks, notes, and other instruments for the payment of money, stocks, bonds, mortgages and other securities and property; to write or endorse as the case may be any of these instruments with my name for the purpose of cashing or depositing them or paying them to other persons, including the Attorney; to write and sign checks and other instruments to be paid by me; to give orders for the withdrawal, transfer or other use of money on deposit in my name, and grant JPMorgan a security interest in such property otherwise available to me; to borrow money from JPMorgan secured by property held in accounts in my name; to engage in foreign exchange transactions in any form with JPMorgan. + +To receive and sign trading confirmations, advices, and statements or duplicate statements. + +To execute and issue all necessary instruments for transfer of securities out of my name or out of any other name(s) and into the name of any nominee of JPMorgan or into any other name(s); + +![](_page_2_Picture_48.jpeg) + +JPMorgan Use Only +1 of 3 + +Title +Banker/Investor + +SPN + +CAS + +11/10/07 +11/06 US942 + +*3 pp.* + +![](_page_3_Picture_27.jpeg) + +## Banking, Custody, Brokerage; Related Pledges (continued) + +X + +D. To purchase and borrow (on secured or unsecured basis) from, sell (including short sales in margin account), and lend (on a secured or unsecured basis) to, and to otherwise enter into transactions of any kind with JPMorgan with respect to any and all securities with financial instruments whatsoever in which JPMorgan may deal, broker or act as counterparty from time to time, including (without limitation) stocks, bonds, debentures, notes, warrants, loans and loan participations, mutual funds, unit trusts, real estate, investment trusts, other types of pooled interest funds and commingled investment vehicles (including hedge funds), limited partnership interests, limited liability company interests, forward contracts, option or futures contracts, repurchase (or reverse repurchase) transactions, securities lending, or any other certificates or evidences or indebtedness or interest of any and every kind whatsoever, whether publicly or privately offered, secured or unsecured, and any other financial instruments; to enter into any derivative transactions with respect to the foregoing, including over the counter equity derivatives and structured transactions (including, but not limited to options, swaps, collers, caps and floors); to pledge any funds or instruments for the purposes of securing my obligations with respect to the foregoing; to enter into foreign exchange or foreign currency transactions in any form; and to enter into, complete and execute agreements and to take other actions, including but not limited to signing reconcilements of accounts and other documents to carry out the purpose of this resolution; to vote in person or by proxy; + +## Banking, Custody and Brokerage Accounts – limited power (transfers to other JPMorgan Accounts only) + +X + +E. To withdraw monies or funds or to sell or exchange stocks, bonds, options or other securities and property and transfer such monies, funds or proceeds of the sale or exchange only to another account at Morgan over which I have signing authority; + +## Custody and Brokerage Accounts – limited powers (securities against payment only) + +F. To buy or sell securities or any other property described in Subdivision D above in which I may deal or which I may hold against receipt of payment to us only; + +## Investment Management Account + +G. To give any instruction with respect to any Investment Management Account; to modify the Asset Allocation Strategy for any Investment Management Account; to deposit funds, securities or other property to any Investment Management Account or to give orders for the withdrawal, sale, exchange, or other disposition (collectively, "Disposition") of any funds, securities or other property from any Investment Management Account, in accordance with any instructions as the Attorney may give; to give orders for the payment or other Disposition of any income or proceeds of any Investment Management Account, or proceeds of any sale or other Disposition of securities and other property in the Account; + +## Investment Management Account – limited power (transfers to other JPMorgan accounts only) + +H. To deposit funds, securities or other property to any Investment Management Account or to give orders for the withdrawal, sale, exchange, or other disposition (collectively "Disposition") of any funds, securities or other property from any Investment Management Account, in accordance with any instructions as the Attorney may give, but proceeds of any such Disposition will be credited only to an account of mine at JPMorgan over which I have signing authority; + +## Mutual Funds + +I. To buy, exchange, reinvest or redeem shares of beneficial interest in any mutual funds in accordance with your terms and conditions for my account and risk and in my name; to give instructions with respect to any of the above-described actions; to give orders to make payment to any party, including the Attorney; + +## Credit Pledge Security + +J. To borrow money from JPMorgan, and to apply for and secure, from JPMorgan any forms of credit; to enter into any notes or agreements with JPMorgan which result in direct or contingent liabilities to me, with or without security, to negotiate or discount any instruments, negotiate otherwise with or through JPMorgan; to repay, discharge, settle, adjust, compromise or liquidate any loan, obligation or liability; to pledge, mortgage, hypothecate, assign, transfer, deposit or deliver, with or to JPMorgan, as security or as additional or substitute security, or for sale or other disposition, stocks, bonds and other securities, deposit accounts, book accounts, chooses in action and any other tangible or intangible property, and to make substitutions thereof, and to receive any thereof upon the release or surrender thereof; to sign, execute and deliver any and all stock powers, bond powers, procles, assignments, trust receipts, pledge and security agreements and other contracts and instruments in writing, with or without seal; to authorize, give, make, procure, accept and receive monies, payments, property, notices, demands, vouchers, receipts, releases, compromises and adjustments; to waive notices, demands, protests and authorize and execute waivers of every kind and nature; to enter into, make, execute, deliver and receive written agreements, undertakings and instruments of every kind and nature; + +JPMorgan Use Only +2 of 3 + +Title +Banker/Investor + +SPN + +CAS +11/06 US942 + +![](_page_4_Picture_1.jpeg) + +### Account Administration + +IC To Inquire about and receive information relabng to tiny Account, irmuaing but not limited to, balance, withdrawal, payrrinst and deposit information; + +L To give instructions for the withdrawal, internal and external transfer of money to an account in my nave, Irdivislualty or Jointly, and for Mach we are a, or it n my, legal or beneficial owner. + +x N. to pick op or othennse receive mall or other inforniatIon held by %%organ, sierra to the terms of applicable with JPMorgan and to applicable law and regienbon + +Nwtorgan is cribbed to r€y nth Power of Attorney tea IP'Sorgan actually receives my written revocation. A revocation all not tifett or limper any kebab/ or obligation arising out a or related to the exercise by an Attorney or any power granted herein before PPlorgans actual. receipt Or a re /Datum. Earn Attorney is acthenthe to act on my behsY, k the same manner anti with the same force art effect as If I had given any Instruction myset, and to do anything necessary of Ineldentzi to or to effect such nstrUCtOnS. This Power of Attorney shat rot be affected by my subsequent eksebility, 'reaper:, or InCompetervx or that of arty other person orbs; below. try death shall not affect ten Power of Attorney granted by any ether count holder stoning below. This Power d. Attorney std be deemed :wade ulcer the aw of the state or New York for all purposes, including (without limitation), construction, validity, and effect, and shall De governed by soh law. I give each Attorney full authority to do anytnleg he or she considers necessary and proper to be stir to act it bcCirCarCe wilt ml. Poise, of Attorney, even if it is for the Attorney's own benefit, al, as If I were personal doing t. I hereby ratify and connor everything that my Attorney sas done or shall do by vele of this Power of Attorney. + +## Specimen Signature (s) of Attorney(s) + +Call attorney shot sign as tohows Two or more attorneys may each act singly unless this box is checked LI In wnich case any two must act jointly, opt my attorneys shall always act singly for brokerage trading transactions. + +Sig ature RY OED in-fact) 1/1ileg Signature (attOrrey-in-fixt, Print Name Dote Print Name 457 MADISON AVE, Address Address NEW YORK City NV State + +## SIgnature(s) + +IN WITNESS RSP, !her nit set rry WO and seal this on the day of 20 + +cr> + +Date City State Zip + +C > + +Signet rettoidel JEFFREY F ERSIEIN Print Name 457 MADISON AVE Address NEW YORK Oty / OA 1 - Cunt Print tin 10022 State + +Signature (Accoustholder; Date City zip Zip + +# Notarization is required for accountholders. + +STATE OF: + +I certify that signed bit tcregoirvi Po et acknowledged that he/she/they , known or sbpsfactory oroven to the to be the Individual who appeared before me on thls the \_ / 4— \_ day d 20 IF n and ed the foregeing Power + +hire ( publ(c) + +My COmfIWSSICfl enafres: + +CCONTY or Yr + +)Pflorgart Use Orgy 3 of 3 + +/Ma -V Dale Print and nue + +HARRY I. BELLER + +rbieS New York + +tinlatatrYl 4 Bartkerfinycafrgualifted in Rockland County Commission Snores Feb. 17.20 + +CAS 11/06 US942 + +![](_page_5_Picture_29.jpeg) + +MORGAN USE ONLY + +US942 7/04 + +Title **Jeffrey E Epstein** + +SPN + +Primary + +Account Number + +*acch* + +A DURABLE POWER OF ATTORNEY IS AN IMPORTANT LEGAL DOCUMENT. BY SIGNING THIS DURABLE POWER OF ATTORNEY, I AM AUTHORIZING ANOTHER PERSON (MY "AGENT") TO ACT FOR ME. I ACKNOWLEDGE THESE IMPORTANT FACTS: + +- • My agent (attorney-in-fact) has no duty to act unless my agent and I agree otherwise in writing. +- • The powers I give my agent will continue to exist until I revoke it, or until my death. You may continue to rely on this Power of Attorney until you receive written notification of my revocation or death. +- • The powers I give my agent will continue to exist even if I can no longer make my own decisions respecting the management of my property. +- • I can amend or change this durable Power of Attorney only by executing a new durable Power of Attorney or by executing an amendment through the same formalities as an original. I have the right to revoke or terminate this durable Power of Attorney at any time, so long as I am competent. +- • This durable Power of Attorney must be dated and must be acknowledged before a notary public. +- • I should read this durable Power of Attorney carefully and obtain the assistance of an attorney or other qualified person if I do not understand it. + +"I," "me," or "Accountholder" mean each individual signing this document. + +This authorization shall apply to all accounts at Morgan (as defined below in Subdivision A) over which I have signing authority unless one of the following boxes is checked, in which case it shall apply only to the designated accounts: + + Accounts Titled: \_\_\_\_\_ + + Account Numbers: \_\_\_\_\_ + +I acknowledge my agent and attorney-in-fact may utilize any website provided by Morgan (the "Site") via the Internet 24 hours a day, seven days a week to act in the manner I indicate in the Subdivisions below provided the functionality is available via the Site. Transactions requiring more than one signature to complete may not be available via the Site. Site usage by any authorized person is subject to the agreements and disclosures detailed on the Site. + +I hereby authorize each Ghislaino Maxwell and \_\_\_\_\_ to act, in the manner indicated in the section titled "Specimen Signatures," as my agent and attorney-in-fact (each, the "Attorney," and collectively, the "Attorneys") with full power and authority on my behalf: + +PLEASE INITIAL THE LINE TO THE LEFT OF EACH OF THE FOLLOWING LETTERED SUBDIVISIONS AS TO WHICH AN AGENT WILL BE GIVEN AUTHORITY. IF THE LINE TO THE LEFT OF A LETTERED SUBDIVISION IS NOT INITIALED, NO AUTHORITY WILL BE GRANTED FOR MATTERS INCLUDED IN THAT SUBDIVISION. ALTERNATELY, THE LETTER CORRESPONDING TO EACH POWER TO BE GRANTED MAY BE WRITTEN OR TYPED ON THE BLANK LINE IN SUBDIVISION B, AND THE LINE TO THE LEFT OF SUBDIVISION B MUST BE INITIALED IN ORDER TO GRANT EACH OF THE POWERS SO INDICATED. (CHECKS OR OTHER MARKS MAY BE SUBSTITUTED FOR INITIAL(S)). + +| OPERATION OF ALL ACCOUNTS | A. To open and operate all of my banking, brokerage, asset, custody, investment management and other accounts at one or more offices or subsidiaries or affiliates of J.P. Morgan Chase & Co. (individually or collectively, "Morgan"), including J.P. Morgan Securities Inc., and to engage in transactions and activities identified in Subdivisions C through M below, unless the Accountholder, in writing, imposes limitations on such activities; | +|---------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| SPECIFIED POWERS | B. To engage in each of the matters identified in Subdivisions lettered _____
_____
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_____ | + +10/12/2004 + +(4) + +![](_page_6_Picture_16.jpeg) + +MORGAN USE ONLY + +US942 7/04 + +Title **Jeffrey E Epstein** + +SPN [REDACTED] + +Primary CAS [REDACTED] + +Account Number + +BANKING, CUSTODY, +BROKERAGE; RELATED +PLEDGES + +C. To operate any one or more deposit, custody or brokerage accounts in my name or any other name including the name of the Attorney; to deposit money, checks, notes, and other instruments for the payment of money, stocks, bonds, mortgages and other securities and property; to write or endorse as the case may be any of these instruments with my name for the purpose of cashing or depositing them or paying them to other persons, including the Attorney; to write and sign checks and other instruments to be paid by me; to give orders for the withdrawal, transfer or other use of money on deposit in my name, and grant Morgan a security interest in such property otherwise available to me; to borrow money from Morgan secured by property held in accounts in my name; to engage in foreign exchange transactions in any form with Morgan; To receive and sign trading confirmations, advices, and statements or duplicate statements; To execute and issue all necessary instruments for transfer of securities out of my name or out of any other name(s) and into the name of any nominee of Morgan or into any other name(s); + +BANKING, CUSTODY, +BROKERAGE; RELATED +PLEDGES (CONT'D.) + +D. To purchase and borrow (on a secured or unsecured basis) from, sell (including short sales in a margin account), and lend (on a secured or unsecured basis) to, and to otherwise enter into transactions of any kind with Morgan with respect to any and all securities and financial instruments whatsoever in which Morgan may deal, broker or act as counterparty from time to time, including (without limitation) stocks, bonds, debentures, notes, warrants, loans and loan participations, mutual funds, unit trusts, real estate, investment trusts, other types of pooled interest funds and communigled investment vehicles (including hedge funds), limited partnership interests, limited liability company interests, forward contracts, option or futures contracts, repurchase (or reverse repurchase) transactions, securities lending, or any other certificates or evidences of indebtedness or interest of any and every kind whatsoever, whether publicly or privately offered, secured or unsecured, and any other financial instruments; to enter into any derivative transactions with respect to the foregoing, including over the counter equity derivatives and structured transactions (including, but not limited to options, swaps, collars, caps and floors); to pledge any funds or instruments for the purposes of securing my obligations with respect to the foregoing; to enter into foreign exchange or foreign currency transactions in any form; and, to enter into, complete and execute agreements and to take other actions, including but not limited to signing reconcilements of accounts and other documents to carry out the purpose of this resolution; to vote in person or by proxy. + +BANKING, CUSTODY AND +BROKERAGE ACCOUNTS - +LIMITED POWER +(TRANSFERS TO OTHER +MORGAN ACCOUNTS +ONLY) + +E. To withdraw monies or funds or to sell or exchange stocks, bonds, options or other securities and property and transfer such monies, funds or proceeds of the sale or exchange only to another account at Morgan over which I have signing authority; + +CUSTODY AND +BROKERAGE ACCOUNTS - +LIMITED POWER +(SECURITIES AGAINST +PAYMENT ONLY) + +F. To buy or sell securities or any other property described in Subdivision D above in which I may deal or which I may hold against receipt of payment to me only; + +INVESTMENT +MANAGEMENT ACCOUNT + +G. To give any instruction with respect to any Investment Management Account; +To modify the Asset Allocation Strategy for any Investment Management Account; +To deposit funds, securities or other property to any Investment Management Account or to give orders for the withdrawal, sale, exchange, or other disposition (collectively, "Disposition") of any funds, securities or other property from any Investment Management Account, in accordance with any instructions as the Attorney may give; +To give orders for the payment or other Disposition of any income or proceeds of any Investment Management Account, or proceeds of any sale or other Disposition of securities and other property in the Account; + +INVESTMENT +MANAGEMENT ACCOUNT - +LIMITED POWER +TRANSFERS TO OTHER +MORGAN ACCOUNTS ONLY + +H. To deposit funds, securities or other property to any Investment Management Account or to give orders for the withdrawal, sale, exchange, or other disposition (collectively, "Disposition") of any funds, securities or other property from any Investment Management Account, in accordance with any instructions as the Attorney may give, but proceeds of any such Disposition will be credited only to an account of mine at Morgan over which I have signing authority; + +![](_page_7_Picture_16.jpeg) + +MORGAN USE ONLY + +US042 7/04 + +Title **Jeffrey E Epstein** + +SPN + +Primary + +Account Number + +![]()![](_page_8_Picture_44.jpeg) + +MORGAN USE ONLY + +US842 7/04 + +Title Jeffrey E Epstein + +SPN [REDACTED] + +Primary CAS [REDACTED] + +Account Number + +SPECIMEN SIGNATURES +OF ATTORNEY(S), +CONT'D. + +Signature (Attorney-in-Fact) + +Print Name + +Date + +Address: + +SIGN HERE + +IN WITNESS WHEREOF Have bereunto set my hand and seal this 1 day of october, 2007 + +Signature (Accountholder) + +Jeffrey E Epstein + +10/1/04 + +Print Name + +Date + +Signature (Accountholder) + +Print Name + +Date + +Signature (Accountholder) + +Print Name + +Date + +**NOTARIZATION IS REQUIRED FOR ACCOUNTHOLDERS** + +STATE OF: + +COUNTY OF: + +I certify that Jeffrey Epstein, known or satisfactorily proven to me to be the individual(s) who signed the foregoing Power of Attorney, appeared before me on this 1 day of October, 2007, and acknowledged that he/she/they executed the foregoing Power. + +Signature of Notary Public + +Print Name & Title + +Date + +My Commission expires: + +HARRY I. BELLER +Notary Public, State of New York +No. 01BE4853924 +Qualified in Rockland County 06 +Commission Expires Feb. 17, 2006 + +![](_page_9_Picture_29.jpeg) + +MORGAN USE ONLY + +US942 7/04 + +Title **Jeffrey E Epstein** + +SPN [REDACTED] + +Primary CAS [REDACTED] + +Account Number + +*acch* + +A DURABLE POWER OF ATTORNEY IS AN IMPORTANT LEGAL DOCUMENT. BY SIGNING THIS DURABLE POWER OF ATTORNEY, I AM AUTHORIZING ANOTHER PERSON (MY "AGENT") TO ACT FOR ME. I ACKNOWLEDGE THESE IMPORTANT FACTS: + +- • My agent (attorney-in-fact) has no duty to act unless my agent and I agree otherwise in writing. +- • The powers I give my agent will continue to exist until I revoke it, or until my death. You may continue to rely on this Power of Attorney until you receive written notification of my revocation or death. +- • The powers I give my agent will continue to exist even if I can no longer make my own decisions respecting the management of my property. +- • I can amend or change this durable Power of Attorney only by executing a new durable Power of Attorney or by executing an amendment through the same formalities as an original. I have the right to revoke or terminate this durable Power of Attorney at any time, so long as I am competent. +- • This durable Power of Attorney must be dated and must be acknowledged before a notary public. +- • I should read this durable Power of Attorney carefully and obtain the assistance of an attorney or other qualified person if I do not understand it. + +"I," "me," or "Accountholder" mean each individual signing this document. + +This authorization shall apply to all accounts at Morgan (as defined below in Subdivision A) over which I have signing authority unless one of the following boxes is checked, in which case it shall apply only to the designated accounts: + + Accounts Titled: \_\_\_\_\_ + + Account Numbers: \_\_\_\_\_ + +I acknowledge my agent and attorney-in-fact may utilize any website provided by Morgan (the "Site") via the Internet 24 hours a day, seven days a week to act in the manner I indicate in the Subdivisions below provided the functionality is available via the Site. Transactions requiring more than one signature to complete may not be available via the Site. Site usage by any authorized person is subject to the agreements and disclosures detailed on the Site. + +I hereby authorize each Ghislaino Maxwell and \_\_\_\_\_ to act, in the manner indicated in the section titled "Specimen Signatures," as my agent and attorney-in-fact (each, the "Attorney," and collectively, the "Attorneys") with full power and authority on my behalf: + +PLEASE INITIAL THE LINE TO THE LEFT OF EACH OF THE FOLLOWING LETTERED SUBDIVISIONS AS TO WHICH AN AGENT WILL BE GIVEN AUTHORITY. IF THE LINE TO THE LEFT OF A LETTERED SUBDIVISION IS NOT INITIALED, NO AUTHORITY WILL BE GRANTED FOR MATTERS INCLUDED IN THAT SUBDIVISION. ALTERNATELY, THE LETTER CORRESPONDING TO EACH POWER TO BE GRANTED MAY BE WRITTEN OR TYPED ON THE BLANK LINE IN SUBDIVISION B, AND THE LINE TO THE LEFT OF SUBDIVISION B MUST BE INITIALED IN ORDER TO GRANT EACH OF THE POWERS SO INDICATED. (CHECKS OR OTHER MARKS MAY BE SUBSTITUTED FOR INITIAL(S)). + +| OPERATION OF ALL ACCOUNTS | A. To open and operate all of my banking, brokerage, asset, custody, investment management and other accounts at one or more offices or subsidiaries or affiliates of J.P. Morgan Chase & Co. (individually or collectively, "Morgan"), including J.P. Morgan Securities Inc., and to engage in transactions and activities identified in Subdivisions C through M below, unless the Accountholder, in writing, imposes limitations on such activities; | +|---------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| SPECIFIED POWERS | B. To engage in each of the matters identified in Subdivisions lettered _____
_____
_____
_____ | + +10/12/2004 + +(4) + +![](_page_10_Picture_16.jpeg) + +MORGAN USE ONLY + +US942 7/04 + +Title **Jeffrey E Epstein** + +SPN [REDACTED] + +Primary CAS [REDACTED] + +Account Number + +BANKING, CUSTODY, +BROKERAGE; RELATED +PLEDGES + +C. To operate any one or more deposit, custody or brokerage accounts in my name or any other name including the name of the Attorney; to deposit money, checks, notes, and other instruments for the payment of money, stocks, bonds, mortgages and other securities and property; to write or endorse as the case may be any of these instruments with my name for the purpose of cashing or depositing them or paying them to other persons, including the Attorney; to write and sign checks and other instruments to be paid by me; to give orders for the withdrawal, transfer or other use of money on deposit in my name, and grant Morgan a security interest in such property otherwise available to me; to borrow money from Morgan secured by property held in accounts in my name; to engage in foreign exchange transactions in any form with Morgan; To receive and sign trading confirmations, advices, and statements or duplicate statements; To execute and issue all necessary instruments for transfer of securities out of my name or out of any other name(s) and into the name of any nominee of Morgan or into any other name(s); + +BANKING, CUSTODY, +BROKERAGE; RELATED +PLEDGES (CONT'D.) + +D. To purchase and borrow (on a secured or unsecured basis) from, sell (including short sales in a margin account), and lend (on a secured or unsecured basis) to, and to otherwise enter into transactions of any kind with Morgan with respect to any and all securities and financial instruments whatsoever in which Morgan may deal, broker or act as counterparty from time to time, including (without limitation) stocks, bonds, debentures, notes, warrants, loans and loan participations, mutual funds, unit trusts, real estate, investment trusts, other types of pooled interest funds and communigled investment vehicles (including hedge funds), limited partnership interests, limited liability company interests, forward contracts, option or futures contracts, repurchase (or reverse repurchase) transactions, securities lending, or any other certificates or evidences of indebtedness or interest of any and every kind whatsoever, whether publicly or privately offered, secured or unsecured, and any other financial instruments; to enter into any derivative transactions with respect to the foregoing, including over the counter equity derivatives and structured transactions (including, but not limited to options, swaps, collars, caps and floors); to pledge any funds or instruments for the purposes of securing my obligations with respect to the foregoing; to enter into foreign exchange or foreign currency transactions in any form; and, to enter into, complete and execute agreements and to take other actions, including but not limited to signing reconcilements of accounts and other documents to carry out the purpose of this resolution; to vote in person or by proxy. + +BANKING, CUSTODY AND +BROKERAGE ACCOUNTS - +LIMITED POWER +(TRANSFERS TO OTHER +MORGAN ACCOUNTS +ONLY) + +E. To withdraw monies or funds or to sell or exchange stocks, bonds, options or other securities and property and transfer such monies, funds or proceeds of the sale or exchange only to another account at Morgan over which I have signing authority; + +CUSTODY AND +BROKERAGE ACCOUNTS - +LIMITED POWER +(SECURITIES AGAINST +PAYMENT ONLY) + +F. To buy or sell securities or any other property described in Subdivision D above in which I may deal or which I may hold against receipt of payment to me only; + +INVESTMENT +MANAGEMENT ACCOUNT + +G. To give any instruction with respect to any Investment Management Account; +To modify the Asset Allocation Strategy for any Investment Management Account; +To deposit funds, securities or other property to any Investment Management Account or to give orders for the withdrawal, sale, exchange, or other disposition (collectively, "Disposition") of any funds, securities or other property from any Investment Management Account, in accordance with any instructions as the Attorney may give; +To give orders for the payment or other Disposition of any income or proceeds of any Investment Management Account, or proceeds of any sale or other Disposition of securities and other property in the Account; + +INVESTMENT +MANAGEMENT ACCOUNT - +LIMITED POWER +TRANSFERS TO OTHER +MORGAN ACCOUNTS ONLY + +H. To deposit funds, securities or other property to any Investment Management Account or to give orders for the withdrawal, sale, exchange, or other disposition (collectively, "Disposition") of any funds, securities or other property from any Investment Management Account, in accordance with any instructions as the Attorney may give, but proceeds of any such Disposition will be credited only to an account of mine at Morgan over which I have signing authority; + +![](_page_11_Picture_16.jpeg) + +MORGAN USE ONLY + +US042 7/04 + +Title **Jeffrey E Epstein** + +SPN [REDACTED] + +Primary CAS [REDACTED] + +Account Number + +![]()![](_page_12_Picture_44.jpeg) + +MORGAN USE ONLY + +US842 7/04 + +Title Jeffrey E Epstein + +SPN [REDACTED] + +Primary CAS [REDACTED] + +Account Number + +SPECIMEN SIGNATURES +OF ATTORNEY(S), +CONT'D. + +Signature (Attorney-in-Fact) + +Print Name + +Date + +Address: + +SIGN HERE + +IN WITNESS WHEREOF Have bereunto set my hand and seal this 1 day of october, 2007 + +Signature (Accountholder) + +Jeffrey E Epstein + +10/1/04 + +Print Name + +Date + +Signature (Accountholder) + +Print Name + +Date + +Signature (Accountholder) + +Print Name + +Date + +**NOTARIZATION IS REQUIRED FOR ACCOUNTHOLDERS** + +STATE OF: + +COUNTY OF: + +I certify that Jeffrey Epstein, known or satisfactorily proven to me to be the individual(s) who signed the foregoing Power of Attorney, appeared before me on this 1 day of October, 2007, and acknowledged that he/she/they executed the foregoing Power. + +Signature of Notary Public + +Print Name & Title + +Date + +My Commission expires: + +HARRY I. BELLER +Notary Public, State of New York +No. 01BE4853924 +Qualified in Rockland County 06 +Commission Expires Feb. 17, 2006 + +# The Morgan Account + +Month \_\_\_\_\_ Date \_\_\_\_\_ Year \_\_\_\_\_ + (CIRCLE ONE BELOW) + Social Security no. / Tax ID no. / Passport no. + +Account type \_\_\_\_\_ Account number \_\_\_\_\_ +**Asset** [REDACTED] + Account type \_\_\_\_\_ Account number \_\_\_\_\_ +**Jeposi** [REDACTED] + +Account title +**Jeffrey E Epstein** + +BAC # + [REDACTED] + +All Accountholders/Signers must sign this Signature Form exactly as the checks/instructions will be signed. + +| Print (Accountholder/Signer, Trustee, Custodian, Director, etc.) | Title | +|------------------------------------------------------------------------|-------| +| Ghislaine Maxwell | | +| | | +| | | +| Print (Joint Accountholder/Signer, Trustee, Custodian, Director, etc.) | Title | +| | | +| | | +| Print (other) | Title | +| | | +| | | +| Print (other) | Title | +| | | +| | | + +SIGN HERE X + +![]()If facsimile signature, check box + +If facsimile signature, check box + +SIGN HERE X + +If facsimile signature, check box + +SIGN HERE X + +If facsimile signature, check box + +SIGN HERE X + +Is this an existing account? yes no If yes, does this card replace all other cards against this account? yes no + +SINKLY + +174 + +![](_page_14_Picture_0.jpeg) + +![Form for Citadel statistics including Comments, Date (06252008), Box Number, and Form Type = 'CITADEL']()![](_page_14_Picture_6.jpeg) + +Doc Code Doc Code Doc Code Doc Code Account Numbers + +942 + + Account Numbers + +![](_page_14_Picture_17.jpeg) + +| | | +|---------------|---------------| +| | | + +| | | +|---------------|---------------| +| | | + +| | | +|---------------|---------------| +| | | + + See the Code of Conditions + +| | | +|---------------|---------------| +| | | + +| | | +|---------------|---------------| +| | | + +| | | +|---------------|---------------| +| | | + +| | | +|---------------|---------------| +| | | + +|--|--| + +[Redacted text block] + +![]()CAUTION STOP FOR ALL SCHOOL, HC, & SA CITIZEN BUSES + This certificate must be carried when driving. If lost, destroyed, or stoien, + a duplicate must be obtained at once. + +VIRGIN ISLANDS POLICE DEPARTMENT + +NOTOR VEHICLE BUREAU + +- Class A = Private +- Class B = School Bus +- Class C = Tail or Chauffeur +- Class D = Motorcycle Only +- Class E = Heavy Equipment +- Class S = Special + +INDELIBLY MAKE AN ANATOMICAL GIFT, TO + BE EFFECTIVE UPON MY DEATH OR + A: Any needed organs or parts. + B: The following body parts: + C: Limitation(s) + +**NO** + +Ellen Lewis + Commissioner + +1 page + +10/25/04 + 905 + +![](_page_15_Picture_22.jpeg) + +![]()![](_page_16_Picture_25.jpeg) + +2 pages + +10/25/06 + +925 + +![](_page_17_Picture_0.jpeg) + +![](_page_18_Picture_0.jpeg) + +SS \* + +![](_page_18_Picture_2.jpeg) + +![](_page_18_Picture_3.jpeg) + +I fat n" s• + +The Morgan Account +Application: Morgan Premier Banking + +![](_page_19_Picture_23.jpeg) + +CAS [REDACTED] + +**SCAN** + SPN #: [REDACTED] + ACCT. #: [REDACTED] + Doc. ID #: [REDACTED] + Effective Date: [REDACTED] + MORGAN USE ONLY US640 04/00 + +Title **JEFFREY EPSTEIN** + +SPN MMIA No. + +Primary CAS [REDACTED] + +Checking Acct. No. + +JPMorgan Representative (sent package) **THOMAS A. RICE** + +A [REDACTED] Account + +INFORMATION **JEFFREY EPSTEIN** + +SPN #: [REDACTED] + +ACCT. #: [REDACTED] + +Entity Type Individual Tenants by the Entirety + Joint (JTWROS) Community Property + Tenants in Common UTMA/UGMA + In Trust For (Payable On Death for Texas residents) + Transfer on Death (TOD) + +B Doc. ID #: [REDACTED] + +ACCOUNT #: [REDACTED] + +Effective Date: [REDACTED] + + Checking Account Checking with Interest Account Premier Checking Account + + Unity Market Investment Account CD (Certificate of Deposit); Investment features will be obtained by JPM Representative + +C PRIMARY ACCOUNTHOLDER INFORMATION + +Name **JEFFREY EPSTEIN** + +Current Mailing Address [REDACTED] + +City **NEW YORK** State **NY** + +Regional Residence [REDACTED] + +Telephone [REDACTED] Fax [REDACTED] + +Date of Birth [REDACTED] + +Mother's Maiden Name/ Password [REDACTED] + +Citizenship U.S. Other \_\_\_\_\_ + +If non-U.S. Citizen: Resident Alien Non-Resident Alien\* + \*May have to complete International Client Application + +BUSINESS INFORMATION + +Type of Business [REDACTED] + +Name of Firm [REDACTED] + +Address [REDACTED] + +City [REDACTED] State [REDACTED] Zip Code [REDACTED] + +Occupation/Position [REDACTED] + +D SECONDARY ACCOUNTHOLDER INFORMATION (For Joint Accounts) + +Name [REDACTED] + +Current Mailing Address [REDACTED] + +City [REDACTED] State [REDACTED] Zip Code/Country [REDACTED] State of Legal Residence [REDACTED] + +Date of Birth [REDACTED] + +Mother's Maiden Name/ Password [REDACTED] + +Citizenship U.S. Other \_\_\_\_\_ + +If non-U.S. Citizen: Resident Alien Non-Resident Alien\* + \*May have to complete International Client Application + +| BUSINESS
INFORMATION FOR
SECONDARY
ACCOUNTHOLDER | Type of Business | Business Telephone | Business Fax | | +|--------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------|---------------|---------------------| +| | Name of Firm | Occupation/Position | Since | | +| | Address | City | State | Zip Code | +| E BENEFICIARY/MINOR
INFORMATION
(Required for UGMA/
UTMA, ITF/POD, TOD) | Name | Address | City | | +| | State | Zip Code / Country | Date of Birth | Social Security No. | +| F ADDITIONAL
ACCOUNTHOLDER(S) | Please send me the Additional Accountholder Form for more than one Additional Accountholder. | | | | +| G CHECKS | Check Style (JPMorgan exclusive check stock): Wallet (single check) | | | | +| | Newport Desk Book (spiral binder, 3 checks per page) Business-Style Book (ring binder, 3 checks per page) | | | | +| | Computer Checks (last software) Other*
*Other check styles may incur additional fee. | | | | +| | Check Imprint: Checks will be imprinted with Title of Account as it appears on this Application, and address as listed in the primary accountholder information section of this application, or on file.
Please omit my address from the check imprint. | | | | +| H CHECKCARD /
ATM CARD | I wish to add a JPMorgan Private Bank Visa® blink Check Card or JPMorgan Private Bank ATM Only Card to my account. | | | | +| I ALTERNATE CHECK
AND CARD DELIVERY
ADDRESS | Alternate Check and Card Delivery Address:
Name Company | | | | +| | Address City | | | | +| | State Zip Code Country | | | | +| | UPS and DHI, cannot deliver to a P.O. Box Address | | | | +| J CHECK IMAGING | Reduced size images of the front and back of each check will be returned with statements unless otherwise indicated
Truncate checks and do not return | | | | +| K ACCOUNT LINKING | Note: Linking Agreement is contained in Subdivision M of this application.
Link for Pricing: To maintain combined average monthly balances and avoid certain transaction fees as listed on my current fee schedule.
Link my following Checking, Money Market Investment Account, Certificate of Deposit, and applicable JPMorgan Money Market Funds** | | | | +| | Account Number for lead Checking Account to be billed any monthly maintenance charges: | | | | +| | Link for Statementing: Combine summary and detailed information for accounts with the same title in one consolidated statement.
Link my following Checking, Money Market Investment Account, Certificate of Deposit Accounts with the same title: | | | | +| | Link for Coverage Now: Coverage Now is a service offered by JPMorgan that automatically transfers available funds from one Account (Checking or Money Market Investment Account) to your Checking Account in order to cover a negative balance.
Use the account listed below as an automatic source of funds if I accidentally overdraw my Checking account
Checking Account Number _____
Source Account Number _____
I am aware that Federal regulations limit the number of pre-authorized transactions such as these from Money Market Investment Accounts (MMIA) to six (or three checks) per statement cycle.
Link for Automatic Dollar Transfers (ADT): ADTs are pre-established, on-going fixed or variable funds transfers between JPMorgan accounts that facilitate the control and management of funds held in multiple collections and/or disbursement accounts.
Use the accounts listed below as an automatic source of funds | | | | + +| L ONLINE ACCOUNT ACCESS
(For more information regarding online access, contact your JPMorgan Private Bank Representative) | I am a current user of Morgan OnLine/Chase OnLine; please add this account to my access.
My User ID is: JEJEJEJE
I would like to access my account via Morgan OnLine
(User IDs must contain 8-32 characters. They cannot be the same as your password or SSN. They may not include special characters such as &, %, *, etc.)
My Choices for an Internet access Login ID:
1 st Choice _____ 2 nd Choice _____
3 rd Choice _____ My Email Address is: _____ | +|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| SECONDARY ACCOUNTHOLDER
ONLINE ACCOUNT ACCESS | I am a current user of Morgan OnLine/Chase OnLine; please add this account to my access.
My User ID is: _____
I would like to access my account via Morgan OnLine
(User IDs must contain 8-32 characters. They cannot be the same as your password or SSN. They may not include special characters such as &, %, *, etc.)
1 st Choice _____ 2 nd Choice _____
3 rd Choice _____ My Email Address is: _____ | +| M ADDITIONAL STATEMENT RECIPIENTS | Additional Statement Recipients (Individuals to receive duplicate copies of statements):
Name of Additional Statement Recipient _____ Address _____
City _____ State _____ Zip Code _____ Country _____
Name of Additional Statement Recipient _____ Address _____
City _____ State _____ Zip Code _____ Country _____
Name of Additional Statement Recipient _____ Address _____
City _____ State _____ Zip Code _____ Country _____ | +| THIS APPLICATION MUST BE COMPLETED BEFORE MORGAN WILL BE ABLE TO PROVIDE FINANCIAL SERVICES. IF ANY SECTION IS INCOMPLETE, YOU MAY CONTACT ME TO OBTAIN ADDITIONAL INFORMATION. I MUST ALSO NOTIFY YOU OF ANY FUTURE CHANGES TO THE INFORMATION IN THIS APPLICATION. ABSENT NOTIFICATION, THE INFORMATION CONTAINED IN THE APPLICATION WILL BE DEEMED ACCURATE AND COMPLETE. | | +| N PLEDGE AGREEMENT | I agree that this account is an account under The General Terms for Accounts and Services and is pledged as collateral for all of my obligations and is subject to the security interest provisions in The General Terms for Accounts and Services, the terms of which are incorporated by reference. The General Terms for Accounts and Services together with this application are the security agreement under Article 9 of the Uniform Commercial Code, as amended from time to time. | + +![]()Deposit Accounts are with JPMorgan Chase Bank, N.A. or J.P. Morgan Trust Company, N.A. or Chase Bank USA, N.A. + +**U.S. VIRGIN ISLANDS +DRIVER'S LICENSE** + +![](_page_23_Picture_19.jpeg) + +CAUTION! STOP FOR ALL SCHOOL, HQ, & SR CITIZEN BUSES + This certificate must be carried when driving. If lost, destroyed, or stolen, + a duplicate must be obtained at once. +**VIRGIN ISLANDS POLICE DEPARTMENT** +**MOTOR VEHICLE BUREAU** + +- Class A = Private +- Class B = School Bus +- Class C = Taxi or Chauffeur +- Class D = Motorcycle Only +- Class E = Heavy Equipment +- Class S = Special + +**CONFIDENTIAL** + +I HEREBY BRACE AN ANATOMICAL DEPT, TO + BE EFFECTIVE UPON MY DEATH OR + +**NO** + +- A: Any needed organs or parts. +- B: The following body parts: +- C: Limitation(s): + +Ellen Lewis + Commissioner + +Restrictions: + +![](_page_23_Picture_28.jpeg) + +RECEIVED + +JUN 27 2008 + +![](_page_24_Picture_8.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084026/EFTA00084026.metadata.json b/marker2/ds9/EFTA00084026/EFTA00084026.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3dbd4ea6deece85f007e7aac26cbf77f1697def6 --- /dev/null +++ b/marker2/ds9/EFTA00084026/EFTA00084026.metadata.json @@ -0,0 +1,1625 @@ +{ + "source_pdf": 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Have you heard anything from him? + +From: Sigrid McCawley + +Sent: Thursday, October 7, 2021 1:04 PM + +To: Cc: + +Subject: RE: [EXTERNAL] RE: Call + +Hi M —do still represent pro bono on the Epstein related matters but she also has Bob Lewis who is helping her on the v. Maxwell unsealing/protective order issues because I represent in that case. His contact info is below. Thanks. + +Robert Y. Lewis The • PLLC Cell: Dire + +T1 IE NATIONAL CRIME VICTIM BAR ASSOCIATION + +CONFIDENTIALITY NOTICE: The information + +Sigrid McCawley + +Partner + +BOIES SCHILLER FLEXNER LLP + +401 E. Las Olas Blvd. Suite 1200 + +Fort Lauderdale. FL, 33301 + +www.bsfllp.com + +From: + +Sent: Thursday, October 7, 2021 10:25 AM + +To: Sigrid McCawley •csmccawley\_@bsfIlp.com> + +Cc: + +Subject: Re: [EXTERNAL] RE: Call + +On Oct 6, 2021, at 1:05 PM, Sigrid McCawley wrote: + +Can I give you a call now? What number should I call? + +Sigrid McCawley Partner + +BOIES SCHILLER FLEXNER LLP + +401 E. Las Olas Blvd. Suite 1200 + +Fort Lauderdale, FL, 33301 + +www.bsfllp.com + +From: + +Sent: Wednesday, October 6, 2021 12:43 PM + +To: Sigrid McCawley cmccawley\_@bsfIlp.com>. + +Subject: RE: Call + +Hi Sigrid, + +We're free until 2:30 today, if there's a time that works for you. Thanks! + +From: Sigrid McCawley + +Sent: Wednesday, October 6, 2021 11:56 AM + +To: + +Subject: [EXTERNAL] Call + +Can we have a quick call when you have a moment? + +Thanks + +Sigrid + +Sigrid McCawley + +Partner + +BOIES SCHILLER FLEXNER LLP + +401 E. Las Olas Blvd. Suite 1200 + +Fort Lauderdale, FL. 33301 + +www.bsfllp.com + +The information contained in this electronic message is confidential information intended only for the use of the named recapient(s) and may calm 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. (v.1 08201831BSE] + +--- + +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. [v.1 08201831BSF] + +--- + +The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not 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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Please feel free to edit content and tone. [REDACTED] previously delivered a drive to the MDC in January (emails attached on this). + +Hi [REDACTED] + +Our paralegals received the hard drive yesterday. It has been loaded with the discovery and is being sent out today. As for the materials due on October 11, the materials for you and your co-counsel will be available for pickup on that date or will otherwise be mailed out; please let us know what you prefer. My understanding of your below emails is that you are requesting that we arrange an in-person meeting between your client and an agent at the MDC for personal hand delivery of a hard drive on Monday, which is a federal holiday. If you would like, please send us two hard drives for Ms. Maxwell. We will plan to send one of the hard drives by mail on Monday. We cannot guarantee that we will be able to have an agent personally hand deliver the hard drive, but we will try to have an agent deliver the hard drive to counsel or a designated person at the MDC on Tuesday. + +Best, +[REDACTED] + +--- + +**From:** Christian Everdell <[REDACTED]> +**Sent:** Wednesday, September 29, 2021 11:00 AM +**To:** [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED]; Jeff Pagliuca <[REDACTED]>; +Laura Menninger <[REDACTED]>; Thomas J. Powers <[REDACTED]> +**Subject:** [EXTERNAL] RE: Hard Drives + +[REDACTED] - + +As a follow-up to this, we spoke to [REDACTED] at the MDC. [REDACTED] informed us that if we want Ms. Maxwell to receive the hard drive on the same day that it is produced, it will have to be hand-delivered to Ms. Maxwell in the visiting room by one of the agents. Can you please make arrangements for that to happen? Happy to discuss if you like. + +Thanks, + +Chris + +--- + +**From:** Christian Everdell +**Sent:** Tuesday, September 28, 2021 10:14 PM +**To:** "[REDACTED] (USANYS)" <[REDACTED]>; [REDACTED] <[REDACTED]>; +[REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED]; Jeff Pagliuca + +Subject: RE: Hard Drives + +Ms. Maxwell has still not received the disk or the hard drive. Can I ask you to follow-up with MDC about this? + +Also, we are in the process of obtaining several 64GB hard drives, which we will deliver to 1 STA shortly. As we discussed, we will expect to receive all the materials that are due on Oct. 11 on the day of the deadline. That includes the 3500 material, Giglio material, 404(b) notice and evidence, co-conspirator identities and statements, the government's witness list, and the government's exhibit list. + +We will also expect Ms. Maxwell to receive those materials on the same day. Given the likely volume and importance of these materials, and the closeness of the trial date, we cannot accept any delays or other snafus that typically happen in getting Ms. Maxwell her copy of the discovery in the MDC. Please let me know if you would like to discuss logistics. We would like this to be as smooth as possible. + +Thanks, + +Chris + +From: (USANYS) + +Sent: Friday, September 24, 2021 7:19 PM + +To: Christian Everdell c= > + +Cc: Jeff Pagliuca + +>; Laura Menninger < >; Thomas J. Powers + +Subject: RE: Hard Drives + +Chris, + +We have not yet received the hard drive, but we will let you know when receive it and will load it with the 9/13 production to send to Ms. Maxwell. As for the disk, we just learned yesterday that the MDC returned the disk to us. We made another copy and are mailing that to your client today. + +As for the size of the hard drive for 3500 materials, we think a drive of 64GB should work. We will let you know if that changes. + +As for the Touhy request, we are in the process of getting in touch with the individuals you identified in your letter to confirm their availability and discuss logistics. We have spoken with a number of them and will let you know when that is complete. With respect to the substance, we anticipate addressing that in our motions in limine. + +Best, + +From: Christian Everdell + +Sent: Friday, September 24, 2021 6:05 PM + +To: >; (USANYS) < >; + +)< + +As a follow-up to this, I have been informed that the MDC apparently (and inexplicably) sent the disk back to SDNY. Can you please expedite another copy of the disk to Ms. Maxwell at the MDC? And I would also ask you to call Ms. Papapetru before sending it so that she is aware that it is coming so we avoid this problem. + +Thanks, + +Chris + +From: Christian Everdell + +Sent: Friday, September 24, 2021 10:39 AM + +To: (USANYS)' + +Cc: Jeff Pagliuca + +>; Laura Menninger < ; Thomas J. Powers + +Subject: Hard Drives + +M, El and + +I am emailing about a few items. First, we realized we never sent you a hard drive for the most recent 9/13 production to send to Ms. Maxwell. We sent it to 1 STA yesterday to attention. Can you confirm receipt? And I don't think she has received the disk you sent. Can you confirm that it was sent to MDC? + +Second, we wanted to return to you about the size of the hard drives we will need to get you for the production of 3500 material. As we mentioned on our last call, we want to be able to receive the loaded hard drives on the day of the deadline on Oct. 11, so we would like to deliver the drives to you early so that they can be loaded ahead of time. You told us on the last call to contact you this week so that you could advise us on the size of the drives. Can you tell us how big the drives need to be? + +Third, can you tell us the status of the Touhy request we made on August 30? + +Thanks, + +Chris + +Christian R Everdell + +COHEN & GRESSER LLP + +800 Third Avenue New York, NY 10022 + +I view bio + +www.cohengresser.com + +New York I Paris I Washington DC I London + +![](_page_2_Picture_24.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. Thank you. \ No newline at end of file diff --git a/marker2/ds9/EFTA00084054/EFTA00084054.metadata.json b/marker2/ds9/EFTA00084054/EFTA00084054.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3bd8bd5bc7ae18087d9d6e9f4e7fb1a5a5cf6f99 --- /dev/null +++ b/marker2/ds9/EFTA00084054/EFTA00084054.metadata.json @@ -0,0 +1,150 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084054.pdf", + "engine": { + "marker_major": "2", + "marker_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": 6650, + "elapsed_seconds": 9.65, + "image_assets": [ + "_page_2_Picture_24.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "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", + 88 + ], + [ + "Line", + 42 + ], + [ + "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", + 73 + ], + [ + "Line", + 37 + ], + [ + "Text", + 25 + ], + [ + "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", + 3 + ], + [ + "Line", + 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/EFTA00084054" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084054/_page_2_Picture_24.jpeg b/marker2/ds9/EFTA00084054/_page_2_Picture_24.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..d30bc2ff5783c127c73ebaf33fda3484f529e8ed --- /dev/null +++ b/marker2/ds9/EFTA00084054/_page_2_Picture_24.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:7f043a419e0ecf2acce49f58a8d644106c615cb05bd0770ffa1fb650e34c910e +size 1234 diff --git a/marker2/ds9/EFTA00084058/EFTA00084058.md b/marker2/ds9/EFTA00084058/EFTA00084058.md new file mode 100644 index 0000000000000000000000000000000000000000..9e9946a93f8e072371bb2dfc8ce5017fc5e0adcc --- /dev/null +++ b/marker2/ds9/EFTA00084058/EFTA00084058.md @@ -0,0 +1,73 @@ +To: cz > + +Cc: (USANYS)[Contractor] `z >, + +Subject: Re: Maxwell drive delivery Monday 1/11 + +Date: Mon, 11 Jan 2021 16:48:50 +0000 + +Importance: Normal + +I'm here in front MDC on 29th Avenue but not totally sure where you would like to meet. Give me a call when you have a chance. + +> On Jan 11, 2021, at 10:54, > wrote: + +> + +> Yes, that works for us! + +> + +1/11/2021 10:47 AM >» + +> + +> I will be picking up the drives today. Are you available to run out to + +> me around 11:30? + +• or ideally I'd be bringing the drives directly to you after + +> pick up. Are you available around 12-1230? + +> Feel free to call me at + +>» On Jan 11, 2021, at 09:48, + +» wrote: + +>> + +>> It will be myself or + +>> Best, + +>>. + +>>>.» 1/8/2021 2:20 + +» pm ).» + +» Good afternoon, + +>> + +» The FBI has very kindly agreed to deliver two new drives from my + +> office + +» to the MDC for Ghislaine Maxwell on Monday, January 11th. I've ced + +» Special Agent , who will be coordinating the delivery. + +> Would + +>> Assistant United States Attorney + +>> Southern District of New York + +» 1 St. Andrew's Plaza + +>> New York. NY 10007 + +; ) <->; Nicolas BOULAY + +Subject: RE: SDNY Investigation + +Hi M, + +My patner Nicolas Boulay (copied) and I would be available this coming Friday at 17 :00, our time. + +Can you send a teams invitation ? + +best + +De: (USANYS) < + +Envoya : mercredi 3 mars 2021 17:23 + +A : Nicolas CASSART + +Cc : ) • >; + +Objet : SDNY Investigation + +Hi Nicolas, + +I hope this email finds you well. Together with my colleagues AUSA and AUSA (both copied), I am one of the federal prosecutors handling the ongoing investigation regarding Jeffrey Epstein and the prosecution of Ghislaine Maxwell. We are hoping to find a time to speak with you this week. Are you available for a call tomorrow or Friday? Please let us know some times that work for you. + +Thanks very much, and looking forward to speaking with you. + +Best, + +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/EFTA00084061/EFTA00084061.metadata.json b/marker2/ds9/EFTA00084061/EFTA00084061.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..aaa58463aaf63260d12d60a050f19dea9c4dbf36 --- /dev/null +++ b/marker2/ds9/EFTA00084061/EFTA00084061.metadata.json @@ -0,0 +1,80 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084061.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1264, + "elapsed_seconds": 1.19, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 76 + ], + [ + "Line", + 38 + ], + [ + "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": [ + [ + "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/EFTA00084061" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084063/EFTA00084063.md b/marker2/ds9/EFTA00084063/EFTA00084063.md new file mode 100644 index 0000000000000000000000000000000000000000..72d4a4633b91927d08569d6800af4c7de59a2925 --- /dev/null +++ b/marker2/ds9/EFTA00084063/EFTA00084063.md @@ -0,0 +1,45 @@ +From: ' )u' To: "a)" Subject: RE: SDNY Investigation Date: Wed, 03 Mar 2021 17:55:10 +0000 >, "-(USANYS)" + +Yes + +From: Sent: Wednesday, March 3, 2021 12:53 PM To: (USANYS) Cc: Subject: Re: SDNY Investigation + +Yes + +Sent from my iPhone + +On Mar 3, 2021, at 12:38 PM, (USANYS) > wrote: + +I actually just realized I have something from 10 to 11:30. Can you guys do 11:30 instead? + +Begin forwarded message: + +From: "-(USANYS)" Date: March 3, 2021 at 12:37:00 PM EST To: Nicolas CASSART < Cc : Nicolas BOULAY Subject: RE: SDNY Investigation + +Thanks very much for your quick reply. That time works for us and I will send a WebEx invite. If you are not able to use WebEx, please let me know. + +Best, + +From: Nicolas CASSART Sent: Wednesday, March 03, 2021 12:19 PM To: Cc: I BOULAY Subject: RE: SDNY Investigation (USANYS) > ES , >; ; Nicolas + +Hi M, My patner Nicolas Boulay (copied) and I would be available this coming Friday at 17 :00, our time. Can you send a teams invitation ? + +De: (USANYS) + +Envoya : mercredi 3 mars 2021 17:23 + +A : Nicolas CASSART cS• + +Cc : + +Objet : SDNY Investigation + +Hi Nicolas, + +I hope this email finds you well. Together with my colleagues AUSA and AUSA (both copied), I am one of the federal prosecutors handling the ongoing investigation regarding Jeffrey Epstein and the prosecution of Ghislaine Maxwell. We are hoping to find a time to speak with you this week. Are you available for a call tomorrow or Friday? Please let us know some times that work for you. + +Thanks very much, and looking forward to speaking with you. + +Best, + +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/EFTA00084063/EFTA00084063.metadata.json b/marker2/ds9/EFTA00084063/EFTA00084063.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..221ef11d98d196628541dcb98e02bc0c20ec1eb4 --- /dev/null +++ b/marker2/ds9/EFTA00084063/EFTA00084063.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084063.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1695, + "elapsed_seconds": 0.73, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 38 + ], + [ + "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", + 42 + ], + [ + "Line", + 21 + ], + [ + "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/EFTA00084063" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084065/EFTA00084065.md b/marker2/ds9/EFTA00084065/EFTA00084065.md new file mode 100644 index 0000000000000000000000000000000000000000..676db34f327ecbcfbf4a007bdadd3f910d87113e --- /dev/null +++ b/marker2/ds9/EFTA00084065/EFTA00084065.md @@ -0,0 +1,71 @@ +From: '• (USANYS)" < To: Nicolas CASSART Cc: ' , Nicolas BOULAY + +Subject: RE: SDNY Investigation + +Date: Wed, 03 Mar 2021 17:55:56 +0000 + +With apologies — are you available to speak at 17:30 instead? Alternatively, we are available before 16:00 Friday. + +Best, + +From: (USANYS) + +Sent: Wednesday, March 03, 2021 12:37 PM + +To: Nicolas CASSART + +Cc: >; Nicolas BOULAY + +Subject: RE: SONY Investigation + +Thanks very much for your quick reply. That time works for us and I will send a WebEx invite. If you are not able to use WebEx, please let me know. + +Best, + +From: Nicolas CASSART + +Sent: Wednesday, March 03, 2021 12:19 PM + +To: (USANYS) + +Cc: <->; Nicolas BOULAY + +Subject: RE: SDNY Investigation + +Hi M, + +My patner Nicolas Boulay (copied) and I would be available this coming Friday at 17 :00, our time. + +Can you send a teams invitation ? + +best + +De: (USANYS) + +Envoya : mercredi 3 mars 2021 17:23 + +A : Nicolas CASSART + +Cc: + +Objet : SONY Investigation + +Hi Nicolas, + +I hope this email finds you well. Together with my colleagues AUSA and AUSA (both copied), I am one of the federal prosecutors handling the ongoing investigation regarding Jeffrey Epstein and the prosecution of Ghislaine Maxwell. We are hoping to find a time to speak with you this week. Are you available for a call tomorrow or Friday? Please let us know some times that work for you. + +Best, + +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/EFTA00084065/EFTA00084065.metadata.json b/marker2/ds9/EFTA00084065/EFTA00084065.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2fccded8ac82d3139316ab620467bda49ae627ea --- /dev/null +++ b/marker2/ds9/EFTA00084065/EFTA00084065.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084065.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1503, + "elapsed_seconds": 1.25, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 78 + ], + [ + "Line", + 38 + ], + [ + "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", + 19 + ], + [ + "Text", + 10 + ], + [ + "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/EFTA00084065" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084067/EFTA00084067.md b/marker2/ds9/EFTA00084067/EFTA00084067.md new file mode 100644 index 0000000000000000000000000000000000000000..1c4616e482e45284dfceaa8dc11875e275e46c06 --- /dev/null +++ b/marker2/ds9/EFTA00084067/EFTA00084067.md @@ -0,0 +1,103 @@ +To: Nicolas CASSART + +Cc: • " " )" , Nicolas BOULAY + +Subject: RE: SDNY Investigation + +Date: Mon, 08 Mar 2021 23:41:26 +0000 + +Attachments: 2020-07-3 L\_GM,\_signed\_protective\_orderidocketed).pdf + +Thank you both for your time on Friday. We very much appreciate it. As discussed, attached please find the protective order entered by the judge presiding over the case here. We are happy to speak again whenever best for you both. We look forward to hearing from you. + +Best, + +From: Nicolas CASSART • + +Sent: Wednesday, March 03, 2021 1:00 PM + +To: (USANYS) + +Cc: >; >; Nicolas BOULAY + +Subject: RE: SDNY Investigation + +No problem. + +Best. + +Nicolas + +De: (USANYS) < + +Envoyé : mercredi 3 mars 2021 18:56 + +À : Nicolas CASSART + +Cc : ) ": >; BOULAY .:1 >; Nicolas + +Objet : RE: SDNY Investigation + +With apologies — are you available to speak at 17:30 instead? Alternatively, we are available before 16:00 Friday. + +Best, + +From: (USANYS) + +Sent: Wednesday, March 03, 2021 12:37 PM + +To: Nicolas CASSART + +Cc: >; Nicolas BOULAY + +Subject: RE: SDNY Investigation + +Thanks very much for your quick reply. That time works for us and I will send a WebEx invite. If you are not able to use WebEx, please let me know. + +Sent: Wednesday, March 03, 2021 12:19 PM + +To: (USANYS) + +Cc: ) < <->; Nicolas BOULAY + +> + +Subject: RE: SDNY Investigation + +Hi M, + +My patner Nicolas Boulay (copied) and I would be available this coming Friday at 17 :00, our time. + +Can you send a teams invitation ? + +best + +De: (USANYS) + +Envoye : mercredi 3 mars 2021 17:23 + +A : Nicolas CASSART + +Cc: + +Objet : SDNY Investigation + +Hi Nicolas, + +I hope this email finds you well. Together with my colleagues AUSA and AUSA (both copied), I am one of the federal prosecutors handling the ongoing investigation regarding Jeffrey Epstein and the prosecution of Ghislaine Maxwell. We are hoping to find a time to speak with you this week. Are you available for a call tomorrow or Friday? Please let us know some times that work for you. + +Thanks very much, and looking forward to speaking with you. + +Best, + +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/EFTA00084067/EFTA00084067.metadata.json b/marker2/ds9/EFTA00084067/EFTA00084067.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ad9a317feff81b2d8cb4a7aeccbf92cf09f6a62e --- /dev/null +++ b/marker2/ds9/EFTA00084067/EFTA00084067.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084067.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2183, + "elapsed_seconds": 1.54, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 87 + ], + [ + "Line", + 39 + ], + [ + "Text", + 34 + ], + [ + "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", + 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/EFTA00084067" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084069/EFTA00084069.md b/marker2/ds9/EFTA00084069/EFTA00084069.md new file mode 100644 index 0000000000000000000000000000000000000000..4144953e59304b7942533fbdc07778e8354e7576 --- /dev/null +++ b/marker2/ds9/EFTA00084069/EFTA00084069.md @@ -0,0 +1,117 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +UNITED STATES OF AMERICA GHISLAINE MAXWELL, Defendant. x x + +USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED:7/30/2020 + +## PROTECTIVE ORDER + +20 Cr. 330 (AJN) + +ALISON J. NATHAN, United States District Judge: + +WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely disclosed, the Government's ongoing investigation; (iii) would risk prejudicial pretrial publicity if publicly disseminated, and (iv) is not authorized to be disclosed to the public or disclosed beyond that which is necessary for the defense of this action, and other materials pursuant to Federal Rule of Criminal Procedure 16 ("Rule 16") and pursuant to any other disclosure obligations (collectively, the "Discovery"), which contain sensitive, confidential, or personal identifying information; + +WHEREAS, the Government seeks to protect sensitive, confidential, or personal identifying information contained in the materials it produces consistent with Rule 16 or other disclosure obligations; + +WHEREAS the Government has applied for the entry of this Order; + +IT HEREBY IS ORDERED: + +1. The Discovery disclosed to the defendant ("Defendant") and/or to the defendant's criminal defense attorneys ("Defense Counsel") during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall not be copied or otherwise recorded or transmitted by the Defendant, except to Defense Counsel, or except as necessary for the Defendant to take notes, which are not to be further transmitted to anyone other than Defense Counsel; + +c) Shall not be disclosed or distributed in any form by the Defendant or her counsel except as set forth in paragraph 1(d) below; + +d) May be disclosed only by Defense Counsel and only to the following persons ("Designated Persons"): + +i. investigative, secretarial, clerical, or paralegal personnel employed full-time, part-time, or as + +independent contractors by the defendant's counsel ("Defense Staff"); + +ii. any expert or potential expert, legal advisor, consultant, or any other individual retained or employed by the Defendant and Defense Counsel for the purpose of assisting in the defense of this case ("Defense Experts/Advisors"); + +iii. such other persons as hereafter may be authorized by Order of the Court ("Other Authorized Persons"); + +e) May be provided to prospective witnesses and their counsel (collectively, "Potential Defense Witnesses"), to the extent deemed necessary by defense counsel, for trial preparation. To the extent Discovery materials are disclosed to Potential Defense Witnesses, they agree that any such materials will not be further copied, distributed, or otherwise transmitted to individuals other than the recipient Potential Defense Witnesses. + +2. The Defendant and Defense Counsel shall provide a copy of this Order to any Designated Persons to whom they disclose Discovery materials. Prior to disclosure of Discovery materials to Designated Persons, any such Designated Person shall agree to be subject to the terms of this Order by signing a copy hereof and stating that they "Agree to be bound by the terms herein," and providing such copy to Defense Counsel. All + +such acknowledgments shall be retained by Defense Counsel and shall be subject to in camera review by the Court if good cause for review is demonstrated. The Defendant and her counsel need not obtain signatures from any member of the defense team (i.e., attorneys, experts, consultants, paralegals, investigators, support personnel, and secretarial staff involved in the representation of the defendants in this case), all of whom are nonetheless bound by this Protective Order. + +3. To the extent that Discovery is disseminated to Defense Experts/Advisors, Other Authorized Persons, or Potential Defense Witnesses, via means other than electronic mail, Defense Counsel shall encrypt and/or password protect the Discovery. + +4. The Government, the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses and their counsel, and Other Authorized Persons are prohibited from posting or causing to be posted any of the Discovery or information contained in the Discovery on the Internet, including any social media website or other publicly available medium. + +5. The Government (other than in the discharge of their professional obligations in this matter), the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses and their counsel, and Other Authorized Persons are strictly prohibited from publicly + +disclosing or disseminating witnesses referenced in the prohibit Defense Counsel or the identity of any victims or Discovery. This Order does not Defense Staff from referencing the identities of individuals they believe may be relevant to the defense to Potential Defense Witnesses and their counsel during the course of the investigation and preparation of the defense case at trial. Any Potential Defense Witnesses and their counsel who are provided identifying information by Defense Counsel or Defense Staff are prohibited from further disclosing or disseminating such identifying information. This Order does not prohibit Defense Counsel from publicly referencing individuals who have spoken by name on the public record in this case. + +6. The Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing the identity of any victims or witnesses referenced in the Discovery, who have not spoken by name on the public record in this case, unless authorized by the Government in writing or by Order of the Court. Any such filings must be filed under seal, unless authorized by the Government in writing or by Order of the Court. + +7. Copies of Discovery or other materials produced by the Government in this action bearing "confidential" stamps, or designated as "confidential" as described below, and/or electronic Discovery materials designated as "confidential" by the Government, including such materials marked as "confidential" either on the documents or materials themselves, or designated as "confidential" in a folder or document title, are deemed "Confidential Information." The Government shall clearly mark all pages or electronic materials containing Confidential Information, or folder or document titles as necessary, with "confidential" designations. + +8. Confidential Information may contain personal identification information of victims, witnesses, or other specific individuals who are not parties to this action, and other confidential information; as well as information that identifies, or could lead to the identification of, witnesses in this matter. The identity of an alleged victim or witness who has identified herself or himself publicly as such on the record in this case shall not be treated as Confidential Information. + +9. Defense Counsel may, at any time, notify the Government that Defense Counsel does not concur in the designation of documents or other materials as Confidential Information. If the Government does not agree to de-designate such documents or materials, Defense Counsel may thereafter move the Court for an Order de-designating such documents or materials. The Government's designation of such documents and materials as Confidential Information will be controlling absent contrary order of the Court. + +10. Confidential Information disclosed to the defendant, or Defense Counsel, respectively, during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall be maintained in a safe and secure manner; + +c) Shall be reviewed and possessed by the Defendant in hard copy solely in the presence of Defense Counsel; + +d) Shall be possessed in electronic format only by Defense Counsel and by appropriate officials of the Bureau of Prisons ("BOP"), who shall provide the defendant with electronic access to the Discovery, including Confidential Information, consistent with the rules and regulations of the BOP, for the Defendant's review; + +e) Shall be reviewed by the Defendant solely in the presence of Defense Counsel or when provided access to Discovery materials in electronic format by BOP officials; + +f) May be disclosed only by Defense Counsel and only to Designated Persons; + +g) May be shown to, either in person, by videoconference, or via a read-only document review platform, but not disseminated to or provided copies of to, Potential Defense Witnesses, to the extent deemed necessary by Defense Counsel, for trial preparation, and after such individual(s) have read and signed this Order acknowledging that such individual(s) are bound by this Order. + +11. Copies of Discovery or other materials produced by the Government in this action bearing "highly confidential" stamps or otherwise specifically designated as "highly confidential," and/or electronic Discovery materials designated as "highly confidential" by the Government, including such materials marked as "highly confidential" either on the documents or materials themselves, or designated as "highly confidential" in an index, folder title, or document title, are deemed "Highly Confidential Information." To the extent any Highly Confidential Information is physically produced to the Defendant and Defense Counsel, rather than being made available to the Defendant and Defense Counsel for on-site review, the + +Government shall clearly mark all such pages or electronic materials containing Highly Confidential Information with "highly confidential" stamps on the documents or materials themselves. + +12. Highly Confidential Information contains nude, partially-nude, or otherwise sexualized images, videos, or other depictions of individuals. + +13. Defense Counsel may, at any time, notify the Government that Defense Counsel does not concur in the designation of documents or other materials as Highly Confidential Information. If the Government does not agree to de-designate such documents or materials, Defense Counsel may thereafter move the Court for an Order de-designating such documents or materials. The Government's designation of such documents and materials as Highly Confidential Information will be controlling absent contrary order of the Court. + +14. Highly Confidential Information disclosed to Defense Counsel during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall not be disseminated, transmitted, or otherwise copied and provided to Defense Counsel or the Defendant; + +c) Shall be reviewed by the Defendant solely in the presence of Defense Counsel; + +d) Shall not be possessed outside the presence of Defense Counsel, or maintained, by the Defendant; + +e) Shall be made available for inspection by Defense Counsel and the Defendant, under the protection of law enforcement officers or employees; and + +f) Shall not be copied or otherwise duplicated by Defense Counsel or the Defendant during such inspections. + +15. The Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing any Confidential Information or Highly Confidential Information referenced in the Discovery, unless authorized by the Government in writing or by Order of the Court. Any such filings must be filed under seal, unless authorized by the Government in writing or by Order of the Court. + +16. The provisions of this Order shall not be construed as preventing disclosure of any information, with the exception of victim or witness identifying information, that is publicly available or obtained by the Defendant or her Defense Counsel from a source other than the Government. + +17. Except for Discovery that has been made part of the record of this case, Defense Counsel shall return to the Government or securely destroy or delete all Discovery, including but not limited to Confidential Information, within 30 days of the expiration of the period for direct appeal from any verdict in the above-captioned case; the period of direct appeal from any order dismissing any of the charges in the abovecaptioned case; the expiration of the period for a petition pursuant to 28 U.S.C. § 2255; any period of time required by the federal or state ethics rules applicable to any attorney of record in this case; or the granting of any motion made on behalf of the Government dismissing any charges in the abovecaptioned case, whichever date is later. + +18. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree in writing otherwise, or (b) this Order is modified by further order of the Court. + +19. The Government and Defense Counsel agree to meet and confer in advance of any hearings or trial to discuss and agree to any modifications necessary for the presentation of evidence at those proceedings. In the absence of agreement, + +Defense Counsel may make an appropriate application to the Court for any such modifications. + +SO ORDERED: + +Dated: New York, New York July 30 , 2020 + +Lc + +HONORABLE ALISON J. NATHAN United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00084069/EFTA00084069.metadata.json b/marker2/ds9/EFTA00084069/EFTA00084069.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f948da07763908324d65b9f82efb89f418ba1c6b --- /dev/null +++ b/marker2/ds9/EFTA00084069/EFTA00084069.metadata.json @@ -0,0 +1,460 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084069.pdf", + "engine": { + "marker_major": "2", + "marker_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": 13927, + "elapsed_seconds": 1.41, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "PROTECTIVE ORDER", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 373.32, + 141.75 + ], + [ + 499.22540283203125, + 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100644 index 0000000000000000000000000000000000000000..00233fd03b01335bd8d9aedf24f91bda9935de9c --- /dev/null +++ b/marker2/ds9/EFTA00084081/EFTA00084081.md @@ -0,0 +1,53 @@ +To: ' + +Cc: 11 + +Subject: Re: Re Jeffrey Epstein/Bill Clinton + +Date: Wed, 25 Sep 2019 15:40:39 +0000 + +That's fine. + +On Sep 25, 2019, at 11:22 AM, > wrote: + +Can I tell her that I sent the information to the FBI agents. + +From: + +Sent: Wednesday, September 25, 2019 10:55 AM + +To: + +Subject: Re: Re Jeffrey Epstein/Bill Clinton + +Dear + +Please tell me who you forwarded my email to please, I am surprised no-one has contacted me. + +Regards + +From: =, (USANYS) < + +Sent: 23 September 2019 20:09 + +To: + +Subject: RE: Re Jeffrey Epstein/Bill Clinton + +Thank you for your email. + +United States Attorney's Office Southern District of New York + +New York, New York 10007 + +From: W P < + +Sent: Monday, September 23, 2019 2:48 PM + +To: + +I have information about a sexual predator who was a pilot for Bill Clinton, he may or may not be involved in the Jeffrey Epstein scandal but I believe his flight manifests and lifestyle deserve a closer look. I am one of his abandoned children and can say that his profile fits that of someone who could assist your enquiries and maybe with personal involvement, he shows strong indications of being a sociopath and his son is a National Security Adviser and he changed both his christian as well as surname when he obtained his work permit and residency. + +If Mr Berman's office would like to know more, please let me know. I live in London but have close knowledge of this gentleman and his history. + +Regards \ No newline at end of file diff --git a/marker2/ds9/EFTA00084081/EFTA00084081.metadata.json b/marker2/ds9/EFTA00084081/EFTA00084081.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fe9900185de721c713e382f88e6056a3a8eeedd4 --- /dev/null +++ b/marker2/ds9/EFTA00084081/EFTA00084081.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084081.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1430, + "elapsed_seconds": 1.31, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Text", + 29 + ], + [ + "Line", + 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", + 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/EFTA00084081" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084083/EFTA00084083.md b/marker2/ds9/EFTA00084083/EFTA00084083.md new file mode 100644 index 0000000000000000000000000000000000000000..c842772c7d2141941c7d11c22aab991f9999be0f --- /dev/null +++ b/marker2/ds9/EFTA00084083/EFTA00084083.md @@ -0,0 +1,63 @@ +Sous-direction de la justice pénale spécialisée Bureau de l'entraide pénale internationale + +Paris, le 9 mars 2021 + +Monsieur le garde des Sceaux, ministre de la Justice à + +Department of Justice (D.O.J) + +Par Piniermédiairel Ambassade des Elms-Unis d'Amérique à Paris + +J'ai l'honneur de porter à votre connaissance que la procédure et les conditions d'extradition sont régies en France par les articles 696 et suivants du code de procédure pénale. + +L'article 696-2 de ce code prévoit ainsi que «k gouvernement français peut remettre, sur leur demande, arec gouvernements étrangers, toute personne n'ayant pas la nationalité française qui, étant fobjet d'une poursuite intentée au nom de fEtat requérant ou d'une condamnation prononcée par lestribunaux, est onde sur k territoire de la République. » + +L'article 694-4 précise expressément que : + +« L'extradition n'est pas accordée : + +1° Lorsque k personne réclamée ala nationalité française, cette dernière étant appréciée à l'époque de l'infraction pour laquelle l'extradition est requise». + +Ainsi, le fait que la personne recherchée ait la nationalité française constitue un obstacle insurmontable à son extradition. Dès lors que cette nationalité s'apprécie au moment de la commission de l'infraction, la perte de la nationalité, postérieurement à la commission de cette dernière, est sans incidence sur la procédure d'extradition, et ne permet pas de lever cet obstacle. + +Le Chef du Bureau de r n ale Internationale + +![](_page_1_Picture_0.jpeg) + +## MINISTRY OF JUSTICE + +Liberty + +Equality + +Fraternity + +## Directorate of Criminal Affairs & Pardons + +Specialized Criminal Justice Sub-Directorate International Criminal Assistance Bureau + +Paris, March 9, 2021 + +His Honor the Keeper of Seals, Minister of Justice + +To the + +Department of Justice (D.O.J) + +Through on behalf of the Embassy of the United States of America located in Paris, France + +I hereby inform you that in France, all removal proceedings and conditions are governed by Articles 696 et sq. of the Code of Criminal Procedure. + +Article 696-2 of said Code provides that: "The French government is able to remit to foreign governments upon their request any individual who is not a French citizen and who is subject to a lawsuit brought on behalf of the requesting State, or who is subject to a sentence passed by the Court of said requesting State, and who is located on the territory of the French Republic." + +Article 694-4 expressly specifies as follows: + +"Removal is not granted: + +1- When the individual claimed to have French citizenship, said citizenship having been assessed at the time of the offense on the basis of which removal is being requested." + +WHEREBY, the fact that the wanted individual is a French national constitutes an insuperable obstacle to his/her removal. As long as said nationality is assessed at the time the offense was committed, any loss of nationality subsequent to said offense has no bearing upon the removal proceedings and shall not supersede said assessment of nationality. + +Head of the International Criminal Assistance Bureau + +![](_page_1_Picture_19.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084083/EFTA00084083.metadata.json b/marker2/ds9/EFTA00084083/EFTA00084083.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a647c912621add47dbe13c0dc1c68db7e774d660 --- /dev/null +++ b/marker2/ds9/EFTA00084083/EFTA00084083.metadata.json @@ -0,0 +1,146 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084083.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3100, + "elapsed_seconds": 1.18, + "image_assets": [ + "_page_1_Picture_0.jpeg", + "_page_1_Picture_19.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "MINISTRY OF JUSTICE", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 47.083999999999996, + 50.858000000000004 + ], + [ + 192.46060180664062, + 50.858000000000004 + ], + [ + 192.46060180664062, + 66.2335205078125 + ], + [ + 47.083999999999996, + 66.2335205078125 + ] + ] + }, + { + "title": "Directorate of Criminal Affairs & Pardons", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 261.64399999999995, + 58.61600000000001 + ], + [ + 499.07110595703125, + 58.61600000000001 + ], + [ + 499.07110595703125, + 74.103515625 + ], + [ + 261.64399999999995, + 74.103515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 281 + ], + [ + "Line", + 24 + ], + [ + "Text", + 13 + ], + [ + "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": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 35 + ], + [ + "Text", + 19 + ], + [ + "Picture", + 2 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00084083" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084083/_page_1_Picture_0.jpeg b/marker2/ds9/EFTA00084083/_page_1_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..9def927def3ef5c93a551159fdaf30c9f192d643 --- /dev/null +++ b/marker2/ds9/EFTA00084083/_page_1_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9ab82a37f46f9263a160db910484011b2972e41f39732a80681f7edb483f9d80 +size 2245 diff --git a/marker2/ds9/EFTA00084083/_page_1_Picture_19.jpeg b/marker2/ds9/EFTA00084083/_page_1_Picture_19.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..7e8b1136afbbabc249f76a9e302c74b3974b992b --- /dev/null +++ b/marker2/ds9/EFTA00084083/_page_1_Picture_19.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:af696929a8268ae63be287f4c249afdb0b9d57fc582413b43865856059048ce2 +size 2663 diff --git a/marker2/ds9/EFTA00084085/EFTA00084085.md b/marker2/ds9/EFTA00084085/EFTA00084085.md new file mode 100644 index 0000000000000000000000000000000000000000..96af7921ab837ab8d02d5473a7282959a649f6f3 --- /dev/null +++ b/marker2/ds9/EFTA00084085/EFTA00084085.md @@ -0,0 +1,43 @@ +From: ' )" , ' + +Subject: RE: following up + +Date: Tue, 24 Sep 2019 13:48:32 +0000 + +Hi + +Thanks, I'll go ahead and book us for 9:30 that morning. That's the only interview in Austin, so it should be a quick trip. Regarding the flight records: sounds like you're talking about CBP records, but I actually meant the records for Epstein's private jet. + +Thanks! + +From: (NY) (FBI) 'c l> Sent: Monday, September 23, 2019 5:31 PM To: < >/ Cc: Subject: RE: following up + +See below... + +From: [mailto Sent: Monday, September 23, 2019 3:17 PM To: . (NY) (FBI) < ).; Cc: Subject: following up + +Hi and M, + +A few small follow-up items: + +- For the trip to Austin, I'm going to confirm our meeting with at 9:30 on October 11th in Austin, but let me know before I do if there are any issues with that timing. + +That should be fine for me. She is the only interview? I just need to get back to NYC that night; so 9:30 interview should be good. + +- For the photo(s) of that were seized during search warrants, could you please pull them from evidence to check if there are dates on the photos? + +Yes we can pull them. May take a few days to pull out of storage. Will let you know. + +- I think you mentioned an analyst was looking at flight records. If it would be possible to get a summary analysis of Maxwell's flights, as well as (noting any overlap), that would be great. If possible, it would be great to have a rough summary sometime in the next week or so, but let us know what timeline is feasible. + +I've asked to help with this. We will take a look at this and see the overlap. Keep in mind this is only international flights. Manifests that we may have from the previous case for Epstein's flights may not go back to the 90's. Make take a few days to pull; but we will let you know when we have it. + +- On VNS stuff, could you please double check that ME, both and are all in VNS? They should all be in minus the but I will double check on all to make sure. +- FYI, we've reached out to E who told us he would send us the emails mentioned. We'll pass those along when we get them. That's great. Thank you. +- We'll add you to the calendar invitation for the meeting with attorney, whenever that is rescheduled. Our meeting with attorneys is scheduled for October ath at 10 a.m., and you're welcome to join us for that. + +Thank you; that would be great. I'd be interested in hearing what they have to say. + +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/EFTA00084085/EFTA00084085.metadata.json b/marker2/ds9/EFTA00084085/EFTA00084085.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..76ecd045bc1cb696c32adf6246cc1c221da86943 --- /dev/null +++ b/marker2/ds9/EFTA00084085/EFTA00084085.metadata.json @@ -0,0 +1,100 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084085.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2528, + "elapsed_seconds": 0.9, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 37 + ], + [ + "Text", + 15 + ], + [ + "ListGroup", + 3 + ], + [ + "ListItem", + 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", + 35 + ], + [ + "Line", + 16 + ], + [ + "Text", + 3 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00084085" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084087/EFTA00084087.md b/marker2/ds9/EFTA00084087/EFTA00084087.md new file mode 100644 index 0000000000000000000000000000000000000000..0a19c79c69367f8a752efbd8d5a5eef01e788baf --- /dev/null +++ b/marker2/ds9/EFTA00084087/EFTA00084087.md @@ -0,0 +1,127 @@ +From: + +To: + +Cc: + +Subject: RE: Taint Review - Epstein + +Date: Thu, 26 Sep 2019 15:45:38 +0000 + +Yeah we're going to have to talk to 'Nand CART. + +Ori inal Message + +From: + +Sent: Thursda Se tember 26 2019 11:44 AM + +To: + +Cc: + +Subject: Re: Taint Review - Epstein + +Wait 20K does seems like an \*insanely\* low number. That's what we got from like 20 devices and hard drives in the New York residence?? Including emails, e.g.? + +Sent from my iPhone + +> On Sep 26, 2019, at 08:37, ote: + +> FYI. + +> Ori inal Messa e + +> From: + +> Sent: urs a e tem er + +> To: + +> Subject: Re: Taint Review - Epstein + +> About 20K but a lot are non-user files, like adobe instructions. + +> Assistant United States Attorney + +> Southern District of New York + +> New York NY 10007 + +>> On Sep 26, 2019, at 11:32 AM, wrote: + +>> Out of curiosity, do you know what the volume of NP documents is? Thanks. + +>> Original Message + +» From: + +>> Sent: Thursda , Se tember 26 2019 11:02 AM + +» To: + +>> Cc: + +>> I've run all the terms that Epstein's attorney gave me and segregated the hits, there were not many. Can I release the NP or did you come to some agreement with the defense that we would give them notice or let them review them first? + +» Thanks, + +>> Messa. e + +» From: + +>> Sent: Monda Se tember 23 2019 8:46 PM + +» To: + +» Cc: + +» Subject: 'A : amt eview + +» Great, thanks very much. + +» From + +>> Sent: on a e tem23, 2019 16:56 + +»To: + +» Cc: + +>> Subject: : amtReview + +>> We are running the lawyer/paralegal names now, you should have access in a couple of days. + +>> + +>> ---Orilinal Mcssa.e + +» From: + +» Se • • + +» To: + +» Cc + +» Subject: FW: Taint Review + +>> The agents on the Epstein case have asked, below, about the status of the taint review of the materials seized from his Manhattan residence, which were made available on September 10 (see attached). I know that you had dealt directly with Epstein's attorneys regarding search terms, etc., so we haven't had visibility on that, but could you please let us know the current status, and when you expect we'll be able to get access to the materials? + +» thanks very much, + +>> Original Messa e + +» From: + +>> Sent: ues a e tem er : + +» To: + +>> Subject: Taint Review + +>> + +>> Our supervisors are requesting a status update on the taint review process on your end. I simple percentage complete is fine, they just want to know before tomorrow they have a meeting with the ADIC about the case. + +» Thanks \ No newline at end of file diff --git a/marker2/ds9/EFTA00084087/EFTA00084087.metadata.json b/marker2/ds9/EFTA00084087/EFTA00084087.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0e21041264ddd738c903f22c7586f857d5f3d979 --- /dev/null +++ b/marker2/ds9/EFTA00084087/EFTA00084087.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084087.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2390, + "elapsed_seconds": 2.11, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Text", + 45 + ], + [ + "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", + 77 + ], + [ + "Text", + 49 + ], + [ + "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", + 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/EFTA00084087" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084090/EFTA00084090.md b/marker2/ds9/EFTA00084090/EFTA00084090.md new file mode 100644 index 0000000000000000000000000000000000000000..44e17c4f3ff3dcb179f6c9fd63e1bb20030eaee6 --- /dev/null +++ b/marker2/ds9/EFTA00084090/EFTA00084090.md @@ -0,0 +1,273 @@ +From: ' )" (CRM)" Cc: IMIEltai" <1 PO + +Subject: RE: Epstein + +Date: Thu, 26 Sep 2019 15:10:35 +0000 + +Hi + +My cellphone showed a voicemail from what I think is your number, but it's not allowing me to play the message. I'm back at my desk if you'd like to call now — + +Thanks, + +Assistant United States Attorney Southern District of New York I St. Plaza New York, NY 10007 + +From: + +Sent: Wednesday, September 25, 2019 1:54 PM + +To: (CRM) C + +Cc: < + +Subject: RE: Epstein + +Perfect, thanks. Can you call my cell at at 11am tomorrow morning? + +Best, + +Assistant United States Attorney Southern District of New York I St. Plaza New York, NY 10007 + +**From:** [REDACTED], [REDACTED] (CRM) <[REDACTED]> +**Sent:** Wednesday, September 25, 2019 10:56 AM +**To:** [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: Epstein + +Sure, thanks. I could do 11am EDT? + +[REDACTED] +DOJ Attaché/Magistrat de liaison américain +U.S. Embassy, Paris + +[REDACTED] +[REDACTED] +[REDACTED] + +**From:** [REDACTED] +**Sent:** Tuesday, September 24, 2019 1:47 PM +**To:** [REDACTED], [REDACTED] (CRM) <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** Re: Epstein + +[REDACTED] +Thank you very much for forwarding and translating. Given their inability to guarantee confidentiality, we will not be able to share any witness statements or identities. + +I'm happy to schedule a call to discuss other possibilities. Would Thursday work for you? + +Thanks, +[REDACTED] + +On Sep 24, 2019, at 5:53 AM, [REDACTED], [REDACTED] (CRM) <[REDACTED]> wrote: + +[REDACTED]: + +I received an email back from the Paris prosecutor's office in response to my request to learn more about confidentiality. The original French is below. Here is my translation...in *italics*. Could we discuss? My takeaway and suggestion is that if your office would approve of an informal—perhaps telephonic exchange—we could communicate the information we discussed in a way that would alert the investigators to what we have (or don't have) and would make it less likely that this information would be provided to those outside of the prosecutors/investigators. + +Let me know what you think. Thx, [REDACTED] + +*Following up on our phone call with Aude Groualle from September 4th, I can confirm the following:* + +*The paris prosecutor's office has entrusted a criminal inquiry to the central group of minor victims of the central office for the repression of violence against persons since August 23, 2019, in relation to acts of rape et sexual agreession committed against minors.* + +*This preliminary inquiry is, according to the rules contained in Article 11 of the French code of criminal procedure, covered by secrecy, in the sense that only the investigators and prosecutor's office have access to witness interviews in* + +*relation to the investigation. Violating this secrecy is punishable by up to one year in prison. Attorneys, witnesses, and victims that are part of the investigation do not have access to the file. However, as you have no doubt already inferred, the media interest created by this matter is such that a variety of information has been distributed, against our wishes. We are there not in position to guarantee total confidentiality in relation to information provided officially as part of the investigation.* + +*Nevertheless, we thought that an informal exchange would be desirable, in a restricted setting, with our counterparts in New York. This method would, by contrast, lend itself to guarantee full confidentiality of our communications and would be useful to help orient the French investigation. We could also assure ourselves that the investigations underway in France do not negatively impact those underway in the U.S., such as the search of Epstein's residence in France.* + +*I leave you then to get back to us and we reiterate our desire for a direct means of communication, by email or telephone, with the minors section of the paris prosecutor's office (with me as well as Aude Groualle) in order to benefit from the maximum level of confidentiality.* + +*I remain at your disposition for any additional information you require.* + +----- +A la suite de l'échange téléphonique avec Aude Groualle du 4 septembre dernier, je suis en mesure de vous confirmer les éléments suivants : + +Le parquet de Paris a confié une enquête pénale au Groupe Central des Mineurs Victimes (GCMV) de l'Office Central pour la Répression des Violences aux Personnes (OCRVP) depuis le vendredi 23 août 2019, des chefs de viols et agressions sexuelles commis notamment au préjudice de mineurs. + +Cette enquête préliminaire est, selon les règles de l'article 11 du code de procédure pénale, couverte par le secret, de sorte que seuls les enquêteurs et le parquet ont accès aux auditions et procès-verbaux de la procédure. Le non-respect de cette confidentialité est puni d'un an d'emprisonnement. Les avocats, témoins, victimes et mis en cause n'ont pas accès à la procédure. Toutefois, comme vous avez probablement pu le constater, l'intérêt médiatique suscité par cette affaire est tel que diverses informations ont pu être diffusées, contre notre volonté. Nous ne sommes donc pas en mesure de garantir cette totale confidentialité s'agissant des informations versées officiellement à cette procédure. + +Néanmoins, nous avions cru comprendre qu'un échange informel était envisageable, en cercle particulièrement restreint, avec nos homologues New-Yorkais. Ce cadre serait par contre de nature à garantir la pleine confidentialité de nos échanges et à utilement orienter les investigations en France. Nous pourrions également dans ce cadre nous assurer que les investigations en cours en France ne nuisent pas à celles diligentées aux Etats Unis, comme la perquisition du domicile français d'Epstein. + +Je vous laisse donc revenir vers nous à ce sujet et vous réitère notre aval à une transmission directe, par voie d'e-mail ou de téléphone, à la section des mineurs du parquet de Paris (à moi-même ainsi qu'à Aude Groualle), ce afin qu'ils bénéficient d'un niveau de confidentialité maximal. + +Je reste à votre disposition pour toute information complémentaire. + +[REDACTED] +DOJ Attaché/Magistrat de liaison américain +U.S. Embassy, Paris +[REDACTED] +[REDACTED] +[REDACTED] + +To: (CRM) + +Subject: Re: Epstein + +That's fine, thanks. Talk soon. + +On Sep 10, 2019, at 2:40 AM, (CRM) ca wrote: + +if you are okay with it, I'd like to have Paris ALAI-join me this afternoon, as FBI is getting request for information as well. - + +DOJ Attache/Magistrat de liaison anthicain + +U.S. Embassy, Paris + +From: + +Sent: Monday, September 9, 2019 4:23 PM + +To: (CRM) + +Cc: + +Subject: RE: Epstein + +9:30 eastern tomorrow (Tuesday) will work for me, thanks. Can you call my desk at please? + +Thanks, + +Assistant United States Attorney + +Southern District of New York + +I St. Plaza + +New York, NY 10007 + +From: (CRM) + +Sent: Monday, September 9, 2019 1:00 AM + +To: + +Cc: + +Subject: RE: Epstein + +Sure. I have 10am eastern open today (Monday), and 9:30 eastern tomorrow (Tuesday). Would either of those times work? + +From: + +Sent: Sunday, September 8, 2019 10:43 PM + +To: (CRM) + +Cc: + +Subject: RE: Epstein + +Hi + +I think it would be helpful for us to have a call with you first before we have direct contact with the Paris prosecutor's office. Are there some times this week that would work for you for a call with us? + +Thanks, + +Assistant United States Attorney Southern District of New York + +I St. Plaza + +New York, NY 10007 + +From: (CRM) + +Sent: Friday, September 6, 2019 2:27 AM + +To: + +Cc: + +Subject: Epstein + +I had a follow up call with the Paris prosecutor's office about their Epstein investigation. + +In terms of confidentiality, they explained that information we share would stay confidential. This would be the case until a criminal defendant is placed under examination, at which point that person would have access to the investigative file; but they are not at that stage yet. She added that the press could not have access to the investigative file at this time. I am waiting on a written follow up from them on this point. + +They are preparing to execute search warrants, possible as early as next week, and don't want to interfere with the US case. Though, I imagine they may obtain some information that could be helpful for your case as well. + +In the meantime, with the investigation ramping up here, I think it could be productive to put you in touch. Is that something you would be open to? Perhaps a call to start? + +DOJ Attache/Magistrat de liaison americain U.S. Embassy, Paris + +[REDACTED] +[REDACTED] +[REDACTED] + +--- + +**From:** [REDACTED], (CRM) +**Sent:** Wednesday, September 4, 2019 11:15 AM +**To:** [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: [REDACTED] Extradition + +Hi, [REDACTED]. + +Just to update you on my interactions with the French on this, I am scheduled to have a call today with the Paris prosecutor's office to discuss the confidentiality of any information we are able to share with them. Once I get a sense of what level of confidentiality they can afford any information we share, I hope to come back to you to discuss the mechanics of sharing information with the French. - [REDACTED] + +[REDACTED] + +DOJ Attaché/Magistrat de liaison américain +U.S. Embassy, Paris + +[REDACTED] +[REDACTED] +[REDACTED] + +--- + +**From:** [REDACTED] +**Sent:** Friday, August 16, 2019 9:50 PM +**To:** [REDACTED], [REDACTED] (CRM) <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: [REDACTED] Extradition + +I'm available at 10:30am on Tuesday and happy to chat then. Want to call my desk at [REDACTED]? + +Thanks, +[REDACTED] + +[REDACTED] + +Assistant United States Attorney +Southern District of New York +1 St. [REDACTED] Plaza +New York, NY 10007 + +[REDACTED] +[REDACTED] + +--- + +**From:** [REDACTED], [REDACTED] (CRM) <[REDACTED]> +**Sent:** Friday, August 16, 2019 3:47 PM +**To:** [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** Re: [REDACTED] Extradition + +On Aug 16, 2019, at 6:20 PM, > wrote: + +passed along your email inquiring about the Epstein investigation. and I are the SDNY team who have been handling the investigation into Epstein and his co-conspirators. We'd be happy to have a call to discuss the inquiry from the Paris prosecutor's office whenever works for you. + +Best, + +Assistant United States Attorney Southern District of New York 1 St. Plaza New York, NY 10007 + +From: (CRM) + +Sent: Friday, August 16, 2019 6:53 AM + +To: ) + +Subject: RE: Extradition + +On a totally unrelated matter, would you be able to connect me with your colleagues who are working on the Epstein investigation? + +I've received an inquiry from the Paris prosecutor's office about Epstein's potential connections to France, and I am trying to figure out if we would be in a position to share anything with the French that could advance their investigation. + +Thanks in advance if you have any thoughts. + +DOJ Attache/Magistrat de liaison americain + +U.S. Embassy, Paris \ No newline at end of file diff --git a/marker2/ds9/EFTA00084090/EFTA00084090.metadata.json b/marker2/ds9/EFTA00084090/EFTA00084090.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..644a6f7490adbd3e70df84574239d517074487ff --- /dev/null +++ b/marker2/ds9/EFTA00084090/EFTA00084090.metadata.json @@ -0,0 +1,234 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084090.pdf", + "engine": { + "marker_major": "2", + "marker_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": 11103, + "elapsed_seconds": 14.14, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 29 + ], + [ + "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": "surya", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Text", + 38 + ], + [ + "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": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 36 + ], + [ + "Text", + 23 + ], + [ + "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", + 63 + ], + [ + "Text", + 37 + ], + [ + "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": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 30 + ], + [ + "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": 5, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Text", + 49 + ], + [ + "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": 6, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 46 + ], + [ + "Text", + 25 + ], + [ + "Line", + 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/EFTA00084090" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084097/EFTA00084097.md b/marker2/ds9/EFTA00084097/EFTA00084097.md new file mode 100644 index 0000000000000000000000000000000000000000..fa67f7419e3cd3d18d9a60386b864d210bd92365 --- /dev/null +++ b/marker2/ds9/EFTA00084097/EFTA00084097.md @@ -0,0 +1,92 @@ +**From:** [REDACTED] +[REDACTED] +[REDACTED] > + +**Subject:** RE: Labyrinth of Deception --Jeff Epstein + +**Date:** Fri, 27 Sep 2019 16:45:14 +0000 + +--- + +Thanks. + +--- + +**From:** [REDACTED] > +**Sent:** Friday, September 27, 2019 12:23 PM +**To:** [REDACTED] +[REDACTED] +**Subject:** RE: Labyrinth of Deception --Jeff Epstein + +Sure, whatever you do is fine. If this person sent it to [REDACTED] it is going to come back around anyway. + +--- + +**From:** [REDACTED] > +**Sent:** Friday, September 27, 2019 10:35 AM +**To:** [REDACTED] +[REDACTED] +**Subject:** RE: Labyrinth of Deception --Jeff Epstein + +Thanks [REDACTED]. We would ordinarily pass this on to the FBI agents on the Epstein case and defer to them on how to respond. Unless you disagree, that's what I'll do here. + +--- + +**From:** [REDACTED] > +**Sent:** Friday, September 27, 2019 9:46 AM +**To:** [REDACTED] >; [REDACTED] +[REDACTED] > +**Subject:** FW: Labyrinth of Deception --Jeff Epstein + +This is addressed to [REDACTED] but sent to me. Should I send it to [REDACTED]. [REDACTED] will send it to [REDACTED] will send it to all of you. + +--- + +**From:** Disanto, Patrick <[REDACTED]> +**Sent:** Friday, September 27, 2019 9:21 AM +**To:** [REDACTED], [REDACTED] (USANYS) [REDACTED] > +**Subject:** Labyrinth of Deception --Jeff Epstein + +[REDACTED] +Victim/Witness Coordinator +United States Attorney's Office + +[REDACTED] Good Morning, within two scripts that sat on Harvey Wiensteins desk in lower Manhatten were "sponsorship" PSA's (public service announcements) on one of Epsteins victims, a 13 year old female, thoughts are not always clear and events upsetting, that seem should have been looked into deeper. [REDACTED] as given those of us that came into contact with these predators, hope. The plight of the young south American girl (from ages 6-14) mentioned is detailed and a very moving account of the life of a "sponsored" person in + +2009. The 1st film is JAKE about Martin Luther King HS soccer coach Martin Jacobsen, a sport film where she appears as side story a PSA because we could not draw attention in 2009 to her situation. + +No advocate agency would help her of the 200+ we contacted and the fact she was "sponsored" by a Canadian official and American official is disturbing in itself. The second script was 35 cents a larger story this time a murder mystery about the young American boys from Texas are ages 13-22, that have vanished at an alarming rate. A municipal sheriff was identified as well as a judge making this an unpopular segment in the second film we put "sponsorship" PSA within. Intended to be as cautionary tale for youth to become aware of putting themselves in compromising situations and hope for those in them. + +I feel as did the other writers that people need to understand rehabilitation for not only the victims but for those involved in the transaction of human life, to comprehend what they have participated in, the innocence they have interrupted and changed forever. The public needs to really look at this problem within our officials as well as in the moral fabric of our America is experiencing, not look for the noose but step back and find a remedy a solution to the problem. This is the only release for the victims of predator stalking/malice/abuse of another human life. + +I am asking your advice on presenting this to as well as Geoffery S. Berman covering the subject currently - most intimately Jeff Epstein as he is connected directly to the young girl, who at last check was doing well protected a decade later in a new community by a church out of the United States. + +The boys effected by these predators, not having the same advocacy tracking mechanism in place and they are a very under investigated section of this equation as men and sexuality often includes deep shame. From what we have witnessed most often leading to death, our story was presented as success the combination of three lives to get it to a point where viewers could digest it. These are from the perspective of actual victims too young to process the complex emotions of coming in contact with a predators such as Epstien, Klein, Wienstein, Cooper or Mandlebaum. Sponsorships are not of interest to most, people believe these victims have done something illegal to end up in this situation, most often they simply are young, inexperienced, ill educated, and traumatized. + +This writing for these films cost me considerably, aside from the TBI/CTE, the mistruths invented creating a riff between myself and my own children (we suspect gas lighting/Stockholm Syndrome) as individuals involved confiscated most of the research findings from a storage locker. Fortunately the staff at the studio was large and hard headed, many intimidation and scare tactics have had to be confronted in attempts to snuff these stories. + +![](_page_2_Picture_0.jpeg) + +![](_page_2_Picture_1.jpeg) + +Athlete stalked then brutally attacked while portraying a young man mixed up in slavery and sex trafficking; Patrick di Santo who portrayed Matt MacKlee in the MEDIAiidp/Kronogruffix Pictures, film "35 cents" was reportedly harassed by officials -including having his children removed from his custody, for the portrayal of the abused teen. Crew and cast complained to local courts and agencies with no relief, Disanto was then assaulted himself, shutting down production, stating reasons of safety. + +Opposing attorneys and child care advocates represented to the courts that di Santo was an unfit parent due to the homosexual content in this film, proving Americans are not safe from their own officials. The officials in question ignored he had been the sole primary caregiver for his children for 10 years prior with no record of the children ever suffering in his care (Stein). + +Representation: + +Attorney + +M. Jim Jenkins + +![](_page_2_Picture_7.jpeg) + +![](_page_2_Picture_8.jpeg) + +Pensacola, Florida 32502 + +Sylvia Penner + +Fleeson, Gooing, Coulson & Kitch, LLC + +![](_page_2_Picture_12.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084097/EFTA00084097.metadata.json b/marker2/ds9/EFTA00084097/EFTA00084097.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f67895e4437c1d0fd33d3a6e20742f27533e82f0 --- /dev/null +++ b/marker2/ds9/EFTA00084097/EFTA00084097.metadata.json @@ -0,0 +1,150 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084097.pdf", + "engine": { + "marker_major": "2", + "marker_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": 5981, + "elapsed_seconds": 7.88, + "image_assets": [ + "_page_2_Picture_0.jpeg", + 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Please use the following identifiers: + +| NAMES/ENTITIES | AKA: | [REDACTED] | +|----------------|-----------------------------|-----------------------------| +| | [REDACTED] | [REDACTED] | +| | [REDACTED] | [REDACTED] | +| | [REDACTED] | [REDACTED] | +| | [REDACTED] | [REDACTED] | +| | [REDACTED] | [REDACTED] | +| DOB | [REDACTED] | [REDACTED] | +| SSN | [REDACTED] | [REDACTED] | +| ADDRESS | [REDACTED], MIAMI BEACH, FL | [REDACTED], NYC, NY | +| | [REDACTED], NYC, NY | [REDACTED], THOMASVILLE, NC | +| PHONE | [REDACTED] | [REDACTED] | +| EMAIL | [REDACTED] | [REDACTED] | + +B. Records to be produced should include but are not limited to the items listed below: + +## 1. DATA TRANSACTION FILES + +- 2. Documents (checks, debit memos, cash in tickets, wires in, wires out, etc.) reflecting additions and/or subtractions to the account and how the account balances are being satisfied on a monthly basis; +- 3. Signature cards; +- 4. Proof of identification (including but not limited to copies of identification used to open the account); +- 5. Opening account(s) documents with attachments, including any and all applications, internal documents generated to open account(s), and identification information or other documentation provided by Customer; and Customer's email address +- 6. "Know your customer" documentation; +- 7. Wire transfer records (incoming and outgoing, and any and all applications and instructions); +- 8. Safe deposit records, including applications, signature cards, and sign-in records; +- 9. Trust accounts; +- 10. Monthly statements; +- 11. Credit card statements; +- 12. Bank, travelers, or cashier checks drawn on account or purchased with an account check; +- 13. Prepaid debit cards, certified checks, cashiers' checks, money orders, and traveler's checks; +- 14. Loan, lease, and/or mortgage application files (whether granted or denied) including credit reports, applications, and payments made on loans; +- 15. Online banking information- All information regarding the electronic use of banking systems to include the following: username, registration IP address, online account creation date, online account status and IP logs/history, MAC addresses and online session times and duration; +- 16. Any and all corporate resolutions, certifications of incorporation, business certificates and/or partnership agreements; and +- 17. Any and all correspondence, electronic or otherwise, including memoranda, emails and text messages, that reference or concern items (1) through (16), above, and/or any financial interests involving the individuals and/or entities identified in Section A. + +If you have any questions or comments, please contact-Forensic Accountant, at \ No newline at end of file diff --git a/marker2/ds9/EFTA00084101/EFTA00084101.metadata.json b/marker2/ds9/EFTA00084101/EFTA00084101.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8c6ba488ebae4e6f669449cd2fc69ba0d68e5cca --- /dev/null +++ b/marker2/ds9/EFTA00084101/EFTA00084101.metadata.json @@ -0,0 +1,147 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084101.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3682, + "elapsed_seconds": 1.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "ALL OPEN AND CLOSED ACCOUNTS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 220.32000000000005 + ], + [ + 230.80508422851562, + 220.32000000000005 + ], + [ + 230.80508422851562, + 233.96759033203125 + ], + [ + 68.544, + 233.96759033203125 + ] + ] + }, + { + "title": "1. 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So if there is any way to bump this up the list a bit it would help keep the peace. + +Thanksl + +From: (USANYS) + +Sent: Thursday, December 31, 2020 12:19 PM + +To: (USANYS) < :›; (USANYS) (USANYS) < (USANYS) < >; •c• ==.; Cc: (USANYS) ).; <1. ›;-(USANYS)1 < > Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera (USANYS) (USANYS) (USANYS) (USANYS) + +Hi Please see our proposed letter, which I understand you would like to review, as well as declarations from associate wardens at the MDC and MCC. The GC and PC chiefs have signed off on these drafts. + +With apologies for the time sensitivity, our contacts at MCC/MDC have asked to leave early today (before 1/1:30), and have asked us to finalize the declarations as soon as possible. + +Best, + +From: (USANYS) + +Sent: Wednesday, December 30, 2020 4:24 PM + +To: (USANYS) < >.; (USANYS) < (USANYS) (USANYS) °c )'; > (USANYS) Cc: (USANYS)< > (USANYS) c M > (usAmes)< :.; (USANYS) + +, who is the Associate Warden at the MCC. There's a possibility that there will be a very short declaration from someone at the MDC to discuss the specific accommodations for Maxwell. I am working through that with + +From: (USANYS) + +Sent: Wednesday, December 30, 2020 2:45 PM + +To: (USANYS) ca; (USANYS) (USANYS) (USANYS) ) < < I>; (USANYS) + +Cc: (USANYS) c: ; (USANYS) , > (USANYS) ; (USANYS) >; (USANYS) 1 .Lc .: + +Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera + +Thanks. Who is signing the declaration for BOP? + +From: (USANYS)< > + +Sent: Wednesday, December 30, 2020 2:40 PM + +To: (USANYS) ; (USANYS) 4 (USANYS) (USANYS) (USANYS) + +Cc: (USANYS) < ; (USANYS) > (USANYS) < >; (USANYS) >; (USANYS) 1 .Lc • + +Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera + +: We are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to explain that the discovery and counsel access accommodations that have been provided to Maxwell and Rivera, respectively, result from the specific circumstances of their cases, the specific requests of their lawyers, and their individual housing circumstances. On all of these factors, there are several important differences, including: + +- The Maxwell case has multiple times more discovery than the Rivera case. Hence, the need for such expanded discovery access is greater in the Maxwell case. +- At the MDC, Maxwell has a unique housing situation, as she is in protective custody outside the general population. She therefore has sole access to a room to use a computer and phone for approximately 13 hours a day. Rivera, by contrast, is housed in the general population. +- There are approximately 8o other inmates at the MCC in Rivera's unit that use the same VTC room for court appearances, probation interviews, and attorney meetings. By contrast, Maxwell shares access to the MDC VTC room with substantially fewer inmates. The MDC can therefore provide 15 hours of VTC meetings with her attorneys without compromising access for other MDC inmates. The same is not true for Rivera at the MCC. + +Going forward, even though Rivera's counsel have asked (and the Court has ordered) that Rivera receive three hours of laptop access each day, the MCC is now leaving the laptop with him all day long, and only takes it back at night to charge it. Therefore, the MCC is now providing the same amount of electronic discovery access to Rivera that Maxwell receives at the MDC. + +As for providing Rivera with up to 15 hours of VTC access, we will explain that doing so will compromise access for other inmates. If defense counsel expresses a need for additional time, the MCC will continue to find ways to accommodate those requests as best as they can. + +Please let me know if you have any questions or would like to discuss this further. + +Best, + +From: (USANYS) + +Sent: Monday, December 21, 2020 4:42 PM + +To: (USANYS) <.a ; (USANYS) (USANYS) .c=a ; 4 (USANYS) (USANYS) + +Cc: (USANYS) c = ; (USANYS) &gt;(USANYS) < 1.),; (USANYS) -(USANYS)1 + +Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera + +Thanks, Can you keep me posted on what we think will be the substance of the draft declaration when you know (that is, before we are submitting anything on 12/31)? And how much of this is attributable to differences between MCC and MDC, as well as specific differences in their housing situations? + +From: (USANYS) + +Sent: Monday, December 21, 2020 4:35 PM + +To: (USANYS) (USANYS) (USANYS) c ) (USANYS) dc > 'c >; 4 (USANYS) + +Cc: (USANYS) >; (USANYS) (USANYS) >; (USANYS) (USANYS) 1 'c :' + +Subject: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera + +All: + +I wanted to bring to your attention a recent issue that's surfaced in United States v. Rivera et al., a sex trafficking case pending before Judge Engelmayer. As I'll describe in more detail below, Judge Engelmayer has asked us to submit a declaration from the BOP explaining why the discovery and counsel access accommodations provided to Ghislaine Maxwell (detained at the MDC outside the general population) cannot be extended to Justin Rivera (detained at the MCC in the general population). + +Justin Rivera was charged in February 2019 with sex trafficking conspiracy. He's been detained at the MCC since April 2019 on consent (he's also serving a state sentence). His trial, which was originally scheduled for April 2019, is expected to start on February 16, 2O2O. In July 2O2O, he had new counsel appointed, citing an irreconcilable breakdown with his former counsel. + +Since this fall, Judge Engelmayer has become increasingly frustrated with the MCC's treatment of Rivera. In particular, he's cited their failure to provide Rivera with adequate accommodations to review discovery and meet with his lawyers, who refuse to visit Rivera at the MCC for personal health concerns. We have two court orders in place to address these issues: (1) a laptop order, which requires the MCC to provide Rivera access to a laptop for three hours per day; and (2) a videoconference order, which requires the MCC to make available four hours of videoconferencing each week, in addition to any telephone or videoconference calls obtained through the Federal Defenders. + +At the moment, there's not a concern, at least from Judge Engelmayer, that the amount of time Rivera has for videoconferences and electronic discovery review is insufficient for trial preparation, although defense counsel has stated that they may request more time in the future. However, in a letter last night and during a court conference this morning (transcript attached), defense counsel cited the accommodations that the MDC has provided to Maxwell, describing them as "strikingly different and far superior" to those afforded to Rivera. Defense counsel further suggested that Rivera was being treated differently on account of his race, gender and class. Judge Engelmayer stated that the disparity in access "jumped off the page" and that the optics were "terrible," and asked us toe lain the rationale for the differing treatment. After conferring with and before our conference, we explained our understanding that the disparity comes down to the fact that Maxwell and Rivera have very different housing situations, with Maxwell's situation being more amenable to greater access to electronic discovery review and legal visits. + +Judge Engelmayer asked us to submit a declaration, from an appropriate person at the BOP, explaining in more detail why the accommodations provided to Maxwell cannot be extended to Rivera. + +Based on the recent bail opposition in the Maxwell case, I believe the differences in counsel/discovery access are as follows: + +| Accommodation | Maxwell | Rivera | +|---------------------------|----------------------------|---------------| +| Counsel visits (by video) | 3 hours per day/5 days per | | +| Weekend legal calls | As needed | Not available | + +The declaration is due by December 31. Because Judge Engelmayer's request implicates at least two criminal cases, and potentially the ongoing civil litigation with the MCC, we wanted to make sure that you were all aware of this issue. We are also ha to set up a call to discuss this further. In the meantime, we are working with to identify the appropriate declarant and draft an explanation for the Court. + +Best, + +Bhaskaran + +Assistant United States Attorney + +United States Attorney's Office for the Southern District of New York + +![](_page_4_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084103/EFTA00084103.metadata.json b/marker2/ds9/EFTA00084103/EFTA00084103.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5bfc3bacea2c4220dae1563df786d49fc8f99c14 --- /dev/null +++ b/marker2/ds9/EFTA00084103/EFTA00084103.metadata.json @@ -0,0 +1,188 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084103.pdf", + "engine": { + "marker_major": "2", + "marker_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": 9163, + "elapsed_seconds": 1.44, + "image_assets": [ + "_page_4_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 111 + ], + [ + "Line", + 42 + ], + [ + "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", + 112 + ], + [ + "Line", + 47 + ], + [ + "Text", + 16 + ], + [ + "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", + 124 + ], + [ + "Line", + 46 + ], + [ + "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", + 97 + ], + [ + "Line", + 49 + ], + [ + "Text", + 13 + ], + [ + "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": 4, + "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/EFTA00084103" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084103/_page_4_Picture_0.jpeg b/marker2/ds9/EFTA00084103/_page_4_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..e0ec752fc4547f6480c58d59f04e973d697e47f4 --- /dev/null +++ b/marker2/ds9/EFTA00084103/_page_4_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:e579286992172300bc6efefe0afad0bc9c47292dfe4283ac1c3deed71488c10c +size 1883 diff --git a/marker2/ds9/EFTA00084108/EFTA00084108.md b/marker2/ds9/EFTA00084108/EFTA00084108.md new file mode 100644 index 0000000000000000000000000000000000000000..0ab43329c80f933c6b1fcf719f240cfe3a63b685 --- /dev/null +++ b/marker2/ds9/EFTA00084108/EFTA00084108.md @@ -0,0 +1,127 @@ +![](_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, + +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 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Albuquerque + +Santa Fe RA + +[Redacted] + +[Redacted] + +San Juan + +St. Thomas RA + +(2) +[Redacted] + +From: Miami + +Squad PB-2, PBCRA + +Contact: SA [Redacted] + +Approved By: [Redacted] + +Drafted By: [Redacted] + +Case ID #: 31E-MM-108062 (Pending) + +Title: JEFFREY EPSTEIN; + +[Redacted] + +WSTA - CHILD PROSTITUTION + +b6 +b7C + +Synopsis: To set leads for captioned investigation. + +Details: On 07/24/2006 the Federal Bureau of Investigation (FBI), Palm Beach County Resident Agency (PBCRA), began investigating Jeffrey Epstein, a part-time resident of Palm Beach, along with [Redacted]. PBCRA obtained information from the City of Palm Beach Police Department (PBPD) [Redacted] + +[Redacted] +[Redacted] +[Redacted] +[Redacted] Epstein +[Redacted] +[Redacted] + +Following the receipt of the case files from the PBPD, PBCRA began interviewing [Redacted] who reported a similar series of events. In particular, [Redacted] described how contact was made via telephone, primarily [Redacted] + +b6 +b7C +b7D + +• 1 + +To: Albuquerque Et: Miami Re: 31E-MM-108062, 12/06/2006 • + +b6 b7C b7D + +mat by Fnetnin + +nd some + +instances. Eosteid + +On most + +exam le, t 'Epstein + +During the course of PBPD's investigation, a search warrant for Epstein's home was obtained and executed. Many of Epstein's belongings were removed from the home prior to the execution of the search warrant - for example, the computer processing units (CPUs) were removed from the house but the computer screens, keyboards, cords, etc. were left behind. The missing CPU's were never recovered. + +During the search, several telephone message pads were recovered. These message pads show messages taken from several of the girls who were interviewed and admitted to engaging in sexual massages or other sexual activity with Epstein. The messages contained text such as "I have a female for him" and "has girl for tonight." Some of the messages from the girls weri addresse to E stein and others were addressed tot Additional messages recovered during the search con aine ext confirming appointment times. + +During the PBCRA's investigation,' that 'would contact i + +[Redacted] + +[Redacted] The investigation revealed that prior to the flights to Palm Beach, [Redacted] would contact some of [Redacted] via cell phone. The massage nads show evidence that [Redacted] + +[Redacted] + +b6 +b7C +b7D + +In addition to the home in Palm Beach, Epstein also maintains a residence in the U.S. Virgin Islands, New York and New Mexico. + +To date, the PBCRA continues to develop witnesses and victims from across the United States. Due to the media coverage, unknown status of the state investigation, vulnerability of the young female victims, and political influences, the AUSAs and Case Agents have a target date of January 2007 for indictment. + +Based on the ongoing criminal investigation, the PBCRA is requesting the assistance in establishing Epstein's criminal activity utilizing interstate commerce and the travel in interstate commerce to engage in illicit sexual conduct and prostitution. Prior to conducting captioned leads, it is requested that the lead agent(s) contact SA [Redacted] FBI Miami, West Palm RA, [Redacted] or SA [Redacted] for investigative direction and questions. \ No newline at end of file diff --git a/marker2/ds9/EFTA00084113/EFTA00084113.metadata.json b/marker2/ds9/EFTA00084113/EFTA00084113.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..00f7dfc7468bb3c50ac0359940520e7fdd8e30e0 --- /dev/null +++ b/marker2/ds9/EFTA00084113/EFTA00084113.metadata.json @@ -0,0 +1,146 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084113.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3284, + "elapsed_seconds": 6.81, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FEDERAL BUREAU OF INVESTIGATION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 132.192, + 58.31999999999999 + ], + [ + 473.076, + 58.31999999999999 + ], + [ + 473.076, + 72.9 + ], + [ + 132.192, + 72.9 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 86 + ], + [ + "Text", + 55 + ], + [ + "Line", + 40 + ], + [ + "PageFooter", + 7 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 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", + 33 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 4 + ] + ], + "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", + 72 + ], + [ + "Line", + 31 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 7 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00084113" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084116/EFTA00084116.md b/marker2/ds9/EFTA00084116/EFTA00084116.md new file mode 100644 index 0000000000000000000000000000000000000000..cb33b11d475b88430dd13cec4af0df5ec74c3e81 --- /dev/null +++ b/marker2/ds9/EFTA00084116/EFTA00084116.md @@ -0,0 +1,43 @@ +To: + +Cc: + +Subject: RE: Request re Ghisliane Maxwell + +Date: Fri, 08 Jan 2021 17:01:41 +0000 + +Np!! + +>» ' /8/2021 12:00 + +PM >>> + +Thanks very much and sorry I missed your response. + +Original Message + +From: + +Sent: Fn ay,January , : + +101.1111 u ject: : equest is laneMaxwell 11M + +I responded earlier today. No, unfortunately not. It would have to come from your office. + +>>>' 1/8/2021 11:58 + +AM > + +Good morning, + +Following up on this email, would it be acceptable for someone from the defense to deliver this new drive from our office to the MDC today, please? + +ssts an ni a staates Attorney Southern District of New York I St. Andrew's Plaza New York NY 10007 + +Sent: Thursday, January 7, 2021 4:35 PM + +At the request of defense counsel, our office is preparing a new drive with a copy of discovery material that was previously produced to Ghislaine Maxwell on a CD, but which she has been unable to view. The drive will be ready tomorrow. Today, defense counsel asked that Maxwell be able to review those materials over this coming weekend, but no one from ow office is available to hand deliver the drive tomorrow, and we understand that Maxwell would not receive a FedEx package sent out tomorrow until next week. Defense counsel has offered to pick the drive up from our office and hand deliver it to the MDC themselves tomorrow. Would that be permissible? + +liTha a + +sms ru tes Attorney Southern District of New York I St. Andrew's Plaza \ No newline at end of file diff --git a/marker2/ds9/EFTA00084116/EFTA00084116.metadata.json b/marker2/ds9/EFTA00084116/EFTA00084116.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a596dee96dd79b8dfd37b20f7108f6ecbec1b3b1 --- /dev/null +++ b/marker2/ds9/EFTA00084116/EFTA00084116.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084116.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1435, + "elapsed_seconds": 1.13, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Line", + 30 + ], + [ + "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", + 33 + ], + [ + "Line", + 16 + ], + [ + "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/EFTA00084116" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084118/EFTA00084118.md b/marker2/ds9/EFTA00084118/EFTA00084118.md new file mode 100644 index 0000000000000000000000000000000000000000..9548b45e769b5846c790a1abfdbc387393aaf0a8 --- /dev/null +++ b/marker2/ds9/EFTA00084118/EFTA00084118.md @@ -0,0 +1,48 @@ +From: "a' + +To: IMMIlla + +Cc: + +Subject: Re: Maxwell drive delivery Monday 1/11 + +Date: Mon, 11 Jan 2021 15:47:12 +0000 + +I will be picking up the drives today. Are you available to run out to me around 11:30? + +or ideally I'd be bringing the drives directly to you after pick up. Are you available around 12- 1230? + +Feel free to call me at + +> On Jan 11, 2021, at 09:48, MMIII MM=.1.> wrote: + +> It will be myself or M. + +> Best, + +>>» " 1/8/2021 2:20 + +> PM >» + +> Good afternoon, + +> The FBI has very kindly agreed to deliver two new drives from my office + +> to the MDC for Ghislaine Maxwell on Monday, January 11th. I've cc'd + +> Special Agent , who will be coordinating the delivery. Would + +> you please let us know what time the FBI should plan to make the + +> delivery and who will be available to receive the drives on Monday? + +> Thank you all very much for your help. + +> Best, + +> Assistant United States Attorney + +> Southern District of New York + +> [REDACTED] +> \ No newline at end of file diff --git a/marker2/ds9/EFTA00084118/EFTA00084118.metadata.json b/marker2/ds9/EFTA00084118/EFTA00084118.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a229e2b86fbaf2db49088017bad4343ae1d1594e --- /dev/null +++ b/marker2/ds9/EFTA00084118/EFTA00084118.metadata.json @@ -0,0 +1,76 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084118.pdf", + "engine": { + "marker_major": "2", + "marker_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": 986, + "elapsed_seconds": 2.38, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Text", + 38 + ], + [ + "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": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 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/EFTA00084118" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084120/EFTA00084120.md b/marker2/ds9/EFTA00084120/EFTA00084120.md new file mode 100644 index 0000000000000000000000000000000000000000..cce03d3a1a389379c4f75f70b52ada0375c94969 --- /dev/null +++ b/marker2/ds9/EFTA00084120/EFTA00084120.md @@ -0,0 +1,61 @@ +From: =Ma + +To: = In' + +Cc: + +Subject: Re: Maxwell drive delivery Monday 1/11 + +Date: Mon, 11 Jan 2021 15:54:41 +0000 + +Yes, that works for us! + +>>.=. > 1/11/2021 10:47 AM >» + +I will be picking up the drives today. Are you available to run out to me around 11:30? + +or ideally I'd be bringing the drives directly to you after pick up. Are you available around 12-1230? + +Feel free to call me at + +> On Jan 11, 2021, at 09:48, MMIII > + +wrote: + +> It will be myself or M. + +> Best, + +>>»' " 1/8/2021 2:20 + +> PM >» + +> Good afternoon, + +> The FBI has very kindly agreed to deliver two new drives from my office + +> to the MDC for Ghislaine Maxwell on Monday, January 11th. I've cc'd + +> Special Agent , who will be coordinating the delivery. Would + +> you please let us know what time the FBI should plan to make the + +> delivery and who will be available to receive the drives on Monday? + +> Thank you all very much for your help. + +> + +> Assistant United States Attorney + +> Southern District of New York + +> 1 St. Andrew's Plaza + +> New York, NY 10007 + +> + +> mailto: > + +> \ No newline at end of file diff --git a/marker2/ds9/EFTA00084120/EFTA00084120.metadata.json b/marker2/ds9/EFTA00084120/EFTA00084120.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2bf13da6da035ced7cc75c816500c9912a8e733c --- /dev/null +++ b/marker2/ds9/EFTA00084120/EFTA00084120.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084120.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1047, + "elapsed_seconds": 1.44, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Text", + 32 + ], + [ + "Line", + 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", + 21 + ], + [ + "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/EFTA00084120" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084122/EFTA00084122.md b/marker2/ds9/EFTA00084122/EFTA00084122.md new file mode 100644 index 0000000000000000000000000000000000000000..4144953e59304b7942533fbdc07778e8354e7576 --- /dev/null +++ b/marker2/ds9/EFTA00084122/EFTA00084122.md @@ -0,0 +1,117 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +UNITED STATES OF AMERICA GHISLAINE MAXWELL, Defendant. x x + +USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED:7/30/2020 + +## PROTECTIVE ORDER + +20 Cr. 330 (AJN) + +ALISON J. NATHAN, United States District Judge: + +WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely disclosed, the Government's ongoing investigation; (iii) would risk prejudicial pretrial publicity if publicly disseminated, and (iv) is not authorized to be disclosed to the public or disclosed beyond that which is necessary for the defense of this action, and other materials pursuant to Federal Rule of Criminal Procedure 16 ("Rule 16") and pursuant to any other disclosure obligations (collectively, the "Discovery"), which contain sensitive, confidential, or personal identifying information; + +WHEREAS, the Government seeks to protect sensitive, confidential, or personal identifying information contained in the materials it produces consistent with Rule 16 or other disclosure obligations; + +WHEREAS the Government has applied for the entry of this Order; + +IT HEREBY IS ORDERED: + +1. The Discovery disclosed to the defendant ("Defendant") and/or to the defendant's criminal defense attorneys ("Defense Counsel") during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall not be copied or otherwise recorded or transmitted by the Defendant, except to Defense Counsel, or except as necessary for the Defendant to take notes, which are not to be further transmitted to anyone other than Defense Counsel; + +c) Shall not be disclosed or distributed in any form by the Defendant or her counsel except as set forth in paragraph 1(d) below; + +d) May be disclosed only by Defense Counsel and only to the following persons ("Designated Persons"): + +i. investigative, secretarial, clerical, or paralegal personnel employed full-time, part-time, or as + +independent contractors by the defendant's counsel ("Defense Staff"); + +ii. any expert or potential expert, legal advisor, consultant, or any other individual retained or employed by the Defendant and Defense Counsel for the purpose of assisting in the defense of this case ("Defense Experts/Advisors"); + +iii. such other persons as hereafter may be authorized by Order of the Court ("Other Authorized Persons"); + +e) May be provided to prospective witnesses and their counsel (collectively, "Potential Defense Witnesses"), to the extent deemed necessary by defense counsel, for trial preparation. To the extent Discovery materials are disclosed to Potential Defense Witnesses, they agree that any such materials will not be further copied, distributed, or otherwise transmitted to individuals other than the recipient Potential Defense Witnesses. + +2. The Defendant and Defense Counsel shall provide a copy of this Order to any Designated Persons to whom they disclose Discovery materials. Prior to disclosure of Discovery materials to Designated Persons, any such Designated Person shall agree to be subject to the terms of this Order by signing a copy hereof and stating that they "Agree to be bound by the terms herein," and providing such copy to Defense Counsel. All + +such acknowledgments shall be retained by Defense Counsel and shall be subject to in camera review by the Court if good cause for review is demonstrated. The Defendant and her counsel need not obtain signatures from any member of the defense team (i.e., attorneys, experts, consultants, paralegals, investigators, support personnel, and secretarial staff involved in the representation of the defendants in this case), all of whom are nonetheless bound by this Protective Order. + +3. To the extent that Discovery is disseminated to Defense Experts/Advisors, Other Authorized Persons, or Potential Defense Witnesses, via means other than electronic mail, Defense Counsel shall encrypt and/or password protect the Discovery. + +4. The Government, the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses and their counsel, and Other Authorized Persons are prohibited from posting or causing to be posted any of the Discovery or information contained in the Discovery on the Internet, including any social media website or other publicly available medium. + +5. The Government (other than in the discharge of their professional obligations in this matter), the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses and their counsel, and Other Authorized Persons are strictly prohibited from publicly + +disclosing or disseminating witnesses referenced in the prohibit Defense Counsel or the identity of any victims or Discovery. This Order does not Defense Staff from referencing the identities of individuals they believe may be relevant to the defense to Potential Defense Witnesses and their counsel during the course of the investigation and preparation of the defense case at trial. Any Potential Defense Witnesses and their counsel who are provided identifying information by Defense Counsel or Defense Staff are prohibited from further disclosing or disseminating such identifying information. This Order does not prohibit Defense Counsel from publicly referencing individuals who have spoken by name on the public record in this case. + +6. The Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing the identity of any victims or witnesses referenced in the Discovery, who have not spoken by name on the public record in this case, unless authorized by the Government in writing or by Order of the Court. Any such filings must be filed under seal, unless authorized by the Government in writing or by Order of the Court. + +7. Copies of Discovery or other materials produced by the Government in this action bearing "confidential" stamps, or designated as "confidential" as described below, and/or electronic Discovery materials designated as "confidential" by the Government, including such materials marked as "confidential" either on the documents or materials themselves, or designated as "confidential" in a folder or document title, are deemed "Confidential Information." The Government shall clearly mark all pages or electronic materials containing Confidential Information, or folder or document titles as necessary, with "confidential" designations. + +8. Confidential Information may contain personal identification information of victims, witnesses, or other specific individuals who are not parties to this action, and other confidential information; as well as information that identifies, or could lead to the identification of, witnesses in this matter. The identity of an alleged victim or witness who has identified herself or himself publicly as such on the record in this case shall not be treated as Confidential Information. + +9. Defense Counsel may, at any time, notify the Government that Defense Counsel does not concur in the designation of documents or other materials as Confidential Information. If the Government does not agree to de-designate such documents or materials, Defense Counsel may thereafter move the Court for an Order de-designating such documents or materials. The Government's designation of such documents and materials as Confidential Information will be controlling absent contrary order of the Court. + +10. Confidential Information disclosed to the defendant, or Defense Counsel, respectively, during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall be maintained in a safe and secure manner; + +c) Shall be reviewed and possessed by the Defendant in hard copy solely in the presence of Defense Counsel; + +d) Shall be possessed in electronic format only by Defense Counsel and by appropriate officials of the Bureau of Prisons ("BOP"), who shall provide the defendant with electronic access to the Discovery, including Confidential Information, consistent with the rules and regulations of the BOP, for the Defendant's review; + +e) Shall be reviewed by the Defendant solely in the presence of Defense Counsel or when provided access to Discovery materials in electronic format by BOP officials; + +f) May be disclosed only by Defense Counsel and only to Designated Persons; + +g) May be shown to, either in person, by videoconference, or via a read-only document review platform, but not disseminated to or provided copies of to, Potential Defense Witnesses, to the extent deemed necessary by Defense Counsel, for trial preparation, and after such individual(s) have read and signed this Order acknowledging that such individual(s) are bound by this Order. + +11. Copies of Discovery or other materials produced by the Government in this action bearing "highly confidential" stamps or otherwise specifically designated as "highly confidential," and/or electronic Discovery materials designated as "highly confidential" by the Government, including such materials marked as "highly confidential" either on the documents or materials themselves, or designated as "highly confidential" in an index, folder title, or document title, are deemed "Highly Confidential Information." To the extent any Highly Confidential Information is physically produced to the Defendant and Defense Counsel, rather than being made available to the Defendant and Defense Counsel for on-site review, the + +Government shall clearly mark all such pages or electronic materials containing Highly Confidential Information with "highly confidential" stamps on the documents or materials themselves. + +12. Highly Confidential Information contains nude, partially-nude, or otherwise sexualized images, videos, or other depictions of individuals. + +13. Defense Counsel may, at any time, notify the Government that Defense Counsel does not concur in the designation of documents or other materials as Highly Confidential Information. If the Government does not agree to de-designate such documents or materials, Defense Counsel may thereafter move the Court for an Order de-designating such documents or materials. The Government's designation of such documents and materials as Highly Confidential Information will be controlling absent contrary order of the Court. + +14. Highly Confidential Information disclosed to Defense Counsel during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall not be disseminated, transmitted, or otherwise copied and provided to Defense Counsel or the Defendant; + +c) Shall be reviewed by the Defendant solely in the presence of Defense Counsel; + +d) Shall not be possessed outside the presence of Defense Counsel, or maintained, by the Defendant; + +e) Shall be made available for inspection by Defense Counsel and the Defendant, under the protection of law enforcement officers or employees; and + +f) Shall not be copied or otherwise duplicated by Defense Counsel or the Defendant during such inspections. + +15. The Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing any Confidential Information or Highly Confidential Information referenced in the Discovery, unless authorized by the Government in writing or by Order of the Court. Any such filings must be filed under seal, unless authorized by the Government in writing or by Order of the Court. + +16. The provisions of this Order shall not be construed as preventing disclosure of any information, with the exception of victim or witness identifying information, that is publicly available or obtained by the Defendant or her Defense Counsel from a source other than the Government. + +17. Except for Discovery that has been made part of the record of this case, Defense Counsel shall return to the Government or securely destroy or delete all Discovery, including but not limited to Confidential Information, within 30 days of the expiration of the period for direct appeal from any verdict in the above-captioned case; the period of direct appeal from any order dismissing any of the charges in the abovecaptioned case; the expiration of the period for a petition pursuant to 28 U.S.C. § 2255; any period of time required by the federal or state ethics rules applicable to any attorney of record in this case; or the granting of any motion made on behalf of the Government dismissing any charges in the abovecaptioned case, whichever date is later. + +18. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree in writing otherwise, or (b) this Order is modified by further order of the Court. + +19. The Government and Defense Counsel agree to meet and confer in advance of any hearings or trial to discuss and agree to any modifications necessary for the presentation of evidence at those proceedings. In the absence of agreement, + +Defense Counsel may make an appropriate application to the Court for any such modifications. + +SO ORDERED: + +Dated: New York, New York July 30 , 2020 + +Lc + +HONORABLE ALISON J. 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We're still waiting on the production version from BOP, but I'll proceed once I get that. Thanks. + +Fron USANYS) < + +Sent: Thursday, January 14, 2021 10:48 AM + +To: Kochevar, Steven (USANYS) < + +Subject: RE: Quick Epstein FOIA check in + +Thanks, No issues on our end if his name is not on it (and probably don't even need to see it). + +From + +Sent: • + +Ti + +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/EFTA00084134/EFTA00084134.metadata.json b/marker2/ds9/EFTA00084134/EFTA00084134.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ac822557a34f4c6fec98b1e546db98f822807749 --- /dev/null +++ b/marker2/ds9/EFTA00084134/EFTA00084134.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084134.pdf", + "engine": { + "marker_major": "2", + "marker_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": 959, + "elapsed_seconds": 0.7, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 20 + ], + [ + "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/EFTA00084134" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084135/EFTA00084135.md b/marker2/ds9/EFTA00084135/EFTA00084135.md new file mode 100644 index 0000000000000000000000000000000000000000..c04c4e1c082f3c2023a3950cac43e17fcbb27866 --- /dev/null +++ b/marker2/ds9/EFTA00084135/EFTA00084135.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 + +ir Assistant United 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 | 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+![](_page_0_Picture_110.jpeg) + +**U.S. Department of Justice** + +*United States Attorney +Southern District of New York* + +*The Silvio J. Mollo Building +One Saint Andrew's Plaza +New York, New York 10007* + +October 22, 2019 + +**VIA EMAIL** + +T-Mobile USA, Inc. +Law Enforcement Relations +4 Sylvan Way +Parsippany, NJ 07504 +[REDACTED] + +**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. 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 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. + +Very truly yours, + +GEOFFREY S. BERMAN +United States Attorney + +By: + +[REDACTED] +Assistant United States Attorney +Southern District of New York +[REDACTED] + +# Anitebr atutvz Piztrirt (Erfurt SOUTHERN DISTRICT OF NEW YORK + +TO: T-Mobile USA, Inc. Law Enforcement Relations 4 Sylvan Way Parsippany, NJ 07504 + +### 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, 500 Pearl Street, Room 480 (via North elevators), 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 5, 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. § 1519, 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 re uired if the requested records are (1) produced by on or before the return date to Special Agent at: Federal Bureau of Investigation, 26 Federal Plaza, VCAC/Human Trafficking, New York, NY 10278, 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 October 22, 2019 + +csr., 4x. GE FFREY S. BERMAN Un ted States Attorney for the So them District of New York + +Assistant United States Attorney One St. Andrew's Plaza New York. New York 10007 .hormimmim + +![](_page_1_Picture_14.jpeg) + +#### RIDER + +(Grand Jury Subpoena to T-Mobile, dated October 22, 2019) + +Please provide any and all records (including, but not limited to, incoming and outgoing calls with any call details, local and long distance usage details, all subscriber opening and/or registration documents, all subscriber identification and contact information, all subscriber billing and payment information, SMS/text messaging records, IP history and login records, associated email addresses and/or screen names, and any additional accounts associated with any of the below-listed names, identifiers, addresses, phone numbers, and accounts listed and associated records for those accounts) relating to the following telephone numbers, as listed below, for the time period of January 1, 2018, through the date of service: + +- • + +Also, for the time period detailed above, provide the phone number(s) and subscriber information for any other calls or accounts involving the same Electronic Serial Number ("ESN"), International Mobile Equipment Identity ("IMEI"), and/or International Mobile Subscriber Identity ("IMSI"), but associated with a telephone not on the above list. Provide the phone number(s) and subscriber information for any other phone number(s) listed to the same account as the above listed number(s) and for any other accounts billed to any subscriber at the same address as the listed number(s). + +N.B.: Personal appearance is not required if the re uested records are (1) produced by on or before the return date to Special Agent at: Federal Bureau of Invesfi at , 26 Federal Plaza, VCAC/Human Trafficking, New York, NY 10278, telephone: M , or via email at ; and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE. + +# IMPORTANT: REQUEST FOR NON-DISCLOSURE + +Due to the ongoing nature of the investigation, it is requested that you do not disclose any information relating to this Grand Jury subpoena request to any third party. + +#### 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 22, 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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INDYKE and RICHARD D. KAHN, +as EXECUTORS OF THE ESTATE OF JEFFREY E. +EPSTEIN, + +Defendants. + +\_\_\_\_\_ x + +Plaintiff [REDACTED] by and through her attorneys, Cuti Hecker Wang LLP and + +Allred, Maroko & Goldberg, for her Complaint alleges as follows: + +**NATURE OF THE ACTION** + +![](_page_0_Picture_78.jpeg) + +![](_page_1_Picture_1.jpeg) + +11. brings this action seeking, at last, some remedy for the egregious abuse that Epstein inflicted when she was a child. + +## PARTIES + +12. Plaintiff.] an individual who resides + +13. Defendants Darren K. Indyke and Richard D. Kahn are the Executors of the Estate of Jeffrey E. Epstein (the "Estate"). As Executors of the Estate, Defendants are liable for the acts and omissions of Epstein and his agents. For purposes of 28 U.S.C. § 1332, Defendants Indyke and Kahn are deemed to be citizens of the United States Virgin Islands, where Epstein was domiciled at the time of his death. + +## JURISDICTION AND VENUE + +14. This Court has subject-matter jurisdiction pursuant to 28 U.S.C. § 1332 because this case is between citizens of different states and the amount in controversy exceeds \$75,000. + +15. Venue is proper in this District pursuant to 28 U.S.C. § 1391(b)(2) because a substantial part of the events or omissions giving rise to the claim occurred in this District. + +16. This Court has personal jurisdiction over Defendants. As Executors of the Estate, Defendants Indyke and Kahn are subject to personal jurisdiction in this Court because Epstein was subject to personal jurisdiction at the time of his death. + +17. This Court had both specific and general personal jurisdiction over Epstein at the time of his death. + +18. Epstein resided in New York State a substantial portion of the time during the time period at issue in this lawsuit, and through the time of his death. + +19. Epstein resided in the Metropolitan Correctional Center in New York County at the time of his death. + +20. Epstein conducted substantial business operations in New York. + +21. Epstein owned and/or controlled numerous companies with principal places of business in New York. + +22. Epstein owned substantial real property assets in New York, including the townhouse located at 9 East 71st Street in Manhattan, which is valued at \$55 million or more. + +23. New York was the epicenter of Epstein's criminal sex-trafficking enterprise. For years, Epstein and his agents took actions in New York in order to arrange for minor girls to be trafficked to his homes throughout the country in order to perform sexual acts for him. Epstein's trafficking and abuse of was part of that New York-based criminal enterprise. + +24. From his Manhattan townhouse, Epstein directed a vast network of agents in recruiting minor girls to be brought to him for his sexual use. + +25. Epstein sexually abused many minor girls, includin in his Manhattan townhouse. + +26. On many occasions, Epstein and his agents made phone calls from New York to schedule appointments for minor girls to come to Epstein's residences outside of New York in order to perform commercial sexual acts for Epstein. + +27. Upon information and belief, Epstein and/or his agents were present in New York when they took various actions to facilitate the trafficking of for the purpose of performing sexual acts for Epstein. + +# JURY DEMAND + +28. Plaintiff hereby demands a trial by jury on all of her claims in this action. + +# FACTUAL ALLEGATIONS + +![](_page_4_Picture_2.jpeg) + +![](_page_5_Picture_1.jpeg) + +![](_page_6_Picture_1.jpeg) + +![](_page_7_Picture_1.jpeg) + +![](_page_8_Picture_1.jpeg) + +![](_page_9_Picture_1.jpeg) + +69. This action is timely under New York law because it falls within New York CPLR 214-g and is brought during the one-year time period set forth in that section. The claims brought herein allege intentional and negligent acts and/or omissions for physical, psychological, and other injury suffered as a result of conduct that would constitute sexual + +offenses as defined in Article 130 of the New York Penal Law, and such acts and/or omissions were committed against when she was less than eighteen years of age. + +70. Epstein's conduct constitutes "childhood sexual abuse" within the meaning of New Mexico Stat. § 37-1-30 and "abuse" within the meaning of Florida Stat. § 95.11(7). + +### FIRST CAUSE OF ACTION (Battery) + +71. Plaintiff hereby incorporates each of the foregoing paragraphs as if fully set forth herein. + +72. In committing the acts described above, Epstein intentionally subjected Plaintiff to bodily contact that was offensive in nature. + +73. Epstein intentionally touched Plaintiff in a rude, insolent, or angry manner. + +74. As a result of Epstein's actions, Plaintiff suffered damages in an amount to be determined at trial. + +### SECOND CAUSE OF ACTION (Assault) + +75. Plaintiff hereby incorporates each of the foregoing paragraphs as if fully set forth herein. + +76. In committing the acts described above, Epstein engaged in physical conduct that placed Plaintiff in imminent apprehension that he would harm her. + +77. As a result of Epstein's actions, Plaintiff suffered damages in an amount to be determined at trial. + +#### THIRD CAUSE OF ACTION (Intentional Infliction of Emotional Distress) + +78. Plaintiff hereby incorporates each of the foregoing paragraphs as if fully set forth herein. + +79. In committing the acts described above, Epstein engaged in extreme and outrageous conduct. + +80. In doing so, Epstein acted with the intent to cause and/or disregard of a substantial likelihood of causing Plaintiff to suffer severe emotional distress. + +81. As a direct result of Epstein's actions, Plaintiff suffered severe emotional distress. + +82. As a result of Epstein's actions, Plaintiff suffered damages in an amount to be determined at trial. + +WHEREFORE, Plaintiff respectfully requests that judgment be entered against Defendants as follows: + +- a. Awarding compensatory damages for all physical injuries, emotional distress, psychological harm, anxiety, humiliation, physical and emotional pain and suffering, family and social disruption, and other harm, in an amount to be determined at trial; +- b. Awarding punitive damages in an amount to be determined at trial; +- c. Awarding attorneys' fees and costs pursuant to any applicable statute or law; +- d. Awarding pit- and post-judgment interest on all such damages, fees and/or costs; +- e. Attaching all of Defendants' real property and other assets located in the State of New York pursuant to New York CPLR 6201 et seq. and Federal Rule of Civil Procedure 64; and +- 1. Awarding such other and further relief as this Court may deem just and proper. + +Dated: New York, New York +November 21, 2019 + +CUTI HECKER WANG LLP + +By: /s/ Mariann Meier Wang +Mariann Meier Wang +Daniel Mullkoff + +![](_page_12_Picture_52.jpeg) + +ALLRED, MAROKO & GOLDBERG +Gloria Allred + +3 +N +(2) +[REDACTED] + +*Attorneys for Plaintiff* \ No newline at end of file diff --git a/marker2/ds9/EFTA00084144/EFTA00084144.metadata.json b/marker2/ds9/EFTA00084144/EFTA00084144.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8ef67541602d99aa8dbcfa53018485520ea4afc0 --- /dev/null +++ b/marker2/ds9/EFTA00084144/EFTA00084144.metadata.json @@ -0,0 +1,706 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084144.pdf", + "engine": { + "marker_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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we'd received the go ahead. She and =will call the brothers and mother later this week to ask to schedule interviews. + +Ori inal Messa e + +From: ) Sent: Monday, December 30, 2019 10:28 PM To: Robert Glassman < Cc: aNIMIE>; 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. + +Original Message + +From: Robert Glassman Sent: Monda 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, c l=1.> wrote: > Robert, > Following up on our most recent meeting with you and .we wanted to confirm that it's alright for us to beg reaching this week to the contacts she identified for us -- in articular we would initially expect to contact, and and the and We also wan e 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 mak 9 nd 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, + +> Original Messa e + +> From: + +> Sent: Friday, December 13, 2019 17:06 + +> To: Robert Glassman + +> Cc: I=ME ) aIMIE>; + +Nathan Werksman + +> Subject: RE: SD 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 + +> From: Robert Glassman + +> Sent: Frida , December 13. 2o It) 16 : 14 + +> To: + +> Cc: aNIMIE>; + +Nathan Werksman + +> Subject: Re: 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, 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 aft 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 + +» thanks, + +>> Original Messa e + +» From: + +>> Sent: Wednesday, December 11, 2019 13:15 + +>> To: Robert Glassman + +>> Cc: + +; Nathan Werksman < + +>> Subject: RE: SDNY investigation + +■ + +**>> 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 of that would be, and to start to talk about specific conduct by Epstein and/or Maxwell to whatever extent is comfortable with that at this stage. And we'll also likely refresh on some other topics as well, but just to flag 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: Wednesday. December 11.2019 12:38** + +**» To:** + +**» Cc:** + +**; Nathan Werksman** + +**>> Subject: RE: SDNY investigation** + +**» Let's do 11 a.m. on Monday.** + +**» Robert Glassman, Esq.** + +**» Panish Shea & Bo le LLP** + +**» Tel:** + +**» Fax:** + +**» Ema** + +**» Web** + +**>> 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.** + +**Los Angeles, CA 90025** + +**>> 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, 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 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. + +>> Original Message + +>> From: Robert Glassman + +>> Sent: Tuesday. 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 time between discussion sessions. And as always, happy to discuss via phone if that's helpful. + +>» + +>» thanks, + +>» Alex. + +>» + +>» 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----- + +Glassman >»From: Robert + +>» Sent: Monda DecembeW + +>» To: + +>» Cc: ; Nathan Werksman + +>» Subject: Re: SDNY investigation + +>» + +>» Yes. Call me on my cell today. + +>» + +>» + +>» Robert S. Glassman + +>» Panish Shea & Boyle + +>» psblaw.com + +>» + +>» + +»»>OnDec9,2019,at9:21AM,I 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 >» + +»» 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, + +»»IM. + +>>» + +>>» Sent: Friday, November "2. . : + +»» To: + +»» Cc: ; Nathan Werksman eza; + +»» 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/EFTA00084157/EFTA00084157.metadata.json b/marker2/ds9/EFTA00084157/EFTA00084157.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..40cb27f8f564780fb1667d9f00326c0c6e03e62e --- /dev/null +++ b/marker2/ds9/EFTA00084157/EFTA00084157.metadata.json @@ -0,0 +1,204 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084157.pdf", + "engine": { + "marker_major": "2", + "marker_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": 8675, + "elapsed_seconds": 2.71, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 84 + ], + [ + "Line", + 38 + ], + [ + "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", + 84 + ], + [ + "Text", + 44 + ], + [ + "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", + 93 + ], + [ + "Line", + 46 + ], + [ + "Text", + 43 + ], + [ + "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 + ], + [ + "Text", + 44 + ], + [ + "Line", + 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": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 107 + ], + [ + "Line", + 54 + ], + [ + "Text", + 50 + ], + [ + "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", + 41 + ], + [ + "Line", + 20 + ], + [ + "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/EFTA00084157" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084163/EFTA00084163.md b/marker2/ds9/EFTA00084163/EFTA00084163.md new file mode 100644 index 0000000000000000000000000000000000000000..d928bd73f73afd5fb6c5bb217768b96109b84541 --- /dev/null +++ b/marker2/ds9/EFTA00084163/EFTA00084163.md @@ -0,0 +1,117 @@ +From: ' To: "I r + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Date: Sun, 05 Jan 2020 22:29:08 +0000 + +Ah, no. + +From: c > Sent: Sunday, January 05, 2020 11:22 To: is Subject: Fwd: Jeffrey Epstein-Related Touhy Requests >; + +I don't think I knew that victim's attorneys had been in touch with Geoff directly. Did you? + +Sent from my iPhone + +Begin forwarded message: + +From: ' Date: Janua To: " Cc: (USANYS)" < 5, 2020 at 10:05:36 AM EST SANYS " (USANYS)" Subject: RE: Jeffrey Epstein-Related Touhy Requests (USANYS)" + +Thanks, . This looks good to me. Some small suggestions in track. My only real substantive suggestion is that we not identify Geoff as the "Department official" but instead keep it a big vaguer. The reason I would prefer to do so is at least some of the victims counsel have already reached out to Geoff directly on other matters pertaining to this case, and I wouldn't want to put him in a position where David Boies or someone is calling him directly to lobby him on a Touhy request. That said, if there is a particular reason to identify him here, happy to discuss further. + +From: (USANYS) Sent: Saturday, January 4, 2020 10:37 AM To: (USANYS) .; Cc: )< >; (USANYS)< >; (USANYS) Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Thanks, all. The changes sound good to me. Please find attached an updated version incorporating edit and nit. + +I'll send this out on Monday unless folks have any further changes. please let me know if I should hold off until you've checked in with Robbie. + +Thanks, + +Sent: Saturday, January 4, 2020 8:31 AM + +To: + +Cc: (USANYS) < ) <->; + +(USANYS) (USANYS) + +Subject: Re: Jeffrey Epstein-Related Touhy Requests + +I defer to you two on tone. One nit—the letter switches between DOJ and Department. I think Department is the more formal. + +On Jan 3, 2020, at 8:49 PM, > wrote: + +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) < + +Sent: Friday, January 03, 2020 12:55 + +To: I < + +Cc: (USANYS) < scS; + +(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). + +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: + +(USANYS) + +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: 4 (USANYS) + +Subject: Jeffrey Epstein-Related Touhy Requests + +I spoke to about continuing to use as the POC to outsiders for Touh.rests 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 requests 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 victimwitnesses 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—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 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. Ct. 1944), *aff’d*, 63 N.Y.S.2d 833 (1st Dep’t 1946). + +<010420 Epstein Touhy Initial Letter to Kaplan.ebd.docx> \ No newline at end of file diff --git a/marker2/ds9/EFTA00084163/EFTA00084163.metadata.json b/marker2/ds9/EFTA00084163/EFTA00084163.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1784abedc3569bfe6e2bb51ea060fefc1213b121 --- /dev/null +++ b/marker2/ds9/EFTA00084163/EFTA00084163.metadata.json @@ -0,0 +1,166 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084163.pdf", + "engine": { + "marker_major": "2", + "marker_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": 11863, + "elapsed_seconds": 4.7, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 90 + ], + [ + "Line", + 41 + ], + [ + "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", + 38 + ], + [ + "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", + 70 + ], + [ + "Line", + 36 + ], + [ + "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", + 105 + ], + [ + "Line", + 52 + ], + [ + "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": "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00084163" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084168/EFTA00084168.md b/marker2/ds9/EFTA00084168/EFTA00084168.md new file mode 100644 index 0000000000000000000000000000000000000000..5457eaccbd6c68c2c1498d60821cab1e28479566 --- /dev/null +++ b/marker2/ds9/EFTA00084168/EFTA00084168.md @@ -0,0 +1,21 @@ +From: To: Cc: + +Subject: RE: inquiry from NY Post re Nxivm discovery + +Date: Wed, 31 Jul 2019 21:08:05 +0000 + +You should say you guys had TWO million documents. + +From: Sent: Wednesday, July 31, 2019 16:49 To: ;1 + +Subject: FW: inquiry from NY Post re Nxivm discovery + +Seriously? + +From: Sent: e nes ay, u y , : + +u•ject: inquiry rom . ost re lx vm . rY + +Today at Jeffrey Epstein's hearing in SDNY it was stated that there are one million documents to be turned over to the defense. Post reporter Emily Saul is asking whether there were one million or more or less documents in the Nxivm case for comparison purposes. + +Follow the U.S. Attorney's Office for the Eastern District of New York on Twitter: @EDNYnews. 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Although I will have access to email durin m absence, my responses may be dela ed. For ur ent matters, please contact the other AUSA(s) on the case, or AUSA or \ No newline at end of file diff --git a/marker2/ds9/EFTA00084169/EFTA00084169.metadata.json b/marker2/ds9/EFTA00084169/EFTA00084169.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..edd954e6c33ee08974b69f5f30dd14bf286576f7 --- /dev/null +++ b/marker2/ds9/EFTA00084169/EFTA00084169.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084169.pdf", + "engine": { + "marker_major": "2", + "marker_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": 360, + "elapsed_seconds": 0.33, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Line", + 7 + ], + [ + "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/EFTA00084169" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084170/EFTA00084170.md b/marker2/ds9/EFTA00084170/EFTA00084170.md new file mode 100644 index 0000000000000000000000000000000000000000..bdbcea0cd82574fd5745a871d306ee91fc426c54 --- /dev/null +++ b/marker2/ds9/EFTA00084170/EFTA00084170.md @@ -0,0 +1,170 @@ +**From:** "[REDACTED]" <[REDACTED]> +**To:** "[REDACTED]" <[REDACTED]>, "[REDACTED]" +<[REDACTED]> +**Subject:** Fwd: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to [REDACTED] [REDACTED] +**Date:** Sat, 03 Aug 2019 21:26:44 +0000 + +--- + +Ok with you guys? + +Sent from my iPhone + +Begin forwarded message: + +**From:** "Hudgens, Johanna Rae" <[REDACTED]> +**Date:** August 3, 2019 at 4:56:45 PM EDT +**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] + +Hi [REDACTED], + +Does 3:45 p.m. work for you all on Monday? If so, we can call you then, or circulate a dial-in number. + +Thanks, +Johanna + +-----Original Message----- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Friday, August 02, 2019 5:24 PM +**To:** Bloom, Suzanne Jaffe <[REDACTED]> +**Cc:** Hudgens, Johanna Rae <[REDACTED]>; [REDACTED] +<[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to [REDACTED] [REDACTED] + +Hi Suzanne, + +Thanks for coming in to meet with us. I think a call to discuss next steps makes sense-- is there a time that would work for you late Monday afternoon? + +Thanks, +[REDACTED] + +[REDACTED] +Assistant United States Attorney +Southern District of New York +One Saint Andrew's Plaza + +Original Message + +From: Bloom, Suzanne Jaffe + +Sent: Thursday. August 1.2019 7:20 PM + +To: + +Cc: Hudgens, Johanna Rae + +Subject: Re: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to + +Hi all. Thanks again for your time yesterday. Just checking in to see when you'd like to continue our conversation. Please let us know what would work best for you. + +Many thanks, + +Suzanne + +Suzanne Jaffe Bloom + +Partner + +Winston & Strawn LLP + +200 Park Avenue New York, NY 10166-4193 + +Bio I + +VCard I Email + +On Jul 30 2019, at 1:54 PM, + +mailto: > 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, + +Original Message + +From: Hudgens, Johanna Rae < + +Sent: Tuesda Jul 30 2019 13:22 + +To: 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 Cc: Hudgens, Johanna Rae + +Suzanne, + +Subject: RE: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to + +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, + +Original Message + +From: Sent: Tuesday, July 23, 2019 14:55 + +To: Bloom, Suzanne Jaffe Cc: Hud ens, Johanna Rae + +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 < + +Sent: Monda Jul 22, 2019 12:32 + +To: mailto: + +Cc: Hudgens, Johanna Rae + +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 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 + +200 Park Avenue New York, NY 10166-4193 + +Bio I 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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Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF + +**Date:** Fri, 24 Jul 2020 23:12:26 +0000 + +[REDACTED], + +Thanks very much, and this generally looks fine to me. Might it be possible to add the following before the "Please contact me" sentence: + +[REDACTED] +[REDACTED] + +[REDACTED] +[REDACTED] + +And the materials that [REDACTED] emailed at 3:06 this afternoon all look good to me, so everything should be ready to go once the letter is approved. If you wouldn't mind letting us know when you send everything out, that would be great. + +thanks again, + +[REDACTED]. + +--- + +**From:** [REDACTED], [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Friday, July 24, 2020 00:07 +**To:** [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF + +Thanks for adding [REDACTED] on this for the redactions, [REDACTED]. Please find attached the letter to go out with the docs. (Note that my supervisor is still looking at it.) Please let me know if you have any edits or concerns. I think last time we ran everything past [REDACTED] before it went out to the door. I planned to do that again, once the packet is ready to go. Thanks. + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Thursday, July 23, 2020 6:14 PM +**To:** [REDACTED] (USANYS) [Contractor] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED], [REDACTED] (USANYS) <[REDACTED]> +**Subject:** FW: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF + +[REDACTED] + +We have a redaction project we need help with, please – could you please take a look at the attachments included in the attached email? As described a couple emails below, they consist mostly of FedEx invoices, plus another few docs, that + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +If you could please send the redacted versions to us and to [REDACTED] (copied here), we'll do a final review for production and then be all set. + +thanks, + +[REDACTED] + +--- + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Thursday, July 23, 2020 00:50 +**To:** [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF + +Thanks, [REDACTED]. I should be able to turn a letter on this quickly. I think if it would be easy to have a paralegal do the redactions, that would be helpful and probably speed things up (it doesn't matter which side that happens on). Let me know if that would work, or I can also ask a paralegal on my side. + +Thanks, + +[REDACTED] + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Wednesday, July 22, 2020 9:38 PM +**To:** [REDACTED] (USANYS) <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF + +[REDACTED] + +This is obviously now very belated, but as previewed earlier today, I've completed a review of our materials for documents responsive to this *Touhy* request. Unfortunately, and as discussed, many of the documents we have that would be otherwise responsive were obtained pursuant to grand jury subpoenas we issued. Based on your discussion with [REDACTED] I am not conveying those materials to you for review. What we're left with are the following, which are attached: + +- - 4 documents relating to FedEx invoices, obtained from the FOIA office in connection with its review of the Florida investigation file (note that there are actually 12 such documents in all, but the remainder are duplicative; please let us know if we should produce all 12 anyway, otherwise I've just given you the 4); +- - 2 documents obtained through electronic search warrants; and +- - 1 document, a photo, obtained through a physical search of Epstein's residence. + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +Given the small volume, if we can get it out quickly that would be fantastic, and please let us know if it would be helpful to have a paralegal do the redactions (not sure if you have to do that on your side, or if we can assist). + +Please let us know if any questions at all, and thanks as always. + +[REDACTED] + +--- + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Monday, June 08, 2020 23:51 +**To:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; +[REDACTED] <[REDACTED]> +**Subject:** FW: Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF +**Importance:** High + +Hi all, + +Will you be able to gather the responsive documents for Glassman's request, as with the request from Kaplan? Except for Item 8, this request seems fairly contained—and they have expressly cabined their request to not seek documents that would interfere with ongoing proceedings. Please let me know if we need to discuss. Otherwise, I'll draft a letter once we have the docs gathered (happy to do redactions again if helpful). + +Thanks, + +[REDACTED] + +--- + +**From:** Robert Glassman <[REDACTED]> +**Sent:** Monday, June 8, 2020 3:08 PM +**To:** [REDACTED] (USANYS) <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; Nathan Werksman <[REDACTED]>; Keilah Betts <[REDACTED]> +**Subject:** Request for Tangible and Documentary Evidence (Touhy Request); Jane Doe v. Indyke et al., SDNY Case No. 1:20-cv-00484-JGK-DCF +**Importance:** High + +Dear Mr. [REDACTED] + +Please see the attached letter of today's date. A copy will also be sent via Fedex. Thank you. + +Robert Glassman + +***Robert Glassman, Esq.*** +***Panish Shea & Boyle LLP*** +11111 Santa Monica Boulevard, Suite 700 +Los Angeles, CA 90025 + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +Web: [www.psblaw.com](http://www.psblaw.com) + +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. \ No newline at end of file diff --git a/marker2/ds9/EFTA00084175/EFTA00084175.metadata.json b/marker2/ds9/EFTA00084175/EFTA00084175.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9508aaea3a36350eba492af0ce89afa029a0c424 --- /dev/null +++ b/marker2/ds9/EFTA00084175/EFTA00084175.metadata.json @@ -0,0 +1,176 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084175.pdf", + "engine": { + "marker_major": "2", + "marker_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": 6966, + "elapsed_seconds": 10.02, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "CONFIDENTIALITY NOTICE:", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 33.048, + 737.1 + ], + [ + 143.82, + 737.1 + ], + [ + 143.82, + 749.25 + ], + [ + 33.048, + 749.25 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 34 + ], + [ + "Text", + 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": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Text", + 34 + ], + [ + "Line", + 31 + ], + [ + "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": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Text", + 46 + ], + [ + "Line", + 34 + ], + [ + "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 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Line", + 7 + ], + [ + "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/EFTA00084175" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084179/EFTA00084179.md b/marker2/ds9/EFTA00084179/EFTA00084179.md new file mode 100644 index 0000000000000000000000000000000000000000..5c20bce2436bca0c7d73b62d4e7cb6490360b151 --- /dev/null +++ b/marker2/ds9/EFTA00084179/EFTA00084179.md @@ -0,0 +1,31 @@ +From: To: (USANYS)" <1 Cc: ' iANYI. Siln" + +Subject: RE: Maxwell VW Page + +Date: Thu, 16 Jul 2020 16:48:49 +0000 + +This looks great, thanksM and thanks especially for conforming it to what we posted in the Epstein case last year. I just made a few very small changes, and we should be good to go. Let's please post the following: + +## July 16, 2019 update: + +On July 14, 2019, an arraignment, initial conference, and bail hearing was held in the case of United States v. Ghislaine Maxwell, 20 Cr. 330 (MN). The defendant entered a plea of not guilty to the Superseding Indictment. The court announced its ruling that the defendant will be incarcerated pending trial. The Court scheduled discovery and motion deadlines for counsel as well as a trial date of July 12, 2021, before the Honorable Alison J. Nathan, United States District Judge for the Southern District of New York, Thurgood Marshall United States Courthouse, 4o Foley Square, New York, New York, in Courtroom 906. No next conference was scheduled at this appearance. + +Separately, currently on the home page we have a box for the Epstein case, that's a link to the updates and also information on where to call with information. Could we please change that to the Maxwell case? So exact same language, just change the case heading to the one for Maxwell, above, and switch "Jeffrey Epstein" to "Ghislaine Maxwell" — so that if people just go to our main website, they can easily see where the updates are. Thank you I I + +From: [USANYS) + +Sent: Wednesday, July 15, 2020 21:49 + +To: gc ) + +Cc: USANYS) [Contractor] + +Subject: Maxwell VW Page + +Should we be updating to the page to reflect yesterday's hearing and order? Let me know if this works: + +## July 14, 2019 update: + +On July 14, 2019, the initial conference, arraignment, and bail hearing were held in the case of United States v. Ghislaine Maxwell, 20 Cr. 330 (MN). The defendant entered a plea of not guilty to the Superseding Indictment. The court announced its ruling that the defendant will be incarcerated pending trial. The Court scheduled discovery and motion deadlines for counsel as well as trial date for July 12, 2021, before the Honorable Alison J. Nathan, United States District Judge for the Southern District of New York, Thurgood Marshall United States Courthouse, 4o Foley Square, New York, New York, in Courtroom 906. + +Sent from my iPad \ No newline at end of file diff --git a/marker2/ds9/EFTA00084179/EFTA00084179.metadata.json b/marker2/ds9/EFTA00084179/EFTA00084179.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6d1a71f21ccfdeb16d431655400c48a443205d0b --- /dev/null +++ b/marker2/ds9/EFTA00084179/EFTA00084179.metadata.json @@ -0,0 +1,105 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084179.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2363, + "elapsed_seconds": 0.84, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "July 16, 2019 update:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 217.07999999999998 + ], + [ + 150.53262329101562, + 217.07999999999998 + ], + [ + 150.53262329101562, + 232.0670166015625 + ], + [ + 30.6, + 232.0670166015625 + ] + ] + }, + { + "title": "July 14, 2019 update:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 555.6600000000001 + ], + [ + 150.96409606933594, + 555.6600000000001 + ], + [ + 150.96409606933594, + 570.9735412597656 + ], + [ + 30.6, + 570.9735412597656 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 86 + ], + [ + "Line", + 33 + ], + [ + "Text", + 15 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00084179" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084180/EFTA00084180.md b/marker2/ds9/EFTA00084180/EFTA00084180.md new file mode 100644 index 0000000000000000000000000000000000000000..a3c28761e3fd5ea5fa2f58754a961e9f22b99f2a --- /dev/null +++ b/marker2/ds9/EFTA00084180/EFTA00084180.md @@ -0,0 +1,167 @@ +To: + +Cc: + +Subject: Re: SDNY investigation, + +Date: Sat, 04 Jan 2020 22:26:23 +0000 + +Inline-Images: image1.png; image2.png + +Agreed about the Florida trip. + +I received• results today regarding the account we subpoenaed for Maxwell. It appears as though it is her account. Her email address is listed and was verified by Facebook. Unfortunately it's not horribly useful to us right now. The last login was in August which comes back to Vermont. The only other IP listed was the registration IP which was 2014, and comes back to New York City. + +See attached. + +![](_page_1_Picture_4.jpeg) + +![](_page_1_Picture_6.jpeg) + +## Instagrarn Business Record Page 1 + +Service Instagram Target 1322128817 Account ghislanemaxwell + +Identifier Account Type InstagramUser Generated 20200104 21:03:00 UTC Date Range 2019.08.08 00:00.00 UTC to 2019.12.11 23:59.59 UTC + +Nemec Reports NCMEC Cybertips: NCMEC cyberto reports associated to the account of the sender. + +Definition CyberTip ID. Unique Identifier associated with the cyberto. + +Time: Date and time the NCMEC cybertip was sent. + +Responsible Id. Identification number of the senders Facebook account associated with the NCMEC cyterbp report. + +NCMEC No responsive records located CyberTip Numbers + +Name flame. Name provided by the account ho/der. Definition foist first name provided by the account holder. Middle. Middle name provided by the account Pokier. Last- Last name provided by the account holder. + +Name First Ghistaine Maxwell + +(mails Registered Email Addresses: Displays a list of regstered email addresses. To 'register an address, it Definition regures confirmation by the account holder. + +Registered Email Addresses + +Vanity Vanity Usemame associated with the account. Definition + +Vanity Name ghislainemanyeti + +Registration Registration Date. Date and lime of account creation. Date Definition + +Registration 2014-05.10 17:10.23 UTC Date + +Registration 1p m address associated with account creation. Definition + +Registration Ip 69 203.141 229 + +## Instagram Business Record Page 2 + +![](_page_1_Picture_28.jpeg) + +![](_page_1_Picture_29.jpeg) + +![](_page_1_Picture_30.jpeg) + +![](_page_1_Picture_31.jpeg) + +![](_page_1_Picture_32.jpeg) + +were + +Registration 1p 1P address associated with accoJrg creation. Definition + +Registration Ip 69 203 141 229 + +Instagram Business Record Page 2 + +Account End + +Date Definition Account End Date: Displays the status of the account at the time the records were generated. + +Account Account Still true Closure Date Active + +Phone Phone numbers- Phone numberls1 provided by the account holder "Verified" indicates the account Numbers holder responded to a text sent to the listed phone number. Definition + +Phone No responsive records located Numbers + +Logins Logins: Information collected at the time the account was logged into. Definition m Address: P address associated to the logo\_ Time: Date and time of the login. Location: Location of the login. + +Logins IP Address 104.119 99.170 Time 2019-08.15 00.41:29 UTC + +> IP Address 104.219 99.170 Time 2019-08.14 11 31:18 UTC + +About I agree we'll want to meet with him again. also in Florida, so when we have records and are ready to meet with him, one idea would be to try to do both meetings on the same trip. + +Sent from my iPhone + +On Jan 4, 2020, at 12:15 PM, wrote: + +In our experience meeting her she seemed very eager to talk about her experiences. I think it's a combination of no one has ever really talked to her about it and she just wants to say what she has to say and put it behind her. In that regard it may be beneficial on both ends for us to have a face to face interview with her during one of our existing California trips. It will be a good sense of closure for her being she appears to have been very involved, and hopefully can give us some valuable info for the investigation moving forward. + +I'd also be fine if you guys wanted to shoot her lawyer some follow up questions but I think a sit down with her at some point could be productive. + +Also unrelated to her, a follow up interview to consider would be Not sure if we spoke about this at all but our initial interview with him as immediately after Epstein s arrest and we really didn't get much into his dealings with or Maxwell. What's your thoughts on that? That could obviously be a Skype if we don't have any upcoming plans for travel to Florida. + +On Jan 3, 2020, at 23:30, ci > wrote: + +following up on the discussions with attorney a couple weeks ago, we got this attorney proffer this evening. In addition to being remarkably thorough, it's pretty interesting; she was in the thick of things in the period that we primarily investigated and much of her account provides additional confirmation of what we already know, but there are also a few relevant additions. + +A couple things I thought looked especially relevant: + +I think we'd want to hear from her about Epstein telling her "that Maxwell was the 'original girl finder' (and on the legal side we'd want to figure out if we could get into evidence in any prosecution against Maxwell). It might be useful in connection with to see what made believe was likely a victim. Unfortunately I think we would want to see if she remembers the names of other girls Epstein induced her to have sexual contact with, particularly to the extent that corroborates the accounts of others (and even if it's not directly related to Maxwell). It's very interesting that she says Epstein asked her to be with multiple friends of his — I believe (?) this is the first person other than.who has had that account. She wasn't close to being underage, but I think we'd still very much want to know who those friends were, in case they were also being visited by underage victims, and/or whether that caused Epstein to have any influence over them, etc. + +Anybody else have initial thoughts? I think ideally we could interview her during an existing trip to California, and/or follow up with her attorney on some of these initial questions in the first instance. + +From: Jeffrey Pop •::M > + +Sent: Friday, January 03, 2020 18:35 + +Dear + +Attached, in letter format, please find a version of an Attorney Proffer regarding and her involvement with Epstein. At the end, I have also included an outline of current perception as to how he operated. + +The foregoing is a culmination of a series of interviews with my client and I believe that it represents her potential testimony. Obviously, I am not certain whether any of the information presented is new to you or helpful to your investigation. + +My take away is that there is no doubt that is a victim; she suffers to this day. At the same time there were other people looking to introduce girls to Epstein. This pattern apparently was ongoing for decades. + +introduction involvement was only in New York and not with minors. was shocked when she found out that Epstein was arrested in Florida. + +Should you feel that an interview is necessary, please propose a couple of dates before January 20, 2020 (I have an upcoming trial in late January). I will make my conference room available for the interview. + +Let me know if you have any questions. + +Sincerely, + +Jeff + +Jeffrey S. Pop, Esq. + +JEFFREY S. POP & ASSOCIATES + +Beverly Hills, California 90212-3429 + +fax + +www.poplawyer.com + +www.vaccineinjuryteam.com + + + +## CONFIDENTIALITY + +This e-mall is for the personal and exclusive use of the recipient(s) named above. It contains confidential information from Jeffrey S. Pop & Associates. Its contents are not only to remain absolutely confidential, but may also be subject to the attorney-client privilege or coverage under the work-product doctrine. If you have received this transmission and are not the intended reciplent(s) or his/her agent, please be advised that any disclosure, use, review, copying. selling, dissemination, publication, or distribution of this transmission is strictly unauthorized and prohibited. If you have received this transmission in error, please notify the sender at the number above, return the original e-mail by mail, and delete the e-mall file from your computer. Postage Is guaranteed. Your cooperation Is appreciated. Thank you. + +From: Pnaitto: + +Sent: Monday, December 23, 2019 9:34 PM + +Following up on our phone conversation today, I wanted to memorialize that, as discussed, we do not currently have reason to believe Ms. has criminal exposure based on what we are aware of in connection with her interactions with Jeffrey Epstein, and your brief attorney proffer regarding the circumstances of those interactions are consistent with that view. In your further discussions with Ms. in advance of a further attorney proffer to address the general nature of her relationship with Mr. Epstein, as well as his employees or relevant close associates, if you have any concerns about additional possible exposure you should please feel free to be in touch with us again. As we also discussed, I believe any non-federal offenses would be well outside the relevant statute(s) of limitation, but of course if you wish to further research that issue, or consult with criminal counsel, we defer to you entirely. + +Please let us know if any other information would be useful at this stage, and hopefully we can be in touch in the coming weeks about productive next steps. + +thank you, + +Assistant U.S. Attorney Southern District of New York + +a -Attorney Proffer 1-3-20.pdf> \ No newline at end of file diff --git a/marker2/ds9/EFTA00084180/EFTA00084180.metadata.json b/marker2/ds9/EFTA00084180/EFTA00084180.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6e4a4db88da1f4a1ba8761cb0de51b02f67da8ed --- /dev/null +++ b/marker2/ds9/EFTA00084180/EFTA00084180.metadata.json @@ -0,0 +1,306 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084180.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", 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a/marker2/ds9/EFTA00084186/EFTA00084186.md b/marker2/ds9/EFTA00084186/EFTA00084186.md new file mode 100644 index 0000000000000000000000000000000000000000..55c98be98d6a0baae87983906673790f32be0a97 --- /dev/null +++ b/marker2/ds9/EFTA00084186/EFTA00084186.md @@ -0,0 +1,43 @@ +To: ' + +Cc: + +Subject: FW: Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell + +Date: Mon, 06 Jan 2020 00:02:36 +0000 + +Inline-Images: —WRD000.jpg + +All, + +Wanted to make sure one of you had received a similar notification re the USAA subpoena for Maxwell. Apologies for the delay—I somehow missed this on my phone while I was out on vacation. + +Thanks, + +Assistant United States Attorney Southern District of New York l St. Andrew's Plaza New York, NY 10007 + +From: inquiry@claimfox.com + +Sent: Tuesday, December 24, 2019 9:42 AM + +To: + +Subject: Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell + +## 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. + +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/EFTA00084186/EFTA00084186.metadata.json b/marker2/ds9/EFTA00084186/EFTA00084186.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5b6091ac9b123805bfe30ad0a155ac3e7d08adff --- /dev/null +++ b/marker2/ds9/EFTA00084186/EFTA00084186.metadata.json @@ -0,0 +1,139 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084186.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1768, + "elapsed_seconds": 1.1, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Your Request is Being Prepared", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 45.288, + 628.5600000000001 + ], + [ + 337.39154052734375, + 628.5600000000001 + ], + [ + 337.39154052734375, + 650.5835266113281 + ], + [ + 45.288, + 650.5835266113281 + ] + ] + }, + { + "title": "Disclaimer", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 213.03000000000003 + ], + [ + 96.3386001586914, + 213.03000000000003 + ], + [ + 96.3386001586914, + 226.5841064453125 + ], + [ + 30.6, + 226.5841064453125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 50 + ], + [ + "Line", + 24 + ], + [ + "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": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Line", + 14 + ], + [ + "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/EFTA00084186" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084188/EFTA00084188.md b/marker2/ds9/EFTA00084188/EFTA00084188.md new file mode 100644 index 0000000000000000000000000000000000000000..b032b364693225a7409a8e75f0080b997bec30f2 --- /dev/null +++ b/marker2/ds9/EFTA00084188/EFTA00084188.md @@ -0,0 +1,77 @@ +From: ' )" To: ' fl air "- Cc: ' + +Subject: FW: SDNY investigation, + +Date: Sat, 04 Jan 2020 04:29:51 +0000 + +Attachments: Attorney\_Proffer 1-3-20.pdf + +Inline-Images: image001.jpg + +M— following up on the discussions with attorney a couple weeks ago, we got this attorney proffer this evening. In addition to being remarkably thorough, it's pretty interesting; she was in the thick of things in the period that we primarily investigated and much of her account provides additional confirmation of what we already know, but there are also a few relevant additions. + +A couple things I thought looked especially relevant: + +I think we'd want to hear from her about Epstein telling her "that Maxwell was the 'original girl finder" (and on the legal side we'd want to figure out if we could get into evidence in any prosecution against Maxwell). It might be useful in connection with to see what made believe \_was likely a victim. Unfortunately I think we would want to see if she remembers the names of other girls Epstein induced her to have sexual contact with, particularly to the extent that corroborates the accounts of others (and even if it's not directly related to Maxwell). It's very interesting that she says Epstein asked her to be with multiple friends of his — I believe (?) this is the first person other than • who has had that account. She wasn't close to being underage, but I think we'd still very much want to know who those friends were, in case they were also being visited by underage victims, and/or whether that caused Epstein to have any influence over them, etc. + +Anybody else have initial thoughts? I think ideally we could interview her during an existing trip to California, and/or follow up with her attorney on some of these initial questions in the first instance. + +From: Jeffrey Pop ‹ > Sent: Friday, January 03, 2020 18:35 To: Cc: Subject: RE: SDNY investigation, + +Dear + +Attached, in letter format, please find a version of an Attorney Proffer regarding involvement with Epstein. At the end, I have also included an outline of how he operated. and her current perception as to + +The foregoing is a culmination of a series of interviews with my client and I believe that it represents her potential testimony. Obviously, I am not certain whether any of the information presented is new to you or helpful to your investigation. + +My take away is that there is no doubt that is a victim; she suffers to this day. At the same time there were other people looking to introduce girls to Epstein. This pattern apparently was ongoing for decades. + +introduction involvement was only in New York and not with minors. was shocked when she found out that Epstein was arrested in Florida. + +Should you feel that an interview is necessary, please propose a couple of dates before January 20, 2020 (I have an upcoming trial in late January). I will make my conference room available for the interview. + +Let me know if you have any questions. + +Sincerely. + +Jeff + +Jeffrey S. Pop, Esq. + +JEFFREY S. POP & ASSOCIATES + +Beverly Hills, California 90212-3429 + +fax + +www.poplawyer.com + +www.vaccineinjuryteam.com + +JEFFREY S. POP & ASSOCIATES + +A LAW CORPORATION + +## CONFIDENTIALITY + +This e-mall Is for the personal and exclusive use of the recipient(s) named above. It contains confidential information from Jeffrey S. Pop & Associates. Its contents are not only to remain absolutely confidential, but may also be subject to the attorney-client privilege or coverage under the work-product doctrine. If you have received this transmission and are not the intended reciplent(s) or his/her agent, please be advised that any disclosure, use, review, coning, selling, dissemination, publication, or distribution of this transmission is strictly unauthorized and prohibited. If you have received this transmission in error, please notify the sender at the number above, return the original e-mall by mail, and delete the e-mall file from your computer. Postage is guaranteed. Your cooperation is appreciated. Thank you. + +From: ) + +Sent: Monday, December 23, 2019 9:34 PM + +To: Jeffrey Pop + +Cc: 5; + +Subject: RE: SDNY investigation, + +Jeff, + +Following up on our phone conversation today, I wanted to memorialize that, as discussed, we do not currently have reason to believe Ms. has criminal exposure based on what we are aware of in connection with her interactions with Jeffrey Epstein, and your brief attorney proffer regarding the circumstances of those interactions are consistent with that view. In your further discussions with Ms. in advance of a further attorney proffer to address the general nature of her relationship with Mr. Epstein, as well as his employees or relevant close associates, if you have any concerns about additional possible exposure you should please feel free to be in touch with us again. As we also discussed, I believe any non-federal offenses would be well outside the relevant statute(s) of limitation, but of course if you wish to further research that issue, or consult with criminal counsel, we defer to you entirely. + +Please let us know if any other information would be useful at this stage, and hopefully we can be in touch in the coming weeks about productive next steps. + +M + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00084188/EFTA00084188.metadata.json b/marker2/ds9/EFTA00084188/EFTA00084188.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e34241cb49b23da953c7ba12115e73e38803ba95 --- /dev/null +++ b/marker2/ds9/EFTA00084188/EFTA00084188.metadata.json @@ -0,0 +1,146 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084188.pdf", + "engine": { + "marker_major": "2", + "marker_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": 5258, + "elapsed_seconds": 1.19, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "CONFIDENTIALITY", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 422.82 + ], + [ + 116.22477722167969, + 422.82 + ], + [ + 116.22477722167969, + 436.5840759277344 + ], + [ + 31.212, + 436.5840759277344 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 89 + ], + [ + "Line", + 41 + ], + [ + "Text", + 14 + ], + [ + "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", + 38 + ], + [ + "Text", + 23 + ], + [ + "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", + 9 + ], + [ + "Text", + 5 + ], + [ + "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/EFTA00084188" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084191/EFTA00084191.md b/marker2/ds9/EFTA00084191/EFTA00084191.md new file mode 100644 index 0000000000000000000000000000000000000000..85f8063bf8d0edd3ee28cdb274a659ea10b4fca7 --- /dev/null +++ b/marker2/ds9/EFTA00084191/EFTA00084191.md @@ -0,0 +1,199 @@ +#### JEFFREY S. POP & ASSOCIATES A LAW CORPORATION + +BEVERLY HILLS. CALIFORNIA 90212-3429 + +ONC FAX + +January 3, 2020 + +Esq. Assistant U.S. Attorney Southern District of New York + +> Re: Attorney Proffer Epstein + +Dear + +Via Electronic Mail + +The following is my understanding of the facts and evidence that would bring forward regarding Jeffrey Epstein. Her most relevant introduction with Epstein occurred between April 19, 2004 to approximately April 2007. + +#### I. Backaround + +Si client, on , prefers to be called =. She was born in She was an only child. She moved to the United States in 1993. Her mom and dad were not proficient in English and took classes to learn. They worked during the day and took classes at night in order to better themselves in this country. went to school but was left isolated at home. Her parents did not have or spend the time necessary to understand her. Her education during the adolescent years from a social point of view was without guidance. She spent time studying but had little emotional support from her parents as she grew up in Brooklyn. had an interest in modeling but her parents stressed education. + +Suddenly, her father died from cancer before she turned seventeen. Her parents kept the fact that he had cancer from her so was very shocked at her father's passing. She didn't get a chance to say goodbye. Her first significant boyfriend was when she was 18 years old; He was older, age 30. They dated for almost 4 years. Thereafter, wanted to pursue modeling and went to casting. She learned that the cut offilor new models is usually 23. Her modeling agency found her a job as a hostess. then learned to be a cocktail waitress. In March 2004, she moved from Brooklyn to Manhattan due to the strained relationship with her mother and because she felt she'd have better modeling opportunities in Manhattan. She was trying to make ends meet in April 2004. Her significant contact with Epstein began on April 19, 2004 and ended in February 2007. + +#### II. Approach — Re: Massage + +was working three jobs, six days a week but worried about making her rent and paying bills. A girl, approximately5 years old, named M, worked a promotional Theafter, re and saw each other at a party. As they chatted, said she was struggling financially where upon mentioned that she knew asho paid her \$300.00 to give him a massage. and talked about the details. understood that this prospective man was well connected, good looking and had models around him. Further, at times, he would help people that he liked with job opportunities or education. Notwithstanding, the had a sexual fetish and would masturbate himself at the end of the topless massage. agreed to meet the guy. + +M had told that she had met at a club and that was the contact. At the time, knew last name. was attempting to be in the hair iiiii business and lived in Harlem. said she was from Paris and was also a model. said she was 28 ears old Attorneywsti ations indicate . contact information email is met at a Starbucks. looked at and criticized her teeth as being too yellow but said that she was very pretty and she would do well with this guy who sometimes had women travel with him to the Caribbean. He potentially would lam clothes and help pay for school. confirmed what had said to the evening before. The next day it was arranged and went to the address that she was given. + +#### III. Introduction to Epstein + +On April 19, 2004, went to the man's residence. It was a large building. was let into a waiting room. She waited for approximately 25 minutes when a man came and smiled and said "I'm Jeffrey." + +After introductionshe said "Give me 5 minutes L nn will show you upstairs." In a short time, Lynn came and IIMI rode in an elevator. was in awe that the residence was so large that he needed an elevator. The elevator opened and u was lead into a massage room. In the room, there was a massage table and it was semi-dar p There were pictures on the wall, a table with lotions, a telephone and pen and paper. The ceiling of the room was concave and painted as clear blue skies. The massage went as expected in the beginning. Epstein laid face down and instructed to massage his back and legs, then proceeded to make phone calls. Then he turned over and started talking to He thanked her for comin , gave her compliments on her looks and asked her about erse f. He instructed she thought Epstein would take her underwear off. Epstein sensed her tens,/ said: to massage his chest, then he touched her stomach and underwear. cringed, "Relax. I want you to have fun. If you're uncomfortable with something I am doin , you have to be straight with me and tell me, it's not a big deal." He respected wishes. The massage ended. Jeffrey masturbated and made a loud noise when he ejacu ate . Afterwards he said, "I'll give you some money and I'd like to see you again, could you write + +your number down. My office will be in touch with you." wrote her number on a pad which was personalized with the Epstein name. The first session ended. + +. Du the same week, roughly two days later, the office called and made an appointment for to meet him again. By the second encounter, knew Epstein had grown up in Brooklyn and was a self-made billionaire. She was astonished by what he had accomplished..1 went and saw Jeffrey for a second time. During this second massage, Jeffrey asked a number of questions about herself, about her background about her schooling, where she was raised, what her career aspirations were, whether she wanted to become a model or not, and showed genuine interest in who she was. asked him some questions. + +After the massage, Jeffery gave a personal tour of three or four floors of his mansion. Each room was very unique and was decorated lavishly. was extremely impressed by the extravagant decor that she saw from room to room. There were many pictures which she later understood were of famous or important people as well as beautiful She left home that day feeling that she had a connection and chemistry with Jeffery. believed that Jeffrey was very charming and felt lucky to have met him. + +# IV. Important Long Term Friends, Employees, Close Associates and Girlfriends + +## Jeffrey's Long Term Fiends + +### 1. Jean Luc Brunel + +He was a friend of Jeffrey before met him. believes that he had been friends with Epstein approximately for more than 10 years. Jean Luc lived at Street. At this address, Epstein owned several apartments that he would either give or ease out to staff, friends, girlfriends, and traveling girls. + +believes that Jean Luc was an owner or part owner of Karin Modeling. Jean Luc also had an interest eling agencies and had an interest or ran Karin Modeling agency in Miami. Later on, became aware that Jean Luc may have had an interest in a modeling agency in Israel. • Modeling agency changed its name to MC2 in approximately 2006. From observations, Jean Luc was one of Epstein's closest friends. + +. In late 2006; heard (but doesn't know firsthand) that the FBI went to . Street where some Brazilian models that Jean Luc brought, had been staying. e were ' d when Confronted by law enforcement. In general, most people that lived at ' tein's apartments, were held in higher esteem. Generally, those t at stayed in Street were staff, his girlfriends or girls that traveled with him regularly, or girls that visited Epstein from out of town or out of country. + +#### 2. Ghislaine Maxwell. + +met Maxwell about the 4th time that she met Epstein. was with Epstein when he suggested that they go to meet some friends at the Spice Market restaurant. When they got there, there was a scientist and Maxwell. sat while they all had dessert. + +The next time met Maxwell was at the island after Jeffrey asked her to come on a trip with him. saw Maxwell at Jeffrey's office, the house or at a charity event. + +From view point, Maxwell was intimidating. She instructed to take down her telephone number and to call her if she ever needed anything. did not have a warm feeling aboutMell and never called. She attempted to stay away from Maxwell as much as possible. recalls between mid-2004 and 2006. She saw Maxwell approximately 4-5 times at the island. Maxwell was in New Mexico the one time went there in the summer of 2005. + +sail seemed to make fun of some of the girls at the island and put them down. It was understanding that Maxwell helped coordinate the su plies of dresses, swimsuits, and skin care oroducts at the island. Epstein told that Maxwell was the "original girl finder". tried to stay away from Maxwell as much as possible because she felt that she was a domineering, aggressive female that placed fear into younger women. + +## 3. Eva Dubin + +an ex-girlfriend of Epstein. was Jeffrey Epstein's' MIS . Jeffrey cared a lot for Eva and He had a large photograph of him and Eva once came to the Caribbean island with her children and spouse. accompanied Epstein to Eva Dubin's home when he was saying goodbye to people before he went to jail. + +#### 4. Faith Kates + +iie was a friend of Epstein since t 's. She owned Next Model Management. understood that she introduced to Jeffrey sometime in 2005. believes that she might be significant because she heard Epstein ask her to introduce him to girls + +## Epstein Employees + +## 1. Lesley Groff (Executive Secretary) + +She called to schedule appointments with Epstein and called to connect with leifrey to talk. lithe time, she was the one who made travel arrangements or . Epstein told that he kept things professional at the office and showed respect to his employees; + +believed that Lesley Groff was Jeffrey's right hand at the office. She was in charge of his call list. Groff was polite, neutral and positive with her words. She also had a cheerful attitude and was easy to talk to. Epstein told that =vas invaluable to him, in part, because she would observe him and anticipate his needs without having to check with him. + +s desk was in an office that was adjacent to Epstein's with an openings in-between. could actually see Epstein when he was at his desk if she turned and looked in that direction but she could not see otal office because in the adjoining or connecting office. At the time met n 2004, would estimate that was in her early forties. + +## 2. (Personal Assistant) + +She was approximately age, maybe a little older. Her duties including handling details regarding travel with Epstein, packing bags, making travel arrangement s for some girls, shopping restocking, making sure things get fixed at the residences. observed following Epstimund with a notebook and she would write down what she wanted done. The times that traveled with Epstein, would be there slightly less than 50% of the time. + +found iet, friendly and reserved. heard that was from She didn't want to follow in the radition so she left her family. She moved to Hawaii where she lived with a boyfriend. Then broke up with her boyfriend and had nowhere to go. That's when she received a call from a girl ilslaw with to work as Epstein's assistant. believes the girl's name was and that was Epstein's former assistant. Apparently, came right away to take the job with Epstein. believes that was years o when she was hired by.Jeffrey. + +never heard or witnesseaoolla girls or approachin an one. She did make phone calls at Jeffrey Epstein's request. believes that might be a victim of Epstein. + +## 3. (Office Assistant) + +ar2004 to 20 , she was an office assistant to Epstein. Her senior was Lesley Groff. elieves that .vas from Sweden originally, and heard that she was introduced to Epstein by Eva Dubin. After finished graduate school, she left approximately in early 2006. She had plans to move to Dubai. + +## 4. + +She w imately a 21 year old model from when she met E stein. heard that met Epstein at an art event in New or . pstein had trave wi him nth or two as a potential girlfriend. Several months later ecame aware that was a second assistant to Jeffrey. Epstein was obsessed wit body and made a comment that just looking at her figure put him in a good moo . Approximately a few months later, left Epstein's employment and Epstein told that had gotten married in Miami and moved. + +#### Jeffrey's Girlfriends + +1. + +tier was introduced and g know Jeffrey Epstein, she became aware that was Jeffrey Epstein's irlfriend. = was 19 at the time when met her. From knowledge, m t effrey Epstein through Jean Luc Brumel who was a close friend of Jeffrey Epstein's. remained Jeffre 's girlfriend through approximately 2007 and possibly longer. She lived at + +2. + +Jeffrey's second girlfriend. At the time she was 21 and was a professional model. met her in approximately 2005. ve ed with Epstein until 2006 when she was in a vehicle accident. After the accident, is not certain whether ■ **remained Jeffrey's girlfriend.** + +## **V. J.E. and M's Relationship** + +**As discussed in detail, her relationship with Epstein began on April 19, 2004 was that she was interested in Epstein as a person. She believed that he had a strange fetish. From talking to him, she believed that he had a difficult childhood and experienced daily stress from talking to many people a day and making business decisions where a lot was at stake. Early on, Epstein showed interest in as to her background, career, and in her future.** + +**Within weeks, Epstein started asking if she had friends to introduce him to. As time when on, the request to introduce friends became a pressure to find girls. was reluctant but Jeffrey explained it was no big deal.** + +**was told that she could do very well with Jeffrey Epstein if she helped him and followed his rules as far as being truthful. During this time she was aware that Jeffrey had helped people with schooling, their career or with medical situations if he liked them.** + +**Jeffrey also had certain rules and was direct about them. He told that he demanded honesty and did not want people around him that lied to him at all. He also said that he did not want people who drank a lot, had any type of criminal background, used drugs or were involved in prostitution or were stripping.** + +**Shortly after meeting Epstein, stopped working her three jobs and did promotional modeling as well as cl otions. With this schedule, was available for Epstein upon his request. After tr with Epstein for several months, he sent her to his ha' He would also instruct on what clothe were to his liking. He explained to that his mentor taught him how to dress. Epstein would take a few of the** girls that were with him to go shopping. He pointed out what he thought was in good taste and looked good as compared to combinations that he didn't think looked good. learned how to dress from his comments. + +Over the years, got to understand Epstein in some ways and not at all in others. She was impressed with his accomplishments and the way he handled people. She attended dinner parties at his house with other youn irls about her age and business associates of Epstein. These parties were interesting and could see how much respect people had for Jeffrey Epstein. To knowledge, there were no sexual encounters at these parties. Social, business acquaintances and Epstein's friends were present at these parties. + +also was invited to teas at Epstein's house with Epstein's friends, business acquaintances, and beautiful women. In these settbaSe matters were purely social and not related to anything sexual. Epstein would call to his office and she would spend time with him, Olin a sexual manner and potentially for a part of the day. There were times he'd call to the office for her company and then leave in a car to run errands. + +Basically, he helped with her living expenses but wanted her available to be with him and accompany him on trips upon request. Epstein, in fact, helped with dental work that she needed. + +During the first three months, there were discussions about and her aspirations regarding whether she wanted to be a model. She replied that she thought she was too old to be a working model. During this time there were also discussions whether she would be interested in working or running a modeling agency. + +This conversation came up a few times, but Epstein said that he wanted to help and was interested in buying an agency. + +During discussion about the modeling agency, Il iein said that he was interested in buying a modeling agency and that he thought that could run it.. mentioned that she had no experience and he said that if she wor e or an agency or a year, she could pick i ause she's smart and there's not that much to it. At the time that he said this in 2004, had known, through Google and her search that Epstein had been interested in buying an agency and she thought she was lucky that he t would and do this because it would give her a good career opportunity. thought that she was lucky and in the right place at the right time. + +By late summer 2004, was aware that there were other individuals who were helping Epstein find new girls for him to see. She did not know exactly who they were but there were days believed knew that Epstein saw girls for a massage three times a day when in New York. This number, if true, was far in excess of the number of girls that , indirectly or directly, introduced to Epstein. + +During there the times that they traveled to the island with two or three other girls and sometimes including , iris assistant. The Little St. James, would be activities on the island were somewhat structured whit t ed. The people that came with him would have breakfast, lunch and dinner together. There were times they had group activities which would include snorkeling, being in the pool, or going to St. Thomas to do shopping or visiting his office there. The group of them would even go out for ice cream after business. The also biked, hiked, and snorkeled. These group activities were generally something that welcomed and enjoyed. There were times when Epstein list had around just to check how she was doing. Sometimes at the island, was called to see Epstein for a bubble bath on more than one occasion which turned out to be nonsexual. Epstein would inquire how was doing and ask if she was having fun. On many occasions, Epstein asked to only give him a foot massage when they were on the island. + +When the modeling a enc didn't work out and wn e ressure was coming from Epstein regarding finding girls, became frustrated. recalled in 2005 that she asked Epstein on two occasions, about three months apart, about whether she could be his second assistant. She thought there was going to be an opening in that position. Epstein replied, "Not now, but let's talk about it later." At the end of this period, believed that he was stringing her along. She disliked the pressure that Epstein was putting on her to find girls. + +In August 2006, Jeffrey Epstein told he had been arrested and the FBI was involved. He told her she should not bring any girls or look for any girls for him at that time. was scared because she didn't understand what happened. Epstein cut the conversation short and didn't want to talk about it. + +For the next 2-3 weeks, access to Epstein was limited as he was traveling and unavailable. As far as Florida was concerned, all the information that got was from Google alerts and whatever newspaper articles they picked up and forwarded to her. She never discussed this with people in the Epstein's circle of influence. + +Starting in May or June of 2004, Epstein used sexual toys such as vibrators on . was not experienced with these before. Later the type of vibrators changed; faked orgasms Eventually, told Epstein that the vibrator hurt her. + +By early 2005, Epstein suggested threesomes. Before this happened, he told that kissing and being with women would help her learn how to please a man. The threesomes occurred 3-4 times in New York, New Mexico, or on the Island. Sometimes Epstein's girlfriends were involved. + +In late 2005, Epstein asked to see male friend on his behalf. The first time Epstein said it would be good for you to meet this guy. + +Thereafter, Epstein directed to go to a hotel room and give a se or be with his friend. This happened about every three months for different friends. was upset and very hurt about being told to be with his friends. + +#### VI. Employment —Introductions + +- 1. 2006, was placed b in an intern fo in New York. At the time, wor 1-,Jrs an intern at that agency until February 2007. +- 2. In February 2007 ' her to work a In 2007, continued until ay . t was in the news and people at Epstein. took an English course to improve her writing skills. By March 2008, Natalie w , take and pass the Series 7 exam. By May 2008, she voluntarily left ue to personal reasons. was a well-recognize agency. and said he had an o rtuni of a lifetime started at and job for because pstein's name knew that she got the job because of + +#### VII. Jeffrey's Incarceration + +During the time that Jeffrey was incarcerated, occasionally sent emails to see how he was doing. Some emails were answered and some were not. These were personal in matter. At this time, life was difficult on many levels, most of which were due to the trauma and relationship she had had with Epstein. + +Post Epstein's incarceration, spoke to E stein in New York in November 2010 by telephone. During that conversation Epstein asked to look for girls, but declined, and the conversation ended. At that point, decided that she had to leave New York. left in early 2011. + +and that she had been named in a lawsuit filed by In February 2017, received an email from E stein stal that was being sued should bn attorney and that,it would be best it'they did not communicate. As it turned out, was never served in the case entitled Doe 43 v. Epstein et al. + +## VIII. Hindsight + +realized that she missed the warning signs regarding Epstein's character and motives. The following summarizes her hindsight beliefs: + +- I. Looking back, the surroundings and the way Epstein conducted business made it possible for him to manipulate people and brainwash them. +- 2. Thee around Epstein who were involved in sexual encounters such as and and others, had nowhere else to go. They had no family, and were young, easily trapped and manipulated. + +- 3. All these girls were unable to separate the aura of success, the private jet, the island, the many houses, and the various influential people who looked up to Epstein from the truth of what was going on and how he was pulling strings and working at sorting through young woman for his own benefit. +- 4. now believes that Epstein was picking through the numerous girls who he could control for his own gratification and to eventually either provide service for Epstein's friends of his or who he could introduce to important people for marriage. Either way, all were, for Epstein's benefit and to increase his influence. +- 5. is still troubled and haunted by Epstein and what ha ened to girls who may have been vulnerable and hurt. It is now over 15 years and continues to suffer psychologically and emotionally from Epstein's control and domination. + +The following 16 points is perception of how Epstein manipulated women (girls) for his purpose: + +- 1. Show interest in the girl personally— make her feel special; +- 2. Gain trust sexually, have fun, feel comfortable, just say something bothers you no big deal, makes you feel comfortable; +- 3. Impress with accomplishments, wealth , power interaction with important people and show mansion; +- 4. Surround young girls by happy people, fun loving , powerful , beautiful and successful people to create an aura of privilege and normalcy; +- 5. Ask friends- massage; +- 6. Promise a path to success modeling agency, you can do well with me; +- 7. Increase financial support and dependency; +- 8. Massage find willing girls no older than 23; +- 9. Control life by making "Epsetin only consideration"-must be available; +- 10. Dominate sexually; +- 11. Increase pressure for more introductions; +- 12. Introduce sexual devices (vibrators); + +- 13. Introduce threesome —group sex with Epstein; +- 14. Direct— strongly suggest sexual encounters with his "friends"; +- 15. Order sexual encounters with "friends" for Epstein's benefit; and +- 16. Discard girls after use when old (age 27) become unstable or unwilling to bear fruit (more introductions). + +Accept my apologies for the length of this document; however, it provides an outline of the environment my client experienced years ago. + +Sincerely, + +Jeffrey S. 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newline at end of file diff --git a/marker2/ds9/EFTA00084202/EFTA00084202.md b/marker2/ds9/EFTA00084202/EFTA00084202.md new file mode 100644 index 0000000000000000000000000000000000000000..e8ac4abae9b85160631d863c4683ee339258de62 --- /dev/null +++ b/marker2/ds9/EFTA00084202/EFTA00084202.md @@ -0,0 +1,233 @@ +From: `z IMIE> To: Robert Glassman < Cc: , Nathan Werksman Subject: RE: SDNY investigation Date: Mon, 30 Dec 2019 21:09:37 +0000 I II + +Robert, + +Following up on our most recent meeting with you and we wanted to confirm that it's alright for us to begin reachin out this week to the contacts she identified for us -- in articular, we would initially expect to contact , and and then Howie Simon, Dr. Cabe, and John Larkin. 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 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, + +Ori inal Messa e + +From: Sent: Friday, December 13, 2019 17:06 To: Robert Glassman < > Cc: ; aNIMME>; Nathan Werksman Subject: RE: investiga + +Totally understand, just wanted to ask. We'll see you Monday at 11:00. And thanks for that additional info as well. + +M. + +Original Message + +From: Robert Glassman Sent: Frida , December 13 2019 16:14 To: Cc: aNIMME>; Nathan Werksman Ce-Subject: Re: SDNY investigation + +M, 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, 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. + +> thanks, + +Original Messa e + +> From: + +> Sent: Wednesday, December 11, 2019 13:15 + +> To: Robert Glassman + +> Cc: ; aNIMME>; + +Nathan Werksman Subject: RE: SDNY investigation + +> 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 of that would be, and to start to talk about specific conduct by Epstein and/or Maxwell to whatever extent is comfortable with that at this stage. And we'll also likely refresh on some other topics as well, but just to flag 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 December + +> To: + +> Cc: • a; + +Nathan Werksman + +> Subject: RE: SDNY investigation + +> Let's do 11 a.m. on Monday. + +> Tel: > Fax: > Ema > 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 II, 2019 8:26 AM + +> To: Robert Glassman + +> Cc: + +> Subject: RE: SDNY investigation + +> 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: ; aNIMME>; 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 + +» 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 time between discussion sessions. And as always, happy to discuss via phone if that's helpful. + +» 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 + +Monda Decembe;Mi n >> Ser + +» From: Robert Glassman + +» To: + +» Cc: ; Nathan Werksman < 1>; + +>> 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: + +>>> 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 ..z > + +>>> 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/EFTA00084202/EFTA00084202.metadata.json b/marker2/ds9/EFTA00084202/EFTA00084202.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..72460200b7e322ba503b1a5738aad6ca1decf5ad --- /dev/null +++ b/marker2/ds9/EFTA00084202/EFTA00084202.metadata.json @@ -0,0 +1,174 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084202.pdf", + "engine": { + "marker_major": "2", + "marker_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": 7362, + "elapsed_seconds": 2.28, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "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": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 40 + ], + [ + "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 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 39 + ], + [ + "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": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 92 + ], + [ + "Text", + 45 + ], + [ + "Line", + 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": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 33 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00084202" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084207/EFTA00084207.md b/marker2/ds9/EFTA00084207/EFTA00084207.md new file mode 100644 index 0000000000000000000000000000000000000000..dd75825023b49abf04d3c92ae2b149024ed92657 --- /dev/null +++ b/marker2/ds9/EFTA00084207/EFTA00084207.md @@ -0,0 +1,87 @@ +To: + +Cc:I + +Subject: RE: Update on your requested records from.USAA - Criminal Banking - Ghislaine Maxwell + +Date: Mon, 06 Jan 2020 15:12:50 +0000 + +Inline-Images: image001.jpg + +Got it, thanks. + +From: + +Sent: Monday, January 06, 2020 10:11 + +To: > + +Cc: + +Subject: RE: Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell + +dropped it off found sent him an email letting him know it was there. + +On Jan 6, 2020 10:09 AM, wrote: Just so we can keep track of the records, who was the SDNY copy given to (or where was it left)? Nobody has put it in our share drive here so not sure who it went to — thanks. + +From: + +Sent: Monday, January 06, 2020 09:59 + +To: + +Cc: + +Subject: RE: Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell + +Thanks, we received the records. A copy was dropped off to SDNY last week. + +From + +Sent: Sunday, January 05, 2020 7:03 PM + +To: + +Cc: + +Subject: FW: Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell + +All, + +Wanted to make sure one of you had received a similar notification re the USAA subpoena for Maxwell. Apologies for the delay—I somehow missed this on my phone while I was out on vacation. + +Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 + +From: inquiry\_@claimfox.com + +Sent: Tuesday, December 24, 2019 9:42 AM + +To: + +Subject: Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell + +## 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. 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A copy was dropped off to SDNY last week. + +From: Sent: Sunday, January 05, 2020 7:03 PM To: Cc: Subject: FW: Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell + +All, + +Wanted to make sure one of you had received a similar notification re the USAA subpoena for Maxwell. Apologies for the delay—I somehow missed this on my phone while I was out on vacation. + +Thanks, + +Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 + +## 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. 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I have a bunch of records from that have been in the paralegal folder. I will organize and send to you this week. + +From: + +Sent: Monday, January 6, 2020 10:14 AM + +To: + +Subject: FW Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell + +Hey see below, just wanted to make sure you actually got this — no rush (and definitely not as high a priority as getting the rest of the Dupont discovery set!) but please let us know when it's saved on the share? + +thanks, + +From: + +Sent: Monday, January 06, 2020 10:11 + +To: + +C + +Subject: RE: Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell + +dropped it off fa and sent him an email letting him know it was there. + +On Jan 6, 2020 10:09 AM, > wrote: Just so we can keep track of the records, who was the SDNY copy given to (or where was it left)? Nobody has put it in our share drive here so not sure who it went to — thanks. + +From: + +Sent: Monday, January 06, 2020 09:59 + +To: + +Cc: + +Subject: RE: Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell + +Thanks, we received the records. A copy was dropped off to SONY last week. + +From: [mailto + +Sent: Sunday, January 05, 2020 7:03 PM + +All, + +Wanted to make sure one of you had received a similar notification re the USAA subpoena for Maxwell. Apologies for the delay—I somehow missed this on my phone while I was out on vacation. + +Thanks, + +Assistant United States Attorney Southern District of New York St. Andrew's Plaza New York, NY 10007 + +From: inquiry\_@claimfox.com + +Sent: Tuesday, December 24, 2019 9:42 AM + +To: + +Subject: Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell + +## 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 #: + +## 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/EFTA00084211/EFTA00084211.metadata.json b/marker2/ds9/EFTA00084211/EFTA00084211.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..45471efe1eb6296c3ca97e8cb5ca3e00dfa13c31 --- /dev/null +++ b/marker2/ds9/EFTA00084211/EFTA00084211.metadata.json @@ -0,0 +1,173 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084211.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2922, + "elapsed_seconds": 1.57, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Your Request is Being Prepared", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 45.9, + 498.96 + ], + [ + 337.3843994140625, + 498.96 + ], + [ + 337.3843994140625, + 521.7000122070312 + ], + [ + 45.9, + 521.7000122070312 + ] + ] + }, + { + "title": "Disclaimer", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 31.212, + 100.44 + ], + [ + 95.165283203125, + 100.44 + ], + [ + 95.165283203125, + 113.61590576171875 + ], + [ + 31.212, + 113.61590576171875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 33 + ], + [ + "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", + 51 + ], + [ + "Line", + 25 + ], + [ + "Text", + 18 + ], + [ + "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", + 17 + ], + [ + "Line", + 9 + ], + [ + "PageHeader", + 2 + ], + [ + "Text", + 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/EFTA00084211" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084214/EFTA00084214.md b/marker2/ds9/EFTA00084214/EFTA00084214.md new file mode 100644 index 0000000000000000000000000000000000000000..056da510c5eeaed1ed991a681729a676e3caab69 --- /dev/null +++ b/marker2/ds9/EFTA00084214/EFTA00084214.md @@ -0,0 +1,87 @@ +From: To:' + +Subject: FW: Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell + +Date: Mon, 06 Jan 2020 15:13:41 +0000 + +Inline-Images: image00 1 jpg + +Hey see below, just wanted to make sure you actually got this — no rush (and definitely not as high a priority as getting the rest of the Dupont discovery set!) but please let us know when it's saved on the share? + +thanks, + +From: + +Sent: Monday, January 06, 2020 10:11 + +To: + +Cc: + +Subject: RE: Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell + +dropped it off for and sent him an email letting him know it was there. + +On Jan 6, 2020 10:09 AM, wrote: Just so we can keep track of the records, who was the SDNY copy given to (or where was it left)? Nobody has put it in our share drive here so not sure who it went to — thanks. + +From: + +Sent: Monday, January 06, 2020 09:59 + +To: c l> + +Cc ) + +Subject: RE: Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell + +Thanks, we received the records. A copy was dropped off to SDNY last week. + +From• + +Sent: Sunday, January 05, 2020 7:03 PM + +To: + +Cc: 4 ; + +Subject: FW: Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell + +All, + +Wanted to make sure one of you had received a similar notification re the USAA subpoena for Maxwell. Apologies for the delay—I somehow missed this on my phone while I was out on vacation. + +Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 + +From: + +Sent: Tuesday, December 24, 2019 9:42 AM + +To: + +Subject: Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell + +## 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. 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Thanks— + +Subject: Re: flight records + +Great, + +Also I called both of brothers today. I spoke with who stated he is willing to speak with us mostly anytime. He has a musician and has a mostly free schedule unless he is touring. Recent dates that do not work for him are between January 28 and February 14. Other than that he is free. + +![](_page_1_Picture_60.jpeg) + +![](_page_1_Picture_61.jpeg) + +**Subject:** RE: flight records + +Looks like the flight to Interlochen in the summer of '94 is on there: + +August 18th, flight from ASE (Aspen, Colorado) to TVC (Grand Traverse County, Michigan). Passengers are Epstein, [REDACTED] TVC airport is a 23 minute drive to Interlochen. + +August 20th, flight from TVC to PBI (Palm Beach). Passengers are Epstein, Maxwell, and [REDACTED]. + +-----Original Message----- + +![](_page_1_Picture_67.jpeg) + +**Subject:** Re: flight records + +Thank you. + +> On Jan 6, 2020, at 10:28, [REDACTED] wrote: + +> [REDACTED] — + +> Counsel for [REDACTED] sent us the attached flight records (for 1991-2006) this morning. I haven't had a chance to review them yet, but wanted to pass along right away. + +> [REDACTED] +> [REDACTED] +> [REDACTED] +> [REDACTED] +> [REDACTED] +> [REDACTED] +> [REDACTED] +> [REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00084217/EFTA00084217.metadata.json b/marker2/ds9/EFTA00084217/EFTA00084217.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cf606e76158c053c98fc7424932531df7d952efe --- /dev/null +++ b/marker2/ds9/EFTA00084217/EFTA00084217.metadata.json @@ -0,0 +1,124 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084217.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1646, + "elapsed_seconds": 88.49, + "image_assets": [ + "_page_1_Picture_60.jpeg", + "_page_1_Picture_61.jpeg", + "_page_1_Picture_67.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Child Exploitation Human Trafficking Task Force", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 42.92999999999999 + ], + [ + 299.88, + 42.92999999999999 + ], + [ + 299.88, + 55.89000000000001 + ], + [ + 31.212, + 55.89000000000001 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 19 + ], + [ + "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": "surya", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Text", + 22 + ], + [ + "Line", + 14 + ], + [ + "Picture", + 6 + ], + [ + "SectionHeader", + 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 + } + } + ], + "debug_data_path": "debug_data/EFTA00084217" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084217/_page_1_Picture_60.jpeg b/marker2/ds9/EFTA00084217/_page_1_Picture_60.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..d4bd9d381b802bece8ac5e49bbc52a55c879ee76 --- /dev/null +++ b/marker2/ds9/EFTA00084217/_page_1_Picture_60.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:4be8dcd05f6f1d20878b903c88f3e37d97938827d22c9799323476708d40a36d +size 2564 diff --git a/marker2/ds9/EFTA00084217/_page_1_Picture_61.jpeg b/marker2/ds9/EFTA00084217/_page_1_Picture_61.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..ec6507b9290edb64d954a158e136cf0670415f4c --- /dev/null +++ b/marker2/ds9/EFTA00084217/_page_1_Picture_61.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:07b17afed640f69286317a3942412cfda8a48784a29a5b8fd1f77837531cce69 +size 7909 diff --git a/marker2/ds9/EFTA00084217/_page_1_Picture_67.jpeg b/marker2/ds9/EFTA00084217/_page_1_Picture_67.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..2e7496d9e0788c1b05ec9ded7cb285f638ef1ca9 --- /dev/null +++ b/marker2/ds9/EFTA00084217/_page_1_Picture_67.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:4f90c55d3206c0cd31f756a1199dad8b48e976b72c86a86213ccb93b529eddb5 +size 5492 diff --git a/marker2/ds9/EFTA00084219/EFTA00084219.md b/marker2/ds9/EFTA00084219/EFTA00084219.md new file mode 100644 index 0000000000000000000000000000000000000000..e4c1c5d81995e0282c84ba53ff17b983750764ac --- /dev/null +++ b/marker2/ds9/EFTA00084219/EFTA00084219.md @@ -0,0 +1,51 @@ +To: + +Subject: Fwd: Epstein + +Date: Thu, 09 Jan 2020 20:39:19 +0000 + +I don't want to be rude, but I also would prefer not to send the memo. Thoughts? + +Sent from my iPhone + +Begin forwarded message: + +From: + +Date: Jana 9.2020 at 3:05:27 PM EST + +To: + +Cc: + +Subject: RE: Epstein + +Thanks,. Completely understand that it's hard to condense the investigation into a paragraph. Could you please send us the memo? We're happy to pull out what will be relevant for him. Thanks. (Sorry, adding who I forgot to add on before.) + +From: + +Sent: Thursda Janua 9, 2020 3:01 PM + +To: + +Subject: RE: Epstein + +in + +We actually just met with\_and the brass today about an 86 page memo we submitted canvassing the full scope of the investigation and the other topics you mentioned, so I think that will cover everything, and no problem from us if you want to note in your memo that you understand we've recently briefed him on this. I would otherwise just send you a blurb, but as I'm sure you can understand this case is sort of impossible to briefly summarize in a blurb. + +Hope that's okay— + +From: + +Sent: Thursday, January 9, 2020 2:53 PM + +To: + +Subject: Epstein + +Could you please send us a blurb on Epstein that includes: number of victims interviewed, charges, any foreign victims, resolution, status of the investigation now? has asked us for a memo and we'd like to include this case to highlight your great work. + +Thanks, + +Assistant United States Attorney Southern District of New York One St. Andrew's Plaza New York, New York 10007 Phone: Email: \ No newline at end of file diff --git a/marker2/ds9/EFTA00084219/EFTA00084219.metadata.json b/marker2/ds9/EFTA00084219/EFTA00084219.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8a50907a5c46cd4a3022d6df55add5b8362ab530 --- /dev/null +++ b/marker2/ds9/EFTA00084219/EFTA00084219.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084219.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1523, + "elapsed_seconds": 1.16, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 32 + ], + [ + "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 + ], + [ + "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/EFTA00084219" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084221/EFTA00084221.md b/marker2/ds9/EFTA00084221/EFTA00084221.md new file mode 100644 index 0000000000000000000000000000000000000000..9ae07a92feb732ccc216d6da73656501f428b86f --- /dev/null +++ b/marker2/ds9/EFTA00084221/EFTA00084221.md @@ -0,0 +1,21 @@ +From: • )" + +To: + +Cc: ' " >, " + +Subject: follow-up request + +Date: Fri, 10 Jan 2020 20:29:31 +0000 + +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 St. Andrew's Plaza New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00084221/EFTA00084221.metadata.json b/marker2/ds9/EFTA00084221/EFTA00084221.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..00a570a28b9773b16a01898fb8ef8d9e0d029402 --- /dev/null +++ b/marker2/ds9/EFTA00084221/EFTA00084221.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084221.pdf", + "engine": { + "marker_major": "2", + "marker_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": 964, + "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", + 21 + ], + [ + "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/EFTA00084221" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084222/EFTA00084222.md b/marker2/ds9/EFTA00084222/EFTA00084222.md new file mode 100644 index 0000000000000000000000000000000000000000..74d22169dd6713cc188279d9a0e064b0d2177ec5 --- /dev/null +++ b/marker2/ds9/EFTA00084222/EFTA00084222.md @@ -0,0 +1,63 @@ +From: ' To: a' r231)" Cc: 1 + +Subject: FW: Information from Norway - Epstein-case (EJ 376/19) + +Date: Thu, 09 Jan 2020 21:11:40 +0000 + +Attachments: 2019\_12\_17\_at\_15h08m22s\_JobID\_28242.pdf + +Inline-Images: image002.png + +Consistent with passing along all tips that come to us directly, please see the email below (and attachment here) that I received earlier today. I have responded to confirm receipt. + +thanks, + +Fro (CRM) + +Sent: Thursday, January 09, 2020 05:51 + +To: + +Subject: FW: Information from Norway - Epstein-case (EJ 376/19) + +I am our DOJ Liaison Prosecutor stationed in The Hague at Eurojust (and an AUSA from Baltimore on detail to OIA). I received the information below, and attached, from our Norwegian partners here. I'm not sure what value add it has, but I am following through on my promise to pass it on. + +Let me know if you have any questions at all, or if I can be of further assistance here. + +Thanks, + +U.S. Department of Justice Office of International Affairs Counsel U.S. Liaison Prosecutor, Eurojust The Hague, Netherlands + +Mobile: + +Email: + +(CRM) Cc: Liaison Prosecutor Norway >; —LP United States Subject: Information from Norway - Epstein-case (EJ 376/19) + +Dear + +The Norwegian Director of Public Prosecution has on behalf of the Norwegian Ministry of Foreign Affairs sent me information that might be of interest in the case against Mr. Epstein, and requested me to forward the information to USA. + +The letter concerns International Peace Institute in New York and donations from Jeffrey Epstein. + +I would highly appreciate your kind assistance to forward the information to the competent authorities in USA conducting the ongoing investigation. The information in the letter is provided by a woman to an employee in the Norwegian Ministry of Foreign Affairs. Her identity will upon request be given to your HA. + +Please let me know if I can be of any further assistance. + +Kind regards + +Liaison Prosecutor for Norway + +![](_page_1_Picture_8.jpeg) + +EUROJUST + +EURO UST - Criminal justice across borders + +The Ha ue, Netherlands + +Mobile: + +Eurojust supports national authorities in the efficient coordination of investigations and prosecutions of serious and organised cross•border crime. + +This message is confidential and may be legally privileged or otherwise protected from disclosure. If you are not the intended recipient, please telephone or e-mail the sender and delete this message and any attachment from your system. You must not copy or disclose the contents of this message or any attachment to any other person. \ No newline at end of file diff --git a/marker2/ds9/EFTA00084222/EFTA00084222.metadata.json b/marker2/ds9/EFTA00084222/EFTA00084222.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e4754ea0fd07fcb82a0e0275359095cb79320b89 --- /dev/null +++ b/marker2/ds9/EFTA00084222/EFTA00084222.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084222.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2543, + "elapsed_seconds": 1.08, + "image_assets": [ + "_page_1_Picture_8.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Line", + 28 + ], + [ + "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", + 47 + ], + [ + "Line", + 24 + ], + [ + "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/EFTA00084222" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084222/_page_1_Picture_8.jpeg b/marker2/ds9/EFTA00084222/_page_1_Picture_8.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a49c83c87612f7d46813e9b63e4949b0e484aa12 --- /dev/null +++ b/marker2/ds9/EFTA00084222/_page_1_Picture_8.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:6fbb41c68dc6b437adf39e9b84b10f5ab27d99c3d031f5108486aab6e593feef +size 1902 diff --git a/marker2/ds9/EFTA00084224/EFTA00084224.md b/marker2/ds9/EFTA00084224/EFTA00084224.md new file mode 100644 index 0000000000000000000000000000000000000000..1c1e39ac652d432c1f54c34169396afdfb995b60 --- /dev/null +++ b/marker2/ds9/EFTA00084224/EFTA00084224.md @@ -0,0 +1,29 @@ +Memo. + +## International Peace Institute in New York and donations from Jeffrey Epstein + +- 1. The International Peace Institute (IPI) is an independent, international, not-for-profit think tank dedicated to managing risk and building resilience to promote peace, security, and sustainable development. (See www.ipinst.org ) +- 2. TPI was founded in 1970 as the International Peace Academy (IPA), which focused on training military officers and diplomats for United Nations peacekeeping opearations. Its offices are next to the United Nations headquarters in New York, with regional offices in Vienna and Manama (Bahrain). Its President, since 2005, is Mr. Terje Rod-Larsen, a Norwegian national. Mr. Kevin Rudd, former Prime Minister of Australia, is the chair of the IPI Board of Directors, with Mr. Antonio Guterres, Secretary-General of the United Nations, as Honorary Chair. +- 3. IPI's funding comes from a diverse donor base, which appears to include go'vernments and private individuals and foundations. +- 4. The deceased Jeffrey Epstein appears to have had at least two charitable foundations from which he distributed funds: + +## a. The reffreys\_Enstein VI Foundation, Virgin Islands (founded in 2000) + +According to press releases from this foundation, and from www.ieffrnvepsteininternational.com dating from April 16, 2013, this foundation established a fellowship fund at the International Peace Institute to honor deceased Middle East diplomat Richard Hooper. Amounts are not specified. + +IPI's own web-page refers to this fellowship being launched October 19, 2011. Details of funding is not provided on IPI's web-page. + +The press release from the Jeffrey Epstein VI Foundation referred to above also indicate that this foundation supported the IPI's launch of its regional office in Bahrain in 2013. No specification of concrete funding is provided. + +## b. Gratitude America LTD, St. Thomas, Virgin Islands (founded in 2012) + +According to The Daily Beast (19 August 2019) one of this foundation's biggest donations include a \$ 375.000 donation to the International Peace Institute. The Daily Beast refers to a review of the tax returns of Gratitude America LTD as a source for this information. + +- 5. One of the employees of the Norwegian ' ' t f Foreign Affairs has been informed by a national currently living in we know her identity), that at the time she was working at the International Peace Institute (Nov. 2014 — Apr. 2016) she was asked on more than one occasion, to attend to very short-term trainees from Eastern Europe. These trainees were all young, beautiful females, and without the education required to + +work at the think tank. They had a brief stint at IPI, during which they also visited the UN building to have pictures taken by them there. These pictures where sent to Mr. Epstein. + +- 6. She thought that this was strange, but did not connect it with Mr. Epstein's other activities at that time. +- 7. We have not contacted the individual or IPI to verify the above. + +Oslo, 18 November 2019 \ No newline at end of file diff --git a/marker2/ds9/EFTA00084224/EFTA00084224.metadata.json b/marker2/ds9/EFTA00084224/EFTA00084224.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a11e48e3ee793ebd82b1dd1ef790ad85af0f8431 --- /dev/null +++ b/marker2/ds9/EFTA00084224/EFTA00084224.metadata.json @@ -0,0 +1,174 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084224.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3022, + "elapsed_seconds": 0.7, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "International Peace Institute in New York and donations from Jeffrey Epstein", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 72.237, + 125.852 + ], + [ + 466.36578369140625, + 125.852 + ], + [ + 466.36578369140625, + 142.85302734375 + ], + [ + 72.237, + 142.85302734375 + ] + ] + }, + { + "title": "a. 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Law School professor Lawrence Lessig launched what he called a "clickbait defamation" action against The New York Times on Monday in Massachusetts federal court, claiming an article in the newspaper falsely implied he defended the notion of taking charitable donations from Jeffrey Epstein. + +Read full article » \ No newline at end of file diff --git a/marker2/ds9/EFTA00084226/EFTA00084226.metadata.json b/marker2/ds9/EFTA00084226/EFTA00084226.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a0e4d62474bde788fbdedfd2f544c5c7d816c44c --- /dev/null +++ b/marker2/ds9/EFTA00084226/EFTA00084226.metadata.json @@ -0,0 +1,183 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084226.pdf", + "engine": { + "marker_major": "2", + "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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Draft for you to review if you want. Will wait to file until your interview is over. + +[REDACTED] + +Co-Chief, Narcotics Unit +United States Attorney's Office +Southern District of New York +One Saint Andrew's Plaza +New York, New York 10007 + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00084230/EFTA00084230.metadata.json b/marker2/ds9/EFTA00084230/EFTA00084230.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..632d1a8718aaa7e1cfec7eee45f26914dc3da2f3 --- /dev/null +++ b/marker2/ds9/EFTA00084230/EFTA00084230.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084230.pdf", + "engine": { + "marker_major": "2", + "marker_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": 430, + "elapsed_seconds": 2.35, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Text", + 17 + ], + [ + "Line", + 12 + ], + [ + "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/EFTA00084230" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084231/EFTA00084231.md b/marker2/ds9/EFTA00084231/EFTA00084231.md new file mode 100644 index 0000000000000000000000000000000000000000..cbc3e1e1e72d64ccc80b9ef9f3d4766efcdb4fbe --- /dev/null +++ b/marker2/ds9/EFTA00084231/EFTA00084231.md @@ -0,0 +1,61 @@ +To: Wetjets + +Cc: + +Subject: RE: + +Date: Tue, 21 Jul 2020 20:37:53 +0000 + +All sounds good, thanks, and we'll be in touch about a next interview date in the next couple weeks. + +thanks again, + +From: Wetjets < > + +Sent: Tuesday, July 21, 2020 15:36 + +To: + +Cc + + + +Subject: Re: + +My calendar and is quite flexible, so I am sure we could arrange a time. + +I will need to check with Jack Scarola, as the time gets closer to see what would work for him. + +Also will go over with any identifying marks etc, and provide you with that info. + +Thanks + +In a message dated 7/21/2020 1:21:17 PM Eastern Standard Time, writes: + +Mike, + +Thanks very much. To the extent we are able, we certainly will tell if we ultimately identify any photos of her, but we can reiterate that we are not aware of having found any such photos as of yet. To assist in our continuing review, are there any particular identifying characteristics by which we might be able to identify her from that time period? I ask in part because it looks like she ma n one of the photos you sent, though I can't tell for certain. + +Separately, we think it would be helpful to do a follow up interview with some time in the coming weeks — our discussion with her was very helpful, and we'd like to speak with her again if that's possible. Would some time in the second or third week of August possibly work? No immediate rush, but wanted to start thinking about getting something on the calendar. + +From: Wetjets < + +Sent: Monda Jul 20 2020 22:08 + +To: + +Cc: + +Subject: + +Pleasure talking with you on Friday. + +As had mentioned, she very much wants to get a copy of the pictures that had taken. + +If you find them, please forward a copy to us so we can give to her. This is something she has been asking me to get for years, but I could never find. + +To assistyou with identifying , as she is now over a decade older, I am enclosing two pictures of from that were closer to the time the Epstein pictures were taken. I had + +You are authorized to provide the pictures I am sending you to and + +Thanks for your help. \ No newline at end of file diff --git a/marker2/ds9/EFTA00084231/EFTA00084231.metadata.json b/marker2/ds9/EFTA00084231/EFTA00084231.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..177b4e0f3acdf206c52db81d379be2e606240784 --- /dev/null +++ b/marker2/ds9/EFTA00084231/EFTA00084231.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084231.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2044, + "elapsed_seconds": 1.24, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "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", + 31 + ], + [ + "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/EFTA00084231" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084233/EFTA00084233.md b/marker2/ds9/EFTA00084233/EFTA00084233.md new file mode 100644 index 0000000000000000000000000000000000000000..56207c017452749a707989df09babeeb84202336 --- /dev/null +++ b/marker2/ds9/EFTA00084233/EFTA00084233.md @@ -0,0 +1,93 @@ +From: "I To: , < H , ii (NY) (FBI)" Cc: " y..,: + +Subject: RE: Maxwell Discovery + +Date: Wed, 22 Jul 2020 00:05:29 +0000 + +let's check in about this tomorrow — I think I'm scheduled to get that thumb drive back from our IT folks here tomorrow, but want to chat with them in the morning. If I haven't gotten back to you by early afternoon, please feel free to remind me. + +From: + +Sent: Tuesday, July 21, 2020 19:54 + +To: >; (NY) (FBI) <= =' + +Cc: >;I <-> + +Subject: Re: Maxwell Discovery + +Actually the photo files are quite large and would have to be broken up into multiple discs. if you are done with the thumb drive I recently dropped off to you would you be able to return that to me? I should be able to fit everything on there. + +Detective + +NYPD / FBI + +Child Exploitation Human Trafficking Task Force + +Office: + +Cell: + +Fax: + +From: + +Sent: Tuesday, July 21, 2020 5:39 PM + +To: (NY) (FBI) + +Cc: >; + +Subject: Re: Maxwell Discovery + +Hey guys, + +I apologize as today is my first day back in the office after my vacation. As for next week my schedule is mostly wide open but I cannot speak fa As far as I know we do not have anything out of the ordinary scheduled outside of the office. Lets try to aim for an afternoon phone call on Monday or Tuesday if possible. + +I will get working on those discovery requests in the meantime. Some of those files are going to be quite large and likely need to be burned to a DVD or thumb drive. Is anyone in the office this week that I could drop that off to once its completed? + +Office: + +Cell: + +Fax: + +From: + +Sent: Tuesday, July 21, 2020 4:20 PM + +To:-. (NY) (FBI) < :,; c= > + +Cc: + +Subject: RE: Maxwell Discovery + +Hi, + +Following up on this, would you guys please let us know when would work for a call next week? And would you be able to send any of the preliminary discovery I listed below, please? + +Thanks, + +From: + +Sent: Thursday, July 16, 2020 3:41 PM + +To: . (NY) (FBI) + +Cc: ) < > + +Subject: Maxwell Discovery + +Would you two be available for a call the week of July 27th to discuss discovery for Maxwell, please? and I will need to make sure we have the entirety of any FBI or NYPD file related to the Epstein investigation, so that we can review those files for any disclosures that need to be made to Maxwell. We'd like to discuss when you're both in the office. + +In the meantime, would you be able to provide us with the below materials so we can prepare some initial discovery productions to Maxwell, please? My hope is that the below materials should be fairly straightforward to gather and provide to us, but please let me know if any of these items would take more than a couple weeks to send to us. + +- All 302s from all FBI searches, including all searches of Epstein's NY residence, and all searches of Epstein's USVI residence +- All photographs from all FBI searches, including all searches of Epstein's NY residence, and all searches of Epstein's USVI residence +- All search warrant returns +- All CART paperwork regarding the extraction of data from all devices seized during the investigation +- All 302s and photographs from Maxwell's arrest +- All phone records gathered regarding Maxwell, including subscriber information and any other information obtained through administrative subpoena, toll records, pen data, historical cell site records, GPS data, and triggerfish data +- All 302s regarding the extraction of data from any seized devices and the review of images (both digital and hard copy) seized during the investigation, including from Epstein's properties. Belatedly, we will need to provide a list or other form of inventory to defense counsel informing them how many images were seized and where they can be reviewed (we can discuss this further on our call). + +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/EFTA00084233/EFTA00084233.metadata.json b/marker2/ds9/EFTA00084233/EFTA00084233.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..dc8c0f5a988dac8385c8ad16ed8edbce1bf4b5cf --- /dev/null +++ b/marker2/ds9/EFTA00084233/EFTA00084233.metadata.json @@ -0,0 +1,173 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084233.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3812, + "elapsed_seconds": 1.26, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "NYPD/FBI", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 28.35 + ], + [ + 96.18495178222656, + 28.35 + ], + [ + 96.18495178222656, + 41.3341064453125 + ], + [ + 31.212, + 41.3341064453125 + ] + ] + }, + { + "title": "Child Exploitation Human Trafficking Task Force", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 42.92999999999999 + ], + [ + 302.5367431640625, + 42.92999999999999 + ], + [ + 302.5367431640625, + 55.5841064453125 + ], + [ + 31.212, + 55.5841064453125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 99 + ], + [ + "Line", + 43 + ], + [ + "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", + 93 + ], + [ + "Line", + 44 + ], + [ + "Text", + 19 + ], + [ + "ListItem", + 7 + ], + [ + "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": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 11 + ], + [ + "Text", + 7 + ], + [ + "Line", + 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/EFTA00084233" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084236/EFTA00084236.md b/marker2/ds9/EFTA00084236/EFTA00084236.md new file mode 100644 index 0000000000000000000000000000000000000000..7d1bef04265cfc358ba0c6ab7554791881f716d7 --- /dev/null +++ b/marker2/ds9/EFTA00084236/EFTA00084236.md @@ -0,0 +1,286 @@ +From: ' To: ' )" C + +Subject: RE: Meeting with Date: Wed, 22 Jul 2020 22:40:20 -4)000 + +Inline-Images: image001.jpg + +![](_page_0_Picture_3.jpeg) + +From: Sent: Wednesday, July 22, 2020 18:37 To: Subject: RE: Meeting with + +Sorry guys, today turned into a complete technological nightmare, so I just had to save the Word doc locally and do my best to look stuff up on my phone. Hopefully it's passable. I'm around this evening it it'd be useful to chat. + +From: j < Sent: Wednesday, July 22, 2020 6:08 PM To: Subject: RE: Meeting with + +Of course, let's plan to touch base at 1:45. + +From: Sent: Wednesday, July 22, 2020 18:07 To: Subject: RE: Meeting with + +On this call in particular — promise it'll be quick. Perhaps we could talk just a few minutes before the call? + +From: I < Sent: Wednesday, July 22, 2020 5:50 PM To: Subject: RE: Meeting with + +From: + +Sent: Wednesday, July 22, 2020 17:32 + +To: + +Subject: FW: Meeting with + +Can we talk for like 5 minutes at some point before this call tomorrow? + +From: McGorty, Glen + +Sent: Wednesday, July 22, 2020 5:30 PM + +To: + +Cc: + +> + +Subject: RE: Meeting with + +Yes, that works. We will send a calendar invite with a dial-in. + +Thanks, Glen + +Glen G. McGorty I Crowell & Moring LLP + +Mane in Partner. New York Office + +www.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 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: Wednesday, July 22, 2020 4:51 PM + +To: McGorty, Glen + +Cc: + +Subject: RE: Meeting with + +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. + +thanks, + +From: McGorty, Glen + +Sent: Wednesday, July 22, 2020 09:53 + +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 + +www.crowoll.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@crcwell.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: C + +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,Mhas 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 hone, and IMmay have introduced one or more individuals to at a bar or other location in the Virgin Is + +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. + +thanks, + +Subject: RE: Meeting with + +— + +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. recognizes the individual in the photo. + +Best, Glen + +Glen G. McGorty I Crowell & Moring LLP + +Mane 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 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: Monday, June 22, 2020 12:49 PM + +To: McGort Glen < + +Cc: + +> + +Subject: RE: Meeting with + +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, + +From: McGorty, Glen + +Sent: Saturday, June 20, 2020 17:28 + +To: + +Cc: + +Subject: RE: Meeting with + +>; + +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.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: Friday, June 19, 2020 3:07 PM + +To: McGorty, Glen < + +Cc: >; >; + +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. + +[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]> +**Subject:** Meeting with [REDACTED] + +Ms. [REDACTED]: + +Have you firmed up the date/s you will be down here? + +**L.D. 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Can you please let me know if there is a specific legal barrier to me naming any of the alleged victims given that (a) they are no longer minors and (b) that at least two of them [REDACTED] (b) have waived anonymity in the past to speak out as survivors of Epstein's abuse? + +Best +[REDACTED] + +[REDACTED] + +[REDACTED] + +London SE1 9GF + +[REDACTED] + +[REDACTED] + +On Fri, 24 Jul 2020 at 18:58, [REDACTED] > wrote: +Hello. Your email was forwarded to me by [REDACTED]. Please note that prosecutors in this office are not available for media inquiries. You can forward any further inquiries to the press office. + +We cannot comment or provide any guidance on your questions. + +Best, + +[REDACTED] +Spokesman +United States Department of Justice + +Sent from my iPhone + +-- +"Please consider the environment before printing this e-mail" + +[REDACTED] + +[REDACTED] + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00084242/EFTA00084242.metadata.json b/marker2/ds9/EFTA00084242/EFTA00084242.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c6a5304d0d298b707bebe6af219065b5200f74ec --- /dev/null +++ b/marker2/ds9/EFTA00084242/EFTA00084242.metadata.json @@ -0,0 +1,88 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084242.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1253, + "elapsed_seconds": 45.33, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 52 + ], + [ + "Text", + 43 + ], + [ + "Line", + 24 + ], + [ + "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", + 14 + ], + [ + "Span", + 7 + ], + [ + "Line", + 4 + ], + [ + "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/EFTA00084242" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084244/EFTA00084244.md b/marker2/ds9/EFTA00084244/EFTA00084244.md new file mode 100644 index 0000000000000000000000000000000000000000..c547e3d1a25fb7e692626c00bac548c3e1585851 --- /dev/null +++ b/marker2/ds9/EFTA00084244/EFTA00084244.md @@ -0,0 +1,359 @@ +**From:** "McGorty, Glen" <[REDACTED]> +**To:** "[REDACTED]" <[REDACTED]> +**Cc:** "[REDACTED]" <[REDACTED]>, "[REDACTED]" <[REDACTED]> +<[REDACTED]>, "Giffuni, Danielle" <[REDACTED]> +**Subject:** Re: Meeting with [REDACTED] +**Date:** Fri, 24 Jul 2020 18:25:37 +0000 + +--- + +Got it. We will get back to you ASAP. + +--- + +Glen G. McGorty | Crowell & Moring LLP +Managing Partner, New York Office + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[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) by reply e-mail, and delete this e-mail. Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited. + +On Jul 24, 2020, at 2:14 PM, [REDACTED] <[REDACTED]> wrote: + +External Email + +Glen, + +One very brief follow-up from our conversation yesterday – the most recent phone numbers we have for Mr. [REDACTED] are [REDACTED], but those may be old. If he currently has different numbers, could you please let us know what they are? And I imagine this goes without saying, but we’re not asking in order to contact him, but rather just for our records. + +thanks, +[REDACTED]. + +**From:** McGorty, Glen <[REDACTED]> +**Sent:** Wednesday, July 22, 2020 17:30 +**To:** [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>, [REDACTED] <[REDACTED]>, [REDACTED] <[REDACTED]>, Giffuni, Danielle <[REDACTED]> +**Subject:** RE: Meeting with [REDACTED] + +Glen G. McGorty | Crowell & Moring LLP +Managing Partner, New York Office + +[Redacted text block] + +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: [Redacted] +<[Redacted]> +Sent: Wednesday, July 22, 2020 4:51 PM +To: McGorty, Glen <[Redacted]> +Cc: [Redacted] <[Redacted]>; [Redacted] +[Redacted] <[Redacted]>; Giffuni, Danielle +<[Redacted]> +Subject: RE: Meeting with [Redacted] + +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. + +From: McGorty, Glen <[REDACTED]> +Sent: Wednesday, July 22, 2020 09:53 +To: [REDACTED] <[REDACTED]>; [REDACTED] +Cc: [REDACTED] <[REDACTED]>; Giffuni, Danielle +<[REDACTED]>; [REDACTED] +<[REDACTED]> +Subject: RE: Meeting with [REDACTED] + +[REDACTED], + +Sorry for the delay. We've spoken to [REDACTED]. Let us know when might be a good time for a call over the next couple days. + +Best, +Glen + +Glen G. McGorty | Crowell & Moring LLP +Managing Partner, New York Office + +[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] + +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: [REDACTED] + +<[REDACTED]> + +Sent: Thursday, July 16, 2020 2:32 PM + +To: McGorty, Glen <[REDACTED]> + +Cc: Zelenko, Daniel <[REDACTED]>>; [REDACTED] + +<[REDACTED]>; [REDACTED] + +<[REDACTED]>; Giffuni, Danielle + +<[REDACTED]> + +Subject: RE: Meeting with [REDACTED] + +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. + +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. + +thanks, + +[REDACTED]. + +From: McGorty, Glen <[REDACTED]> + +Sent: Monday, June 22, 2020 14:27 + +To: [REDACTED] <[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 + +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. + +fdd77108c0d835d5&q=1&e=8d8322d4-2603-49f5-bdd8-910bb2b8edf0&u=https%3A%2F%2Furldefense.proofpoint.com%2Fv2%2Furl%3Fu%3Dhttps-3A\_protect2.fireeye.com\_v1\_url-3Fk-3D4018287d-2D1c6f99dc-2D401f0c98-2Dac1f6b01771c-2D5c35947fbc1ca6ca-26q-3D1-26e-3Dc99c3520-2Daa46-2D4b60-2Dab9b-2D07ff62196c7c-26u-3Dhttps-253A-252F-252Furldefense.proofpoint.com-252Fv2-252Furl-253Fu-253Dhttps-2D3A-5F-5Fprotect2.fireeye.com-5Fv1-5Furl-2D3Fk-2D3D7d020af2-2D2D217aa958-2D2D7d052e17-2D2Dac1f6b017490-2D2D9ea7085d04257ca0-2D26q-2D3D1-2D26e-2D3D10f88aea-2D2Dc33c-2D2D4886-2D2Db7b1-2D2D3b3f83c2c8f5-2D26u-2D3Dhttps-2D253A-2D252F-2D252Furldefense.proofpoint.com-2D252Fv2-2D252Furl-2D253Fu-2D253Dhttps-2D2D3A-2D5F-2D5Fprotect2.fireeye.com-2D5Fv1-2D5Furl-2D2D3Fk-2D2D3Deaed7b4d-2D2D2Db682ea7c-2D2D2Deaea5fa8-2D2D2D0cc47adc5fdc-2D2D2Db03d01e5ea777855-2D2D26q-2D2D3D1-2D2D26e-2D2D3Df0216fda-2D2D2D7d13-2D2D2D42b5-2D2D2Da641-2D2D2Deb2c4498e015-2D2D26u-2D2D3Dhttps-2D2D253A-2D2D252F-2D2D252Fwww.crowell.com-2D2D252FPractices-2D2D252FCoronavirus-2D2D2DCOVID-2D2D2D19-2D2D2DResource-2D2D2DCenter-2D2526d-2D253DDwMGaQ-2D2526c-2D253DAnw7wKLFSGyH7zEzIqo-2D2DzgMRy5HE-2D2DAH-2D2DSibmOy3H7xE-2D2526r-2D253Dz3qSdxmKBzz6GPGylff-2D2D3-2D5FHq7hsd5IK6MsiI28sDI2s-2D2526m-2D253DOVNJ4Noklk3ffCw3-2D2DpJyGtbqMhTRvz9iAXGfQEYCAIE-2D2526s-2D253Dnz2UaQDyt8fRHwhX0UuGMEarlgI-2D5Fe80pif2to4o8cT0-2D2526e-2D253D-2526d-253DDwMGaQ-2526c-253DAnw7wKLFSGyH7zEzIqo-2DzgMRy5HE-2DAH-2DSibmOy3H7xE-2526r-253Dz3qSdxmKBzz6GPGylff-2D3-5FHq7hsd5IK6MsiI28sDI2s-2526m-253DMgPNBiyyd9iaA05xkqiMRHufQ23MYQms1M3OD2TzRqY-2526s-253Df-5F5EA5doqPqt9FSABwFM2Woyw1HVBQ8nZutW3bgF3X4-2526e-253D%26d%3DDwMGaQ%26c%3DAnw7wKLFSGyH7zEzIqo-zgMRy5HE-AH-SibmOy3H7xE%26r%3Dz3qSdxmKBzz6GPGylff-3\_Hq7hsd5IK6MsiI28sDI2s%26m%3D5OVhEmt2xa\_ZdWLxnllIDmM-5AS0Lf84EYIVljloekU%26s%3DORq96Ogx4dyGnQUubyew2UPtEBvITVMWdgwrMjBalhQ%26e%3D> + +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] + +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] +[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.](https://protect2.fireeye.com/v1/url?k=f3ff048d-af93d3a2-f3f82068-ac1f6b017516-788728b8e0ea38d5&q=1&e=8d8322d4-2603-49f5-bdd8-910bb2b8edf0&u=http%3A%2F%2Fwww.crowell.com%2F

) 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<[https://protect2.fireeye.com/v1/url?k=3cafc371-60d872d0-3ca8e794-ac1f6b01771c-e87adb3f889c3b73&q=1&e=c99c3520-aa46-4b60-ab9b-07ff62196c7c&u=https%3A%2F%2Furldefense.proofpoint.com%2Fv2%2Furl%3Fu%3Dhttps-3A\\_protect2.fireeye.com\\_v1\\_url-3Fk-3D5254901c-2D0e2c33b6-2D5253b4f9-2Dac1f6b017490-](https://protect2.fireeye.com/v1/url?k=3cafc371-60d872d0-3ca8e794-ac1f6b01771c-e87adb3f889c3b73&q=1&e=c99c3520-aa46-4b60-ab9b-07ff62196c7c&u=https%3A%2F%2Furldefense.proofpoint.com%2Fv2%2Furl%3Fu%3Dhttps-3A_protect2.fireeye.com_v1_url-3Fk-3D5254901c-2D0e2c33b6-2D5253b4f9-2Dac1f6b017490-) + +2D42766727d0935964-26q-3D1-26e-3D10f88aea-2Dc33c-2D4886-2Db7b1-2D3b3f83c2c8f5-26u-3Dhttps- +253A-252F-252Furldefense.proofpoint.com-252Fv2-252Furl-253Fu-253Dhttps-2D3A-5F- +5Fprotect2.fireeye.com-5Fv1-5Furl-2D3Fk-2D3D2d1b0125-2D2D71749014-2D2D2d1c25c0- +2D2D0cc47adc5fdc-2D2D3196025400b6b0c9-2D26q-2D3D1-2D26e-2D3Df0216fda-2D2D7d13-2D2D42b5- +2D2Da641-2D2Deb2c4498e015-2D26u-2D3Dhttps-2D253A-2D252F-2D252Furldefense.proofpoint.com- +2D252Fv2-2D252Furl-2D253Fu-2D253Dhttps-2D2D3A-2D5F-2D5Fprotect2.fireeye.com-2D5Fv1-2D5Furl- +2D2D3Fk-2D2D3D0962aa97-2D2D2D550c8d1d-2D2D2D09658e72-2D2D2D0cc47adc5e1a- +2D2D2D4ba7b87e8595eff1-2D2D26q-2D2D3D1-2D2D26e-2D2D3D1520a42f-2D2D2D95a1-2D2D2D40c3- +2D2D2Db916-2D2D2D0a037cad8bfa-2D2D26u-2D2D3Dhttps-2D2D253A-2D2D252F- +2D2D252Fwww.crowell.com-2D2D252FPractices-2D2D252FCoronavirus-2D2D2DCOVID-2D2D2D19- +2D2D2DResource-2D2D2DCenter-2D2526d-2D253DDwMGaQ-2D2526c-2D253DAnw7wKLFSGyH7zEzIqo- +2D2DzgMRy5HE-2D2DAH-2D2DSibmOy3H7xE-2D2526r-2D253Dz3qSdxmKBzz6GPGylff-2D2D3- +2D5FHq7hsd5IK6MsiI28sDI2s-2D2526m-2D253D9ypJBRR8E1QNyYZnOgl6- +2D5FsjXjloiKstss3X5Tn5EuA8-2D2526s-2D253D9ESNFBFATDePnDwWUA5j1dto- +2D2DGIAuk7KD19O8r98hNQ-2D2526e-2D253D-2526d-253DDwMGaQ-2526c- +253DAnw7wKLFSGyH7zEzIqo-2DzgMRy5HE-2DAH-2DSibmOy3H7xE-2526r- +253Dz3qSdxmKBzz6GPGylff-2D3-5FHq7hsd5IK6MsiI28sDI2s-2526m-253DOVNJ4Noklk3ffCw3- +2DpJyGtbqMhTRvz9iAXGfQEYCAIE-2526s-253D2tJcyIUFG5VpIEDLrrs48AG3PkJmjcNNKuRJs8X1WeY- +2526e-253D%26d%3DDwMGaQ%26c%3DAnw7wKLFSGyH7zEzIqo-zgMRy5HE-AH- +SibmOy3H7xE%26r%3Dz3qSdxmKBzz6GPGylff- +3\_Hq7hsd5IK6MsiI28sDI2s%26m%3DMgPNBiyyd9iaA05xkqiMRHufQ23MYQms1M3OD2TzRqY%26s%3D +p5R0pASpqSGZi8Vgw6iO4zvWOJs1hQ2G\_VfPZ8dAnqI%26e%3D> + +From: [REDACTED] ) + +<[REDACTED]> + +Sent: Friday, June 19, 2020 3:07 PM + +To: McGorty, Glen <[REDACTED]> + +Cc: Zelenko, Daniel <[REDACTED]>>; [REDACTED] + +<[REDACTED]>; [REDACTED] + +<[REDACTED]> + +Subject: FW: Meeting with [REDACTED] + +External Email + +Glen, + +Per my previous email, please see the below. + +thanks, +[REDACTED] + +From: [REDACTED] ) + +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. 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: mailteaa + +Sent: Friday, August 09. 2019 15:'0 + +To: Donnie Murrell - + +Cc: mailto: + +Subject: RE: Meeting with mailto: + +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 a> + +Sent: Frida , Au ust 9, 2019 11:19 AM + +To: alMlEgnailtcalMIN> + +Subject: Meeting with + +Ms. + +Have 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/EFTA00084244/EFTA00084244.metadata.json b/marker2/ds9/EFTA00084244/EFTA00084244.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d23ff1c461efbe5858c6581e2f7c8ff4c4e25d04 --- /dev/null +++ b/marker2/ds9/EFTA00084244/EFTA00084244.metadata.json @@ -0,0 +1,278 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084244.pdf", + "engine": { + "marker_major": "2", + "marker_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": 18781, + "elapsed_seconds": 128.01, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Text", + 34 + ], + [ + "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", + 55 + ], + [ + "Line", + 32 + ], + [ + "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 + } + }, + { + "page_id": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 50 + ], + [ + "Line", + 26 + ], + [ + "Text", + 24 + ], + [ + "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", + 77 + ], + [ + "Text", + 47 + ], + [ + "Line", + 44 + ], + [ + "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", + 34 + ], + [ + "Text", + 21 + ], + [ + "Line", + 18 + ], + [ + "PageFooter", + 3 + ] + ], + "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", + 78 + ], + [ + "Line", + 47 + ], + [ + "Text", + 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": 6, + "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 + } + }, + { + "page_id": 7, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 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": 8, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 62 + ], + [ + "Line", + 31 + ], + [ + "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/EFTA00084244" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084253/EFTA00084253.md b/marker2/ds9/EFTA00084253/EFTA00084253.md new file mode 100644 index 0000000000000000000000000000000000000000..52582823b1c5e0f69dd3dbde2d4aa3011da6ebf5 --- /dev/null +++ b/marker2/ds9/EFTA00084253/EFTA00084253.md @@ -0,0 +1,137 @@ +To: "Weinstein, Marc A." + +Cc: "Tomback, Andrew" + +Subject: RE: Grand jury subpoena response + +Date: Mon, 20 Jan 2020 18:56:04 +0000 + +Received and understood, thank you. + +From: Weinstein, Marc A. + +Sent: Saturday, January 18, 2020 16:00 + +To: + +Cc: Tomback, Andrew c M> + +Subject: Re: Grand jury subpoena response + +M, we should be able to produce these by the middle of the week. + +Have a good weekend, Marc + +Marc A. Weinstein I Partner + +Chair. Waite Collar Delouse + +Hughes Hubbard & Reed LLP + +One Battery Park Plaza, 17th floor INew York, NY 10004-1482 + +Office + +This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this email 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 . • • • r yet a hard-copy version. + +On Jan 17, 2020, at 1:24 PM, wrote: + +CAUTION: This email was sent by someone outside of the Firm. + +Marc, + +You're absolutely correct that our request was specifically for prior wills—my email below was the result of an incorrect recollection on my part, and I apologize for the suggestion that there might have been a mutual misunderstanding. I don't specifically recall the details of our discussion as to the trusts in particular, but having been reminded through our communications yesterday and today, I certainly remember that our request was for the wills specifically, and it is the case that the original directive we received was to request the wills. In any event, and regardless of the cause, the reference to a possible miscommunication was my mistake. + +In terms of going forward, and notwithstanding that I've also communicated to my supervisors that the oversight was mine, there is a tremendous interest in receiving the trusts expeditiously (in part because the production of the wills took a substantially longer time than we had anticipated). If at all possible, we are hoping to receive them early next week following the holiday—or if you think that is not possible, if you could please give us a sense of when we should expect them, I will pass that up our chain. Thank you for your consideration. + +From: Weinstein, Marc A. + +Sent: Friday, January 17, 2020 10:23 + +To: + +Cc: Tomback, Andrew + +Subject: RE: Grand jury subpoena response + +We will of course speak to our clients about the request. We thought it was quite clear in our call with you about the Office's request that it was specifically limited to prior wills, and not trusts. Indeed, we asked you to confirm that the request was so limited since it should be obvious to those investigating that the trusts are a necessary part of the overall sequence. You confirmed that the request was limited to the wills. So we then suggested that perhaps we should enlarge the request to cover the trusts and you said that the requester had clearly asked for just the wills and it was best to stick with that. We will get back to you as soon as possible on this additional request. + +Best regards, Marc + +Marc A. Weinstein I Partner + +Chair. While Collar Defense + +Hughes Hubbard & Reed LLP + +One Battery Park Plaza, 17th floor I New York, NY 10004-1482 + +Office + +s \_ontains confidential information and is intended only for the inc ,: LL:, (2 'I' u yu .1 d I . :1 I I ..2C 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 email from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, • late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this se as a result of e-mail transmission. If verification is required please request a hard-copy version. + +From: + +Sent: Thursday, January 16, 2020 11:59 AM + +To: Weinstein, Marc A. + +**Sent:** Thursday, January 16, 2020 11:20 + +**To:** [REDACTED]; [REDACTED] + +**Cc:** Tomback, Andrew <[REDACTED]> + +**Subject:** Grand jury subpoena response + +[REDACTED], [REDACTED]: + +In response to your request for any prior wills of Jeffrey Epstein, which request we understand was made pursuant to the October 18, 2019 grand jury subpoenas to the executors of the estate of Jeffrey Epstein, attached please find documents bearing Bates numbers GJ\_000103 through GJ\_000197. + +Regards, +Marc + +**Marc A. Weinstein** | Partner + +Chair, White Collar Defense + +**Hughes Hubbard & Reed LLP** + +One Battery Park Plaza, 17th floor | New York, NY 10004-1482 + +Office [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. \ No newline at end of file diff --git a/marker2/ds9/EFTA00084253/EFTA00084253.metadata.json b/marker2/ds9/EFTA00084253/EFTA00084253.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..63254ffbc29b028c4e84d4ed13674654c422f4aa --- /dev/null +++ b/marker2/ds9/EFTA00084253/EFTA00084253.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084253.pdf", + "engine": { + "marker_major": "2", + "marker_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": 6687, + "elapsed_seconds": 8.61, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 78 + ], + [ + "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 + } + }, + { + "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": "surya", + "block_counts": [ + [ + "Span", + 54 + ], + [ + "Text", + 44 + ], + [ + "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/EFTA00084253" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084256/EFTA00084256.md b/marker2/ds9/EFTA00084256/EFTA00084256.md new file mode 100644 index 0000000000000000000000000000000000000000..8b3f3e579bd10da8c20276a5da75f58fa8c7392d --- /dev/null +++ b/marker2/ds9/EFTA00084256/EFTA00084256.md @@ -0,0 +1,349 @@ +From: Robert Glassman To: "S" Cc: ' , Nathan Werksman + +Subject: RE: SDNY investigation Date: Sat, 18 Jan 2020 03:18:16 +0000 + +Attachments: Fed\_Complaint.pdf + +M, sorry for not giving you a heads up on this. That was not my intent. Just been really busy with a couple of other big 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 Los An eles CA 90025 Tel: Fax Em 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: 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. + +thanks, + +Ori inal Messa e From: Sent: Monday, December 30 2019 22:28 To: Robert Glassman + +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. + +Original Message + +From: Robert Glassman + +Sent: Monda December + +To: + +Cc: ; On Dec 30, 2019, at 1:10 PM, wrote: + +> Robert, + +> Following up on our most recent meeting with you and NW we wanted to confirm that it's alright for ' us to begi this week to the contacts she ide 1 us -- in articular we would initially ex ect to contact , and il. and then , e 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 m 9 d 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. + +>- + +> + +> > ----Ori inal Messa e + +> From: + +> Sent: Friday, December 13.2019 17:06 + +> To: Robert Glassman + +> Totally understand, just wanted to ask. We'll see you Monday at 11:00. And thanks for that additional info as well. + +> Original Message + +> From: Robert Glassman + +> Sent: Frida December 111.II MI> + +> To: + +> Cc: • < IIMIE>; + +Nathan Werksman + +> Subject: Re: SDNY investigation + +> Alex, 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, < 1=1.> 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. + +» thanks, + +» -----Ori inal Messa e + +» From: + +>> Sent: Wednesday, December 11, 2019 13:15 + +» To: Robert Glassman < + +» Cc: + +; Nathan Werksman > Subject: RE: SDNY investigation + +>> 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 of that would be, and to start to talk about specific conduct by Epstein and/or Maxwell to whatever extent is comfortable with that at this stage. And we'll also likely refresh on some other topics as well, but just to flag 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 <1.atipliS + +» Sent: Wednesday, December 11 2019 12:38 + +» To: + +» Cc: + +>> Subject: RE: SDNY investigation + +>> Let's do 11 a.m. on Monday. + +» Robert Glassman, Esq. + +» Panish Shea & Bo le LLP Los Angeles, CA 90025 + +» Tel: + +» Fax: + +» Ema + +» 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 e + +» 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 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 Tues ay if that ends up being useful as well. + +>> + +>> + +>> Original Message + +>> From: Robert Glassman <- + +>> Sent: Tuesday. 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 time between discussion sessions. And as always, happy to discuss via phone if that's helpful. + +>>> + +>» thanks, + +>»IIII + +>» + +>>> 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 <1 > + +>>> Sent: Monday. December 09.2019 17:34 + +>» To: + +>» Cc: ; Nathan Werksman + +>» + +>» + +>» 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, + +»»a. + +>>» + +»» inal Messa + +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, »» a . + +>>» + +>>» + +»» -----Original Message + +»» From: Robert Glassman < + +»» Sent: Friday,November 2 , • + +»» 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/EFTA00084256/EFTA00084256.metadata.json b/marker2/ds9/EFTA00084256/EFTA00084256.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d47d24f64dd42b3866d9cd0bf7fd9c710e9bb643 --- /dev/null +++ b/marker2/ds9/EFTA00084256/EFTA00084256.metadata.json @@ -0,0 +1,262 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084256.pdf", + "engine": { + "marker_major": "2", + "marker_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": 9965, + "elapsed_seconds": 2.72, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "CONFIDENTIALITY NOTICE:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.823999999999998, + 344.25 + ], + [ + 194.51611328125, + 344.25 + ], + [ + 194.51611328125, + 359.2330322265625 + ], + [ + 31.823999999999998, + 359.2330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 82 + ], + [ + "Line", + 41 + ], + [ + "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 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 94 + ], + [ + "Line", + 45 + ], + [ + "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": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Text", + 43 + ], + [ + "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": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 41 + ], + [ + "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": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 99 + ], + [ + "Line", + 48 + ], + [ + "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": 5, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 109 + ], + [ + "Line", + 53 + ], + [ + "Text", + 49 + ], + [ + "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", + 5 + ], + [ + "Line", + 3 + ], + [ + "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/EFTA00084256" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084263/EFTA00084263.md b/marker2/ds9/EFTA00084263/EFTA00084263.md new file mode 100644 index 0000000000000000000000000000000000000000..4669037bb7a744b232bc901c9139eda355ba52e5 --- /dev/null +++ b/marker2/ds9/EFTA00084263/EFTA00084263.md @@ -0,0 +1,41 @@ +From: " (USMS)" To: " (USANYS)" ‹ > Cc: "=(U6!)" (USMS)" (USMS)" , + +Subject: Epstein Touhy + +Date: Thu, 23 Apr 2020 18:10:51 +0000 + +Attachments: Epstein\_ROls.pdf; ATT00001.htm; Disclosure\_Letter.pdf; ATT00002.htm; Epstein\_Docs.redacted.pdf; ATT00003.htm; ATT00004.htm; SOJPWASKM4320041811581.pdf; 2020\_04.23\_Letter\_to\_USVI.DOC + +Embedded: FW: Freedom of Information Act Request: USMS files re: Jeffrey\_Epstein.msg + +When we spoke in September, 2019, I advised you that the USMS had released the attached material in response to a FOIA request. We felt it prudent to inform you of this, given the potential pendency of other matters in your office related to the then-recently deceased Jeffrey Epstein. + +The USMS has recently received a copy of a Touhy request from the Government of the United States Virgin Islands (GVI) to the Office of Justice Programs and the USDO1 SMART Office that seeks information about Mr. Epstein for potential use in a civil matter in the GVI. I have attached a copy of that letter. + +I have also attached a response to that letter from the Office of Justice Programs that points out that the USMS is the more logical recipient of this Touhy request. + +I forwarded the Touhy request to the Civil Chief of the USAO/GVI, nd I will be their USMS POC in crafting a response. The attached material will be a significant factor in our response. + +I thought the USMS should make you aware of these recent developments and the impending response to the Touhy request in the event your office is involved in any matters involving Mr. Epstein or his estate that could be impacted by the release of information as requested in the recent Touhy letter. Additionally, if your office has also received a Touhy request from the GVI regarding Mr. Epstein, I thought it best that we respond in a coordinated fashion. + +If you or one of your Assistants would like to discuss this, I will be available at your convenience. E-mail is the most reliable way to reach me quickly. + +V/r, + +Associate General Counsel + +USMS/HQ/OGC + +(cell) + +Thank you for your prompt return call and your time this afternoon. + +Attached above is the material we discussed. + +You or anyone on your staff is welcome to call me if you have any questions or concerns about this material. + +V/r, + +Associate General Counsel + +USMS/HQ/OGC \ No newline at end of file diff --git a/marker2/ds9/EFTA00084263/EFTA00084263.metadata.json b/marker2/ds9/EFTA00084263/EFTA00084263.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..28082af7384da1fa76320fca3d8ef947c6716626 --- /dev/null +++ b/marker2/ds9/EFTA00084263/EFTA00084263.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084263.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2310, + "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", + 35 + ], + [ + "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", + 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/EFTA00084263" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084265/EFTA00084265.md b/marker2/ds9/EFTA00084265/EFTA00084265.md new file mode 100644 index 0000000000000000000000000000000000000000..703b8c49b73808c66f4dd6b005881cc65680ca3d --- /dev/null +++ b/marker2/ds9/EFTA00084265/EFTA00084265.md @@ -0,0 +1,26 @@ +![](_page_0_Picture_0.jpeg) + +## VIRGIN ISLANDS DEPARTMENT OF JUSTICE OFFICE OF THE ATTORNEY GENERAL + +April 2, 2020 + +By. U.S. Mail + +By U.S. Mail and Email: FOIAOJP(tZusdoj.gov + +Dear + +The Government of the United States Virgin Islands ("GVI") submits this Touhy request to the Office of Justice Program Office of Sex Offender Sentencing, Monitoring, Apprehending, Registering and Tracking ("SMART"). This request relates to the matter currently pending in the Superior Court of the Virgin Islands, Case No. ST-2020-CV-14, filed by the GVI against the Estate of Jeffrey E. Epstein. The complaint details numerous violations of the Virgin Islands' Criminally Influenced and Corrupt Organizations Act ("CICO"), based on violations of the laws against human trafficking, child abuse, and sexual abuse committed by Jeffrey Epstein and the other named defendants in the Virgin Islands (the "Acts"). + +The Acts underlying this request involve the international travel of registered sex offender Jeffrey E. Epstein. Upon information and belief, as a registered sex offender, Epstein was required to, at a minimum, alert SMART, in accordance with the Sex Offender Registration and Notification Act ("SORNA"), of any international travel twenty-one days in advance. By this request, the GVI specifically seeks all information related to every occasion Jeffrey E. Epstein traveled outside of the United States from the date of his registration as a sex offender in June 2008 until August 2019. + +For each date identified, please provide all information related to his international travel, including the destination of the international travel, as well as any other information provided to or provided by SMART in accordance with SORNA. This request includes any and all information provided to or obtained from the following agencies in conjunction with the operation of SMART and SORNA: the U.S. Marshals Service National Sex Offender Targeting Center; INTERPOL-Washington for foreign country notification; the Federal Bureau of Investigation; and the Department of Homeland Security's Angel Watch Center. Additionally, the GVI requests any and all documentation related to the above via the Correspondence Tracking System and/or obtained by or retained in the Program Accountability Library. + +This information is not otherwise reasonably procurable by exercise of due diligence. The Government of the United States Virgin Islands is unable to properly execute its case without production SMART's records, and the failure to obtain such inspection may unreasonably delay effective prosecution of the pending case. This request is narrowly tailored, and made with a good faith reason to believe the information will directly advance issues at the heart of the litigation. The GVI is willing to pay for the costs of producing any documents responsive to its request. Our request does not include anything that would be precluded by any act under United States law. + +Sincerely, + +![](_page_1_Picture_78.jpeg) + +Chief, Civil Division, +Virgin Islands Department of Justice \ No newline at end of file diff --git a/marker2/ds9/EFTA00084265/EFTA00084265.metadata.json b/marker2/ds9/EFTA00084265/EFTA00084265.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a9e80763ac14d5f8bf48a03e9e51afa6c33f67fc --- /dev/null +++ b/marker2/ds9/EFTA00084265/EFTA00084265.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084265.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3054, + "elapsed_seconds": 5.98, + "image_assets": [ + "_page_0_Picture_0.jpeg", + "_page_1_Picture_78.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIRGIN ISLANDS DEPARTMENT OF JUSTICE \nOFFICE OF THE ATTORNEY GENERAL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 185.43599999999998, + 129.60000000000002 + ], + [ + 419.4065246582031, + 129.60000000000002 + ], + [ + 419.4065246582031, + 157.4830322265625 + ], + [ + 185.43599999999998, + 157.4830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Line", + 21 + ], + [ + "Text", + 6 + ], + [ + "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": "surya", + "block_counts": [ + [ + "Span", + 44 + ], + [ + "Line", + 23 + ], + [ + "Text", + 7 + ], + [ + "PageHeader", + 2 + ], + [ + "Caption", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 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/EFTA00084265" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084265/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00084265/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..4c9a1c6a9649ef9b5cdd57d54eb33a122290a1dc --- /dev/null +++ b/marker2/ds9/EFTA00084265/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:c23d10de0dd3619e4b39ab383097809367c6f9630db25d9fe74720af47f60256 +size 8025 diff --git a/marker2/ds9/EFTA00084265/_page_1_Picture_78.jpeg b/marker2/ds9/EFTA00084265/_page_1_Picture_78.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..08dabedf618abd8e9450a3289ad1e3092fa457d2 --- /dev/null +++ b/marker2/ds9/EFTA00084265/_page_1_Picture_78.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:688ef65d90543fb70685881b4a522758615a67f3f006911d61a6f641c6b140c9 +size 3143 diff --git a/marker2/ds9/EFTA00084267/EFTA00084267.md b/marker2/ds9/EFTA00084267/EFTA00084267.md new file mode 100644 index 0000000000000000000000000000000000000000..e3b934d45e9df8c4dca0cd3e5ac1d68bf92f56e7 --- /dev/null +++ b/marker2/ds9/EFTA00084267/EFTA00084267.md @@ -0,0 +1,27 @@ +![](_page_0_Picture_0.jpeg) + +## Office of Justice Programs + +## Office of Sex Offender Sentencing, Monitoring, Apprehending, Registering, and Tracking + +Washington. D.C. 20331 + +April 23, 2020 + +![](_page_0_Picture_6.jpeg) + +Dear + +This letter responds to your request, dated April 2, 2020, seeking information "related to every occasion that Jeffrey E. Epstein traveled outside of the United States from the date of his registration as a sex offender in June 2008 to August 2019." The Office of Sex Offender Sentencing, Monitoring, Apprehending, Registering, and Tracking ("SMART Office") is responsible for providing jurisdictions with guidance regarding the implementation of the Adam Walsh Act, and providing technical assistance to the states, territories, Indian tribes, local governments, and to public and private organizations. The SMART Office does not, and has never, maintained any records or files on individual sex offenders, nor does it track, or monitor or receive notifications regarding the international travel of individual offenders. Information about specific individual sex offenders, to include the international travel of and/or the compliance with international travel requirements for an individual sex offender, is best obtained from jurisdiction(s) in which the sex offender lives, works, or attends school. + +Accordingly, the SMART Office does not have any information that is responsive to your request. We would advise that you contact the United States Marshals Service National Sex Offender Targeting Center; INTERPOL-Washington; the Federal Bureau of Investigation; and/or the Department of Homeland Security Angel Watch Center directly if you have questions about what information, if any, those agencies may have in their possession. + +cc: + +enera ounse Office of Justice Programs Si erely, + +![](_page_0_Picture_11.jpeg) + +irector + +![](_page_1_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084267/EFTA00084267.metadata.json b/marker2/ds9/EFTA00084267/EFTA00084267.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c9855bcd2861ab6c53845e8d4d9748d5598f251f --- /dev/null +++ b/marker2/ds9/EFTA00084267/EFTA00084267.metadata.json @@ -0,0 +1,167 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084267.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + 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a/marker2/ds9/EFTA00084269/EFTA00084269.md b/marker2/ds9/EFTA00084269/EFTA00084269.md new file mode 100644 index 0000000000000000000000000000000000000000..34f6348896a37c093041de95c65e2b86bd09c81d --- /dev/null +++ b/marker2/ds9/EFTA00084269/EFTA00084269.md @@ -0,0 +1,15 @@ +To: + +Cc: + +Subject: Ghislaine Maxwell + +Date: Tue, 07 Jul 2020 18:12:58 +0000 + +Hi = + +With apologies for bothering you during a busy time, we were hoping you might be able to assist us with an issue in this case. Maxwell's attorneys have informed us that they are having difficulty arranging for a legal call with her this afternoon to discuss a time-sensitive matter relating to a court filing. Could ou ossibl assist them in arranging for a call this afternoon? Her attorney is who can be reached at + +Thanks very much, + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York. 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I am an owner of an aviation company (Lyon Aviation Inc that flies people around the world irLpilvate jets. I have worked with a Customs Agent out of Albany NY in the past, One of the tips I provided was on or about February 7th or 8th 2015. We transported a lone woman of Massachusetts to St. Thomas on February 07th 2015 from Boston and returned her on February 10th 2015. We found this odd that this woman was flying privately, because she didn't appear to be able to afford this flight that may have costs \$35,000. I suspected this woman might have or be transporting drugs. She was questioned for several hours by ST Thomas Customs on her return. The only info gathered was that she was an escort and not drug related. This woman was transported to and from St. Thomas on a private helicopter to a nearby island. + +Being in the private flying arena for 35 years one tends to learn patterns and fli ht requests. I was always keenly aware of one particular "Charter Broker ( Dan Ryan, owner of BIG FLY INC. ) who appeared to be working for the same person (many years) and filling numerous requests to the island of St. Thomas from all different parts of the USA. A "Charter Broker" doesn't own or operate aircraft, but represents clients in finding aircraft for their particular missions. + +This particular flight that we performed on behalf of Dan Ryan always stuck in my head. One reason was the frequency of the requests to the same island and because these were great revenue requests. I always thought these flights were for someone in the St. Thomas region bringing in many guests and had to be quite wealthy. + +After the Epstein story broke the news, I instantly remembered the Boston St. Thomas flight and knew with almost certainty that Dan Ryan was the "CHARTER BROKER" fulfilling the requests to transport people into and of out of St. Thomas on behalf of Jeffrey Epstein or his representatives. I'm sure Dan will have passenger names and where he was being paid from. Again the requests originated in many parts of the USA and Los Angeles was one of the more favorite routes. I do prefer my name NOT be used if inquiring with Dan, but always happy to discuss with your agency. + +My contact is: + +Michael Lyon Lyon Aviation Inc Pittsfield Massachusetts + +Leading Private jet charter since 1980 with personal attention and service; safe, reliable, privately-owned flee... \ No newline at end of file diff --git a/marker2/ds9/EFTA00084270/EFTA00084270.metadata.json b/marker2/ds9/EFTA00084270/EFTA00084270.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8a52a2ad3ac03b234b2a100221ed1f8c47df5a01 --- /dev/null +++ b/marker2/ds9/EFTA00084270/EFTA00084270.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084270.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2790, + "elapsed_seconds": 1.12, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Home - Lyon Aviation - Air Charter Services", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 48.348, + 48.599999999999994 + ], + [ + 270.3968505859375, + 48.599999999999994 + ], + [ + 270.3968505859375, + 63.17999999999999 + ], + [ + 48.348, + 63.17999999999999 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 82 + ], + [ + "Line", + 41 + ], + [ + "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", + 7 + ], + [ + "Line", + 4 + ], + [ + "SectionHeader", + 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/EFTA00084270" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084272/EFTA00084272.md b/marker2/ds9/EFTA00084272/EFTA00084272.md new file mode 100644 index 0000000000000000000000000000000000000000..bdb872cd590925864fd605a5fa5309b4d0667b4e --- /dev/null +++ b/marker2/ds9/EFTA00084272/EFTA00084272.md @@ -0,0 +1,106 @@ +To: "Erica T. Dubno, Esq." , " + +Cc: Aaron Mysliwiec cam@fmamlaw.com>, "- + +Subject: RE: Checking in + +Date: Mon, 06 Jul 2020 22:31:22 +0000 + +Aaron and Erica, + +![](_page_0_Picture_6.jpeg) + +Please feel free to give me a call if you have any questions or would like to discuss. You can reach me on my cell at 347- 344-8771. + +Best, + +![](_page_0_Picture_9.jpeg) + +![](_page_0_Picture_10.jpeg) + +Assistant United States Attorney Southern District of New York I St. Andrew's Plaza + +![](_page_0_Picture_12.jpeg) + +From: Erica T. Dubno, Esq. + +Sent: Thursday, July 2, 2020 3:05 PM + +To: + +Cc: Aaron Mysliwiec ; + +Subject: Re: Checking in + +![](_page_0_Picture_18.jpeg) + +Aaron is out of town and has bad cell service right now. Thanks so much for getting back to us so quickly. We appreciate your message and investigation o Wishing you and the rest of the team a happy and safe holiday. + +Fahringer & Dubno + +43 West 40 Street Suite 261 + +New York, New York 10036 + +www.fahringerlaw.com + +(212) 319-5351 + +(212) 319-6657 (fax) + +IMPORTANT: This email (and any attachment) is exclusively for the intended recipient and likely contains information that is proprietary, privileged, confidential or exempt from disclosure under law. If you are not the intended recipient, viewing, copying, use, disclosure or distribution of this information may be subject to legal restriction or sanction, and is not intended to waive any privilege. Please notify the sender of any unintended recipients and immediately delete the original message and any copies. + +On Jul 2, 2020, at 2:21 PM, > wrote: + +Aaron, + +We appreciate that, and we had intended to check in with you today when we got a chance, but you beat us to it. We continue to appreciate your client's assistance and cooperation, and we certainly will let you know if it makes sense to connect again in the near term, though I think for the moment we're alright. And we also haven't forgotten about the about which we hope to follow up with you next week, pending final internal discussions. + +Thanks very much, + +From: Aaron Mysliwiec + +Sent: Thursday, July 02, 2020 13:07 + +To: + +Cc: Erica T. Dubno, Esq. • >; + +Subject: Checking in + +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 + +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. + +[REDACTED] + +--- + +**From:** Aaron Mysliwiec <[am@fmamlaw.com](mailto:am@fmamlaw.com)> + +**Sent:** Friday, May 15, 2020 08:30 + +**To:** [REDACTED] > + +**Cc:** Erica T. Dubno, Esq. <[erica.dubno@fahringerlaw.com](mailto:erica.dubno@fahringerlaw.com)>; [REDACTED] >; [REDACTED] + +[REDACTED] > + +**Subject:** R [REDACTED] + +[REDACTED] + +![](_page_2_Picture_52.jpeg) + +Please let us know if you have additional questions. + +Thanks, +Aaron \ No newline at end of file diff --git a/marker2/ds9/EFTA00084272/EFTA00084272.metadata.json b/marker2/ds9/EFTA00084272/EFTA00084272.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..769e5fcd834f8fd726188787131f1ddb5d35dc71 --- /dev/null +++ b/marker2/ds9/EFTA00084272/EFTA00084272.metadata.json @@ -0,0 +1,129 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084272.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3141, + 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Thanks. + +On Jul 2.2020 5:06 pm, " PO < > wrote: + +We are passing along the below for the FBI to follow up on. + +Thanks, + +Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York NY 10007 + +![](_page_1_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084275/EFTA00084275.metadata.json b/marker2/ds9/EFTA00084275/EFTA00084275.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3e1bacde651ec4c9578e57e1ecd64d706f75e116 --- /dev/null +++ b/marker2/ds9/EFTA00084275/EFTA00084275.metadata.json @@ -0,0 +1,86 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084275.pdf", + "engine": { + "marker_major": "2", + "marker_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": 353, + "elapsed_seconds": 0.59, + "image_assets": [ + "_page_1_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 36 + ], + [ + "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 + } + }, + { + "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/EFTA00084275" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084275/_page_1_Picture_0.jpeg b/marker2/ds9/EFTA00084275/_page_1_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..e16e25fc8bcaa43fab330789ede61136068747a2 --- /dev/null +++ b/marker2/ds9/EFTA00084275/_page_1_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:68f5a4959b6cf558ba8d91f6c6c2d42c28cbef36945254e10e202bc4edfe7852 +size 7816 diff --git a/marker2/ds9/EFTA00084279/EFTA00084279.md b/marker2/ds9/EFTA00084279/EFTA00084279.md new file mode 100644 index 0000000000000000000000000000000000000000..940a03c3664903a1c497ed12b5b3aaf4b7519536 --- /dev/null +++ b/marker2/ds9/EFTA00084279/EFTA00084279.md @@ -0,0 +1,39 @@ +To: ' + +Cc: irr> + +Subject: FW: Amazon Ref. No. CRIM 1073122 2020 DS In Re Case No. In Re: Subpoena 20 Mag. 6216) External + +Date: Thu, 02 Jul 2020 15:13:51 +0000 + +Attachments: CRIM1073122 2020 DS Response 02July2020.xlsx + +Attached is the response from Amazod anything that's relevant to bail? Thanks. could you please take a look and let me know if this tells us + +From: + +Sent: Thursday, July 2, 202011:10 AM + +To: + +Cc: >; + +Subject: Amazon Ref. No. CRIM1073122 2020 DS In Re Mag. 6216) (External Case No. In Re: Subpoena 20 + +Dear AUSA + +Attached please find Amazon's response to the above-referenced request. For privacy and other legal reasons, we have redacted the titles of expressive materials. Amazon reserves any and all objections that Amazon may have with respect to this law enforcement request, including that the information and/or records requested are unusually voluminous in nature and that compliance with such order otherwise would cause an undue burden on Amazon. + +Sincerely, + +Teresa Rodelo + +Manager, Law Enforcement Response Team + +Amazon.com, Inc. + +2021 7th Avenue, Seattle, WA 98121 + +w: • e + +NOTICE: This communication might contain privileged and/or confidential information. If you are not the intended recipient or you believe that you have received this communication in error, please delete this message and do not print, share, or otherwise use this message or its contents in any way. Please also indicate by reply email that you have received this communication in error and that you have deleted it. \ No newline at end of file diff --git a/marker2/ds9/EFTA00084279/EFTA00084279.metadata.json b/marker2/ds9/EFTA00084279/EFTA00084279.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ec6f92fd287d55d7cbd15fe30e94090de434edd9 --- /dev/null +++ b/marker2/ds9/EFTA00084279/EFTA00084279.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084279.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1522, + "elapsed_seconds": 0.99, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 34 + ], + [ + "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/EFTA00084279" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084280/EFTA00084280.md b/marker2/ds9/EFTA00084280/EFTA00084280.md new file mode 100644 index 0000000000000000000000000000000000000000..7701cdd14879bb75554c76088e8627ab793784a0 --- /dev/null +++ b/marker2/ds9/EFTA00084280/EFTA00084280.md @@ -0,0 +1,53 @@ +To: + +Subject: RE: Activity in Case 1:20-mj-00132-AJ USA v. Maxwell Notice of Hearing + +Date: Thu, 02 Jul 2020 17:11:14 +0000 + +Ha you have a moment for a quick call to discuss the court conference? I'm when you have a chance. Thanks! + +From: + +Sent: Thursday, July 2, 202012:14 PM + +To: + +Subject: FW: Activity in Case 1:20-mj-00132-AJ USA v. Maxwell Notice of Hearing + +Removal hearing is scheduled for 3:30. + +From: ecf bounceanhd.uscourts.gov + +Sent: Thursday, July 2, 202012:10 PM + +To: nefPnhd.uscourts.gov + +Subject: Activity in Case 1:20-n1j-00132-A1 USA v. Maxwell Notice of Hearing + +This is an automatic e-mail message generated by the CMIECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +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-mj-00132-Al + +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) + +lov, CaseView.ECF@usdoj,gov ait ninal@usdoj.gov, USANH.ECFDocket@usdoj.gov + +1:20-mj-00132-AJ-1 Notice, to the extent appropriate, must be delivered conventionally to: \ No newline at end of file diff --git a/marker2/ds9/EFTA00084280/EFTA00084280.metadata.json b/marker2/ds9/EFTA00084280/EFTA00084280.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..70a19acd6196dd94f1cca72c2e7e2034f44986e2 --- /dev/null +++ b/marker2/ds9/EFTA00084280/EFTA00084280.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084280.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1891, + "elapsed_seconds": 1.25, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 564.5699999999999 + ], + [ + 184.79776000976562, + 564.5699999999999 + ], + [ + 184.79776000976562, + 580.3535614013672 + ], + [ + 30.6, + 580.3535614013672 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 72 + ], + [ + "Line", + 35 + ], + [ + "Text", + 26 + ], + [ + "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", + 9 + ], + [ + "Line", + 4 + ], + [ + "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/EFTA00084280" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084282/EFTA00084282.md b/marker2/ds9/EFTA00084282/EFTA00084282.md new file mode 100644 index 0000000000000000000000000000000000000000..f8eea204ddcd2dc8556db70fe58c640f0b453f91 --- /dev/null +++ b/marker2/ds9/EFTA00084282/EFTA00084282.md @@ -0,0 +1,35 @@ +**To:** "[REDACTED]" + +**Subject:** Re: [REDACTED] + +**Date:** Mon, 06 Jul 2020 12:56:20 +0000 + +--- + +Sure. I should be around. + +On Jul 6, 2020, at 8:55 AM, [REDACTED] wrote: + +Hi [REDACTED] - yes, definitely. I'm about to head into a few back-to-back mtgs, can we plan for later this morning? + +Thanks | + +[REDACTED] + +- + +On Jul 6, 2020 8:46 AM, [REDACTED] wrote: + +[REDACTED] + +Do you have a few minutes to discuss this morning? + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00084282/EFTA00084282.metadata.json b/marker2/ds9/EFTA00084282/EFTA00084282.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..38e2a8e998d67ab27890c1634b73c31bb74ada9e --- /dev/null +++ b/marker2/ds9/EFTA00084282/EFTA00084282.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084282.pdf", + "engine": { + "marker_major": "2", + "marker_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": 481, + "elapsed_seconds": 3.16, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 35 + ], + [ + "Span", + 23 + ], + [ + "Line", + 12 + ], + [ + "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/EFTA00084282" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084283/EFTA00084283.md b/marker2/ds9/EFTA00084283/EFTA00084283.md new file mode 100644 index 0000000000000000000000000000000000000000..29b1c25bf90979c7b99b9767e714713f5a0e6d19 --- /dev/null +++ b/marker2/ds9/EFTA00084283/EFTA00084283.md @@ -0,0 +1,43 @@ +From: ' + +To:' + +Cc:I 1). + +Subject: Re: RE Bill Clinton + +Date: Fri, 03 Jul 2020 16:09:45 +0000 + +Thank you for this information. + +On Jul 3, 2020, at 12:02, > wrote: + +Passing on the below, per our practice. + +hanks, + +From: + +Sent: Friday, July 3, 202012:01 PM + +To: + +Subject: Fwd: RE Bill Clinton + +For you + +Sent from my iPhone + +Begin forwarded message: + +From: Andy Kay + +Date: July 2, 2020 at 9:23:08 PM EDT + +To: ' + +Subject: RE Bill Clinton + +I know the former President Bill Clinton made 32 plane trips to Jeffrey Epstein island. + +Is there any reason why he is not being interviewed and charged? 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Lisa Margaret Smith, U.S. Magistrate Judge +Printed name and title + +### Return + +This warrant was received on (date) , and the person was arrested on (date) , +at (city and state) . + +Date: \_\_\_\_\_ + +Arresting officer's signature + +Printed name and title \ No newline at end of file diff --git a/marker2/ds9/EFTA00084285/EFTA00084285.metadata.json b/marker2/ds9/EFTA00084285/EFTA00084285.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8635d5e05bb2419ca0abb6bc83e99a910db8ca72 --- /dev/null +++ b/marker2/ds9/EFTA00084285/EFTA00084285.metadata.json @@ -0,0 +1,142 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084285.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1514, + "elapsed_seconds": 7.42, + "image_assets": [ + "_page_0_Picture_155.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 173.808, + 71.28 + ], + [ + 434.52, + 71.28 + ], + [ + 434.52, + 89.1 + ], + [ + 173.808, + 89.1 + ] + ] + }, + { + "title": "ARREST WARRANT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 238.06800000000004, + 254.34 + ], + [ + 369.64799999999997, + 254.34 + ], + [ + 369.64799999999997, + 268.11 + ], + [ + 238.06800000000004, + 268.11 + ] + ] + }, + { + "title": "Return", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 287.64, + 591.3 + ], + [ + 324.36, + 591.3 + ], + [ + 324.36, + 603.45 + ], + [ + 287.64, + 603.45 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Text", + 41 + ], + [ + "Line", + 35 + ], + [ + "SectionHeader", + 6 + ], + [ + "PageHeader", + 3 + ], + [ + "ListGroup", + 3 + ], + [ + "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/EFTA00084285" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084285/_page_0_Picture_155.jpeg b/marker2/ds9/EFTA00084285/_page_0_Picture_155.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..df6f1ec827994f4224b19183d551e8659e511597 --- /dev/null +++ b/marker2/ds9/EFTA00084285/_page_0_Picture_155.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:25b49c8f61490dbc3dd354ef7054980a66a14f42b2b93e0ad53719b8091af41e +size 3553 diff --git a/marker2/ds9/EFTA00084286/EFTA00084286.md b/marker2/ds9/EFTA00084286/EFTA00084286.md new file mode 100644 index 0000000000000000000000000000000000000000..610f9ec1044366769b1bdbb838b979fb74e694e2 --- /dev/null +++ b/marker2/ds9/EFTA00084286/EFTA00084286.md @@ -0,0 +1,231 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x UNITED STATES OF AMERICA GHISLAINE MAXWELL, Defendant. 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. 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*Southern District of New York* + +ACTING U.S. ATTORNEY AUDREY STRAUSS + +FOR IMMEDIATE RELEASE +Thursday, July 2, 2020 + + +CONTACT: U.S. ATTORNEY'S OFFICE +[REDACTED] +(212) 637-2600 + +NYPD +[REDACTED] + +FBI +[REDACTED] + +### **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 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 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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I have sent the below email addresses to the New Hampshire USAO with a request that those addresses receive invitations to the video conference. + +- • +- • +- • +- • +- • + +Best, + +From: Christian Everdell • + +Sent: Thursday, July 2, 20201:14 PM + +To: 'Jeff Pagliuca' ; Mark S. Cohen < >; Laura Menninger + +Cc: + +Subject: RE: SDNY indictment + +Mark and I would also like to listen in. As we mentioned, we will not be appearing (Larry Vogelman will), but we would like to hear the proceedings. Our emails are: and + +Thanks. + +From: Jeff Pagliuca imallto + +Sent: Thursday July 02 2020 12:50 PM + +To: ); Christian Everdell; Mark S. Cohen; Laura Menninger + +Cc: + +Subject: RE: SDNY indictment + +Please add and to the list. Thank you, + +Jeff + +![](_page_1_Picture_131.jpeg) + +[REDACTED] + [REDACTED] + [REDACTED] + [REDACTED] + [REDACTED] + +mation that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its attachments without reading or saving it in any manner. Thank you + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Thursday, July 2, 2020 10:54 AM +**To:** Jeff Pagliuca <[REDACTED]>; [REDACTED] <[REDACTED]>; Christian Everdell <[REDACTED]>; Mark S. Cohen <[REDACTED]>; Laura Menninger <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]> +**Subject:** RE: SDNY indictment + +Jeff, + +My understanding from the clerk's office is that if we provide your email address to the clerk, she will send you an invitation to the video conference. You will then be able to join the conference, but you would only observe and would not speak on the record. + +If you would like to do so, please let me know what email address(es) I should send to the clerk. + +Thanks, + +[REDACTED] + +[REDACTED] + Assistant United States Attorney + Southern District of New York + +[REDACTED] + [REDACTED] + [REDACTED] + [REDACTED] + +--- + +**From:** Jeff Pagliuca <[REDACTED]> +**Sent:** Thursday, July 2, 2020 12:45 PM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; Christian Everdell <[REDACTED]>; Mark S. Cohen <[REDACTED]>; Laura Menninger <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]> +**Subject:** RE: SDNY indictment + +[REDACTED], neither Laura Menninger nor I are admitted to practice in the District of New Hampshire and given that we had no notice of the arrest we have not submitted any request to appear pro hac. Accordingly, I doubt we can appear. I would + +Jeff + +![](_page_2_Picture_148.jpeg) + +Jeffrey S. Pagliuca +Haddon, Morgan and Foreman, P.C. + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +ivering it to the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its attachments without reading or saving it in any manner. Thank you + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Thursday, July 2, 2020 10:38 AM + +**To:** [REDACTED] <[REDACTED]>; Christian Everdell + +<[REDACTED]>; Mark S. Cohen <[REDACTED]>; Jeff Pagliuca <[REDACTED]> + +**Cc:** [REDACTED] <[REDACTED]> + +**Subject:** RE: SDNY indictment + +Chris, Mark, and Jeff: + +The clerk's office in the District of New Hampshire plans to send email invitations to the video conference for this afternoon's proceedings. The USAO in New Hampshire has asked us to gather the email addresses for the attorneys who will appear for the defense. Would you please let us know the names and email addresses of the attorneys who plan to join the video conference this afternoon? + +Thanks, + +[REDACTED] + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Thursday, July 2, 2020 11:08 AM + +**To:** Christian Everdell <[REDACTED]>; [REDACTED] <[REDACTED]>; Mark S. + +Cohen <[REDACTED]>; [REDACTED] + +**Cc:** [REDACTED] <[REDACTED]> + +**Subject:** RE: SDNY indictment + +Chris, + +[REDACTED] is having a brief connectivity issue and asked me to respond – we're available for a call at 11:15, and I'll send a dial-in momentarily. + +thanks, + +[REDACTED] + +Subject: RE: SDNY indictment + +Are you free for a call at 11:15? + +From: [rra + +Sent: Thursday, July 02, 2020 10:08 AM + +To: Christian Everdell; Mark S. Cohen' + +Cc: ) + +Subject: RE: SDNY indictment + +Following up, the District of New Hampshire has informed us that local counsel will need to appear for Ms. Maxwell at the presentment this afternoon. + +From: + +Sent: Thursday, July 2, 2020 9:20 AM + +To: + +Cc: + +Subject: SDNY indictment + +Chris, Mark, and Jeff, + +We are writing to inform you that the FBI arrested your client, Ghislaine Maxwell, this morning in Bradford, New Hampshire. I have attached the indictment and arrest warrant, which we are providing to you as a courtesy while we seek the formal unsealing of the indictment in SDNY this morning. We will let you know when a district judge is assigned in SDNY. The defendant is currently being transported for arrest processing by the FBI, and our current expectation is that she will be presented this afternoon in the District of New Hampshire, via remote proceedings. We will update you as we learn more. + +and I are available for a call later this morning, if that would be useful. 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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 (212) 637-2600. + +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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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. 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b/marker2/ds9/EFTA00084332/EFTA00084332.md @@ -0,0 +1,149 @@ +To: ' + +Subject: RE: 338 E. Washington Road, Bradford, NH + +Date: Mon, 06 Jul 2020 23:52:41 +0000 + +Inline-Images: image001.jpg: image002.jpg + +We can't use a trial subpoena with out a trial date — I do want this information for bail purposes, but I'm not sure how we could obtain it. We could ask to just call her and interview her and see what information she can provide (or if she can refer us to a non-lawyer involved in the process we could talk to). + +From: + +Sent: Monday, July 6, 2020 7:50 PM + +To: ) + +Subject: FW: 338 E. Washington Road, Bradford, NH + +We could serve a trial subpoena, I guess? But probably not a GJ subpoena?? And do we want this sooner rather than later, for use at the bail arg? (Also apologies if either of you has already moved ahead with this, my inbox remains a slight disaster, though to be fixed by the end of the day, come hell or high water.) + +From: (NY) (FBI) < > + +Sent: Monday, July 06, 2020 13:29 + +To: < )'; + +Cc: + +Subject: FW: 338 E. Washington Road, Bradford, NH + +Hey all, + +FYI...see below. The attorney who handled the purchase closing for 338 E. Washington Road, Bradford, NH. I spoke with her on the phone and she is willing to speak further after going through the proper channels. + +From + +Sent: Monday, July 6, 2020 12:04 PM + +To: (BS) (FBI) < + +Cc: . (NY) (FBI) < > + +Subject: RE: 338 E. Washington Road, Bradford, NH + +Thank you for the introduction and nice to meet you I am a real estate attorney in NH. I was retained by "Jen and Steve Marshal" and handled the purchase closing for Granite Reality, LLC which was the buying entity of the property located at 338 E. Washington Road, Bradford, NH where Ghislaine Maxwell was arrested on Thursday July 2, 2020. I handled the title and settlement for the closing and was retained for additional services. + +So that I do not breach my ethics obligations pursuant to the NH Bar, I presume you may proceed with issuing a subpoena for my file. + +Attorney at Law + +Admitted to Practice in NH and MA + +Phone + +Fat + +ClicI to watch our YouTube Channel—delivering content on real estate topics on a weekly basis! + +![](_page_1_Picture_6.jpeg) + +## Ce&brating 13 (Years of Service + +Locations: Bedford, NH — Concord, NH — Hampton, NH — Keene, NH — New London, NH — Windham, NH — Norwich, VT — Andover, MA + +Mailing Address For All Correspondence: + +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 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. + +From: (BS) (FBI) + +Sent: Monday, July 6, 2020 11:58 AM + +To + +Cc: . (NY) (FBI) < > + +Subject: RE: 338 E. Washington Road, Bradford, NH + +I hope that you had a nice weekend and good July 4th. CC'ed on this email is Special Agent ==. She will follow up with you directly about Ghislaine Maxwell. + +Thank you again for reaching out and don't ever hesitate to be in touch, + +Special Agent + +Federal Bureau of Investigation — Boston + +Thank you I appreciate your assistance. + +Happy Fourth! + +Attorney at Law-NH & MA + +From: (BS) (FBI) + +Sent: Friday, July 3, 2020 6:44 PM + +To + +Subject: Re: 338 E. Washington Road, Bradford, NH + +H + +I remember meeting! Thank you for reaching out! That was a great conference, I really enjoyed being part of it. I will reach out to the agents involved in that case and be in touch shortly (it will likely be Monday). + +Thanks again for reaching out, I hope that you are doing well! Have a great July 4th. + +Special Agent + +Federal Bureau of Investigation - Boston Division + +From + +Sent: Friday, July 3, 2020 5:34 PM + +To: (BS) (FBI) < + +Subject: 338 E. Washington Road, Bradford, NH + +Dear - + +We met at the Mortgage Banker's conference in Portsmouth, NH in February. + +I handled the real estate closing for 338 E. Washington Road, Bradford, NH where Ghislaine Maxwell was arrested yesterday. I have information regarding my legal representation that could be of interest. I am hoping you may be willing to connect me with an agent so that I may be helpful in providing my file. + +Thank you + +[REDACTED] + +Phone [REDACTED] + +Fax [REDACTED] + +[REDACTED] + +Click [REDACTED] to view our YouTube channel + +[REDACTED] + +*Celebrating 13 Years of Service* + +Locations: Bedford, NH – Concord, NH – Hampton, NH – Keene, NH – New London, NH – Windham, NH – Wilder, VT – Andover, MA + +Mailing Address For All Correspondence: [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. 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Cohen" + +Cc: ' " ' + +Subject: RE: SDNY indictment + +Date: Ilte, 07 Jul 2020 00:43:41 +0000 + +Attachments: 2020.07.06\_Letter to\_Judge\_Nathan.DOCX + +Attached is our letter to Judge Nathan. We will file before 9pm unless we hear otherwise from you. + +Thanks, + +Chris + +From: ) [mailto: + +Sent: Monday, July 06, 2020 5:36 PM + +To: Christian Everdell• Mark S. Cohen + +Cc: + +Subject: RE: SDNY indictment + +Chris and Mark, + +In light of Judge Nathan's order, are you available for a call this evening to discuss scheduling? We are available at 6, if that works for you. + +Thanks, + +From: Christian Everdell + +Sent: Monday, July 6, 20201:23 PM + +To: + +Cc: Mark S. Cohen + +Subject: RE: SDNY indictment + +Thanks, + +From: + +Sent: Monday, July 06, 2020 1:22 PM + +To: Christian Everdell + +Cc: Mark S. Cohen; + +Subject: RE: SDNY indictment + +Ms. Maxwell's BOP number is . My understanding is that she has arrived in SONY and will be housed at the MDC. + +Best, + +Assistant United States Attorney Southern District of New York + +From: Christian Everdell + +Sent: Monday, July 6, 20201:15 PM + +To: + +Cc: Mark S. Cohen + +Subject: RE: SDNY indictment + +Can you tell me what Ms. Maxwell's BOP number is? She is not in the BOP system yet. + +Thanks, + +Chris + +From: imailto + +Sent: Sunday, July 05, 2020 9:03 PM + +To: Christian Everdell + +Cc: Mark S. Cohen; + +Subject: RE: SDNY indictment + +Attached please find a copy of the letter we just filed on ECF. + +Thanks, + +From: + +Sent: Sunday, July 5, 2020 8:23 PM + +To: 'Christian Everdell' + +Cc: Mark S. Cohen > + +Subject: RE: SDNY indictment + +We can make that work, thanks. We will note in the letter that the parties propose the defense submission be due at 3pm on Thursday, any reply be due at 12pm on Friday, and the court appearance take place Friday afternoon. + +From: Christian Everdell + +Sent: Sunday, July 5, 2020 7:38 PM + +To: + +Cc: Mark S. Cohen > + +Subject: Re: SDNY indictment + +We will need until 3pm on Thursday. Let us know if that's a problem. + +Thanks, + +Chris + +Sent from my iPhone + +On Jul 5, 2020, at 6:40 PM, > wrote: + +Understood, thanks. Would you agree to a 12pm Thursday deadline for your submission, and a 12pm Friday deadline for any written response from us, followed by the arraignment and bail hearing Friday afternoon? If so, we'll propose that to the Court. + +We will reach out to Pretrial Services tomorrow to arrange for an interview. + +From: Christian Everdell + +Sent: Sunday, July 5, 2020 5:49 PM + +To: cz :; Mark S. Cohen + +Cc: tc >; < + +Subject: RE: SDNY indictment + +Thanks, We are planning to make a bail submission on Thursday, subject to being able to communicate with our client. So we will need your help to arrange an interview with Pretrial Services. + +From: S[n , + +Sent: Sunday, July 05, 2020 5:31 PM + +To: Christian Everdell' Mark S. Cohen + +Cc: + +Subject: RE: SDNY indictment + +Thanks Chris. We will request that the arraignment take place this Friday and will note your consent. + +Are you planning to file a written submission in support of a bail application in advance of Friday? If so, would it make sense for us to include a proposed briefing schedule in our letter? + +Along those same lines, please let us know if you need assistance coordinating an interview with Pretrial Services, which will need to take place in advance of any bail application. + +Sent: Sunday, July 5, 2020 5:25 PM + +To: >; Mark S. Cohen + +Cc: >; + +Subject: RE: SONY indictment + +Hi + +We would prefer that the arraignment take place on Friday, rather than Wednesday, and will consent to an exclusion of speedy trial time until Friday. I don't think a call is necessary, but let me know if you want to discuss. + +Thanks, + +Chris + +From: [mailto + +Sent: Sunday, July 05, 2020 5:18 PM + +To: Mark S. Cohen; Christian Everdell + +Cc: + +Subject: RE: SDNY indictment + +Chris and Mark, + +We are planning to submit a letter to Judge Nathan this evening informing her that the Marshals expect Ms. Maxwell to arrive in SDNY in time for a court appearance this Wednesday, requesting that the Court schedule an arraignment, and requesting the exclusion of time through the arraignment date. We intend to seek the exclusion of time both for the transportation of the defendant from another district and to allow for us to discuss the terms of a protective order to cover discovery in this case. + +If possible, we would like to include your views in that letter. Would you please let us know whether you have any preferences on scheduling and whether you will consent to the exclusion of speedy trial time? + +We are also happy to have a call if that would be useful. + +Thanks, + +From: Mark S. Cohen + +Sent: Friday, July 3, 2020 12:12 PM + +To: Christian Everdell + +Cc: >; + +Subject: Re: SDNY indictment + +Thanks very much, + +My mobile is 917-608-8612 + +Best + +Mark + +From: ) [mailto Sent: Friday, July 03, 2020 11:42 AM To: Christian Everdell• Cc: Subject: RE: SDNY indictment ; Mark S. Cohen + +Chris and Mark, + +We are working with the USMS in New Hampshire to add you both to the list of attorneys who may contact your client while she is detained there. To that end, the NH USMS have asked for the best phone numbers to contact you two. Would you please let me know what numbers to provide? + +Thanks, + +From: Christian Everdell + +Sent: Thursday, July 2, 2020 8:48 PM + +To: + +Mark S. Cohen < c>; + +Cc: ) + +Subject: RE: SDNY indictment + +Thanks, . We'll speak to you then. + +From: ) [mailto + +Sent: Thursday, July 02 2020 6:20 PM + +To: Christian Everdell• ; Mark S. Cohen; + +Cc: + +Subject: RE: SDNY indictment + +Chris, + +Some combination of the SDNY team will be available for a call tomorrow at 10am. We can use the below conference line: + +Dial-in: + +Passcode: + +Thanks, + +Assistant United States Attorney Southern District of New York + +Sent: Thursday, July 2, 2020 5:55 PM + +To: + +Mark S. Cohen < >; + +Cc: ) + +Subject: RE: SDNY indictment + +- + +Are you free for a call with Mark and me tomorrow at 10am? I realize it is a holiday, so we'll try to keep it brief. + +Let me know if that works for you. + +Thanks, + +Chris + +From: pa ri + +Sent: Thursday, July 02, 2020 4:18 PM + +To: Christian Everdell: ); Mark S. Cohen; + +Cc: + +Subject: Re: SDNY indictment + +Chris, + +We will need to put in a scheduling letter to the judge today. Would it be possible to discuss the below on a conference call together at 4:30? If so, we can use the same call in info as before. + +thanks, + +On Jul 2, 2020, at 15:04, wrote: + +Chris, + +In addition to our question regarding the exclusion of speedy trial time, we've been asked by chambers to ask whether the defense expects to make a bail application before the district judge, and if so, if you know when that application will occur. I realize you may not know the answer to those questions, and that the answer also may depend on precisely when the arraignment occurs, but we pass along those queries as requested by the Court. + +thank you, + +From: + +Sent: Thursday, July 02, 2020 11:08 + +To: Christian Everdell ; Mark S. + +Cohen + +Cc: + +Subject: RE: SONY indictment + +thanks, + +From: Christian Everdell + +Sent: Thursday, July 02, 2020 11:02 + +To: ; Mark S. Cohen + +Cc: + +Subject: RE: SDNY indictment + +Are you free for a call at 11:15? + +From: ) [mailto + +Sent: Thursday, July 02, 2020 10:08 AM + +To: Christian Everdell; Mark S Cohen• + +Cc: ); + +Subject: RE: SDNY indictment + +Following up, the District of New Hampshire has informed us that local counsel will need to appear for Ms. Maxwell at the presentment this afternoon. + +From: + +Sent: Thursday, July 2, 2020 9:20 AM + +To: + +Cc: + +Subject: SDNY indictment + +Chris, Mark, and Jeff, + +We are writing to inform you that the FBI arrested your client, Ghislaine Maxwell, this morning in Bradford, New Hampshire. I have attached the indictment and arrest warrant, which we are providing to you as a courtesy while we seek the formal unsealing of the indictment in SDNY this morning. We will let you know when a district judge is assigned in SDNY. The defendant is currently being transported for arrest processing by the FBI, and our current expectation is that she will be presented this afternoon in the District of New Hampshire, via remote proceedings. We will update you as we learn more. + +and I are available for a call later this morning, if that would be useful. Please let us know what time would be convenient for you. + +Thanks, + +Assistant United States Attorney Southern District of New York + +EFTA00084343 \ No newline at end of file diff --git a/marker2/ds9/EFTA00084336/EFTA00084336.metadata.json b/marker2/ds9/EFTA00084336/EFTA00084336.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1f4e7bf44d766ae98ae55ee104458f79a8e354fa --- /dev/null +++ b/marker2/ds9/EFTA00084336/EFTA00084336.metadata.json @@ -0,0 +1,260 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084336.pdf", + "engine": { + "marker_major": "2", + "marker_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": 8289, + "elapsed_seconds": 2.14, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Text", + 35 + ], + [ + "Line", + 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", + 55 + ], + [ + "Text", + 31 + ], + [ + "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": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "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": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "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": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "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": 5, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Line", + 38 + ], + [ + "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": 6, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 35 + ], + [ + "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": 7, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Text", + 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/EFTA00084336" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084344/EFTA00084344.md b/marker2/ds9/EFTA00084344/EFTA00084344.md new file mode 100644 index 0000000000000000000000000000000000000000..ba5672c528ebbbf67686e9b06850ca35cf932dac --- /dev/null +++ b/marker2/ds9/EFTA00084344/EFTA00084344.md @@ -0,0 +1,41 @@ +![](_page_0_Picture_2.jpeg) + +![](_page_0_Picture_4.jpeg) + +Christian R. I + +![](_page_0_Picture_6.jpeg) + +## VIA ECF. + +The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse + +![](_page_0_Picture_10.jpeg) + +July 6, 2020 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Dear Judge Nathan: + +On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter in response to the Court's order from earlier today regarding the scheduling of the arraignment, initial appearance, and bail hearing in this matter. Pursuant to the Court's order, we have attempted to contact our client at the Metropolitan Detention Center, but we have been unable to speak to her at this point. We will continue trying to contact her to discuss the topics raised in the Court's order. + +We anticipate that our client will be amenable to proceeding remotely, subject to us having the opportunity to speak to her. As directed by the Court, we have met and conferred with the Government regarding scheduling. Assuming our client agrees to proceed remotely, all parties will be able to proceed remotely on the morning of July 14, 2020. The defense will not be able to proceed on July 9, 2020. + +The Honorable Alison J. Nathan July 6, 2020 Page 2 + +Once we have spoken to our client, we will meet and confer further with the Government regarding a proposed briefing schedule. Assuming we are able to speak to our client tomorrow, we anticipate providing a joint proposed briefing schedule for the Court's consideration by the end of the day. + +Respectfully submitted, + +Is/ Mark S. Cohen + +Mark S. Cohen + +Christian R. Everdell + +COHEN & GRESSER LLP + +IMm + +cc: e-mail) (by e-mail) (by e-mail) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084344/EFTA00084344.metadata.json b/marker2/ds9/EFTA00084344/EFTA00084344.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..99809bb743d365eb6a8d18e7ba48dd9044534282 --- /dev/null +++ b/marker2/ds9/EFTA00084344/EFTA00084344.metadata.json @@ -0,0 +1,125 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084344.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1730, + "elapsed_seconds": 0.82, + "image_assets": [ + "_page_0_Picture_2.jpeg", + "_page_0_Picture_4.jpeg", + "_page_0_Picture_6.jpeg", + "_page_0_Picture_10.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA ECF.", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 69.156, + 243.81 + ], + [ + 125.31083679199219, + 243.81 + ], + [ + 125.31083679199219, + 258.68701171875 + ], + [ + 69.156, + 258.68701171875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 44 + ], + [ + "Line", + 22 + ], + [ + "Text", + 8 + ], + [ + "Picture", + 4 + ], + [ + "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", + 34 + ], + [ + "Line", + 17 + ], + [ + "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/EFTA00084344" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084344/_page_0_Picture_10.jpeg b/marker2/ds9/EFTA00084344/_page_0_Picture_10.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..ffccf1c002e9caf3e964c5c2e1bded1a8c2b285d --- /dev/null +++ b/marker2/ds9/EFTA00084344/_page_0_Picture_10.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:ce068c9efcd259e0a752360913f18c081c957c6b8497fc5165c56a4dc8888b3c +size 3058 diff --git a/marker2/ds9/EFTA00084344/_page_0_Picture_2.jpeg b/marker2/ds9/EFTA00084344/_page_0_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..0738556a3657e52e931b76b50c492b2f8d0b8e41 --- /dev/null +++ b/marker2/ds9/EFTA00084344/_page_0_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:eae6c41b3de1094805a75751268afc878670d396e637f26fcc2ba2c438c0e497 +size 2274 diff --git a/marker2/ds9/EFTA00084344/_page_0_Picture_4.jpeg b/marker2/ds9/EFTA00084344/_page_0_Picture_4.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..22bed9da3749998513e48e19a8c36b711c8344b0 --- /dev/null +++ b/marker2/ds9/EFTA00084344/_page_0_Picture_4.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:720d76ea997833d649627cb199f032d33f634f0f0dd08f178526ad7005705407 +size 2008 diff --git a/marker2/ds9/EFTA00084344/_page_0_Picture_6.jpeg b/marker2/ds9/EFTA00084344/_page_0_Picture_6.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..feb689196e895f2b8f2c8017513c85933b3450e0 --- /dev/null +++ b/marker2/ds9/EFTA00084344/_page_0_Picture_6.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:8173ebfa1856dd3a25d35b7ddcb9c6908af4d3760d1fcf210ef933f5b6bc635f +size 1752 diff --git a/marker2/ds9/EFTA00084346/EFTA00084346.md b/marker2/ds9/EFTA00084346/EFTA00084346.md new file mode 100644 index 0000000000000000000000000000000000000000..f8cad3a789d10730d208d25830640ee8e7b81f8e --- /dev/null +++ b/marker2/ds9/EFTA00084346/EFTA00084346.md @@ -0,0 +1,41 @@ +To: + +Cc: + +Subject: RE: Jeffrey Epstein / Private Jets + +Date: Tue, 07 Jul 2020 19:25:10 +0000 + +Thanks for sending along + +From: + +Sent: Tuesday, July 07, 2020 15:10 + +Subject: FW: Jeffrey Epstein / Private Jets + +He called and I asked him to send me an email. + +From: Michael Lyon + +Sent: Tuesday, July 7, 2020 3:02 PM + +To: + +Subject: Jeffrey Epstein / Private Jets + +Hello + +My name is Michael Lyon in Pittsfield Massachusetts. I am an owner of an aviation company (Lyon Aviation Inc) that flies people around the world irlpSvate jets. I have worked with a Customs Agent out of Albany NY in the past One of the tips I provided was on or about February 7th or 8th 2015. We transported a lone woman of Massachusetts to St. Thomas on February 07th 2015 from Boston and returned her on February 10th 2015. We found this odd that this woman was flying privately, because she didn't appear to be able to afford this flight that may have costs \$35,000. I suspected this woman might have or be transporting drugs. She was questioned for several hours by ST Thomas Customs on her return. The only info gathered was that she was an escort and not drug related. This woman was transported to and from St. Thomas on a private helicopter to a nearby island. + +Being in the private flying arena for 35 years one tends to learn patterns and flight requests. I was always keenly aware of one particular "Charter Broker ( Dan Ryan, owner of BIG FLY INC.MININIIIIINIS who appeared to be working for the same person (many years) and filling numerous requests to the island of St. Thomas from all different parts of the USA. A "Charter Broker" doesn't own or operate aircraft, but represents clients in finding aircraft for their particular missions. + +This particular flight that we performed on behalf of Dan Ryan always stuck in my head. One reason was the frequency of the requests to the same island and because these were great revenue requests. I always thought these flights were for someone in the St. Thomas region bringing in many guests and had to be quite wealthy. + +After the Epstein story broke the news, I instantly remembered the Boston St. Thomas flight and knew with almost certainty that Dan Ryan was the "CHARTER BROKER" fulfilling the requests to transport people into and of out of St. Thomas on behalf of Jeffrey Epstein or his representatives. I'm sure Dan will have passenger names and where he was being paid from. Again the requests originated in many parts of the USA and Los Angeles was one of the more favorite routes. I do prefer my name NOT be used if inquiring with Dan, but always happy to discuss with your agency. + +My contact is: + +Michael Lyon Lyon Aviation Inc Pittsfield Massachusetts + +Leading Private jet charter since 1980 with personal attention and service; safe, reliable, privately-owned flee... \ No newline at end of file diff --git a/marker2/ds9/EFTA00084346/EFTA00084346.metadata.json b/marker2/ds9/EFTA00084346/EFTA00084346.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..43370f89dde32ade6fc1546b194b378930998802 --- /dev/null +++ b/marker2/ds9/EFTA00084346/EFTA00084346.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084346.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2809, + "elapsed_seconds": 1.03, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Home - Lyon Aviation - Air Charter Services", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 49.572, + 38.07 + ], + [ + 270.4057312011719, + 38.07 + ], + [ + 270.4057312011719, + 51.84 + ], + [ + 49.572, + 51.84 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 40 + ], + [ + "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", + 7 + ], + [ + "Line", + 4 + ], + [ + "SectionHeader", + 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/EFTA00084346" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084348/EFTA00084348.md b/marker2/ds9/EFTA00084348/EFTA00084348.md new file mode 100644 index 0000000000000000000000000000000000000000..364d6bc617d15a79cbd20122375691fdd12b25e1 --- /dev/null +++ b/marker2/ds9/EFTA00084348/EFTA00084348.md @@ -0,0 +1,155 @@ +## EXHIBIT A + +![](_page_1_Picture_1.jpeg) + +IIADDON M O R G A N FOREMAN + +July 21, 2020 + +## VIA ECF + +The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 + +Haddon, Morgan and Foreman, t.c Jeffrey Pagliuca + +150 East 10th Avenue Denver, Colorado 80203 PH 303.831/364 FX 303.832.2628 vvw.hmflaw.com jpaglucaahmflaw.com + +Re: United States v. Ghislaine Maxwell, Case No. 20 Cr. 330 (MN), Local Criminal Rule 23.1 + +Dear Judge Nathan, + +On behalf of our client, Ghislaine Maxwell, we write to request that the Court enter an order prohibiting the Government, its agents and counsel for witnesses from making extrajudicial statements concerning this case. Although Ms. Maxwell is presumed innocent, the Government, its agents, witnesses and their lawyers have made, and continue to make, statements prejudicial to a fair trial. The Sixth Amendment to the United States Constitution guarantees an accused the right to an impartial jury. This fundamental guarantee is part of a criminal defendant's basic right to a fair trial, which requires that a defendant must be judged by a jury of her peers based on evidence presented at trial, not in the media. The Court, to safeguard the due process rights of the accused, has "an affirmative constitutional duty to minimize the effects of prejudicial pretrial publicity." Gannett Co. v. DePasquale, 443 U.S. 368, 378 (1979). This District has given effect to this Sixth Amendment right through Local Criminal Rule 23.1. Accordingly, Ms. Maxwell requests that the Court exercise its express power under Local Criminal Rule 23.1(h) and enter an Order requiring compliance with that rule to prevent further unwarranted and prejudicial pretrial publicity by the Government, its agents, and lawyers for alleged witnesses. + +## Legal Standard + +More than fifty years ago, warning of the danger of pretrial publicity to fair trials, the Supreme Court directed trial judges to take "such steps by rule and regulation that will protect their processes from prejudicial outside interferences. Neither prosecutors, counsel for defense, the accused, witnesses, court staff nor enforcement officers coming under the jurisdiction of the court should be permitted to frustrate its function." Sheppard v. Maxwell, 384 U.S. 333, 363 (1966) (emphasis added). + +July 21, 2020 + +Page 2 + +In an effort to protect the trial process from "prejudicial outside interferences," this Court promulgated Local Criminal Rule 23.1(a) which provides, in relevant part, that: + +> It is the duty of the lawyer or law firm, ... and government agents and police officers, not to release or authorize the release of nonpublic information or opinion which a reasonable person would expect to be disseminated by means of public communication, in connection with pending or imminent criminal litigation with which they are associated, if there is a substantial likelihood that such dissemination will interfere with a fair trial or otherwise prejudice the due administration of justice. + +To avoid any confusion this Court identified seven "subject matters" that "presumptively involve a substantial likelihood that their public dissemination will interfere with a fair trial or otherwise prejudice the due administration of justice." Id. at (d). Accordingly, lawyers for parties and witnesses and their agents are prohibited from publicly disseminating information concerning: + +- (1) The prior criminal record (including arrests, indictments or other charges of crime), or the character or reputation of the accused...; +- (2) The existence or contents of any confession, admission or statement given by the accused, or the refusal or failure of the accused to make any statement; +- (3) The performance of any examinations or tests or the accused's refusal or failure to submit to an examination or test; +- (4) The identity, testimony or credibility of prospective witnesses, except that the lawyer or law firm may announce the identity of the victim if the announcement is not otherwise prohibited by law; +- (5) The possibility of a plea of guilty to the offense charged or a lesser offense; +- (6) Information the lawyer or law firm knows is likely to be inadmissible at trial and would if disclosed create a substantial likelihood of prejudicing an impartial trial; and +- (7) Any opinion as to the accused's guilt or innocence or as to the merits of the case or the evidence in the case. + +Id. at (d)(1-7) (emphasis added). + +July 21, 2020 + +Page 3 + +## Recent Prejudicial Public Statements by the Government, its Agents and Counsel to Prospective Witnesses + +Recent public statements by the Government, its agents and counsel for prospective witnesses have included presumptively prejudicial information. + +On July 2, 2020 Ms. Maxwell was arrested without notice to her lawyers who had been in active communication with the Government for one year. Because plain vanilla surrenders lack the fanfare and attendant media coverage afforded to secret, armed, raids at dawn, the Government chose to invade Ms. Maxwell's New Hampshire residence, arrest her, and stage a media presentation that included numerous statements that prejudice Ms. Maxwell's right to a fair trial. + +Immediately following Ms. Maxwell's arrest, Acting U.S. Attorney Audrey Strauss held a press conference in which she commented on Ms. Maxwell's credibility and her incorrect opinions concerning "guilt or innocence or as to the merits of the case or the evidence in the case" in violation of Local Rule 23.1(d)(1), (4) and (7): + +Per the New York Law Journal: + +'Maxwell lied because the truth, as alleged, was almost unspeakable,' Strauss said at a press conference announcing the charges. `Maxwell enticed minor girls, got them to trust her and then delivered them into the trap that that she and Epstein had set for them. She pretended to be a woman they could trust, all the while she was setting them up to be sexually abused by Epstein and, in some cases, by Maxwell herself." + +As reported in the Washington Post, + +Strauss, the acting U.S. attorney in Manhattan, said the socialite told that lie and others in deposition because the truth `was almost unspeakable.' + +Acting U.S. Attorney Audrey Strauss called the sex abuse described in the Maxwell case `the prequel' to the charges they lodged against Epstein.... + +Maxwell played a critical role in helping Epstein to identify, befriend, and groom minor victims for abuse' ... `In some cases Maxwell participated in the abuse itself.'2 + +https://www.law.corninewyorklawjournal/2020/07/02/ghislaine-maxwell-arrested-inconnection-with-jeffrey-epstein-sex-trafficking-ringfislreturn=202006 14124921 + +2 https://www.washingtonpost.comMational-security/ghislaine-maxwell-arrested-jeffreyepstein/2020/07/02/20c74502-bc69-11ea-8cf5-9c1b8d7f84c6 story.html + +July 21, 2020 + +Page 4 + +Although Ms. Strauss sprinkled her comments with the phrase "as alleged," she presented certain of her statements as fact? Regardless, after Ms. Strauss's remarks, FBI Special Agent went even further, calling Ms. Maxwell "one of the villains in this investigation" and compared her to a snake that "slithered away to a gorgeous property in New Hampshire." Thus, ligimmoffers the Government's, again flatly wrong, opinions about character and guilt while, at the same time, invoking a semi-biblical reference involving a snake slithering away to a garden in New Hampshire. These types of comments, which serve no compelling law enforcement or investigatory purpose, are prohibited by the local rules of this District. + +New York attorney David Boies and his partner Sigrid McCawley, who represent several witnesses in this matter, have also made public and presumptively prejudicial statements in recent days, notwithstanding the fact that such conduct is prohibited by Local Rule 23.1, which applies to lawyers practicing in this District, generally, and lawyers for witnesses, specifically. See Rule 23.1(a) and (b). + +As reported by the Washington Post, Mr. Boies expressed his views on the prohibited subject of "the possibility of a plea of guilty to the offense charged or a lesser offense" in violation of sections (d)(5) and (7) of the Rule: + +Boies said he thinks Maxwell will be `under tremendous pressure to cooperate' as she looks for ways to shave time off what may be a significant prison sentence. Maxwell could potentially help prosecutors shed light on Epstein's dealings with other wealthy and influential people who may have had encounters with underaged victims, he said, adding `There were a lot of people with a lot of public stature who were involved with Epstein!' + +Ms. McCawley echoed Mr. Boies, saying that, "The pain [Maxwell] has caused will never go away but today is a step toward healing." Id. + +Bradley Edwards, another attorney representing witnesses in this matter made similar presumptively prejudicial statements following Ms. Maxwell's arrest:5 + +'The reality of how this organization worked was that 99.9% of it was orchestrated for Jeffrey Epstein's personal sexual satisfaction. So to the degree that um there was a main facilitator that started the whole thing, it was Ghislaine. + +3 A purported transcript of the press conference is contained on the intemet at https://www.rev.comiblogAranscripts/announcement-transcript-of-charges-against-ghislainemaxwell-in-new-york-jeffrey-epstein-associate-arrested. + +hups://www.washingtonpost.cominational-security/ghislaine-maxwell-arrested-jeffreyepstein/2020/07/02/20c74502-bc69-11ea-8cf5-9c1b8d7f84c6 story.html + +https://www.youtube.com/watch?v=mDKHdzix2kO + +July 21, 2020 + +Page 5 + +So to cooperate in the way that that kind of rumors out there would mean that she's cooperating downwards. She'd be cooperating with people who are much less culpable than her. Will she name names to try to shave years off of what would be a lengthy prison sentence maybe, I think you should probably expect that if she's going to share information that's going to actually help her, it's probably gonna be about unrelated crimes that she may be aware about because with respect to this particular operation, in terms of living people, she's as high as it gets. ... I think like most of my clients would really hope that she does cooperate, at least shares the information that she has. I mean I know that it would only be to help herself but the public deserves to know who was involved besides her and Jeffrey Epstein, and only she knows that. + +The violations of Rule 23.1 did not stop after Ms. Maxwell's arrest and detention. Following the detention hearing on July 14, 2020, Mr. Boies, counsel for one of the accusers who spoke at the hearing, commented on the content of the hearing. As reported by Bloomberg, Mr. Boies offered his gratuitous critique of defense counsel, commented on the credibility of Ms. Maxwell and his client, and commented on what Mr. Boies considers "evidence" in this case, all in violation of subsections (1), (4), (6), and (7) of the Rule: + +That's a dan erous tactic that might backfire at trial, said David Boies, who represents and several other women who say they were sexually abused by Epstein and Maxwell. ... It's "a tone-deaf argument" that cost Maxwell her credibility, said Boies, who listened to the hearing remotely. + +'To mount a `blame the victim' defense, particularly in today's world and trying to blame these girls for what happened is so contrary to the evidence, is so contrary to people's normal sense of morality,' Boies said. 'I think that's just going to enrage a jury if she goes to trial -- which I would not do if I were representing her.' + +Boies said he was confident would stand up to cross-examination if there's a trial. , who addressed the court by telephone, urged the judge not to grant Maxwell bail, calling her a `sexual predator who groomed and abused me.' Maxwell `lied under oath and tormented her survivors,' said. Boies said that was a 16-year-old who 'wanted to go to college' when she met Maxwell. `Maxwell and Epstein tellMand her mother 'we're having a group of high school students to this ranch to help them get into college,' Boies said. 'But wher gets there, there are no high school students, all these claims are fraudulent and she's in this isolated place in New Mexico.'6 + +6 https://www.bnnbloomberg.ca/ghislaine-maxwell-may-play-the-victim-card-in-trialdefense-1.1465631 + +July 21, 2020 + +Page 6 + +Mr. Boles and Ms. McCawley gave on-air interviews with ABC News following Ms. Maxwell's detention that contained repeated, presumptively prejudicial quotes, including: 7 + +Boles: Remember these girls were abused twice, once sexually years ago and then a second time when Epstein and Maxwell and all their enablers began these vicious attacks on their credibility. ... No question about it. Maxwell knows where a lot of the bodies are buried. If I was somebody who had participated in their sex trafficking, um, I would not be sleeping easily tonight. + +Boles: I think that [the accusers] want to see her go to trial. On the other hand, the arrest and conviction that would come from a plea deal is an enormous step and I think they also recognize that Jeffrey Epstein and Maxwell did not act alone. There are lots of other people that need to be brought to justice. + +McCawley: I think that the prosecutors in the Southern District of New York have done an incredible job and they're being very meticulous, they want to make sure that the Indictments stick. ...They took a lot of time to be very careful and thoughtful and that gives me a lot of hope that she will remain in prison for the remainder of her life. ... This morning was a very joyful and tearful filled morning, it was a wonderful moment in my journey with these survivors, to be able to call them and tell them that the one person's who's been out in the public without being held accountable was finally in prison....She was really, Ghislaine was really the central figure, so she worked hand-in-hand with Jeffrey Epstein to be able to facilitate these crimes over the course of more than two decades; and she was the main person who assisted him and allowed him to be able to perpetrate so many crimes against young females. + +These comments violate subsections (6) and (7) of the Rule. + +It appears that given any opportunity lawyers associated with the prosecution of this case will offer any opinion that damages Ms. Maxwell's opportunity for a fair trial. Entry of an order prohibiting extrajudicial statements, therefore, is a necessary remedy to avoid further dissemination of prejudicial information. The Court, under Local Criminal Rule 23.1(h) should enter an Order, punishable by contempt, that all lawyers associated with this case, and their agents, comply with the Rule and refrain from publicly commenting on the seven prohibited topics identified in subsection (d). + +7 https://abcnews.go.corn/US/ghislaine-maxwell-epsteins-alleged-recruiter-private-battlepublic/story?id=7 1705375 + +July 21, 2020 + +Page 7 + +Respectfully Submitted, + +![](_page_7_Picture_5.jpeg) + +Jeffrey S. Pagliuca + +cc: + +U.S. Attorney's Office for the Southern District of New York + +Mark Cohen + +Christian Everdell + +Cohen & Gresser LLP + +Laura A. 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+ +**Fax No.** + +**Telephone No.** + +![](_page_1_Picture_10.jpeg) + +**FROM: Sigrid S. McCawley, Esq.** + +**DATE: February 26, 2016** + +**RE: .r . Maxwell, Case no. 15-cv-07433-RWS** **Total Number of Pages: 26** + +**(including this cover sheet)** + +**MESSAGE: Attached please find a copy of my email transmission to you from today at 12:10 pm, along with the accompanying Agreed Protective Order in both redline and clean version. Thank you.** + +#### THE ATTORNEY-CLIENT AND/OR ATTORNEY WORK-PRODUCT PRIVILEGES + +This facsimile transmission is intended solely for the above-named recipient and may contain confidential information which is exempt from disclosure and protected by the attorney-client and/or attorney work-product privileges. My unauthorized use or disclosure is strictly prohibited and may result in civil and/or criminal liability. limy of the information contained in this transmission is misdirected to you, pkase call (954) 356-0011 collect and mad such information back to us. Thank you. + +**United States District Court +Southern District Of New York** + +----- +[REDACTED] + +**Plaintiff,** + +v. + +**15-cv-07433-RWS** + +**Ghislaine Maxwell,** + +**Defendant.** + +----- + +**AGREED PROTECTIVE ORDER** + +Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information, including sensitive personal information relating to a victim of sexual abuse, copyright or trade secrets, commercially sensitive information, or proprietary information. + +**I. Purposes And Limitations** + +(a) The Parties acknowledge that this Order does not confer blanket protections on all disclosures during discovery. Designations under this Order shall be made sparingly, with care, and shall not be made absent a good faith belief that the designated material satisfies the criteria set forth herein. If it comes to a Designating Party's attention that designated material does not qualify for protection at all, or does not qualify for the level of protection initially asserted, the Designating Party must promptly notify all other parties that it is withdrawing or changing the designation. + +**IT IS ORDERED:** + +- 1. This Protective Order shall apply to all documents, materials, and information, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure. +- 2. As used in this Protective Order, "document" is defined as provided in FED.R.CIV.P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term. +- 3. Information designated "CONFIDENTIAL" shall be information that is confidential and is covered by common law and statutory privacy protections of + - (a) plaintif and (b) defendant Ghislaine Maxwell or any non-party that was subject to sexual abuse. +- 4. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case and any related matter, including but not limited to, investigations by law enforcement. +- 5. CONFIDENTIAL documents, materials, and/or information (collectively "CONFIDENTIAL INFORMATION") shall not, without the consent of the party producing it or further Order of the Court, be disclosed except that such information may be disclosed to: + - a. attorneys actively working on this case; + - b. persons regularly employed or associated with the attorneys actively working on this case whose assistance is required by said attorneys in the preparation for trial, at trial, or at other proceedings in this case; + +- c. the parties; +- d. expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, trial or other proceedings in this case; +- e. the Court and its employees ("Court Personnel") in this case; +- f. stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action; +- g. deponents, witnesses, or potential witnesses; +- h. any person (1) who authored or received the particular Protected Material; (2) who has or had at any point in time access to the Protected Material outside of the context of this action; or (3) for which there is a good faith basis to conclude that the individual has earlier received or seen such Protected Material; and +- i. any other persons by written agreement of the parties or by Order of a Court of competent jurisdiction. +- 6. Prior to disclosing any CONFIDENTIAL INFORMATION to any person listed above (other than counsel, persons employed by counsel, Court Personnel and stenographic reporters), counsel shall provide such person with a copy of this Protective Order and obtain from such person a written acknowledgment stating that he or she has read this Protective Order and agrees to be bound by its provisions. All such acknowledgments shall be retained by counsel and shall be subject to in camera review by the Court if good cause for review is demonstrated by opposing counsel. + +- 7. Documents are designated as CONFIDENTIAL by placing or affixing on them (in a manner that will not interfere with their legibility) the following or other appropriate notice: "CONFIDENTIAL." Discovery material designated CONFIDENTIAL shall be identified by Bates number. To the extent practical, the respective legend shall be placed near the Bates number. +- 8. Designation of a document as CONFIDENTIAL INFORMATION shall constitute a representation that such document has been reviewed by an attorney for the designating party, that there is a valid and good faith basis for such designation, made at the time of disclosure or production to the receiving party, and that disclosure of such information to persons other than those permitted access to such material would cause a privacy harm to the designating party. +- 9. Whenever a deposition involves the disclosure of CONFIDENTIAL INFORMATION, the deposition or portions thereof shall be designated as CONFIDENTIAL and shall be subject to the provisions of this Protective Order. Such designation shall be made on the record during the deposition whenever possible, but a party may designate portions of depositions as CONFIDENTIAL after transcription, provided written notice of the designation is promptly given to all counsel of record within thirty (30) days after notice by the court reporter of the completion of the transcript, and until the expiration of such thirty (30) days after notice by the court reporter of the + +completion of the transcript, no party or counsel for any such party may share the contents of the deposition outside the limitations of this Protective Order. + +- 10. Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. + +#### 11. Challenging Designations Of Protected Material + +- (a) A Party shall not be obligated to challenge the propriety of any designation of Discovery Material under this Order at the time the designation is made, and a failure to do so shall not preclude a subsequent challenge thereto. Moreover, failure to challenge the designation of any Discovery Material as CONFIDENTIALshall not in any way constitute an admission that such material contains any competitively sensitive information, trade secret information, or other protectable material. + - (b) In the event that counsel for the Party receiving Protected Material objects to the CONFIDENTIAL designation of any or all such items, said counsel shall provide the Producing Party and, if different, the Designating Party written notice of, and the basis for, such objections. The Parties will use their best efforts to resolve such objections among themselves. Should the Receiving Party, the Producing Party and, if different, the Designating Party be unable to resolve the + +objections, the Receiving Party may seek a hearing before this Court with respect to the propriety of the designation. The Designating Party will cooperate in obtaining a prompt hearing with respect thereto. Pending a resolution, the discovery material in question shall continue to be treated as Protected Material as provided hereunder. The burden of proving that Discovery Material is properly designated shall at all times remain with the Designating Party. + +- 12. At the conclusion of this case, unless other arrangements are agreed upon, each document and all copies thereof which have been designated as CONFIDENTIAL shall be returned to the party that designated it CONFIDENTIAL, or the parties may elect to destroy CONFIDENTIAL documents. Where the parties agree to destroy CONFIDENTIAL documents, the destroying party shall provide all parties with an affidavit confirming the destruction. +- 13. With respect to any Discovery Material produced by such non-party, the non-party may invoke the terms of this Order in writing to all Parties by designating Discovery Material "CONFIDENTIAL". Any such Protected Material produced by the non-party designated "CONFIDENTIAL" shall be subject to the restrictions contained in this Order and shall only be disclosed or used in a manner consistent with this Order. +- 14. In the event that any Producing Party inadvertently produces Discovery Material eligible for designation as CONFIDENTIAL without such designation, the Parties agree that the Producing Party may retroactively apply the correct designation. If a + +Producing Party makes a subsequent designation, the Receiving Party will treat the Protected Material according to the retroactive designation, including undertaking best efforts to retrieve all previously distributed copies from any recipients now ineligible to access the Protected Material. + +- 16. Limitations. Nothing in this Order shall restrict in any way the use or disclosure of Protected Material by a Receiving Party (a) that is or has become publicly known through no fault of the Receiving Party; (b) that is lawfully acquired by or known to the Receiving Party independent of the Producing Party; (c) that was previously produced, disclosed, and/or provided by the Producing Party to the Receiving Party or a non-party without an obligation of confidentiality and not by inadvertence or mistake; (d) with the consent of the Producing Party and, if different, the Designating Party; (e) pursuant to Order of the Court; or (f) for purposes of law enforcement.15. This Protective Order shall have no force and effect on the use of any CONFIDENTIAL INFORMATION at trial in this matter.This Protective Order may be modified by the Court at any time for good cause shown following notice to all parties and an opportunity for them to be heard. + +BY THE COURT + +UNITED STATES DISTRICT JUDGE \ No newline at end of file diff --git a/marker2/ds9/EFTA00084356/EFTA00084356.metadata.json b/marker2/ds9/EFTA00084356/EFTA00084356.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0301e5f6a9f77086fdaa0cdcc19c013590852da2 --- /dev/null +++ b/marker2/ds9/EFTA00084356/EFTA00084356.metadata.json @@ -0,0 +1,604 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084356.pdf", + "engine": { + "marker_major": "2", + "marker_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": 11222, + "elapsed_seconds": 5.89, + "image_assets": [ + "_page_1_Picture_4.jpeg", + "_page_1_Picture_10.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "EXHIBIT D", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 228.276, + 381.51 + ], + [ + 386.9979553222656, + 381.51 + ], + [ + 386.9979553222656, + 412.98394775390625 + ], + [ + 228.276, + 412.98394775390625 + ] + ] + }, + { + "title": "Bows, SCHILLER & FLEXNER LLP", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 138.924, + 80.4178466796875 + ], + [ + 464.40521240234375, + 80.4178466796875 + ], + [ + 464.40521240234375, + 104.05718994140625 + ], + [ + 138.924, + 104.05718994140625 + ] + ] + }, + { + "title": "FACSIMILE COVER SHEET", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 206.856, + 207.34295654296875 + ], + [ + 394.6973876953125, + 207.34295654296875 + ], + [ + 394.6973876953125, + 223.1214599609375 + ], + [ + 206.856, + 223.1214599609375 + ] + ] + }, + { + "title": "THE ATTORNEY-CLIENT AND/OR ATTORNEY WORK-PRODUCT PRIVILEGES", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 148.71599999999998, + 688.5 + ], + [ + 450.8013916015625, + 688.5 + ], + [ + 450.8013916015625, + 698.8694458007812 + ], + [ + 148.71599999999998, + 698.8694458007812 + ] + ] + }, + { + "title": "United States District Court Southern District Of New York", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 216.036, + 86.67 + ], + [ + 381.276, + 86.67 + ], + [ + 381.276, + 115.01999999999998 + ], + [ + 216.036, + 115.01999999999998 + ] + ] + }, + { + "title": "AGREED PROTECTIVE ORDER", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 206.24400000000003, + 341.82 + ], + [ + 389.84400000000005, + 341.82 + ], + [ + 389.84400000000005, + 355.59000000000003 + ], + [ + 206.24400000000003, + 355.59000000000003 + ] + ] + }, + { + "title": "I. 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January 18. 2020 I 12.O4am I Updated + +Jeffrey Epstein + +nn + +A woman claiming she was Jeffrey Epstein's "first-known victim" says she was sexually abused by the now-dead pedophile + +— who called himself her "Godfather" — when she was 13 years old. + +Jane Doe met Epstein and his friend. Ghislaine Maxwell, in the summer of 1994 at Michigan's Interlochen Arts Camp, where + +she was in voice training, according to newly filed court papers suing Epstein's estate and Maxwell. + +The duo quickly took her under their wing, taking her to movies and on shopping trips in her home state of Florida and all + +the while grooming her for abuse, the Manhattan federal court suit says. + +Epstein "started to slowly display his pedophilic ways when shopping with Doe and Maxwell. Instead of letting Doe pick out clothes she wanted to wear, Epstein insisted that she pick out and wear little children's cotton underwear." the suit says. + +The attacks escalated, the court papers claim. The financier would regularly sexually assault her and force her to perform sex acts in Palm Beach, New York City and his New Mexico ranch, always traveling to the locations on his private plane + +dubbed the "Lolita Express." + +At 16, Epstein put Doe up in one of his apartments in New York City — near his own townhouse, where he would allegedly + +rape her the next year. + +A I LI I + +Feds finally start investigating Jeffrey Epstein's gal pal Ghislaine + +Maxwell + +"In 1997, while at Epstein's townhouse on 9 East 71st Street in the City of New York. Epstein asked 17-year-old Doe if she had a boyfriend. Doe replied that she did not," the lawsuit reads. "Epstein responded that when she did have a boyfriend she + +would want the sex to be 'good' and that she should 'get it over with already; meaning lose her virginity." + +"Despite Doe's resistance, Epstein then pushed Doe down onto her stomach and raped her. From that point forward for several years in New York. Epstein raped Doe on multiple occasions." the papers claim, noting Maxwell was often present + +when the abuse took place. + +The court papers also claim Epstein introduced her to President Trump when she was 14 years old, allegedly elbowing + +Trump and saying, "This is a good one, right?" + +"Trump smiled and nodded in agreement." the suit states. + +A spokesperson for the president did not immediately return a request for comment. + +Doe is suing Epstein's estate, alleging sexual assault, sexual battery, false imprisonment and other charges. Her complaint + +joins over a dozen filed by other women claiming they were trafficked and abused by the multi-millionaire. + +Epstein was found dead in his jail cell in August while awaiting trial for sex trafficking. His death was officially ruled a suicide + +by hanging. + +Lawyers for Maxwell and Epstein's estate did not immediately return emails. + +MED LIND:" COURTS. DONALD TRUMP. GHISLAINE MAXWELL JEFFREY EPSTEIN, LAWSUITS, PEDOPHILES, SEXUAL ABUSE, 1/18/20 + +Epstein, Maxwell wanted me to have surrogate baby: + +Former teen "sex slave says she finally fled Jeffrey Epstein and Ghislaine Maxwell after three years, + +when they asked her, at age 19. to bear their surrogate baby. + +just 17, was revealed by her attorney, Bradley Edwards, in his new memoir, "Relentless Pursuit." + +"It was the final straw," Edwards writes in an excerpt published in the Daily Mail. + +"She knew she had to escape." + +FILED UNDER GHISLAINE MAXWELL JEFFREY EPSTEIN, PRINCE ANDREW, 3/22/20 + +Socialite Ghislaine Maxwell 'groped a 16-year-old girl + +during a naked massage,' victims' lawyer says + +dailvmail.co.uk/news/article-8163681/Socialite-Ghislaine-Maxwell-eroped-16-vear-old-rad-naked-massaae-victims- + +lawyer-says.html + +March 28. 2020 + +Socialite Ghislaine Maxwell 'groped a 16-year-old girl during a + +naked massage while Jeffrey Epstein watched,' lawyer who + +dedicated his life to nailing Prince Andrew's paedophile friend + +claims in new book + +• Ghislaine Maxwell, 58, allegedly sexually assaulted 16-year-old + +• It reportedly happened at paedophile Epstein's 7,5OO-acre New Mexico + +ranch + +• A lawyer for more than 20 of Epstein's victims has made the allegation + +By Mark Hookham For The Mail On Sunday + +Published: 18:03 EDT, 28 March 2O2O I Updated: 15:59 EDT, 2 July 2O2O + +• • + +• e-mail + +• + +713 shares + +Socialite Ghislaine Maxwell allegedly groped a teenage girl during a naked massage while + +paedophile Jeffrey Epstein watched, a new book claims. + +Maxwell, 58, allegedly sexually assaulted 16-year-old at Epstein's 7,5OO-acre ranch in New Mexico, according to the book by Bradley Edwards, a lawyer for more than + +2O of Epstein's victims. + +The book, from which we are summarising stories in The Mail on Sunday, details + +Maxwell's alleged role in recruiting and grooming underage girls for Epstein. According to + +some accounts, she was even involved in some of the abuse herself. + +Ghislaine Maxwell, 58, attending to an Alzheimer's Association event in New York in 2010 + +It raises serious questions as to why Maxwell, whose whereabouts have been a mystery for months, has never been charged with any wrongdoing. She has always maintained that + +allegations against her are abhorrent and untrue. + +The book also claims that: + +Maxwell, Epstein's ex-girlfriend, was at the wedding of former US President Bill + +Clinton's daughter Chelsea in July 2010, a year after Epstein was released from jail as + +a convicted sex offender; + +She loved to take nude photographs of girls and allegedly took many of the pictures + +displayed on the walls of Epstein's mansions. + +According to one witness, she felt `indebted' to Epstein for helping her following the + +mysterious death in 1991 of her father, disgraced tycoon Robert Maxwell; + +Epstein `wasn't beyond killing someone' to keep his sex addiction alive, the witness + +claimed. + +now 4o, helped keep Epstein behind bars last July after giving evidence + +about her ordeal as a teenager during a bail hearing. The financier was found dead in his cell the following month. is now suing Epstein's estate and Maxwell in the New + +York district court for damages. + +According to Lestimony, detailed in the book, she was flown to the financier's + +vast Zorro Ranch after he offered to pay for her to attend a summer educational + +programme in Thailand. + +1 + +Prince Andrew pictured with his arm around Queen's 'favourite son' of having sex with her + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 10 of 161 + +5/6 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 11 of 161 + +616 + +When will feds arrest Jeffrey Epstein `fixer' Ghislaine Maxwell? + +By Ber Feuerherd May 28.2020 I 4:l7pm I Updated + +Jeffrey Epstein and Ghislaine Maxwell Penick McMullan via Getty image.. + +Nine months after Attorney General William Barr warned that Jeffrey Epstein's co-conspirators "should not rest easy," the pedophile's alleged madam. Ghislaine Maxwell, remains at large — and is using a potential criminal investigation to thwart + +civil action against her. + +Maxwell is currently a co-defendant in several civil cases brought by alleged Epstein sex-trafficking victims. + +Among them i who claims in her suit against Maxwell and the proprietors of Epstein's estate that she was + +lured to his New Mexico ranch as a teenager and sexually abused by the pair. + +According to the suit, Maxwell allegedly forcer to undress in view of Epstein after promising to give her a massage. + +gShislaine Maxwell + +Paul Eltumouge:Patnsk McMullan Na Getty Images + +But the former fixer has successfully dodged a grilling in the case, citing an ongoing criminal investigation into co- + +conspirators of Epstein — all while not admitting she herself is being probed by the feds. + +An investigation into Epstein's accomplices was alluded to by Barr days after the pedophile's suicide in a Lower Manhattan + +lockup, and has been mentioned repeatedly by the US Attorney's Office in New York. according to court filings. + +A spokesperson for the Southern District of New York declined to comment on the investigation. + +Maxwell's attorney cited the investigation in an effort to block her testimony in theMase. + +SE A + +Ghislaine Maxwell wins questioning delay in sexual + +battery suit + +"The Southern District of New York has publicly and repeatedly announced its 'ongoing' criminal investigation into alleged Epstein 'co-conspirators' on the same topic as Plaintiff alleges in this case," Maxwell's attorney wrote in a May13 letter to + +Manhattan federal Judge Debra Freeman seeking to stay discovery in the case. + +"Denial of a stay, particularly a stay of Ms. Maxwell's deposition, pending outcome of the criminal investigation could impair + +her Fifth Amendment privilege against self-incrimination: added her attorney, Laura Menninger. + +attorney, David Boies, noted in his response that Maxwell has not publicly admitted she herself is the center of a + +federal investigation, but is nevertheless using it to shield herself. + +"Maxwell has provided no information about the subject matter of the criminal investigation into Epstein's co-conspirators. the status of the investigation, or even disclosed whether she herself is a target of the Southern District's investigation," + +Boies wrote. + +Epstein investigators contacted by 'dozens' since + +his death + +Freeman agreed Maxwell could potentially incriminate herself by giving a deposition and ordered that she not be required + +to sit for one as part of the suit. + +the \$570 single speed + +tokyobike + +Maxwell, who is apparently in hiding, has not given testimony or a public statement since Epstein's arrest and suicide. + +Attorneys forMand Maxwell did not immediately respond. + +IL E r) GHISLAINE MAXWELL, JEFFREY EPSTEIN, LAWSUITS, SEX TRAFFICKING, WILLIAM BARR, 5/28/20 + +Ghislaine Maxwell felt no guilt in procuring girls for + +Jeffrey Epstein, claims friend + +MI dailymail.co.ukffemailiarticle-8384165/Ghislaine•Maxwell-felt-no-guilt-orocuring-airls-Jeffrev-Eostein-claims- + +friend.htrnl + +June 3, 2020 + +• US\_based Christina Oxenberg, 57, has spoken out in new documentary + +• Claims Ghislaine Maxwell felt 'no guilt' in procuring girls for Jeffrey Epstein + +• reveals she 'feared for her life' at the hands of Epstein and + +Maxwell + +• Who Killed Jeffrey Epstein? premieres at iipm Saturday 6th June on Quest + +Red and dplay + +• + +• e-mail + +• + +592 shares + +Ghislaine Maxwell felt no guilt in procuring girls for Jeffrey Epstein to satisfy his + +'incredible sex drive,' Prince Andrew's distant cousin has claimed - adding that 'if anything, + +she was proud.' + +In Quest Red's new true crime documentary special Who Killed Jeffrey Epstein? it is alleged that socialite Ghislaine Maxwell - Epstein's former partner - procured girls for + +Epstein to 'satisfy his insatiable sex drive.' + +Socialite writer Christina Oxenberg, 57, from the US, who is a friend of Maxwell, notes that + +Maxwell felt no guilt in procuring girls for his pleasure. + +'She says he has an incredible sex drive, he has to have three orgasms a day, so I help him out by bringing in the females,' explains Christina. 'She felt no compunction about telling + +me this, if anything she was proud.' + +Christina is the daughter of a Serbian princess and sister of the Hollywood actress, + +Catherine Oxenberg - who rescued her eldest daughter India, now 28, from the Nxivm sex + +cult run by its leader, Keith Raniere, after an 18 month battle. + +India was among the women he recruited under the guise of offering them self-help courses. Her actress mother pulled her out of it in 2O18 after fighting relentlessly in the + +Christina Oxenberg claims that Ghislaine Maxwell felt no guilt in procuring girls for Jeffrey + +Epstein to satisfy his 'incredible sex drive' in Quest Red's new true crime documentary + +special Who Killed Jeffrey Epstein? + +C? Patrick McMullan via Getty Image + +Jeffrey Epstein and Ghislaine Maxwell attend de Grisogono Sponsors The 2005 Wall Street Concert Series Benefitting Wall Street Rising on March 15, 2005 in New York + +Prince Andrew and aged 17 at Ghislaine Maxwell's townhouse in London, + +Britain on March 13, 2001 + +The documentary dives headfirst into the Epstein story, examining the mysterious + +circumstances surrounding the financier's death, aiming to answer one vital question: Did + +Epstein take his own life, or was it something much more sinister? + +It was a dramatic end to one of the world's most mysterious billionaires, with the coroner + +officially ruling the cause of death as suicide. + +RELATED ARTICLES + +• previcni + +• + +• Next + +The Queen's official birthday will be marked with a 'small'... flops I kvett + +it again! Boyfriend ends up with black hands... From a luxury Hotel Chocolat hamper to personalised. . Meghan Markle detailed her + +experience with racism and... + +But it wasn't long before the circumstances surrounding Epstein's death were + +called into question. + +Having being linked with some of the world's most influential and powerful celebrity figures — including Prince Andrew, Donald Trump and Bill Clinton — + +some believe that Epstein may have been murdered. + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 19 of 161 + +5/12 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 20 of 161 + +6112 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 21 of 161 + +7/12 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 22 of 161 + +8112 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 23 of 161 + +9/12 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 24 of 161 + +10/12 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 25 of 161 + +11/12 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 26 of 161 + +12/12 + +Whe Washington post + +Democracy Dies in Darkness + +Ghislaine Maxwell, longtime associate of Jeffrey + +Epstein, charged in sex abuse case + +By Shayna Jacobs and Devlin Barrett + +July 2, 2020 at 3:14 p.m. MDT + +NEW YORK — Ghislaine Maxwell, a longtime confidante of sex offender Jeffrey + +Epstein, was arrested Thursday in New Hampshire on charges she recruited and + +groomed underage girls for abuse by her then-boyfriend, officials said. + +Support our journalism. Subscribe today. 3 + +A grand jury indictment unsealed Thursday charged Maxwell, daughter of the late + +media tycoon Robert Maxwell, with perjury and conspiring to entice minors to + +travel to engage in sex acts. + +Maxwell has been under investigation for months as a possible accomplice to + +Epstein's history of sexual abuse of underage girls. Epstein, who committed suicide + +while in federal custody last summer, dated Maxwell for years, and the indictment + +charges she played a key role in grooming girls for him to abuse. + +Beginning in at least 1994, the indictment alleges, Maxwell "enticed and groomed + +multiple minor girls to engage in sex acts with Jeffrey Epstein, through a variety of + +means and methods." + +Acting U.S. Attorney Audrey Strauss called the sex abuse described in the Maxwell + +case "the prequel" to the charges they lodged last year against Epstein covering + +alleged acts of abuse in the early 2000S. + +"Maxwell played a critical role in helping Epstein to identify, befriend, and groom + +minor victims for abuse," said Strauss, who oversees the federal prosecutor's office + +in the Southern District of New York. "In some cases, Maxwell participated in the + +abuse herself." + +A lawyer for Maxwell, Jeff Pagliuca, did not immediately respond to messages + +seeking comment. + +David Boies, who along with Sigrid McCawley represents a dozen of Epstein's + +accusers, said their clients were elated by the development. "It's just an enormous + +step," he said. + +Boies said he thinks Maxwell will be under "tremendous pressure to cooperate" as + +she looks for ways to shave time off what may be a significant prison sentence. + +Maxwell could potentially help prosecutors shed light on Epstein's dealings with + +other wealthy and influential people who may have had encounters with underage + +victims, he said, adding, "There were a lot of people with a lot of public stature ... + +who were involved with Epstein." + +"The pain [Maxwell] has caused will never go away but today is a step toward + +healing," McCawley added in a statement, praising prosecutors on the case for their + +"unrelenting courage." + +U.S. Magistrate Judge ordered Maxwell to remain in custody at a + +brief hearing via videoconference in federal court in New Hampshire, where + +another of her attorneys, Lawrence Vogelman, did not seek an immediate bail + +hearing because her lawyers plan to make those arguments after she is transferred + +to New York. + +AD + +In a court filing, prosecutors said Maxwell should stay behind bars pending trial + +because she might flee given her "extensive international ties," noting she has + +citizenship in two countries and three passports in her name. Maxwell, 58, faces the + +possibility of 85 years in prison if convicted and has "absolutely no reason to stay in + +the United States," prosecutors argued in the filing. + +Prosecutors also said the Epstein investigation is not over and asked any victims or + +witnesses to Epstein's abuse of minors to contact the FBI. + +head of the FBI's New York office, called Maxwell "one of the + +villains" of the Epstein saga and said that agents kept close tabs on her after she + +"slithered away to a gorgeous property in New Hampshire." + +AD + +present for sex acts involving the minor victim and Epstein." + +One of the victims was 14 years old when Epstein and Maxwell began grooming her + +for sex acts with Epstein, according to the indictment. + +The victims were groomed or abused at a number of Epstein's luxurious homes, + +including his sprawling Upper East Side townhouse in Manhattan, an estate in + +Palm Beach, Fla., a ranch in Santa Fe, N.M., and Maxwell's home in London, + +according to the charges. + +"Minor Victim-2," according to the indictment, was under 18 when she was flown to + +New Mexico at Epstein's invitation. "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," + +the indictment charged. + +Maxwell is also accused of grooming and befriending a third victim, whom she met + +in London between 1994 and 1995. She allegedly encouraged that victim to give + +Epstein massages "knowing that Epstein would engage in sex acts with Minor + +Victim-3 during those massages." + +The indictment also accuses Maxwell of lying in a deposition in 2016 when asked + +about these activities by a lawyer for one of Epstein's alleged victims, when she + +denied any knowledge of him engaging in sex acts with minors. When asked if + +Epstein had a scheme to recruit underage girls for sexual massages, Maxwell + +replied, "I don't know what you're talking about," the indictment says. + +Strauss, the acting U.S. attorney in Manhattan, said the socialite told that lie and + +others in the deposition because the truth "was almost unspeakable — Maxwell + +enticed minor girls, got them to trust her, then delivered them into the trap that she + +and Epstein had set for them. She pretended to be a woman they could trust, all the + +while she was setting them up to be sexually abused by Epstein." + +Maxwell's arrest was first reported Thursday by NBC News. + +Epstein, 66, was a registered sex offender who was arrested last year on federal sex + +trafficking charges for alleged abuses of underage girls in New York and Florida. + +His suicide in a Manhattan federal detention center led to charges against two of his + +guards who were accused of failing to check on him in his cell in the hours before he + +was found hanging from a bedsheet. + +Epstein's ability to avoid a lengthy prison sentence has raised questions about + +whether the wealthy, politically connected sex offender — with ties to both + +President Trump and former president Bill Clinton — was able to manipulate state + +and federal officials to go easy on him. + +Years before his 2019 arrest, Epstein had resolved similar allegations with a plea + +deal involving state charges in Florida that allowed him to spend a little more than a + +year in jail and leave daily for work — an arrangement widely criticized as too + +lenient. As part of that deal, prosecutors agreed not to pursue cases against + +Epstein's associates who might have recruited girls for him. + +AD + +Gloria Mired, a lawyer representing more than a dozen of Epstein's alleged victims, + +said her clients hope Maxwell "will be accountable if the evidence presented in + +court proves beyond a reasonable doubt that she had a role in assisting and + +recruiting young girls to be sex trafficked and sexually victimized by Jeffrey + +Epstein." + +The investigation into Epstein's conduct continued after his jailhouse death and has + +ensnared Britain's Prince Andrew, another old friend of the late financier. + +Federal prosecutors complained earlier this year that Andrew has provided "zero + +cooperation" to authorities. + +One of Epstein's accusers, claims she was paid by Epstein + +for sexual encounters with the prince when she was 17. The prince has denied any + +wrongdoing. + +On Thursday, Strauss made clear prosecutors still want to talk to him. + +"We would welcome Prince Andrew coming in to talk to us," she said. "We would + +like to have the benefit of his statement." + +Ghislaine Maxwell leaves luxe life behind for tiny jail cell in Brooklyn By CC ri . Jut),7. 2020 I 8A7pm I upaimed + +It' + +'411Q. + +t ti ! f \_ ! III!(((((( + +gift/yr + +fill + +ii -faIIIulinrnnfiiul + +I i + +\_nn + +T . + +From beef bourguignon to beef jerky: Ghislaine Maxwell has traded in her palatial New Hampshire cabin for stripped-down + +confinement at Brooklyn's Metropolitan Detention Center. + +The Oxford-educated British socialite had been lying low in a million-dollar New Hampshire hideaway featuring a cathedral + +ceiling, a massive floor-to-ceiling stone fireplace and a gourmet kitchen, according to the home's listing. + +Jeffrey Epstein's alleged right-hand woman cooked stews for herself in a kitchen with two ovens, a six-burner stove and a + +luxury refrigerator. + +Maxwell, 58, on Monday was transferred to the city's largest federal jail, where she is expected to be kept in a 1O-foot-by-12- + +foot cell. + +The notorious facility is in the midst of a lawsuit that has sounded the alarm over its potential to foster a dangerous coronavirus outbreak. It's the same facility where officers last month pepper-sprayed inmate Jamel Floyd to death. + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 35 of 161 In January 2019, inmates went freezing for weeks when an electrical fire knocked out power in the building, an environment + +The Interior of the Metropolitan Detention Center + +D0J + +Maxwell will be given a T-shirt and other basic clothing at the MDC along with a thin mattress, pillow and blanket. She may be allowed to have an approved religious medallion or book, such as the Bible — but cannot have any other personal + +possessions. + +After schmoozing among the global elite, Maxwell has apparently had a difficult time socializing with her fellow inmates. One + +inmate at a New Hampshire jail where she was briefly held reportedly called her a "snooty b—h." + +Injuring a high-profile inmate like Maxwell "would be a badge of honor: former MDC warden said. + +"You go from living a life like Maxwell to all of a sudden being in a situation where you're being strip-searched and having + +people look into your body cavities," \_added. + +rtit a UN:1?), BROOKLYN, GNISLAINE MAXWELL, JAIL JEFFREY EPSTEIµ 7/7/20 + +For Ghislaine Maxwell, Epstein's alleged + +recruiter, a private battle has become a + +public reckoning + +Site has been charged with conspiring with the Infamous sea• offender. + +By Jaws IIM end Petelblyklea + +hob 10. 2020. 2 % AM • II nun read 11 tI + +Ott13 + +Ghislaine Maxwell behind bars as now details emerge + +Jeffrey Epstein'' ex-girlfriend Ghtslaine Mature! is accused of facihtating Epstein's sex crimes by hclotng him + +'recruit, groom and ultimately abuse three unnamed teens &toren 2994 and 2997. + +Ghislaine Maxwell, a British socialite and longtime companion of disgraced + +financier Jeffrey Epstein, is facing a reckoning for her alleged role in + +facilitating Epstein's sexual abuse of young women. + +Federal prosecutors say Maxwell played a "key role" in a multi-state sex trafficking scheme, in which she not only allegedly "befriended\* and later 'enticed and groomed multiple minor girls to engage in sex acts with Epstein, through a variety of means and methods," but was also, at times, + +"present for and involved" in the abuse herself. + +Maxwell is scheduled to appear before a federal judge in New York on Tuesday, where she is expected to publicly address those allegations for the first time. But court filings make clear that Tuesday's hearing is only the latest chapter in long-running legal battles waged mostly out of public + +view. + +Top Stories + +For Ghislaine Maxwell, Ilpstein's alleged recrulter.a private battle has become a public reckoning + +Jul 10, 1116AM + +Ex-officials say Trump administration didn't use pandemic'playbooks + +M 29, 216 AM + +Congressman who Mimed to wear a mask tests positive for + +COVID-I9 1 how ago + +woman dead after attack by great white shark off Maine + +008\$1. 24 It 208 PM + +Contentious S-hour House hearing with AG William Barr + +concludes PA 28,2.12 PM • + +■ + +Jeffrey Epstein and Galata\* Monoit Wend de 01509000 Sponsors The 1005 Wait Street Conceil Sows + +Benefiting Wall Street Rising with a Performance try Rod Stewart at Cipriani Walt Sheet an. moro + +Patrick McmultatVPatnck McMullan eta Getty Image. FILL + +But in lawsuits several of Epstein's alleged victims tell an entirely different story, one that often places Maxwell in a role that was central to their abuse. + +One anonymous victim, identified only as Jane Doe, alleged that Epstein and Maxwell "attempted to groom and mentor" her when she was just 13 + +years old. + +"They took her to movies, went shopping with her and lounged around Epstein's estate with her," Doe alleged in her complaint. "Epstein and Maxwell then started to make sexual references when they were with her.' + +Ultimately, according to Doe's complaint. Maxwell "regularly facilitated Epstein's abuse of Doe and was frequently present when it occurred? + ++ MORE: Ghislaine Maxwell given paper clothes at correctional center to avoid + +suicide attempt: Sources + +nd another anonymous alleged victim + +identified only as Doe 1000, have alleged that Maxwell not only recruited girls for Epstein but, in their cases, even participated in their abuse. alleged Epstein and Maxwell sexually abused her between 2000 and 2002 and claims that she was directed to have sex with some of their prominent friends alleged that Maxwell "groped her" and "touched intimate parts of Iherl body against her will for the sexual benefit of Maxwell and Epstein"; Doe alleged 'Epstein and Maxwell proceeded to sexually assault Jane Doe simultaneously and by forcible compulsion" and that Maxwell + +'forcibly penetrated Jane Doe with a sex toy? + +Maxwell has, in court filings, strenuously denied any such misconduct. + +'She absolutely denies that she participated in this or any other sexual + +Ei Jeffrey Epstein and Guskine Moretti! attend on event in New York Ciqtry, June11199S + +Patrick McMullan via Gatti Images. FILE + +Following Epstein's arrest last July and his death in prison a month later, Maxwell's whereabouts became the subject of intense scrutiny. She sold her former residences in New York and London and shuttered her non-profit ocean conservation organization. Various press reports placed her in Massachusetts, California, France and Israel, and attorneys for several of Epstein's alleged victims struggled to locate her in order to serve their lawsuits. She was ultimately arrested by the FBI in Bradford. New Hampshire, where prosecutors say she was living at a 156-acre property, + +nicknamed "Tucked Away? + +Prosecutors are now arguing that Maxwell poses an 'extreme' flight risk, citing her "three passports, large sums of money, extensive international + +connections." + +Maxwell is a citizen of the United States, United Kingdom and France, prosecutors said, and she has traveled abroad frequently within the last three years. Prosecutors also believe she possesses "significant sums of money," citing a government investigation that 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." + ++ MORE: Truth and Lies: Jeffrey Epstein' Podcast + +As with Epstein, however, prosecutors have found the full extent of + +'Maxwell had no involvement in or knowledge of Epstein's alleged misconduct," one lawyer for Maxwell wrote earlier this year in her own + +lawsuit against the Epstein estate. + ++ MORE: As feds continue to seek interview with Prince Andrew, Attorney + +General William Barr says Jeffrey Epstein probe marches on + +In court filings related to that lawsuit, in which she claimed that Epstein had "promised that he would indemnify, defend, and advance any expenses incurred by reason of my prior employment relationship with him and his + +affiliated businesses," Maxwell contended that she had "incurred substantial expenses defending myself against false accusations and investigations." She claimed to owe more than \$318,000 to a criminal defense firm, more than \$101,000 to a civil litigation firm, and more than \$194,000 in security and relocation costs. The estate, according to court + +records, declined to reimburse the costs. + +zsn ro.woge of &nosing news and live twit + +According to Joshua Schiller of Boles, Schiller, Flexner, LLP, a firm that represents three Epstein's alleged victims who have filed civil suits against her, Maxwell has been at the forefront of the fight with Epstein's alleged + +victims long before her recent arrest. + +"(Maxwell] has been using this Court as a sword and a shield for many years." Schiller wrote in a filing earlier this year. "and she. Jeffrey Epstein, and their other co-conspirators have attempted to thwart their victims from + +obtaining justice for decades." + +GhisJoine Maxwell of Spring Studios in New York ON, Oct. 18, 2016. + +Patna McMullan via Getty Images, File + +Maxwell, 58, is the Oxford-educated daughter of Robert Maxwell, the larger than life publishing baron whose rags-to-riches story captivated England. She lived an extravagant life among the British elite until her father's business empire collapsed in the wake of his death. She fled to New York + +In a letter to a Florida state prosecutor related to Epstein's 2008 guilty plea, Epstein's attorneys describe his relationship with Maxwell as one of two long-term intimate relationships" Epstein had in adulthood. They met through mutual friends in 1991, his attorneys said, and parted "amicably" in 2000 because "the demands of his work ... precluded a good married life with children." The same letter contains what purports to be a quote from Maxwell. in which she describes Epstein as a "thoughtful, kind, generous, + +loving man." + +Maxwell has asserted in court filings that she entered Epstein's employ in 1999, where she remained, despite the end of their romantic relationship. + +until at least 2006. + +Maxwell's only sworn testimony on the nature of her work for Epstein can be found in excerpts unsealed by a federal court last year -- of two 2016 depositions related to a defamation lawsuit filed bi one of Epstein's alleged victims, who has accused Maxwell of recruiting her into Epstein's alleged child trafficking scheme, an accusation Maxwell denied. + +• O Truth and Lies: Jere + +• han a decade see mystemous I + +it + +According to Maxwell's testimony, she was responsible for the staffing and + +management of Epstein's various properties. + +'There were six homes," Maxwell said. "I hired assistants, I hired architects, I hired decorators, I hired cooks, I hired cleaners, I hired gardeners, I hired + +pool people, I hired pilots, I hired all sorts of people." + +"A very small part of my Job." she added, "was from time to time to find + +adult professional massage therapists for Jeffrey." + +She denied, under oath, that she had ever hired underage girls to work for + +Epstein, assertions that are now the subject of perjury charges. + +"As far as I'm concerned, everyone who came to his house was an adult, professional person," Maxwell said. "I am not aware of teenagers who + +worked in his home." + +'I'm no Cruella de Vil': Ghislaine Maxwell insists she is + +not an 'evil villain' + +CO dailymail.co.uk/news/article-8513675/Im-no-Cruella-Vil-Ghislaine-Maxwell-insists-not-evil-villain.html + +July 11, 2020 + +• Maxwell says she is not the 'cartoon caricature of a villain' she is portrayed + +as + +• The 58-year-old is scheduled to appear before a judge in New York on + +Tuesday + +• She will be charged with procuring girls as young as 14 for Jeffrey Epstein + +• • + +• e-mail + +• + +685 shares + +Defiant Ghislaine Maxwell has rounded on her accusers, insisting that her portrayal as a + +'cartoon caricature of a villain' is utterly false. + +Friends say that the 58-year-old socialite, who is scheduled to appear before a judge in + +New York on Tuesday to be formally charged with procuring girls as young as 14 for Jeffrey + +Epstein — the serial paedophile and her former boyfriend — 'is no Cruella de Vil'. + +Referring to the glamorous but evil character from the Disney film One Hundred And One Dalmatians, one friend told The Mail on Sunday: "Phis cartoon caricature of a villain she is + +being painted as is utterly untrue and false. + +This is a real human being with real feelings.' + +Ghislaine Maxwell, 58, has rounded on her accusers, insisting that her portrayal as a + +`cartoon caricature of a villain' is utterly false + +Breaking a year-long silence since Epstein's death, sources close to Maxwell have gone on + +the offensive to put her side of the story. + +After a year during which she was neither seen nor heard, her allies now reveal how she intends to salvage her liberty and reputation against claims that she supplied depraved + +Epstein with young girls. + +Maxwell's allies have told The Mail on Sunday that she: + +• Is not the person who introduced billionaire Epstein to Prince Andrew; + +• Fears dying of Covid-19 while in prison; + +• Insists she and Epstein had not met in person for 15 years; + +• Weeps over friends who have lost jobs because of their association with her; + +• Has not had a haircut in a year and is being moved `from cell-to-cell' for her own + +safety. + +judge in New York on Tuesday to be + +formally charged with procuring girls as young as 14 for Jeffrey Epstein — the serial + +paedophile and her former boyfriend + +The daughter of the late newspaper tycoon Robert Maxwell will make global headlines on Tuesday when she appears in court via remote link from her New York jail cell. + +She will be formally charged with sex offences between 1994 and 1997 and will + +plead not guilty to them all. Her lawyers will argue for her release from the high-security Metropolitan Detention Center in Brooklyn on £4 million bail, arguing that her life is in danger from coronavirus and 'multiple and + +credible' death threats. + +Maxwell, who is a long-time friend of Prince Andrew and who saw him most recently in + +2019, was arrested at her £800,000 New Hampshire hideaway on July 2. + +Prosecuto ondemned her as `playing a critical role in finding and + +grooming victims', while scores of Epstein's victims claim that she acted as his 'madam', often driving from his £20 million mansion in Palm Beach, Florida, to nearby trailer parks + +to 'procure' vulnerable young girls for the paedophile. + +But last night a source close to Maxwell hit back, saying: `Ghislaine is no Cruella de Vil. She + +is being portrayed as this evil character and a cartoon-like villain but she is nothing like that. She is a real person and is determined to prove her innocence despite the fact that she + +has been characterised as some sort of monster.' + +Maxwell insists that her romance with Epstein ended in 2001 and that she did not see him + +in person after 2005 when she was photographed with him at a party. + +At the time, she was dating billionaire Gateway computer founder Ted Waitt. + +®Clive CooteAValt 1:1 is ney Koba I REX Shutte rstock + +A source close to Maxwell hit back, saying: 'Ghislaine is no Cruella de Vil'. Pictured: The + +character played by Glenn Close in the 1996 film 101 Dalmatians + +'The reality is that Ghislaine's relationship with Epstein ended in 2001,' says the friend. 'Starting in late 2002, early 2003, she was dating Ted and she loved him deeply. Epstein + +kept trying to woo her back but she wasn't interested.' + +However, the friend adds, Maxwell continued to work for the twisted tycoon. 'She hired + +Epstein's pool guys, the IT guys. + +'She managed his household. They weren't that close. It was a professional relationship.' + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 47 of 161 + +5/13 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 48 of 161 + +6113 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 49 of 161 + +7/13 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 50 of 161 + +8113 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 51 of 161 + +9/13 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 52 of 161 + +10/13 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 53 of 161 + +11/13 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 54 of 161 + +12113 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 55 of 161 + +13113 + +Four more women accused of supplying young girls for + +Epstein to abuse + +0 + +July 12. 2020 + +Epstein's other 'recruiters': Four more women accused of + +supplying young girls for him to abuse face probe as it's revealed Ghislaine Maxwell moved house 36 times in a year before she was + +caught + +• re under investigation for their role in Epstein's sex-trafficking ring, + +according to reports + +• The four women are accused of helping to procure and groom the girls • In one case a previous victim went on to help groom other young women + +• dubbed Maxwell's 'lieutenant', 'flew on the lolita express + +almost as many times as the disgraced couple' + +• Reports suggest that Ms Maxwell moved 36 times before her arrest last + +week + +By Ryan Fahey For Mailonline + +Published: 20:46 EDT, 11 July 2020 I Updated: 09:08 EDT, 12 July 2020 + +• • + +• e-mail + +• + +21k shares + +Four more women accused of supplying young girls for billionaire paedophile Jeffrey Epstein to abuse are facing investigation as it's revealed Ghislaine Maxwell moved house + +36 times in a year before she was caught by the FBI. + +re being investigated for + +their alleged role in Epstein's sex-trafficking ring, according to a report in the Sunday + +Telegraph. + +dubbed Ghislaine Maxwell's 'lieutenant' by Epstein's victims, is said to have + +women, have previously been accused of recruiting and grooming underage girls for + +Epstein to sleep with. + +One was also said to have been involved in a sexual relationship with the financier. + +agreement as 'potential co-conspirators' + +who now goes b was allegedly one of Epstein's victims according + +to interviews with victims back in 2005, before she began procuring girls for the + +paedophile herself + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 59 of 161 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 60 of 161 + +5/11 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 61 of 161 + +6111 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 62 of 161 + +7111 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 63 of 161 + +8111 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 64 of 161 + +9/11 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 65 of 161 + +10/11 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 66 of 161 + +11111 + +Ghislaine Maxwell breaks down in + +tears as she is DENIED bail and must + +stay locked up until her July 2021 trial + +as judge rules Epstein's 'madam' has + +shown 'sophistication in hiding her + +finances AND herself and poses + +significant flight risk' + +• Ghislaine Maxwell cried as she was denied bail on Tuesday, with a judge ruling she + +must stay locked up until her trial in July of 2021 + +• The British socialite, 58, pleaded not guilty to the sex trafficking charges brought + +against her + +• She hung her head as she learned her fate, wearing a prison-issued brown top and + +with her normally short hair now long and swept back into a bun + +• Judge-ruled Maxwell was a significant flight risk, citing her 'substantial international' ties and 'extraordinary financial resources' + +• Maxwell appeared via video, accused of grooming girls as young as 14 for Jeffrey + +Epstein to abuse between 1994 and 1997 + +• She had offered a \$5 million bond co-signed by two of her sisters and backed up + +by more than \$3.75 million in property in the UK + +• Prosecutors fought for no bail, presenting evidence that she is 'skilled at living in hiding', citing her three passports and claimed she is worth more than \$10M • They said Maxwell refused to open the front door to the FBI and tried to flee to + +another room when they raided her \$1 million home on July 2 + +• A victim also argued she was a flight risk and wrote: 'Without Ghislaine, Jeffrey + +couldn't have done what he did. She is a predator and a monster' + +By CHEYENNE ROUNDTREE FOR DAILYMAIL.COM and DANIEL BATES FOR DAILYMAIL.COM + +PUBLISHED: 13:21 EDT, 14 July 2020 I UPDATED: 17:20 EDT, 14 July 2020 + +Ghislaine Maxwell cried as she was denied bail on Tuesday and learned she must stay locked up until her trial next summer, as Jeffrey Epstein's accused madam pleaded not + +guilty to the sex trafficking charges brought against her. + +The 58-year-old wiped tears away and hung her head as she learned her fate, wearing a prison-issued brown top and with her normally short hair now long and swept back into a + +bun, appearing via video link. + +U.S. District Judge Alison Nathan denied Maxwell's proposal of a \$5 million bond cosigned by two of her sisters and backed up by more than \$3.75 million in property in the + +UK. + +Maxwell's legal team had argued she would be confined to a 'luxury hotel' in the New + +York area, surrender all her travel documents and be subject to GPS monitoring. + +But Judge Nathan ruled the British socialite was a significant flight risk, citing her + +'substantial international' ties and 'extraordinary financial resources', setting an anticipated + +trial date for July 12, 2021. + +Maxwell is accused of grooming girls as young as 14 for Epstein to abuse between 1994 + +and 1997, a period when she was his girlfriend. + +She faces up to 35 years in prison if found guilty of the charges, as + +prosecutors successfully argued that along with her three passports, connections to some of the world's most powerful people and her own fortune of more than \$10 million - + +Maxwell had every incentive to try and flee. + +Maxwell will now return to the fortress-like Metropolitan Detention Center in Brooklyn + +where she has been given paper clothes to ensure she doesn't kill herself. + +Ghislaine Maxwell cried as she was denied bail on Tuesday and learned she must stay locked up until her trial next summer, as Jeffrey Epstein's accused madam pleaded not guilty to the + +sex trafficking charges brought against her + +But Judge uled the British socialite was a significant flight risk, citing her 'substantial international' ties and 'extraordinary financial resources', setting an anticipated trial date for + +July 12, 2021 + +Maxwell is accused of grooming girls as young as 14 for Epstein to abuse between 1994 and 1997, a period when she was his girlfriend. She faces up to 35 years in prison if found guilty of + +the charges, as prosecutors successfully argued that along with her three passports, + +connections to some of the world's most powerful people and her own fortune of more than + +\$10 million - Maxwell had every incentive to try and flee + +Maxwell is currently in custody in the Metropolitan Detention Center in Brooklyn (pictured) + +where she is wearing paper clothes to ensure she doesn't kill herself + +Maxwell is being closely watched as the Department of Justice wants to ensure she does not kill herself like Epstein, who hanged himself last August while awaiting trial on sex + +trafficking charges. + +During the two hour and 20 minute hearing at Manhattan's Federal Court, Maxwell + +appeared via video from the Metropolitan Detention Center in Brooklyn. + +The small room she was in had white walls, a white bed, a window with frosted glass and + +a door at the back. + +She was wearing a dark brown prison issued top and her dark hair was far longer than in the past - she reportedly has not had a haircut in a year - and was swept behind her head + +in a bun. + +At the start of the hearing, Maxwell rested her elbows on a table in front of the camera + +and put her head on her hands. + +She appeared nervous and pensive and kept looking from side to side, as she leaned into + +the camera. + +Maxwell briefly spoke and only to confirm she could hear the judge and to enter her + +plea by saying: 'Not guilty, your honor'. + +Her demeanor changed when prosecutor began outlining the allegations against her, sitting back in her chair and bowing her head when Moe accused her of + +'sexual abuse of minors'. + +With every allegation, Maxwell either scratched her face or moved her hair, but was + +emotionless as victim impact statements were read aloud. + +It wasn't until Judge started reading her decision that Maxwell finally broke down. She began moving uneasily in her chair as the judge said the evidence against her was + +'strong'. + +When Judge said a 'combination of factors' showed she had the 'motive and + +opportunity' to flee before her trial, Maxwell wiped a tear away. + +The second tear fell as the judge said Maxwell was 'sophisticated at hiding her financial + +resources'. + +During the two hour and 20 minute hearing at Manhattan's Federal Court, Maxwell appeared via video from the Metropolitan Detention Center in Brooklyn. She was wearing a dark brown prison issue top and her dark hair was far longer than in the past - she reportedly has not had a + +haircut in a year - and was swept behind her head in a bun + +It wasn't until Judged began reading her decision that Maxwell finally broke down. She began moving uneasily in her chair as the judge said the evidence against her was 'strong'. + +When Judge said a 'combination of factors' showed she had the 'motive and + +opportunity' o ee efore her trial, Maxwell wiped a tear away + +For the rest of the decision, Maxwell rested her head in her hands as she had done at the + +start of the hearing. + +Maxwell sat though prosecutors detailing how she was 'skilled at living in hiding' and as two victims argued she was a flight risk, with one writing: 'Without Ghislaine, Jeffrey + +couldn't have done what he did. She is a predator and a monster.' + +Prosecutors argued against Maxwell being granted bail, citing that due to holding both French and British passports, she has the ability to 'live beyond the reach of extradition + +indefinitely'. + +Prosecutor argued: 'She is good at living under an assumed identity. There really + +can be no question that she can live in hiding.' + +She revealed when Maxwell bought her \$1 million home in Bradford, New Hampshire last + +December, she toured the property with a real estate agent using an alias. + +said: 'The real estate agent told the FBI agent the buyers for the house introduced + +themselves as Scott and Janet Marshall. Both had British accents. + +'Scott Marshall told her he was retired from the British military and was currently working + +on a book. Janet Marshall described herself as a journalist.' + +Last summer, DailyMail.com previously tracked down Maxwell in Manchester-by-the-Sea, living at a home owned by her tech CEO lover Scott Borgerson. It is unclear if the man + +who toured the New Hampshire home with Maxwell was Borgerson. + +also read out a victim impact statement from a woman identified as Jane Doe, who + +also made the case that Maxwell was a flight risk. + +The victim said she knew Maxwell for 10 years and the socialite intended to 'deliver' her + +to Epstein, all the while knowing the 'heinous dehumanization that awaited me'. + +The woman claimed Maxwell 'was in charge' and 'egged' Epstein on. + +She described Maxwell as 'sociopathic' and said she would 'have done anything to get + +what she wanted - to satisfy Jeffrey Epstein'. + +Victirni lctured) also spoke at the hearing, detailing how she met Maxwell when she was 16 years old. has previously gone on record with her claims against Maxwell + +Prosecutor said when Maxwell bought her \$1 million Bradford, New Hampshire home (pictured), she toured the home back in November of 2019 using the alias of Janet + +Marshall and claimed to the real estate agent that she worked as a journalist + +The victim added that 'if [Maxwell) is out, I need to be protected', citing a phone call she + +also spoke at the hearing, detailing how she met Maxwell when she was 16 + +years old. has previously gone on record with her claims against Maxwell. + +She said Maxwell 'has never shown any remorse [andj tormented her survivors... She has + +associates across the globe, some of great means.' + +Maxwell's attorney Mark Cohen tried to argue his client was not a flight risk, claiming she + +has community ties and is 'part of a very large and close family'. + +He said: 'Our client is not Jeffrey Epstein, and she has been the target of endless media spin', leading prosecuto to later shoot back: 'These are the facts. It is not dirt, it is + +not spin, it is evidence to the court.' + +Cohen claimed Maxwell had received numerous threats and denied she had refused to + +open her front door to the FBI when they raided her home on July 2. + +He claimed her front door was unlocked, the windows were open and she had + +'surrendered' to the agents. + +Addressing reports that Maxwell had wrapped her mobile phone in tin foil, which + +prosecutors called a 'seemingly misguided effort to evade detection' by law enforcement, + +Cohen claimed her phone had been hacked and she had to preserve the phone as + +evidence. + +MAXWELL'S LEGAL TEAM: Pictured l-r: Jeffrey S. Pagliuca,Christian R Everdell, Laura A. Menninger and Mark Cohen. In their filings to the court Maxwell's lawyers had argued that she is at increased risk of catching the coronavirus whilst in prison. They claim that the restrictions + +Cohen went above the issue of Maxwell being a flight risk to complain that the charges against her are from 25 years ago, calling the indictment 'an effort to dance around' the controversial non-prosecution sweetheart deal Epstein and his associates received in + +Florida in 2007. + +With her bail now denied, Maxwell will return to the Metropolitan Detention Center in + +Brooklyn. + +Journalists had started lining up outside the federal court in downtown Manhattan at 6am + +to get a seat inside the courtroom. + +They were allowed in at 11.45am and had to stand 6ft apart while they waited to ensure + +social distancing. + +The hearing took place in the jury assembly room which normally has space for hundreds + +of people but had a dramatically reduced capacity of just 60 due to the coronavirus. + +A dial-in phone line allowed 1,000 more people to listen in - the capacity was increased + +from 500 due to world-wide interest. + +Inside the room there were two projector screens, which showed the proceedings live. + +All parties, including the judge, appeared remotely and no one was physically in court. + +Maxwell's lawyer was visible at all times in a box on the screen. Maxwell had her own + +box, the judge had one and the prosecutors had another. + +Maxwell's mugshot has not been released by the federal authorities and the hearing + +offered the first chance to see her in at least a year. + +Maxwell's whereabouts had largely been unknown since Epstein's arrest last July. + +Although DailyMail.com tracked her down to the New England coast last summer, she + +vanished again, later popping up in a photo at an In-N-Out in Los Angeles. + +The FBI managed to finally trace her down in the quiet and rural town of Bradford, New + +Hampshire earlier this month, where she had been living since December. + +Women: Inspiratioi + +Maxwell's mugshot has not been released by the federal authorities and the hearing offered the first chance to see her in at least a year. Maxwell's whereabouts had largely been unknown since Epstein's arrest last July. Although DailyMail.com tracked her down to the New England + +coast last summer, she vanished again, later popping up in a photo at an In-N-Out in Los + +Angeles + +1r' Park k M2020 + +• • + +• e-mail + +• + +337 shares + +For talented young artist it was the night she'd been working towards for + +months — her graduation show at the prestigious New York Academy of Art. + +then 25, was ecstatic, having sold all three of her exhibited paintings for five-figure + +sums. + +Then a senior staff member appeared at her shoulder, took her arm and pointed out two + +people she'd never seen before. + +July 15, 2019 + +`This couple here are going to buy your art . . . they're very important benefactors of the + +academy,' she was told. + +It was Jeffrey Epstein and Ghislaine Maxwell, and they got the painting they wanted — a semi-naked man observing a sleeping girl, inspired by Edgar Degas's The Rape — for \$6,000, half the pricenad + +been offered earlier. + +Fast-forward 25 years and this week + +younger sister gave an emotional statement to a Manhattan court about why Maxwell + +should not be granted bail. + +Speaking via an audio feed from her home + +in Texas, + +one of three women whose claims are the basis for the criminal case against the + +British socialite, said Maxwell was a `sexual + +predator' who had `never shown any remorse for her heinous crimes or the devastating, lasting effects her actions + +caused'. + +who says she feels guilty for unwittingly bringing her then teenage sister + +into the orbit of Maxwell and Epstein, was the first person to report the pair's alleged sexual abuse of underage girls in 1996. But her attempts to get the police and FBI to + +investigate the attack on= then 16, were ignored, leaving Epstein free to pursue his + +depravity. + +The sisters' story is shocking and their determination to get justice remarkable. Now, at last, their voices are being heard estimony was a key factor in the judge's decision to deny Maxwell bail and keep her in a New York jail cell before her trial next year — which + +is as it should be, Mold the Mail yesterday. + +For her, Epstein — who was found dead in his remand jail cell last year — isn't the worst + +says. `She was definitely the mastermind. She was in charge.' + +w orked for Epstein, a financial guru, for a year, during which time she says she saw + +first hand Maxwell's astonishing charm and her terrifying viciousness. + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 116 of 161 + +4113 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 117 of 161 + +513 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 118 of 161 + +613 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 119 of 161 + +7113 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 120 of 161 + +813 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 121 of 161 + +9,13 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 122 of 161 + +1013 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 123 of 161 + +11113 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 124 of 161 + +12;13 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 125 of 161 + +13,13 + +Ghislaine Maxwell was `a sexual predator,' alleged victim says in new + +testimony + +July18.2020 I 6:32pm + +Ghlslalne Maxwell + +Paw& McMullan via Getty Images + +Ghislaine Maxwell had to find three girls a day to be sexually abused by her longtime associate, convicted pedophile Jeffrey + +Epstein, according to blockbuster new testimony by an alleged victim who has waived her anonymity in the case. + +"She was a sexual predator who abused me and countless other children and young women. old a federal Judge who denied Maxwell, 58, bail Tuesday and ordered her to spend a year awaiting trial at the Brooklyn Detention + +Center. where she has been held since shortly after her July 2 arrest in New Hampshire. + +now 41, is believed to be one of three victims — all of them minors at the time of the alleged abuse between 1994 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 127 of 161 Although prosecutors have not revealed all o evidence, details of her abuse, which began when she was 16 and + +Papers filed in Maxwell's case on Saturday allege that "Maxwell spent years overseeing and managing Epstein's sex- + +trafficking network . . . Epstein's preference was to have three different girls a day for his sexual pleasure and Maxwell was in + +charge of recruiting the girls," according to a report in the Sunday Times of London. + +The documents say thatM parents divorced when she was young and her "mother struggled financially to support + +and her siblings". + +"Maxwell appeared charming and friendly to "Upon arriving, Maxwell and E stein too hopping and lavished her with gifts, including beauty products and a pair of brand new cowboy boots. older sister =an artist, also + +claims that she was abused by Epstein. + +Maxwell and Epstein also took to see a movie while she was in New Mexico. While they were standing in line, Maxwell "pulled down Epstein's sweatpants, exposing part of his buttocks. Both Epstein and Maxwell repeatedly fondled + +each other in front of=trying to normalize sexual behavior to a child." + +"Upon returning [to the ranch] from the movie, Maxwell repeatedly told hat she wanted to give her a massage . . . + +Maxwell directed to take off all of her clothes and lay on the massage table. + +SE S + +Ghislaine Maxwell's + +'lieutenan + +maybes ne , er + +parents fear + +"Maxwell touched intimate parts o body against her will for the sexual benefit of Maxwell and Epstein. Maxwell expose' reasts and groped he was extremely distressed and afraid. She was a child in a massive ranch, + +away from her family, and isolated from any source of help." + +The following morning, the court papers say. Epstein went taedroom got into bed demanding a "cuddle" and + +sexually assaulted her. + +s awyers claim that she decided to go public with her allegations only after Epstein's apparent suicide in a Manhattan federal lockup in August: "Until his death, the plaintiff feared that Epstein and his co-conspirators, including + +Maxwell, would harm her or her family, or ruin her life, if she came forward." + +Maxwell, who has claimed that she only has \$1 million left in her bank accounts, used to keep a "sex swing" and would hang + +upside down "like a bat" on another device in an attempt to look younger, the newspaper reported. + +FILED urn OHIStAINE MAXWELL JEFFREY EPSTEIN, NEW MEXICO, SEXUAL ABUSE. 7/18/20 + +Ghislaine Maxwell paid \$25k to Jacob Wohl to 'smear + +victims' + +dailymail.co.uldnews/arlicle-8531293/Ghislaine-Maxwell-Daid-25K-Jacob-Wohl-smear-victims-AG-fired.html + +July 21, 2020 + +EXCLUSIVE: Ghislaine Maxwell paid \$25K to fake news purveyor + +Jacob Wohl to 'smear Epstein victims and to get prosecutor + +Geoffrey Berman fired in attempt to stall sex trafficking + +investigation against her' + +• Ghislaine Maxwell hired Jacob Wohl to smear alleged victims of Jeffrey Epstein and her, a former friend told DailyMail.com in an exclusive + +interview + +• As part of a \$25k deal, Wohl and his lobbyist colleague Jack Burkman also allegedly pushed to get former New York US Attorney Geoffrey + +Berman fired + +• Wohl and Burkman are far-right lobbyists who have become a laughing stock in DC after several failed attempts to smear top political figures • Maryland paralegal claims she was initially contacted by the duo to use her in a smear campaign against Nancy Pelosi and Ted + +• r illiO told DailyMail.com they bragged to her they had been hired in early June for \$25,000 to dig up dirt on Maxwell's alleged sex trafficking + +victims + +• Federal documents filed this month show a company linked to Maxwell had hired Wohl and Burkman to lobby on `issues relating to US DOJ, Senate Judiciary, House Judiciary,' DailyMail.com can exclusively + +reveal + +• Berman's removal was intended to stall or stop the criminal investigation + +into Maxwell, said + +• Berman was ultimately pushed out by Barr in June, but two weeks later + +Maxwell was charged as part of Epstein's sex trafficking ring + +By Josh Boswell For Dailymail.com + +Published: 09:15 EDT, 21 July 2O2O I Updated: O2:55 EDT, 22 July 2O2O + +• • + +Ghislaine Maxwell hired fake news purveyor Jacob Wohl to smear her and Jeffrey Epstein's + +alleged victims, a former friend has told DailyMail.com in an exclusive interview. + +As part of a \$25,000 deal made in June, Wohl and his lobbyist colleague Jack Burkman + +also allegedly pushed to get New York US Attorney Geoffrey Berman, who had led Epstein's + +case, fired in order to stall or stop the criminal investigation into Maxwell. + +Wohl and Burkman are far-right lobbyists who have become a laughing stock in DC after several failed attempts to smear top political figures including Elizabeth Warren, Kamala Harris, Nancy Pelosi, Ted Cruz, Robert Mueller and Dr. Anthony Fauci by paying women + +to make false claims of sordid affairs and drug-dealing. + +One of the women they tried to use for their smear plots, + +old DailyMail.com the men had been hired by Maxwell, who currently + +faces trial over charges she and Epstein trafficked underage girls for sex. + +36, said the lobbyists bragged to her they had been hired in early June for + +\$25,000 to dig up dirt on Maxwell's alleged sex trafficking victims and to get Berman fired + +using Burkman's supposed influence with Attorney General William Barr. + +Berman ultimately stepped down after a push from Barr. But less than two weeks later, Maxwell was charged on July 2 as being part of Epstein's sex trafficking ring and taken + +into custody. + +Ghislaine Maxwell hired fake news purveyor and accused felon Jacob Wohl to smear + +alleged victims of her and Jeffrey Epstein, Wohl's former friend has told DailyMail.com in + +an exclusive interview + +As part of a \$25,000 deal made in June, Wohl (left) and his lobbyist colleague Jack Burkman (right) also allegedly pushed to get New York US Attorney Geoffrey Berman, who had led Epstein's case, fired to stall or stop the criminal investigation into Maxwell + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 132 of 161 + +5,21 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 133 of 161 + +621 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 134 of 161 + +7,21 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 135 of 161 + +8121 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 136 of 161 + +9121 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 137 of 161 + +10;21 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 138 of 161 + +11,21 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 139 of 161 + +12,21 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 140 of 161 + +13,21 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 141 of 161 + +14]21 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 142 of 161 + +15,21 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 143 of 161 + +1621 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 144 of 161 + +17:21 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 145 of 161 + +18,21 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 146 of 161 + +19i21 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 147 of 161 + +20;21 + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 148 of 161 + +21;21 + +ail li mo MAUREEN CALLAHAN + +Authorities are letting Jeffrey Epstein's fixer Ghislaine Maxwell get + +away with it + +June 77. 7020 I 5100pm + +Jeffrey Epstein and Ghislaine Maxwell + +Photo by Joe SchildhoiniPatrick McMullan via Geoy Images + +We got Osama bin Laden, but we can't catch a repulsive fugitive socialite? + +Since the death of sex trafficker-rapist-pedophile Jeffrey Epstein last August, the woman who allegedly recruited his many. + +many underage girls and sexually abused them herself has been in hiding. + +At the risk of stating the obvious, Paris, too, is on COVID-19 lockdown. The Sun reports that Maxwell is currently living on Avenue Matignon in the city's 8th arrondissement, in an apartment reportedly owned by a Normandy-based millionaire. + +This would put her just five minutes away from the late Epstein's own Parisian apartment, which was raided shortly after his + +suicide. + +So: where is the urgency? Why hasn't this depraved criminal suspect, one who by many credible accounts sexually abused + +minors for years, been arrested yet? + +France may not have an extradition treaty with the U.S.. but that doesn't explain why French authorities haven't taken her into custody. It's well-known that Jeffrey Epstein was a sexual predator who knew no geographic boundaries. Maxwell appears to have been his madam, his pimp, his enabler, his co-conspirator, and reportedly a sexual offender herself. + +The world would be better off without her moving around in it. Yet it seems there are powerful people who disagree. What + +other explanation is there? + +Maxwell is one of the world's most wanted women, sought by the FBI for questioning. Yet before the lockdown, she was seen swanning around Paris. patronizing high-profile, four-star restaurants and cafés, dropping into art galleries. a scarf tied + +around her head as if she were Jackie 0 on Fifth Avenue. + +These are the defiant actions of a remorseless woman who knows she is well protected. Her hiding seems almost + +performative. Maxwell isn't hunkered down on a private island or on a yacht in international waters. Her whereabouts are + +well known. + +Yet we're still playing "Where in the World is Ghislaine Maxwell?" + +;luxury apartments on on Avenue Matignon in Paris where Maxwell has reportedly been living. + +Luxury apartments on Avenue Matignon In Paris where Maxwell has reportedly been IIAng + +benvtiarvies + +There's a reason conspiracy theories still swirl around Epstein's suicide. At the time, he was likely the most high value suspect in U.S. federal custody. As it was, his arrest was long overdue. His case made international headlines. He was on + +suicide watch. + +A SE + +Ghislaine Maxwell reportedly hiding from the fads in plush Paris apartment + +And he was friends with very powerful men, heads of state and royals among them, hosted at his homes and on his private + +island, flying on his private jet, known to all as The Lolita Express. + +So the idea that none of these men knew about Jeffrey Epstein, again, defies the most basic logic. + +Sure, Prince Andrew has "stepped down" as a senior royal. So what? What does that even mean? He has never faced any consequences of any kind, even though as made consistent and credible claims that Epstein sex + +Maxwell doesn't even have the temerity of a Roman Polanski, who also fled to France and whose stance for decades has + +been -Yes, I raped a 13-year-old girl. Bygones." + +We are living in a fraught and electric moment, one in which all manner of injustice is no longer tolerated, protests in the + +streets day after day, forcing us to ask hard and painful questions in pursuit of a fairer and freer world. + +She dreamed of walking like other kids. + +> Cmcodt.—) 11- p,. + +Don't let Ghislaine Maxwell benefit from this as a distraction. Make her part of it. Make her — and whoever else, no matter + +how powerful — pay. + +fit ED UND FBI, FRANCE, GHISTAINE MAXWELL, JEFFREY EPSTEIN, PARIS, SEX TRAFFICKING, 6/22/20 + +Ghislaine Maxwell latest news: Socialite and Jeffrey + +Epstein said to have had `mysterious' relationship over + +the years + +thesun.co.ukinews/12041691fghislaine-maxwell-liye-jeffrey-eostein-latest-news/ + +July 29. 2020 + +JAIL BIRD + +- Who is Ghislaine Maxwell and where is she now? - Is Scott Borgerson Ghislaine Maxwell's husband? - Who was Ghislaine's famous father Robert Maxwell? + +- More news on Ghislaine Maxwell + +Live Blog + +• Alex Winter • Debbie White + +• 29 Jul 2O2O, 15:09 + +• Updated: 29 Jul 2O2O, 15:09 + +Ghislaine Maxwell and Jeffrey Epstein are said to have had a "mysterious" relationship + +over the years. + +The two are thought to have linked up not long after she moved to New York in 1991. + +One pal claims that Epstein and Maxwell were not linked romantically as has been often + +reported, but instead their relationship was a financial one. + +"I couldn't work out at first how, the second Ghislaine landed in New York, she was all of a + +sudden — overnight really — very chummy with Jeffrey," the source said. + +"Then he started spending on a different level, suddenly buying these extraordinary + +townhouses." + +Meanwhile, Ghislaine Maxwell could strike a plea deal, exonerate Prince Andrew from any + +wrongdoing and walk in a few years, according to a pal. + +An anonymous friend told the Sunday Times that they expect her to get a good deal with + +the prosecutors by turning on key members of the Epstein inner circle. + +But the pal said Maxwell would use the deal to "exonerate" Prince Andrew of his alleged + +links - with the Duke of York denying any wrongdoing. + +L + +Load more entries... + +• • + +Jeffrey Epstein rape survivor, now 22, claims + +paedophile was abusing girls right up to his death + +I + +Patrick Knox + +July 24, 2020 + +A JEFFREY Epstein rape survivor believes the warped financier was still abusing girls right + +up until he was jailed and hanged himself. + +The former model claimed this will leave behind a "second wave" of younger victims too + +afraid to even tell their parents. + +&Click here for the latest news on Ghislaine Maxwell + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 155 of 161 + +7 + +2.6 + +Jeffrey Epstein's mugshot after his arrest in 2019.... one of his victims claims he was abusing right up to this pointCredit: AFP or licensors + +2 The girl alleges she was raped by Epstein in his Manhattan mansion — dubbed the House of Horrors by many of his victimsCredit: Getty Images - Getty + +The woman who was speaking to DailyMail.com says she was raped and molested during + +two visits to Epstein's mansion in New York, in the summer of 2015. + +She said: "I believe he was abusing young girls right up until the day he was arrested. + +"There are likely to be multiple young victims out there who are still in their teens, perhaps + +still living with their parents and too ashamed and confused to speak out. + +"I know how it feels because I was one of them. I thought about suicide, I tried to cut my + +wrists. These girls need support before it's too late. + +"They need to know it's OK to tell their stories." + +She contacted the FBI and police after Epsetin's arrest last July 6 on federal sex trafficking charges filed in the Southern District of New York because she knew Epstein was locked + +up. + +The 22-year-old, who is thought to be the youngest woman to come forward, wants to + +remain anonymous because she fears reprisals from Epstein's powerful pals and + +accomplices. + +This is despite the 66-year-old being found hanged in a New York jail cell nearly a year + +ago. + +vas an aspiring 16-year-old model in the Autumn of 2014 when she met an older + +Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 158 of 161 + +516 + +There are likely to be multiple young victims out there who are still in their teens, perhaps + +still living with their parents and too ashamed and confused to speak out + +Epstein victim + +Last week Ms Maxwell pleaded not guilty to charges that in the 199os she recruited three + +girls, one aged 14, for Epstein to sexually abuse. + +It is also alleged that she sometimes participated in the abuse during massage sessions at Epstein's Manhattan mansion and properties in Palm Beach, New Mexico and London. She + +also denies this. + +When Epstein brought her into a dimly lit mom with red velvet curtains she claimed he began fondling her, saying it was normal for young models to do "favours" for older men in + +the fashion industry. + +She was later raped by Epstein, who in doing so took her virginity. + +Epstein was subject to two criminal indictments. + +One focused largely on his activities in Palm Beach, Florida before 2008 when Epstein + +signed a controversial non-prosecution deal to avoid federal charges. + +The other cites abuse in New York, Florida and other locations between 2002 and "at least + +in or about 2005". + +But civil lawsuits give a broader timeframe for his crimes.. + +A January 2020 suit filed by prosecutors in the US Virgin Islands alleges that Epstein + +trafficked, raped and abused children on his private island as recently as 2019. + +This was the year he was arrested and was later found dead last August 10. + +Jeffrey Epstein accusers claim he rigged his New York mansion with CCTV and kept videos + +to use as blackmail + +Ghislaine Maxwell latest news: Socialite and Jeffrey + +Epstein said to have had `mysterious' relationship over + +the years + +thesun.co.ukinews/12041691/ghislaine-maxwell-liye-jeffrey-eostein-latest-news/ + +July 29. 2020 + +JAIL BIRD + +- Who is Ghislaine Maxwell and where is she now? - Is Scott Borgerson Ghislaine Maxwell's husband? - Who was Ghislaine's famous father Robert Maxwell? + +- More news on Ghislaine Maxwell + +Live Blog + +• Alex Winter • Debbie White + +• 29 Jul 2O2O, 15:09 + +• Updated: 29 Jul 2O2O, 15:09 + +Ghislaine Maxwell and Jeffrey Epstein are said to have had a "mysterious" relationship + +over the years. + +The two are thought to have linked up not long after she moved to New York in 1991. + +One pal claims that Epstein and Maxwell were not linked romantically as has been often + +reported, but instead their relationship was a financial one. + +"I couldn't work out at first how, the second Ghislaine landed in New York, she was all of a + +sudden — overnight really — very chummy with Jeffrey," the source said. + +"Then he started spending on a different level, suddenly buying these extraordinary + +townhouses." + +Meanwhile, Ghislaine Maxwell could strike a plea deal, exonerate Prince Andrew from any + +wrongdoing and walk in a few years, according to a pal. + +An anonymous friend told the Sunday Times that they expect her to get a good deal with + +the prosecutors by turning on key members of the Epstein inner circle. + +But the pal said Maxwell would use the deal to "exonerate" Prince Andrew of his alleged + +links - with the Duke of York denying any wrongdoing. + +L + +Load more entries... + +• • \ No newline at end of file diff --git a/marker2/ds9/EFTA00084366/EFTA00084366.metadata.json b/marker2/ds9/EFTA00084366/EFTA00084366.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..58b869df4f57371621c9638bb51a64fa4473efef --- /dev/null +++ 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+1,53 @@ +From: To: Cc: + +Subject: RE: US v. Epstein Date: Sat, 01 Aug 2020 18:22:23 +0000 + +Got it, thanks. + +From: Sent: Friday, July 31, 2020 09:19 To: Cc: ) ) < (USANYS) < Subject: RE: US v. Epstein + +Good Morning, + +Here are the answers to your questions: + +- 1. I checked my previous e-mail to you to see what was on the first set of data to confirm that the data was listed twice as it was on the hard drive I sent out this week. You will not see two copies of the same document in the database as we will globally dedupe the data. You may want to ask the FBI if this was an updated version from the first delivery. I did not highlight NYCO24366 as I missed it in the spread sheet. +- 2. Anything that is supplemental will just be added to the database. There should be no issue with those documents. +- 3. I checked the list before I sent it to you so I did not see it on the list. You should have received the hard drive and you should be able to plug the drive into your computer to check to see if you see the NYC number on the drive. + +Please let us know if there are any questions. + +Thank you. + +From: Sent: Thursda Jul 30 2020 6:49 PM To: Cc: • Subject: RE: US v. Epstein + +I think we're just trying to line up what has been sent to PAE \*in total\* -- including both this recent drive and also the previous one. So, a few questions, that I'll try to keep as non-confusing as possible. + +- 1) I take it from your email below that three items were listed as having been provided on 7/23, but there are three that were in the first set of data you received and send out last week (NYCO24328, NYCO24366, and NYCO24392). My question on these is, were they actually \*also\* included in this recent disc, or was that incorrect on the spreadsheet? The reason I ask is, if they were provided twice, I just want to make sure the FBI didn't provide an updated version, such that we'd need to supplement or replace what we previously sent out. + +- And then of these three, one of them NYC024366 you didn't highlight in yellow. Is that because this was the only one of the three that wasn't repeated on the most recent disc? Or just an oversight? +- 2) For the four NYC numbers that had "supplemental" information (NYC024363, NYC024365, NYC024371, and NYC024383), will those be able to just be added to the folders we already sent out? I have no idea why there is now supplemental info on those, but regardless of why, I want to make sure they don't get new, separate folders in Relativity (rather than being incorporated into the existing folders for those NYC numbers) +- 3) Assuming all of the above checks out, there appears to be only one item that is listed as having been provided to us, but which was not in the seven items provided previously, and also that you did not highlight here. I believe that means that the FBI erroneously listed it as having been provided to us, but I want to triple-check that with you before going back to them. So could you please confirm that we did not get the following NYC-numbered item in either the prior disc or this most recent one? That item is: NYC027913 (row 40 in your spreadsheet). + +Thanks very much, + +From Sent: Thursday, July 30, 2020 08:51 To: Subject: RE: US v. Epstein + +Everything that I highlighted was what was on the hard drive I sent to the vendor. If on the spreadsheet I sent to you the items were not highlighted then it was not on the hard drive. + +From: Sent: Wednesda Jul 29 2020 7:16 PM To: >; > Subject: RE: US v. Epstein •fl + +Thanks very much, So does that mean that some of the rows highlighted in green saying that they were provided to SDNY on 7/23/20 were not in fact provided to us yet? + +From Sent: e nes ay, u y , : To: < >: Subject: US v. Epstein + +Good Morning, + +Attached is a spread sheet that was on the hard drive you sent to me this week. I highlighted everything in yellow that was on the hard drive I received this week. Please note the following regarding the data that was sent out last week: + +NYC024328 — according to the chart this data was provided again but was on the first set of data I sent out last week NYC024363 — supplemental data was provided regarding this drive. NYC024365 - supplemental data was provided regarding this drive NYC024366 — according to the chart this data was provided again but was on the first set of data I sent out last week NYC024371 - supplemental data was provided regarding this drive NYC024383 - supplemental data was provided regarding this drive + +Please let me know if there are any questions. + +Thank you. + +![](_page_2_Picture_3.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084527/EFTA00084527.metadata.json b/marker2/ds9/EFTA00084527/EFTA00084527.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8e737657655dd9c419b65e84fa219beea520c9f4 --- /dev/null +++ b/marker2/ds9/EFTA00084527/EFTA00084527.metadata.json @@ -0,0 +1,136 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084527.pdf", + "engine": { + "marker_major": "2", + "marker_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": 4537, + "elapsed_seconds": 0.83, + "image_assets": [ + "_page_2_Picture_3.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 37 + ], + [ + "Text", + 12 + ], + [ + "ListItem", + 4 + ], + [ + "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", + 81 + ], + [ + "Line", + 41 + ], + [ + "Text", + 9 + ], + [ + "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", + 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/EFTA00084527" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084527/_page_2_Picture_3.jpeg b/marker2/ds9/EFTA00084527/_page_2_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..53bbaba419563c4504de2f7c5b1877b6ba9da8a3 --- /dev/null +++ b/marker2/ds9/EFTA00084527/_page_2_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:b6ffe068f106299ac509f9271cf7376f37eda5464afb92c379dd1ef9b792c7a6 +size 1165 diff --git a/marker2/ds9/EFTA00084530/EFTA00084530.md b/marker2/ds9/EFTA00084530/EFTA00084530.md new file mode 100644 index 0000000000000000000000000000000000000000..56ad55f6150f2a7dbcedd0ce9f6d8aa2e5a0de3d --- /dev/null +++ b/marker2/ds9/EFTA00084530/EFTA00084530.md @@ -0,0 +1,23 @@ +From: 'a" To: a' Cc: Min 1 11 + +Subject: RE: initial discovery production + +Date: Sat, 01 Aug 2020 21:02:36 +0000 + +Attachments: 2020-07-28"govemment\_letter\_re\_protective\_orderidocketed).pdf; 2020-07- 31,\_GM,memorandum\_&\_order\_granting\_govemment\_motion.pdf; 2020-07- 31"GM,signed\_protective\_order (docketed).pdf + +We wanted to briefly check with you on a few issues. First, I expect that we will very shortly—hopefully Monday, but I expect not later than early this week—be producing materials to you in response to your Touhy request. That has been pending final supervisory approval this week, but we are continuing to follow up with the person who needs to approve and we expect it will go out shortly. As I previously mentioned, we are constrained in our ability to produce any materials obtained in connection with the grand jury process, which are subject to stringent restrictions under Rule 6(e) — I expect that will be noted in the letter, but I mention it given the relatively limited volume of disclosable materials. + +Second, and as we've also previously talked about (though not for some time), now that there is a protective order entered in the Maxwell case, we expect to begin making discovery productions to the defense this coming week. As you may have seen this past week, defense counsel argued that they should be able to publicly identify victims in certain circumstances, which we vigorously opposed. Ultimately the judge ruled in our favor, and the protective order is exceptionally strong. For your reference, the Government's letter on this issue, the Court's decision, and the final protective order are all attached. + +As you would imagine, some of the discovery we will begin to produce will include information about your client, including information such as her name and date of birth, in connection with documents we have gathered. Consistent with the protective order, defense counsel may not disclose or distribute any discovery materials except under very strict conditions, and in any event the defendant and counsel "are strictly prohibited from publicly disclosing or disseminating the identity of any victims or witnesses referenced in the Discovery." To the extent they need to reference the identity of individuals as part of their investigation, e.g., in individual interviews, any potential defense witnesses and counsel are similarly prohibited from further disclosing or disseminating such identifying information. All of these appropriate restrictions notwithstanding, we nevertheless did want to let you know that we are beginning to make discovery productions, in an abundance of caution and in the interests of transparency. + +Finally, when we make the initial discovery production, with your permission we may advise defense counsel that each victim in the Indictment is represented by counsel, and identify the counsel for each person (i.e., we would identify you as counsel fo . The reason we would do that would be to preempt attempts at direct contact with represented witnesses by defense counsel or defense investigators. For your client in particular, we not + +Please + +let us know if you have a preference on this, and we're also happy to discuss it via phone. + +As always, please do not hesitate to be in touch on any of these issues, we'll keep you advised of any significant developments, and thanks. + +![](_page_1_Picture_1.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084530/EFTA00084530.metadata.json b/marker2/ds9/EFTA00084530/EFTA00084530.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6d519e2e3c49a2ee6fc6ac8829e40192ea842838 --- /dev/null +++ b/marker2/ds9/EFTA00084530/EFTA00084530.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084530.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3393, + "elapsed_seconds": 0.79, + "image_assets": [ + "_page_1_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 40 + ], + [ + "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", + 7 + ], + [ + "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/EFTA00084530" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084530/_page_1_Picture_1.jpeg b/marker2/ds9/EFTA00084530/_page_1_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..2d5a651ca63945d8ca3d17c94c2882ac46ca9bd0 --- /dev/null +++ b/marker2/ds9/EFTA00084530/_page_1_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:53ff406d83bf926f32bf296eb8f2cb2e937c212a887edeefade90efd80d116ce +size 1184 diff --git a/marker2/ds9/EFTA00084532/EFTA00084532.md b/marker2/ds9/EFTA00084532/EFTA00084532.md new file mode 100644 index 0000000000000000000000000000000000000000..e0c67f5f8581887f3bdabc798462e1c9492aa881 --- /dev/null +++ b/marker2/ds9/EFTA00084532/EFTA00084532.md @@ -0,0 +1,233 @@ +![](_page_0_Picture_1.jpeg) + +## U.S. Department of Justice + +United Stales Attorney Southern District of New York + +The Silvio J. Mollo Building One saint Andrew's Plaza New York. New York 10007 + +July 28, 2020 + +## VIA ECF + +The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Dear Judge Nathan: + +The Government respectfully submits this letter with respect to the protective order to be entered in the above-captioned case, and to respond to the defendant's letter and submission of July 27, 2020 (the "Defendant Letter" or "Def. Ltr.") (Dkt. 29). The Government and defense counsel have conferred regarding a protective order several times via telephone and email between July 9, 2020, and today, including as recently as this morning. The Government and defense counsel have come to an agreement on much of the proposed protective order. However, the parties disagree as to two inclusions sought by the defendant which the Government objects to and for which, as detailed herein, the Government submits there is no legal basis. Accordingly, the Government respectfully requests that the Court enter its proposed protective order (the "Government Proposed Order"), which is attached hereto as Exhibit A, and which differs from the defendant's proposed order in those two respects, as further described below. + +## A. The Defendant's Request to be Permitted to Publicly Name and Identify Victims + +As detailed herein, the Government seeks to protect the identities of victims, consistent with their significant privacy interests and the well-established law in this Circuit, and proposes a protective order consistent with those very significant interests. In contrast, the defendant insists that the protective order be modified such that she and her counsel would be permitted to "publicly referenc[e]" individuals, by name, who have "spoken on the public record to the media or in public fora, or in litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' + +Specifically, the defendant's proposed protective order differs from the Government's in that it adds a sentence, in its paragraph 6 (which is paragraph 5 of the Government Proposed Order), stating the following: "Nor does this Order prohibit Defense Counsel from publicly referencing individuals who have spoken on the record to the media or in public fora, or in litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell." The defendant also either adds + +July 28, 2020 + +Page 2 + +The defendant's demand that she and her counsel be permitted to name any individuals who have ever publicly identified themselves as a victim of either Epstein or the defendant in any "public fora," and at any time, without limitation, is extraordinarily broad, unnecessary, and inappropriate, and should be denied. + +As an initial matter, there can be no serious question that there are significant privacy and victim interests at issue here, which the Government Proposed Order seeks to protect. Particularly in the context of victim witnesses, there are compelling reasons to limit public disclosure of victim identities and other sensitive information. Indeed, the Crime Victims' Rights Act, 18 U.S.C. § 3771, requires district courts to implement procedures to ensure that crime victims are accorded, among other rights, "[t]he right to be reasonably protected from the accused," in addition to "[t]he right to be treated with fairness and with respect for the victim's dignity and privacy." Id. §§ (a)(1), (a)(8) (emphasis added). Moreover, "the public generally has a strong interest in protecting the identities of ... victims so that other victims will not be deterred from reporting such crimes." United States v. Paris, 2007 WL 1484974, at \*2 (D. Conn. May 18, 2007). + +Moreover, and consistent with those interests, courts in this Circuit have routinely acknowledged the need to protect victim-witness identities. See, e.g., United States v. Corley, 13 Cr. 48 (AJN), 2016 WL 9022508, at \*4 (S.D.N.Y. Jan. 15, 2016) ("Because Corley's minor victims have significant privacy and safety interests at stake, while Corley's interests are minimal, the Court finds good cause to modify the protective order in this case to prevent Corley from learning the surnames of the minor victims."); United States v. Kelly, 07 Cr. 374 (SJ), 2008 WL 5068820, at \*2 (E.D.N.Y. July 10, 2008) ("Given the potentially explicit nature of the government witnesses' expected testimony, the government argues that it is necessary to conceal their identity to protect them from public humiliation and embarrassment. This Court agrees. Thus, the parties [. . .] are hereby prohibited from releasing to anyone, including members of the press, the identity or any identifying information of the government's witnesses."). It is similarly routine in this District for parties in a criminal case to refer to witnesses by pseudonyms (such as "Victim-I" or "Witness-1") to protect the privacy interests of third parties unless and until they testify publicly. + +The Government's proposed order endeavors to protect those interests by generally requiring the parties to abstain from identifying any victim by name in any public statement or filing while also ensuring that the defendant and her counsel are fully able to prepare for trial. Indeed, to facilitate the defendant's investigation and preparation for trial, the Government's proposal makes clear that defense counsel and defense staff, including defense investigators, should not be prohibited from referencing identities of individuals in conversations with prospective witnesses, so long as those witnesses and their counsel abstain from further disclosing or disseminating any such identities. See Government Proposed Order ¶ 5. The terms of the Government's proposed order also would permit defense counsel to refer to any individual by name in any filing under seal, merely requiring redaction of identifying information or the use of a pseudonym in public filings. The Government further proposes that defense counsel not be prohibited from publicly referencing individuals who have spoken—or who at some future time + +or deletes language in furtherance of its desire to publicly reference victim identities in defense paragraphs 7, 9, and 17 (which are Government Proposed Order paragraphs 6, 7, and 16). + +July 28, 2020 + +Page 3 + +speak—by name on the public record in this case, as one victim has already chosen to do, because those victims, and only those victims, have affirmatively chosen to be publicly identified in connection with this case. These proposals are reasonable, narrowly tailored, and not broader than necessary to protect victims' privacy interests, safety, and well-being, to avoid potential harassment of witnesses by the press and others, and to prevent undue embarrassment and other adverse consequences. At this stage in the case, permitting defense counsel to refer to witnesses by name in sealed filings, to refer to witnesses by name in the course of private conversations during their investigation, and to refer by name to individuals who have made the affirmative choice to be identified by name in connection with this criminal case is more than enough to enable the defendant ability to vigorously pursue her defense. + +The defendant has rejected this proposal because, as noted above, she believes that she and her counsel should be permitted to "publicly referenc[e]" individuals, by name, who have "spoken on the public record to the media or in public fora, or in litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell." In support of the defendant's application for such sweeping ability to publicly name any such individuals, defense counsel provides only the conclusory assertion that an inability to publicly reference the names of victims, in court proceedings and beyond, will hinder their ability to investigate, prepare witnesses for trial, and advocate on the defendant's behalf. The Government has repeatedly asked defense counsel to explain how or why it would need to publicly name victims of sexual abuse to prepare for trial, and the defense repeatedly has declined to do so, presumably because the argument borders on the absurd.2 + +The Government's proposed protective order would do no such thing. As described above, the Government's proposed order would permit defense counsel and defense staff to reference the identities of individuals they believe may be relevant to the defense to potential witnesses and their counsel (who then would be prohibited from further disclosing or disseminating such identifying information). Government Proposed Order ¶ 5. It would further permit the defendant to publicly identify individuals who have chosen to speak on the record on this case. Id. ¶ 6. And it would permit the defendant to reference identifying information in filings made under seal. See id. + +2 Despite the Government's requests for clarity on the need for the defendant's requested modification, the sole additional reason provided by defense counsel for why it would be appropriate or necessary to publicly name victims is that certain of these victims have obtained what defense counsel described as the "benefit" of publicly identifying themselves as victims (and thus, as the defendant presumably would have it, deserve whatever public identification and scrutiny the defendant intends to invite upon them). Beyond the offensive notion that victims of sexual abuse experience a "benefit" by making the incredibly difficult decision to share their experience publicly, the suggestion that victims who receive this supposed "benefit" should receive fewer protections than the law ordinarily offers to victims in criminal cases is alarming. Permitting defense counsel to publicly identify witnesses who have not identified themselves on the record in this case risks subjecting witnesses to harassment and intimidation, with no conceivable benefit to the defense other than perhaps discouraging witnesses from cooperating with the Government. + +July 28, 2020 + +Page 4 + +Moreover, the defendant is able, at any time, to apply to the Court for a modification of the protective order should she be able to identify a particularized need to publicly name victims who have not yet identified themselves on the record in this case—as opposed to redacting their names from court filings, or referring to them in an anonymized fashion. As noted, to date, defense counsel has declined to identify to the Court or to the Government any example of why doing so would be necessary or helpful to the defense, or even under what circumstances the defense might want to do so. + +The defendant's proposal is also extraordinarily broad, and without any temporal or subject matter limitation as to the phrase "public fora." Adopting the defendant's proposal would mean that any individual who has ever self-identified as a victim ofJeffrey Epstein or Ghislaine Maxwell publicly in any capacity would be subject to public identification by the defendant and her counsel in connection with this case. This would include, as hypothetical examples, someone who spoke to a journalist for a local story in 1997, or posted on a MySpace page followed by a handful of friends in 2005, or made a statement on a small podcast in 2009, or posted on Twitter to a handful of followers in 2013. But none of these examples of ventures into the "public fora" can possibly be construed as efforts by hypothetical victims to consent or choose "to self-identify," Def. Ltr. at 3, in a future criminal case against Ghislaine Maxwell subject to extraordinary public attention and scrutiny. + +Additionally, while some individuals have identified themselves as victims without providing any details or additional information about their abuse, the defense contemplates no limitation of publicly associating those individuals with the details of their abuse in public defense statements or filings. In essence, the defendant's proposal seeks authorization to drag into the public glare any victim who has ever made any type of public statement of victimization—no matter how long ago or how brief—without that victim's knowing consent and without any substantive justification. That is particularly troubling given that the Government expects to make productions of discovery and 3500 materials well surpassing its obligations. Those productions will necessarily include the identities of individuals whom the Government does not expect to call as witnesses, and whose accounts—much less identities—will have no bearing on this case. But the defendant's proposal would allow her and her counsel to publicly name them in any public statement or filing at their sole discretion. This is plainly unnecessary for any investigative steps or trial preparation, would be grossly inappropriate and unfair, and would be inconsistent with the Crime Victims' Rights Act. + +Conversely, the Government's submission proposes that the defendant and her counsel not be precluded from discussing publicly individuals who identify themselves on the record in this criminal prosecution, because any such individuals will have made a conscious and informed choice to be associated publicly with this case. See Government Proposed Order¶¶ 5, 6, 8. The identity of any other individuals should be protected from public broadcast by the defendant and her counsel. + +The defendant argues that her proposed language is "nearly identical in all material respects" to the protective order entered in United States v. Epstein, 19 Cr. 490 (RMB) (Dkt. 38). Def. Ltr. at 3. In the first instance, that is false. The protective order in the Epstein case included + +The Honorable Alison J. Nathan +July 28, 2020 +Page 5 + +a provision stating that it did not prohibit defense counsel from publicly referencing individuals who had spoken on the public record *in litigation* relating to Jeffrey Epstein. *Id.* ¶ 4. Here, defense counsel seeks permission to publicly identify any individuals who have self-identified as victims of either the defendant or Epstein “*to the media or in public fora*, or in litigation”—a vastly broader allowance. Indeed, as a comparison, *none* of the hypothetical examples described above would have been subject to public naming and identification under the *Epstein* protective order, but every single one would be under the defendant’s proposed order in this case. + +Additionally, beyond the differences in the language itself, there are two significant differences between the circumstances of the *Epstein* prosecution and this case. First, at the time the *Epstein* protective order was entered, there were exceptionally few victims who had identified themselves by name in litigation. Accordingly, the practical application of that provision was extremely limited. Second, and related, in the time between when the *Epstein* protective order was entered and the indictment in this case, many more victims have made public statements about their victimization at the hands of Epstein, and the defendant, on their own terms and in their own ways, including by exercising their rights under the Crime Victims’ Rights Act in the context of the dismissal of the indictment against Jeffrey Epstein following his suicide. Those victims could not possibly have predicted, much less chosen, that their names would be publicly broadcast by defense counsel in connection with a subsequent criminal case. Victims should be able to continue to come forward, in the ways and in the venues they themselves choose, without fear of reprisal, shaming, or other consequence arising from having their identities broadcast by defense counsel in this case. + +In sum, the requested modification to the Government’s proposed order sought by the defendant is contrary to precedent and the compelling privacy interests of victims. Moreover, it is without basis in fact or law, and, despite the Government’s repeated requests for clarity, the defendant and defense counsel have offered no legitimate reason for their desire to be able to publicly identify any number of victims, in the context of this criminal case and elsewhere, other than a minimal, conclusory statement, without factual examples or legal support.3 At bottom, the defendant and her counsel seek an unlimited ability to name victims and witnesses publicly, for no discernible reason, and without justification or legal basis. The victims of Ghislaine Maxwell and Jeffrey Epstein have suffered enough, and the Crime Victims’ Rights Act, applicable law, and common decency compel far more protection of their privacy interests here than the defense proposal would afford. + +#### B. The Defendant’s Demand that the Government Restrict Use of its Own Documents + +The defendant and her counsel also ask the Court to impose restrictions upon the Government in its use, through potential witnesses and their counsel, of documents it currently possesses, beyond the already-extensive restrictions and protections applicable to the + +--- + +3 To the extent defense counsel attempts to provide such examples or arguments for the first time in a reply filing, the Government respectfully requests leave to reply to those examples or arguments. + +July 28, 2020 + +Page 6 + +Government.4 The defendant cites not a single example in any district court in the country where such a restriction has been imposed in a protective order. Indeed, it is nonsensical for a protective order to require limitations of the Government in its use of material already in its possession so that the Government may provide a defendant with discovery. The defendant's attempt to refuse to agree to receive discovery unless the Government agrees to additional restrictions upon the use of its own materials should be rejected. + +As an initial matter, the Government's use of materials it has gathered through its investigation, including through the grand jury process, search warrants, interviews, and voluntary disclosures, is already subject to a wide range of restrictions, including Rule 6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and other policies of the Department of Justice and the U.S. Attorney's Office for the Southern District of New York. In this case, consistent with the Government's customary practice, and as the Government has informed defense counsel, the Government has no intention of providing witnesses, victims or their counsel with the entirety of discovery produced to the defendant, nor anything even close to that. Indeed, consistent with its standard practice, the Government rarely provides any third party, including a witness, with any material they did not already possess. While the Government does more commonly show a witness materials in connection with proffers or trial preparation, the Government rarely if ever shows a witness material she has not already seen, does not have personal knowledge of, or would not have some specific reason to opine upon. Practically speaking, therefore, the concerns defense counsel raises about future use in civil litigation are not likely to occur. + +Nevertheless, a criminal protective order is not the appropriate forum for the defendant to demand restrictions on the Government's use of its own materials. To the contrary, as noted above, many of those restrictions are already established by rule and law—standards the defendant makes no suggestion the Government has failed to adhere to in this case. Moreover, the Government as a whole, including those beyond the prosecutors on this case, may have obligations that would conflict with such language in a protective order. For example, the Government has obligations under various statutory and regulatory regimes, including but not limited to the Freedom of Information Act and Touhy v. Ragen, 340 U.S. 462 (1951), that cannot be bargained away through a protective order. Indeed, the Government can represent that the Department of Justice has received both FOIA and Touhy requests in connection with this investigation, requests to which the Department has a legal obligation to respond appropriately. The Government respectfully submits it would be inappropriate for the defendant to seek—or the Court to order—language in a protective order that conflicts with or supersedes those obligations. Tellingly, the defendant cites no authority or precedent for her request regarding this issue. + +By contrast, to the extent the defendant intends to produce reciprocal discovery to the Government, it may in that case be appropriate to limit the Government's use, or third parties' use, + +Specifically, the defendant's proposed protective order differs from the Government's in that it adds a paragraph, its paragraph 3, proposing restrictions upon the Government and its potential witnesses, and their counsel, as well as adding language to its paragraph 5, which is Government paragraph 4, further restricting potential government witnesses and their counsel. + +July 28, 2020 + +Page 7 + +of such materials provided by the defendant to the Government. But there is no basis to add additional restrictions upon the Government's use of materials gathered by the Government itself. + +The defendant's only counter-argument, as noted—that this Court should put third parties "on equal footing with the defense"—is both unlikely to be relevant given the Government's standard practice, as described above, and, the Government submits, an irrelevant consideration in the context of a criminal protective order. Indeed, the Government respectfully submits that neither it nor this Court is well-positioned to, or should, become the arbiter of what is appropriate or permissible in civil cases. + +In sum, the defendant's attempt to restrict the Government and to restrict third parties in this way appears to be unprecedented, and is without legal basis, and should be denied. + +Accordingly, for the reasons set forth above, the Court should enter the Government's proposed protective order, which is enclosed, and deny the defendant's motion. + +Respectfully submitted, + +By: + +Alex Rossmiller / Alison Moe / Maurene Comey Assistant United States Attorneys Southern District of New York Tel: (212) 637-2415 + +REY STRAUSS ng United States Attorney + +Cc: All counsel of record (via ECF) + +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x UNITED STATES OF AMERICA GHISLAINE MAXWELL, Defendant. x + +PROPOSED] PROTECTIVE ORDER + +20 Cr. 330 (AJN) + +ALISON J. NATHAN, United States District Judge: + +WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely disclosed, the Government's ongoing investigation; (iii) would risk prejudicial pretrial publicity if publicly disseminated, and (iv) is not authorized to be disclosed to the public or disclosed beyond that which is necessary for the defense of this action, and other materials pursuant to Federal Rule of Criminal Procedure 16 ("Rule 16") and pursuant to any other disclosure obligations (collectively, the "Discovery"), which contain sensitive, confidential, or personal identifying information; + +WHEREAS, the Government seeks to protect sensitive, confidential, or personal identifying information contained in the materials it produces consistent with Rule 16 or other disclosure obligations; + +WHEREAS the Government has applied for the entry of this Order; + +IT HEREBY IS ORDERED: + +1. The Discovery disclosed to the defendant ("Defendant") and/or to the defendant's criminal defense attorneys ("Defense Counsel") during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall not be copied or otherwise recorded or transmitted by the Defendant, except to Defense Counsel, or except as necessary for the Defendant to take notes, which are not to be further transmitted to anyone other than Defense Counsel; + +c) Shall not be disclosed or distributed in any form by the Defendant or her counsel except as set forth in paragraph 1(d) below; + +d) May be disclosed only by Defense Counsel and only to the following persons ("Designated Persons"): + +i. investigative, secretarial, clerical, or paralegal personnel employed full-time, part-time, or as + +independent contractors by the defendant's counsel ("Defense Staff"); + +ii. any expert or potential expert, legal advisor, consultant, or any other individual retained or employed by the Defendant and Defense Counsel for the purpose of assisting in the defense of this case ("Defense Experts/Advisors"); + +iii. such other persons as hereafter may be authorized by Order of the Court ("Other Authorized Persons"); + +e) May be provided to prospective witnesses and their counsel (collectively, "Potential Defense Witnesses"), to the extent deemed necessary by defense counsel, for trial preparation. To the extent Discovery materials are disclosed to Potential Defense Witnesses, they agree that any such materials will not be further copied, distributed, or otherwise transmitted to individuals other than the recipient Potential Defense Witnesses. + +2. The Defendant and Defense Counsel shall provide a copy of this Order to any Designated Persons to whom they disclose Discovery materials. Prior to disclosure of Discovery materials to Designated Persons, any such Designated Person shall agree to be subject to the terms of this Order by signing a copy hereof and stating that they "Agree to be bound by the terms herein," and providing such copy to Defense Counsel. All + +such acknowledgments shall be retained by Defense Counsel and shall be subject to in camera review by the Court if good cause for review is demonstrated. The Defendant and her counsel need not obtain signatures from any member of the defense team (i.e., attorneys, experts, consultants, paralegals, investigators, support personnel, and secretarial staff involved in the representation of the defendants in this case), all of whom are nonetheless bound by this Protective Order. + +3. To the extent that Discovery is disseminated to Defense Experts/Advisors, Other Authorized Persons, or Potential Defense Witnesses, via means other than electronic mail, Defense Counsel shall encrypt and/or password protect the Discovery. + +4. The Government, the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses and their counsel, and Other Authorized Persons are prohibited from posting or causing to be posted any of the Discovery or information contained in the Discovery on the Internet, including any social media website or other publicly available medium. + +5. The Government (other than in the discharge of their professional obligations in this matter), the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses and their counsel, and Other Authorized Persons are strictly prohibited from publicly + +disclosing or disseminating the identity of any victims or witnesses referenced in the Discovery. This Order does not prohibit Defense Counsel or Defense Staff from referencing the identities of individuals they believe may be relevant to the defense to Potential Defense Witnesses and their counsel during the course of the investigation and preparation of the defense case at trial. Any Potential Defense Witnesses and their counsel who are provided identifying information by Defense Counsel or Defense Staff are prohibited from further disclosing or disseminating such identifying information. This Order does not prohibit Defense Counsel from publicly referencing individuals who have spoken by name on the public record in this case. + +6. The Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing the identity of any victims or witnesses referenced in the Discovery, who have not spoken by name on the public record in this case, unless authorized by the Government in writing or by Order of the Court. Any such filings must be filed under seal, unless authorized by the Government in writing or by Order of the Court. + +7. Copies of Discovery or other materials produced by the Government in this action bearing "confidential" stamps, or designated as "confidential" as described below, and/or electronic Discovery materials designated as "confidential" by the Government, including such materials marked as "confidential" either on the documents or materials themselves, or designated as "confidential" in a folder or document title, are deemed "Confidential Information." The Government shall clearly mark all pages or electronic materials containing Confidential Information, or folder or document titles as necessary, with "confidential" designations. + +8. Confidential Information may contain personal identification information of victims, witnesses, or other specific individuals who are not parties to this action, and other confidential information; as well as information that identifies, or could lead to the identification of, witnesses in this matter. The identity of an alleged victim or witness who has identified herself or himself publicly as such on the record in this case shall not be treated as Confidential Information. + +9. Defense Counsel may, at any time, notify the Government that Defense Counsel does not concur in the designation of documents or other materials as Confidential Information. If the Government does not agree to de-designate such documents or materials, Defense Counsel may thereafter move the Court for an Order de-designating such documents or materials. The Government's designation of such documents and materials as Confidential Information will be controlling absent contrary order of the Court. + +10. Confidential Information disclosed to the defendant, or Defense Counsel, respectively, during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall be maintained in a safe and secure manner; + +c) Shall be reviewed and possessed by the Defendant in hard copy solely in the presence of Defense Counsel; + +d) Shall be possessed in electronic format only by Defense Counsel and by appropriate officials of the Bureau of Prisons ("BOP"), who shall provide the defendant with electronic access to the Discovery, including Confidential Information, consistent with the rules and regulations of the BOP, for the Defendant's review; + +e) Shall be reviewed by the Defendant solely in the presence of Defense Counsel or when provided access to Discovery materials in electronic format by BOP officials; + +f) May be disclosed only by Defense Counsel and only to Designated Persons; + +g) May be shown to, either in person, by videoconference, or via a read-only document review platform, but not disseminated to or provided copies of to, Potential Defense Witnesses, to the extent deemed necessary by Defense Counsel, for trial preparation, and after such individual(s) have read and signed this Order acknowledging that such individual(s) are bound by this Order. + +11. Copies of Discovery or other materials produced by the Government in this action bearing "highly confidential" stamps or otherwise specifically designated as "highly confidential," and/or electronic Discovery materials designated as "highly confidential" by the Government, including such materials marked as "highly confidential" either on the documents or materials themselves, or designated as "highly confidential" in an index, folder title, or document title, are deemed "Highly Confidential Information." To the extent any Highly Confidential Information is physically produced to the Defendant and Defense Counsel, rather than being made available to the Defendant and Defense Counsel for on-site review, the + +Government shall clearly mark all such pages or electronic materials containing Highly Confidential Information with "highly confidential" stamps on the documents or materials themselves. + +12. Highly Confidential Information contains nude, partially-nude, or otherwise sexualized images, videos, or other depictions of individuals. + +13. Defense Counsel may, at any time, notify the Government that Defense Counsel does not concur in the designation of documents or other materials as Highly Confidential Information. If the Government does not agree to de-designate such documents or materials, Defense Counsel may thereafter move the Court for an Order de-designating such documents or materials. The Government's designation of such documents and materials as Highly Confidential Information will be controlling absent contrary order of the Court. + +14. Highly Confidential Information disclosed to Defense Counsel during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall not be disseminated, transmitted, or otherwise copied and provided to Defense Counsel or the Defendant; + +c) Shall be reviewed by the Defendant solely in the presence of Defense Counsel; + +d) Shall not be possessed outside the presence of Defense Counsel, or maintained, by the Defendant; + +e) Shall be made available for inspection by Defense Counsel and the Defendant, under the protection of law enforcement officers or employees; and + +f) Shall not be copied or otherwise duplicated by Defense Counsel or the Defendant during such inspections. + +15. The Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing any Confidential Information or Highly Confidential Information referenced in the Discovery, unless authorized by the Government in writing or by Order of the Court. Any such filings must be filed under seal, unless authorized by the Government in writing or by Order of the Court. + +16. The provisions of this Order shall not be construed as preventing disclosure of any information, with the exception of victim or witness identifying information, that is publicly available or obtained by the Defendant or her Defense Counsel from a source other than the Government. + +17. Except for Discovery that has been made part of the record of this case, Defense Counsel shall return to the Government or securely destroy or delete all Discovery, including but not limited to Confidential Information, within 30 days of the expiration of the period for direct appeal from any verdict in the above-captioned case; the period of direct appeal from any order dismissing any of the charges in the abovecaptioned case; the expiration of the period for a petition pursuant to 28 U.S.C. § 2255; any period of time required by the federal or state ethics rules applicable to any attorney of record in this case; or the granting of any motion made on behalf of the Government dismissing any charges in the abovecaptioned case, whichever date is later. + +18. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree in writing otherwise, or (b) this Order is modified by further order of the Court. + +19. The Government and Defense Counsel agree to meet and confer in advance of any hearings or trial to discuss and agree to any modifications necessary for the presentation of evidence at those proceedings. In the absence of agreement, + +Defense Counsel may make an appropriate application to the Court for any such modifications. + +SO ORDERED: + +Dated: New York, New York , 2020 + +> HONORABLE ALISON J. 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NATHAN, District Judge: + +Both parties have asked for the Court to enter a protective order. While they agree on most of the language, two areas of dispute have emerged. First, Ms. Maxwell seeks language allowing her to publicly reference alleged victims or witnesses who have spoken on the public record to the media or in public fora, or in litigation relating to Ms. Maxwell or Jeffrey Epstein. Second, Ms. Maxwell seeks language restricting potential Government witnesses and their counsel from using discovery materials for any purpose other than preparing for the criminal trial in this action. The Government has proposed contrary language on both of these issues. For the following reasons, the Court adopts the Government's proposed protective order. + +Under Federal Rule of Criminal Procedure 16(d)(1), "[alt any time the court may, for good cause, deny, restrict, or defer discovery or inspection, or grant other appropriate relief." The good cause standard "requires courts to balance several interests, including whether dissemination of the discovery materials inflicts hazard to others . . . whether the imposition of the protective order would prejudice the defendant," and "the public's interest in the information." United States v. Smith, 985 F. Supp. 2d 506, 522 (S.D.N.Y. 2013). The party seeking to restrict disclosure bears the burden of showing good cause. Cf. Gambale v. Deutsche Bank AG, 377 F.3d 133, 142 (2d Cir. 2004). + +First, the Court finds that the Government has met its burden of showing good cause with regard to restricting the ability of Ms. Maxwell to publicly reference alleged victims and witnesses other than those who have publicly identified themselves in this litigation. As a general matter, it is undisputed that there is a strong and specific interest in protecting the privacy of alleged victims and witnesses in this case that supports restricting the disclosure of their identities. Dkt. No. 29 at 3 (acknowledging that as a baseline the protective order should "prohibit[] Ms. Maxwell, defense counsel, and others on the defense team from disclosing or disseminating the identity of any alleged victim or potential witness referenced in the discovery materials"); see also United States v. Corley, No. 13-cr-48, 2016 U.S. Dist. LEXIS 194426, at \*11 (S.D.N.Y. Jan. 15, 2016). The Defense argues this interest is significantly diminished for individuals who have spoken on the public record about Ms. Maxwell or Jeffrey Epstein, because they have voluntarily chosen to identify themselves. But not all accusations or 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, particularly since such a statement might have occurred decades ago and have no relevance to the charges in this case. These individuals still maintain a significant privacy interest that must be safeguarded. The exception the Defense seeks is too broad and risks undermining the protections of the privacy of witnesses and alleged victims that is required by law. In contrast, the Government's proffered language would allow Ms. Maxwell to publicly reference individuals who have spoken by name on the record in this case. It also allows the Defense to "referenc[e] the identities of individuals they believe may be relevant ... to Potential Defense Witnesses and their counsel during the course of the investigation and preparation of the defense case at trial." Dkt. No. 33-1, 1 5. This proposal adequately balances the interests at + +stake. And as the Government's letter notes, *see* Dkt. No. 33 at 4, to the extent that the Defense needs an exception to the protective order for a specific investigative purpose, they can make applications to the Court on a case-by-case basis. + +Second, restrictions on the ability of potential witnesses and their counsel to use discovery materials for purposes other than preparing for trial in this case are unwarranted. The request appears unprecedented despite the fact that there have been many high-profile criminal matters that had related civil litigation. The Government labors under many restrictions including Rule 6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and other policies of the Department of Justice and the U.S. Attorney's Office for the Southern District of New York, all of which the Court expects the Government to scrupulously follow. Furthermore, the Government indicates that it will likely only provide potential witnesses with materials that those witnesses already have in their possession. *See* Dkt. No. 33 at 6. And of course, those witnesses who do testify at trial would be subject to examination on the record as to what materials were provided or shown to them by the Government. Nothing in the Defense's papers explains how its unprecedented proposed restriction is somehow necessary to ensure a fair trial. + +For the foregoing reasons, the Court adopts the Government's proposed protective order, which will be entered on the docket. + +This resolves Dkt. No. 29. + +SO ORDERED. + +Dated: July 30, 2020 +New York, New York + +![]() + +--- + +ALISON J. 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NATHAN, United States District Judge: + +WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely disclosed, the Government's ongoing investigation; (iii) would risk prejudicial pretrial publicity if publicly disseminated, and (iv) is not authorized to be disclosed to the public or disclosed beyond that which is necessary for the defense of this action, and other materials pursuant to Federal Rule of Criminal Procedure 16 ("Rule 16") and pursuant to any other disclosure obligations (collectively, the "Discovery"), which contain sensitive, confidential, or personal identifying information; + +WHEREAS, the Government seeks to protect sensitive, confidential, or personal identifying information contained in the materials it produces consistent with Rule 16 or other disclosure obligations; + +WHEREAS the Government has applied for the entry of this Order; + +IT HEREBY IS ORDERED: + +1. The Discovery disclosed to the defendant ("Defendant") and/or to the defendant's criminal defense attorneys ("Defense Counsel") during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall not be copied or otherwise recorded or transmitted by the Defendant, except to Defense Counsel, or except as necessary for the Defendant to take notes, which are not to be further transmitted to anyone other than Defense Counsel; + +c) Shall not be disclosed or distributed in any form by the Defendant or her counsel except as set forth in paragraph 1(d) below; + +d) May be disclosed only by Defense Counsel and only to the following persons ("Designated Persons"): + +i. investigative, secretarial, clerical, or paralegal personnel employed full-time, part-time, or as + +independent contractors by the defendant's counsel ("Defense Staff"); + +ii. any expert or potential expert, legal advisor, consultant, or any other individual retained or employed by the Defendant and Defense Counsel for the purpose of assisting in the defense of this case ("Defense Experts/Advisors"); + +iii. such other persons as hereafter may be authorized by Order of the Court ("Other Authorized Persons"); + +e) May be provided to prospective witnesses and their counsel (collectively, "Potential Defense Witnesses"), to the extent deemed necessary by defense counsel, for trial preparation. To the extent Discovery materials are disclosed to Potential Defense Witnesses, they agree that any such materials will not be further copied, distributed, or otherwise transmitted to individuals other than the recipient Potential Defense Witnesses. + +2. The Defendant and Defense Counsel shall provide a copy of this Order to any Designated Persons to whom they disclose Discovery materials. Prior to disclosure of Discovery materials to Designated Persons, any such Designated Person shall agree to be subject to the terms of this Order by signing a copy hereof and stating that they "Agree to be bound by the terms herein," and providing such copy to Defense Counsel. All + +such acknowledgments shall be retained by Defense Counsel and shall be subject to in camera review by the Court if good cause for review is demonstrated. The Defendant and her counsel need not obtain signatures from any member of the defense team (i.e., attorneys, experts, consultants, paralegals, investigators, support personnel, and secretarial staff involved in the representation of the defendants in this case), all of whom are nonetheless bound by this Protective Order. + +3. To the extent that Discovery is disseminated to Defense Experts/Advisors, Other Authorized Persons, or Potential Defense Witnesses, via means other than electronic mail, Defense Counsel shall encrypt and/or password protect the Discovery. + +4. The Government, the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses and their counsel, and Other Authorized Persons are prohibited from posting or causing to be posted any of the Discovery or information contained in the Discovery on the Internet, including any social media website or other publicly available medium. + +5. The Government (other than in the discharge of their professional obligations in this matter), the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses and their counsel, and Other Authorized Persons are strictly prohibited from publicly + +disclosing or disseminating witnesses referenced in the prohibit Defense Counsel or the identity of any victims or Discovery. This Order does not Defense Staff from referencing the identities of individuals they believe may be relevant to the defense to Potential Defense Witnesses and their counsel during the course of the investigation and preparation of the defense case at trial. Any Potential Defense Witnesses and their counsel who are provided identifying information by Defense Counsel or Defense Staff are prohibited from further disclosing or disseminating such identifying information. This Order does not prohibit Defense Counsel from publicly referencing individuals who have spoken by name on the public record in this case. + +6. The Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing the identity of any victims or witnesses referenced in the Discovery, who have not spoken by name on the public record in this case, unless authorized by the Government in writing or by Order of the Court. Any such filings must be filed under seal, unless authorized by the Government in writing or by Order of the Court. + +7. Copies of Discovery or other materials produced by the Government in this action bearing "confidential" stamps, or designated as "confidential" as described below, and/or electronic Discovery materials designated as "confidential" by the Government, including such materials marked as "confidential" either on the documents or materials themselves, or designated as "confidential" in a folder or document title, are deemed "Confidential Information." The Government shall clearly mark all pages or electronic materials containing Confidential Information, or folder or document titles as necessary, with "confidential" designations. + +8. Confidential Information may contain personal identification information of victims, witnesses, or other specific individuals who are not parties to this action, and other confidential information; as well as information that identifies, or could lead to the identification of, witnesses in this matter. The identity of an alleged victim or witness who has identified herself or himself publicly as such on the record in this case shall not be treated as Confidential Information. + +9. Defense Counsel may, at any time, notify the Government that Defense Counsel does not concur in the designation of documents or other materials as Confidential Information. If the Government does not agree to de-designate such documents or materials, Defense Counsel may thereafter move the Court for an Order de-designating such documents or materials. The Government's designation of such documents and materials as Confidential Information will be controlling absent contrary order of the Court. + +10. Confidential Information disclosed to the defendant, or Defense Counsel, respectively, during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall be maintained in a safe and secure manner; + +c) Shall be reviewed and possessed by the Defendant in hard copy solely in the presence of Defense Counsel; + +d) Shall be possessed in electronic format only by Defense Counsel and by appropriate officials of the Bureau of Prisons ("BOP"), who shall provide the defendant with electronic access to the Discovery, including Confidential Information, consistent with the rules and regulations of the BOP, for the Defendant's review; + +e) Shall be reviewed by the Defendant solely in the presence of Defense Counsel or when provided access to Discovery materials in electronic format by BOP officials; + +f) May be disclosed only by Defense Counsel and only to Designated Persons; + +g) May be shown to, either in person, by videoconference, or via a read-only document review platform, but not disseminated to or provided copies of to, Potential Defense Witnesses, to the extent deemed necessary by Defense Counsel, for trial preparation, and after such individual(s) have read and signed this Order acknowledging that such individual(s) are bound by this Order. + +11. Copies of Discovery or other materials produced by the Government in this action bearing "highly confidential" stamps or otherwise specifically designated as "highly confidential," and/or electronic Discovery materials designated as "highly confidential" by the Government, including such materials marked as "highly confidential" either on the documents or materials themselves, or designated as "highly confidential" in an index, folder title, or document title, are deemed "Highly Confidential Information." To the extent any Highly Confidential Information is physically produced to the Defendant and Defense Counsel, rather than being made available to the Defendant and Defense Counsel for on-site review, the + +Government shall clearly mark all such pages or electronic materials containing Highly Confidential Information with "highly confidential" stamps on the documents or materials themselves. + +12. Highly Confidential Information contains nude, partially-nude, or otherwise sexualized images, videos, or other depictions of individuals. + +13. Defense Counsel may, at any time, notify the Government that Defense Counsel does not concur in the designation of documents or other materials as Highly Confidential Information. If the Government does not agree to de-designate such documents or materials, Defense Counsel may thereafter move the Court for an Order de-designating such documents or materials. The Government's designation of such documents and materials as Highly Confidential Information will be controlling absent contrary order of the Court. + +14. Highly Confidential Information disclosed to Defense Counsel during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall not be disseminated, transmitted, or otherwise copied and provided to Defense Counsel or the Defendant; + +c) Shall be reviewed by the Defendant solely in the presence of Defense Counsel; + +d) Shall not be possessed outside the presence of Defense Counsel, or maintained, by the Defendant; + +e) Shall be made available for inspection by Defense Counsel and the Defendant, under the protection of law enforcement officers or employees; and + +f) Shall not be copied or otherwise duplicated by Defense Counsel or the Defendant during such inspections. + +15. The Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing any Confidential Information or Highly Confidential Information referenced in the Discovery, unless authorized by the Government in writing or by Order of the Court. Any such filings must be filed under seal, unless authorized by the Government in writing or by Order of the Court. + +16. The provisions of this Order shall not be construed as preventing disclosure of any information, with the exception of victim or witness identifying information, that is publicly available or obtained by the Defendant or her Defense Counsel from a source other than the Government. + +17. Except for Discovery that has been made part of the record of this case, Defense Counsel shall return to the Government or securely destroy or delete all Discovery, including but not limited to Confidential Information, within 30 days of the expiration of the period for direct appeal from any verdict in the above-captioned case; the period of direct appeal from any order dismissing any of the charges in the abovecaptioned case; the expiration of the period for a petition pursuant to 28 U.S.C. § 2255; any period of time required by the federal or state ethics rules applicable to any attorney of record in this case; or the granting of any motion made on behalf of the Government dismissing any charges in the abovecaptioned case, whichever date is later. + +18. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree in writing otherwise, or (b) this Order is modified by further order of the Court. + +19. The Government and Defense Counsel agree to meet and confer in advance of any hearings or trial to discuss and agree to any modifications necessary for the presentation of evidence at those proceedings. In the absence of agreement, + +Defense Counsel may make an appropriate application to the Court for any such modifications. + +SO ORDERED: + +Dated: New York, New York July 30 , 2020 + +Lc + +HONORABLE ALISON J. 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100644 index 0000000000000000000000000000000000000000..7f31b827de86b85947da044709ae71c2d8ab24e7 --- /dev/null +++ b/marker2/ds9/EFTA00084566/EFTA00084566.md @@ -0,0 +1,17 @@ +From: iS" To: ' Cc: + +Subject: RE: initial discovery production + +Date: Sat, 01 Aug 2020 21:20:35 +0000 + +Attachments: 2020-07-28"govemment\_letter\_re\_protective\_orderidocketed).pdf; 2020-07- 31,\_GM,memorandum\_&\_order\_granting\_govemment\_motion.pdf; 2020-07- 31"GM,signed\_protective\_order (docketed).pdf + +We wanted to briefly check with you on a couple issues. First, as we briefly discussed this past week, now that there is a protective order entered in the Maxwell case, we expect to begin making discovery productions to the defense in the very near future. As you know, defense counsel argued that they should be able to publicly identify victims in certain circumstances, which we vigorously opposed, and ultimately the judge ruled in our favor. The resulting protective order is exceptionally strong. I know you have some of these materials, but just to give them to you all in one place, attached are the Government's letter, the Court's opinion, and the Order. + +As you would expect, some of the discovery we will begin to produce will include information about your client, including, e.g., her name and date of birth, in connection with documents we have gathered that require production. Consistent with the protective order, defense counsel may not disclose or distribute any discovery materials except under very strict conditions, and in any event the defendant and counsel "are strictly prohibited from publicly disclosing or disseminating the identity of any victims or witnesses referenced in the Discovery." To the extent they need to reference the identity of individuals as part of their investigation, e.g., in individual interviews, any potential defense witnesses and counsel are similarly prohibited from further disclosing or disseminating such identifying information. All of these appropriate restrictions notwithstanding, we nevertheless did want to let you know that we are beginning to make discovery productions, in an abundance of caution and in the interests of transparency. + +Additionally, when we make the initial discovery production, with your permission we may advise defense counsel that each victim in the Indictment is represented by counsel, and identify the counsel for each person (i.e., we would identify you as counsel for . The reason we would do that would be to preempt attempts at direct contact with represented witnesses by defense counsel or defense investigators. Please let us know if you have a preference on this, and we're also happy to discuss it via phone. + +As always, please don't hesitate to be in touch on any of these issues, we'll keep you advised of any significant developments, and thanks. + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00084566/EFTA00084566.metadata.json b/marker2/ds9/EFTA00084566/EFTA00084566.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d9737dc16cfb05be986ec38f223d907eab2682ea --- /dev/null +++ b/marker2/ds9/EFTA00084566/EFTA00084566.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084566.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2719, + "elapsed_seconds": 0.53, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 33 + ], + [ + "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/EFTA00084566" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084567/EFTA00084567.md b/marker2/ds9/EFTA00084567/EFTA00084567.md new file mode 100644 index 0000000000000000000000000000000000000000..e3de534475d4119b9953d002e6a17f87d9d0b3ec --- /dev/null +++ b/marker2/ds9/EFTA00084567/EFTA00084567.md @@ -0,0 +1,239 @@ +![](_page_0_Picture_1.jpeg) + +## U.S. Department of Justice + +United Stales Attorney Southern District of New York + +The Silvio J. Mollo Building One saint Andrew's Plaza New York. New York 10007 + +July 28, 2020 + +## VIA ECF + +The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Dear Judge Nathan: + +The Government respectfully submits this letter with respect to the protective order to be entered in the above-captioned case, and to respond to the defendant's letter and submission of July 27, 2020 (the "Defendant Letter" or "Def. Ltr.") (Dkt. 29). The Government and defense counsel have conferred regarding a protective order several times via telephone and email between July 9, 2020, and today, including as recently as this morning. The Government and defense counsel have come to an agreement on much of the proposed protective order. However, the parties disagree as to two inclusions sought by the defendant which the Government objects to and for which, as detailed herein, the Government submits there is no legal basis. Accordingly, the Government respectfully requests that the Court enter its proposed protective order (the "Government Proposed Order"), which is attached hereto as Exhibit A, and which differs from the defendant's proposed order in those two respects, as further described below. + +## A. The Defendant's Request to be Permitted to Publicly Name and Identify Victims + +As detailed herein, the Government seeks to protect the identities of victims, consistent with their significant privacy interests and the well-established law in this Circuit, and proposes a protective order consistent with those very significant interests. In contrast, the defendant insists that the protective order be modified such that she and her counsel would be permitted to "publicly referenc[e]" individuals, by name, who have "spoken on the public record to the media or in public fora, or in litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell."' + +Specifically, the defendant's proposed protective order differs from the Government's in that it adds a sentence, in its paragraph 6 (which is paragraph 5 of the Government Proposed Order), stating the following: "Nor does this Order prohibit Defense Counsel from publicly referencing individuals who have spoken on the record to the media or in public fora, or in litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell." The defendant also either adds + +July 28, 2020 + +Page 2 + +The defendant's demand that she and her counsel be permitted to name any individuals who have ever publicly identified themselves as a victim of either Epstein or the defendant in any "public fora," and at any time, without limitation, is extraordinarily broad, unnecessary, and inappropriate, and should be denied. + +As an initial matter, there can be no serious question that there are significant privacy and victim interests at issue here, which the Government Proposed Order seeks to protect. Particularly in the context of victim witnesses, there are compelling reasons to limit public disclosure of victim identities and other sensitive information. Indeed, the Crime Victims' Rights Act, 18 U.S.C. § 3771, requires district courts to implement procedures to ensure that crime victims are accorded, among other rights, "[t]he right to be reasonably protected from the accused," in addition to "[t]he right to be treated with fairness and with respect for the victim's dignity and privacy." Id. §§ (a)(1), (a)(8) (emphasis added). Moreover, "the public generally has a strong interest in protecting the identities of ... victims so that other victims will not be deterred from reporting such crimes." United States v. Paris, 2007 WL 1484974, at \*2 (D. Conn. May 18, 2007). + +Moreover, and consistent with those interests, courts in this Circuit have routinely acknowledged the need to protect victim-witness identities. See, e.g., United States v. Corley, 13 Cr. 48 (AJN), 2016 WL 9022508, at \*4 (S.D.N.Y. Jan. 15, 2016) ("Because Corley's minor victims have significant privacy and safety interests at stake, while Corley's interests are minimal, the Court finds good cause to modify the protective order in this case to prevent Corley from learning the surnames of the minor victims."); United States v. Kelly, 07 Cr. 374 (SJ), 2008 WL 5068820, at \*2 (E.D.N.Y. July 10, 2008) ("Given the potentially explicit nature of the government witnesses' expected testimony, the government argues that it is necessary to conceal their identity to protect them from public humiliation and embarrassment. This Court agrees. Thus, the parties [. . .] are hereby prohibited from releasing to anyone, including members of the press, the identity or any identifying information of the government's witnesses."). It is similarly routine in this District for parties in a criminal case to refer to witnesses by pseudonyms (such as "Victim-I" or "Witness-1") to protect the privacy interests of third parties unless and until they testify publicly. + +The Government's proposed order endeavors to protect those interests by generally requiring the parties to abstain from identifying any victim by name in any public statement or filing while also ensuring that the defendant and her counsel are fully able to prepare for trial. Indeed, to facilitate the defendant's investigation and preparation for trial, the Government's proposal makes clear that defense counsel and defense staff, including defense investigators, should not be prohibited from referencing identities of individuals in conversations with prospective witnesses, so long as those witnesses and their counsel abstain from further disclosing or disseminating any such identities. See Government Proposed Order ¶ 5. The terms of the Government's proposed order also would permit defense counsel to refer to any individual by name in any filing under seal, merely requiring redaction of identifying information or the use of a pseudonym in public filings. The Government further proposes that defense counsel not be prohibited from publicly referencing individuals who have spoken—or who at some future time + +or deletes language in furtherance of its desire to publicly reference victim identities in defense paragraphs 7, 9, and 17 (which are Government Proposed Order paragraphs 6, 7, and 16). + +July 28, 2020 + +Page 3 + +speak—by name on the public record in this case, as one victim has already chosen to do, because those victims, and only those victims, have affirmatively chosen to be publicly identified in connection with this case. These proposals are reasonable, narrowly tailored, and not broader than necessary to protect victims' privacy interests, safety, and well-being, to avoid potential harassment of witnesses by the press and others, and to prevent undue embarrassment and other adverse consequences. At this stage in the case, permitting defense counsel to refer to witnesses by name in sealed filings, to refer to witnesses by name in the course of private conversations during their investigation, and to refer by name to individuals who have made the affirmative choice to be identified by name in connection with this criminal case is more than enough to enable the defendant ability to vigorously pursue her defense. + +The defendant has rejected this proposal because, as noted above, she believes that she and her counsel should be permitted to "publicly referenc[e]" individuals, by name, who have "spoken on the public record to the media or in public fora, or in litigation — criminal or otherwise — relating to Jeffrey Epstein or Ghislaine Maxwell." In support of the defendant's application for such sweeping ability to publicly name any such individuals, defense counsel provides only the conclusory assertion that an inability to publicly reference the names of victims, in court proceedings and beyond, will hinder their ability to investigate, prepare witnesses for trial, and advocate on the defendant's behalf. The Government has repeatedly asked defense counsel to explain how or why it would need to publicly name victims of sexual abuse to prepare for trial, and the defense repeatedly has declined to do so, presumably because the argument borders on the absurd.2 + +The Government's proposed protective order would do no such thing. As described above, the Government's proposed order would permit defense counsel and defense staff to reference the identities of individuals they believe may be relevant to the defense to potential witnesses and their counsel (who then would be prohibited from further disclosing or disseminating such identifying information). Government Proposed Order ¶ 5. It would further permit the defendant to publicly identify individuals who have chosen to speak on the record on this case. Id. ¶ 6. And it would permit the defendant to reference identifying information in filings made under seal. See id. + +2 Despite the Government's requests for clarity on the need for the defendant's requested modification, the sole additional reason provided by defense counsel for why it would be appropriate or necessary to publicly name victims is that certain of these victims have obtained what defense counsel described as the "benefit" of publicly identifying themselves as victims (and thus, as the defendant presumably would have it, deserve whatever public identification and scrutiny the defendant intends to invite upon them). Beyond the offensive notion that victims of sexual abuse experience a "benefit" by making the incredibly difficult decision to share their experience publicly, the suggestion that victims who receive this supposed "benefit" should receive fewer protections than the law ordinarily offers to victims in criminal cases is alarming. Permitting defense counsel to publicly identify witnesses who have not identified themselves on the record in this case risks subjecting witnesses to harassment and intimidation, with no conceivable benefit to the defense other than perhaps discouraging witnesses from cooperating with the Government. + +July 28, 2020 + +Page 4 + +Moreover, the defendant is able, at any time, to apply to the Court for a modification of the protective order should she be able to identify a particularized need to publicly name victims who have not yet identified themselves on the record in this case—as opposed to redacting their names from court filings, or referring to them in an anonymized fashion. As noted, to date, defense counsel has declined to identify to the Court or to the Government any example of why doing so would be necessary or helpful to the defense, or even under what circumstances the defense might want to do so. + +The defendant's proposal is also extraordinarily broad, and without any temporal or subject matter limitation as to the phrase "public fora." Adopting the defendant's proposal would mean that any individual who has ever self-identified as a victim ofJeffrey Epstein or Ghislaine Maxwell publicly in any capacity would be subject to public identification by the defendant and her counsel in connection with this case. This would include, as hypothetical examples, someone who spoke to a journalist for a local story in 1997, or posted on a MySpace page followed by a handful of friends in 2005, or made a statement on a small podcast in 2009, or posted on Twitter to a handful of followers in 2013. But none of these examples of ventures into the "public fora" can possibly be construed as efforts by hypothetical victims to consent or choose "to self-identify," Def. Ltr. at 3, in a future criminal case against Ghislaine Maxwell subject to extraordinary public attention and scrutiny. + +Additionally, while some individuals have identified themselves as victims without providing any details or additional information about their abuse, the defense contemplates no limitation of publicly associating those individuals with the details of their abuse in public defense statements or filings. In essence, the defendant's proposal seeks authorization to drag into the public glare any victim who has ever made any type of public statement of victimization—no matter how long ago or how brief—without that victim's knowing consent and without any substantive justification. That is particularly troubling given that the Government expects to make productions of discovery and 3500 materials well surpassing its obligations. Those productions will necessarily include the identities of individuals whom the Government does not expect to call as witnesses, and whose accounts—much less identities—will have no bearing on this case. But the defendant's proposal would allow her and her counsel to publicly name them in any public statement or filing at their sole discretion. This is plainly unnecessary for any investigative steps or trial preparation, would be grossly inappropriate and unfair, and would be inconsistent with the Crime Victims' Rights Act. + +Conversely, the Government's submission proposes that the defendant and her counsel not be precluded from discussing publicly individuals who identify themselves on the record in this criminal prosecution, because any such individuals will have made a conscious and informed choice to be associated publicly with this case. See Government Proposed Order¶¶ 5, 6, 8. The identity of any other individuals should be protected from public broadcast by the defendant and her counsel. + +The defendant argues that her proposed language is "nearly identical in all material respects" to the protective order entered in United States v. Epstein, 19 Cr. 490 (RMB) (Dkt. 38). Def. Ltr. at 3. In the first instance, that is false. The protective order in the Epstein case included + +Page 5 + +a provision stating that it did not prohibit defense counsel from publicly referencing individuals who had spoken on the public record *in litigation* relating to Jeffrey Epstein. *Id.* ¶ 4. Here, defense counsel seeks permission to publicly identify any individuals who have self-identified as victims of either the defendant or Epstein “*to the media or in public fora*, or in litigation”—a vastly broader allowance. Indeed, as a comparison, *none* of the hypothetical examples described above would have been subject to public naming and identification under the *Epstein* protective order, but every single one would be under the defendant’s proposed order in this case. + +Additionally, beyond the differences in the language itself, there are two significant differences between the circumstances of the *Epstein* prosecution and this case. First, at the time the *Epstein* protective order was entered, there were exceptionally few victims who had identified themselves by name in litigation. Accordingly, the practical application of that provision was extremely limited. Second, and related, in the time between when the *Epstein* protective order was entered and the indictment in this case, many more victims have made public statements about their victimization at the hands of Epstein, and the defendant, on their own terms and in their own ways, including by exercising their rights under the Crime Victims’ Rights Act in the context of the dismissal of the indictment against Jeffrey Epstein following his suicide. Those victims could not possibly have predicted, much less chosen, that their names would be publicly broadcast by defense counsel in connection with a subsequent criminal case. Victims should be able to continue to come forward, in the ways and in the venues they themselves choose, without fear of reprisal, shaming, or other consequence arising from having their identities broadcast by defense counsel in this case. + +In sum, the requested modification to the Government’s proposed order sought by the defendant is contrary to precedent and the compelling privacy interests of victims. Moreover, it is without basis in fact or law, and, despite the Government’s repeated requests for clarity, the defendant and defense counsel have offered no legitimate reason for their desire to be able to publicly identify any number of victims, in the context of this criminal case and elsewhere, other than a minimal, conclusory statement, without factual examples or legal support.3 At bottom, the defendant and her counsel seek an unlimited ability to name victims and witnesses publicly, for no discernible reason, and without justification or legal basis. The victims of Ghislaine Maxwell and Jeffrey Epstein have suffered enough, and the Crime Victims’ Rights Act, applicable law, and common decency compel far more protection of their privacy interests here than the defense proposal would afford. + +#### B. The Defendant’s Demand that the Government Restrict Use of its Own Documents + +The defendant and her counsel also ask the Court to impose restrictions upon the Government in its use, through potential witnesses and their counsel, of documents it currently possesses, beyond the already-extensive restrictions and protections applicable to the + +--- + +3 To the extent defense counsel attempts to provide such examples or arguments for the first time in a reply filing, the Government respectfully requests leave to reply to those examples or arguments. + +July 28, 2020 + +Page 6 + +Government.4 The defendant cites not a single example in any district court in the country where such a restriction has been imposed in a protective order. Indeed, it is nonsensical for a protective order to require limitations of the Government in its use of material already in its possession so that the Government may provide a defendant with discovery. The defendant's attempt to refuse to agree to receive discovery unless the Government agrees to additional restrictions upon the use of its own materials should be rejected. + +As an initial matter, the Government's use of materials it has gathered through its investigation, including through the grand jury process, search warrants, interviews, and voluntary disclosures, is already subject to a wide range of restrictions, including Rule 6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and other policies of the Department of Justice and the U.S. Attorney's Office for the Southern District of New York. In this case, consistent with the Government's customary practice, and as the Government has informed defense counsel, the Government has no intention of providing witnesses, victims or their counsel with the entirety of discovery produced to the defendant, nor anything even close to that. Indeed, consistent with its standard practice, the Government rarely provides any third party, including a witness, with any material they did not already possess. While the Government does more commonly show a witness materials in connection with proffers or trial preparation, the Government rarely if ever shows a witness material she has not already seen, does not have personal knowledge of, or would not have some specific reason to opine upon. Practically speaking, therefore, the concerns defense counsel raises about future use in civil litigation are not likely to occur. + +Nevertheless, a criminal protective order is not the appropriate forum for the defendant to demand restrictions on the Government's use of its own materials. To the contrary, as noted above, many of those restrictions are already established by rule and law—standards the defendant makes no suggestion the Government has failed to adhere to in this case. Moreover, the Government as a whole, including those beyond the prosecutors on this case, may have obligations that would conflict with such language in a protective order. For example, the Government has obligations under various statutory and regulatory regimes, including but not limited to the Freedom of Information Act and Touhy v. Ragen, 340 U.S. 462 (1951), that cannot be bargained away through a protective order. Indeed, the Government can represent that the Department of Justice has received both FOIA and Touhy requests in connection with this investigation, requests to which the Department has a legal obligation to respond appropriately. The Government respectfully submits it would be inappropriate for the defendant to seek—or the Court to order—language in a protective order that conflicts with or supersedes those obligations. Tellingly, the defendant cites no authority or precedent for her request regarding this issue. + +By contrast, to the extent the defendant intends to produce reciprocal discovery to the Government, it may in that case be appropriate to limit the Government's use, or third parties' use, + +Specifically, the defendant's proposed protective order differs from the Government's in that it adds a paragraph, its paragraph 3, proposing restrictions upon the Government and its potential witnesses, and their counsel, as well as adding language to its paragraph 5, which is Government paragraph 4, further restricting potential government witnesses and their counsel. + +July 28, 2020 + +Page 7 + +of such materials provided by the defendant to the Government. But there is no basis to add additional restrictions upon the Government's use of materials gathered by the Government itself. + +The defendant's only counter-argument, as noted—that this Court should put third parties "on equal footing with the defense"—is both unlikely to be relevant given the Government's standard practice, as described above, and, the Government submits, an irrelevant consideration in the context of a criminal protective order. Indeed, the Government respectfully submits that neither it nor this Court is well-positioned to, or should, become the arbiter of what is appropriate or permissible in civil cases. + +In sum, the defendant's attempt to restrict the Government and to restrict third parties in this way appears to be unprecedented, and is without legal basis, and should be denied. + +Accordingly, for the reasons set forth above, the Court should enter the Government's proposed protective order, which is enclosed, and deny the defendant's motion. + +Respectfully submitted, + +By: + +Alex Rossmiller / Alison Moe / Maurene Comey + +Assistant United States Attorneys + +Southern District of New York + +Tel: (212) 637-2415 + +REY STRAUSS + +ng United States Attorney + +Cc: All counsel of record (via ECF) + +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x UNITED STATES OF AMERICA GHISLAINE MAXWELL, Defendant. x + +PROPOSED] PROTECTIVE ORDER + +20 Cr. 330 (AJN) + +ALISON J. NATHAN, United States District Judge: + +WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely disclosed, the Government's ongoing investigation; (iii) would risk prejudicial pretrial publicity if publicly disseminated, and (iv) is not authorized to be disclosed to the public or disclosed beyond that which is necessary for the defense of this action, and other materials pursuant to Federal Rule of Criminal Procedure 16 ("Rule 16") and pursuant to any other disclosure obligations (collectively, the "Discovery"), which contain sensitive, confidential, or personal identifying information; + +WHEREAS, the Government seeks to protect sensitive, confidential, or personal identifying information contained in the materials it produces consistent with Rule 16 or other disclosure obligations; + +WHEREAS the Government has applied for the entry of this Order; + +IT HEREBY IS ORDERED: + +1. The Discovery disclosed to the defendant ("Defendant") and/or to the defendant's criminal defense attorneys ("Defense Counsel") during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall not be copied or otherwise recorded or transmitted by the Defendant, except to Defense Counsel, or except as necessary for the Defendant to take notes, which are not to be further transmitted to anyone other than Defense Counsel; + +c) Shall not be disclosed or distributed in any form by the Defendant or her counsel except as set forth in paragraph 1(d) below; + +d) May be disclosed only by Defense Counsel and only to the following persons ("Designated Persons"): + +i. investigative, secretarial, clerical, or paralegal personnel employed full-time, part-time, or as + +independent contractors by the defendant's counsel ("Defense Staff"); + +ii. any expert or potential expert, legal advisor, consultant, or any other individual retained or employed by the Defendant and Defense Counsel for the purpose of assisting in the defense of this case ("Defense Experts/Advisors"); + +iii. such other persons as hereafter may be authorized by Order of the Court ("Other Authorized Persons"); + +e) May be provided to prospective witnesses and their counsel (collectively, "Potential Defense Witnesses"), to the extent deemed necessary by defense counsel, for trial preparation. To the extent Discovery materials are disclosed to Potential Defense Witnesses, they agree that any such materials will not be further copied, distributed, or otherwise transmitted to individuals other than the recipient Potential Defense Witnesses. + +2. The Defendant and Defense Counsel shall provide a copy of this Order to any Designated Persons to whom they disclose Discovery materials. Prior to disclosure of Discovery materials to Designated Persons, any such Designated Person shall agree to be subject to the terms of this Order by signing a copy hereof and stating that they "Agree to be bound by the terms herein," and providing such copy to Defense Counsel. All + +such acknowledgments shall be retained by Defense Counsel and shall be subject to in camera review by the Court if good cause for review is demonstrated. The Defendant and her counsel need not obtain signatures from any member of the defense team (i.e., attorneys, experts, consultants, paralegals, investigators, support personnel, and secretarial staff involved in the representation of the defendants in this case), all of whom are nonetheless bound by this Protective Order. + +3. To the extent that Discovery is disseminated to Defense Experts/Advisors, Other Authorized Persons, or Potential Defense Witnesses, via means other than electronic mail, Defense Counsel shall encrypt and/or password protect the Discovery. + +4. The Government, the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses and their counsel, and Other Authorized Persons are prohibited from posting or causing to be posted any of the Discovery or information contained in the Discovery on the Internet, including any social media website or other publicly available medium. + +5. The Government (other than in the discharge of their professional obligations in this matter), the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses and their counsel, and Other Authorized Persons are strictly prohibited from publicly + +disclosing or disseminating the identity of any victims or witnesses referenced in the Discovery. This Order does not prohibit Defense Counsel or Defense Staff from referencing the identities of individuals they believe may be relevant to the defense to Potential Defense Witnesses and their counsel during the course of the investigation and preparation of the defense case at trial. Any Potential Defense Witnesses and their counsel who are provided identifying information by Defense Counsel or Defense Staff are prohibited from further disclosing or disseminating such identifying information. This Order does not prohibit Defense Counsel from publicly referencing individuals who have spoken by name on the public record in this case. + +6. The Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing the identity of any victims or witnesses referenced in the Discovery, who have not spoken by name on the public record in this case, unless authorized by the Government in writing or by Order of the Court. Any such filings must be filed under seal, unless authorized by the Government in writing or by Order of the Court. + +7. Copies of Discovery or other materials produced by the Government in this action bearing "confidential" stamps, or designated as "confidential" as described below, and/or electronic Discovery materials designated as "confidential" by the Government, including such materials marked as "confidential" either on the documents or materials themselves, or designated as "confidential" in a folder or document title, are deemed "Confidential Information." The Government shall clearly mark all pages or electronic materials containing Confidential Information, or folder or document titles as necessary, with "confidential" designations. + +8. Confidential Information may contain personal identification information of victims, witnesses, or other specific individuals who are not parties to this action, and other confidential information; as well as information that identifies, or could lead to the identification of, witnesses in this matter. The identity of an alleged victim or witness who has identified herself or himself publicly as such on the record in this case shall not be treated as Confidential Information. + +9. Defense Counsel may, at any time, notify the Government that Defense Counsel does not concur in the designation of documents or other materials as Confidential Information. If the Government does not agree to de-designate such documents or materials, Defense Counsel may thereafter move the Court for an Order de-designating such documents or materials. The Government's designation of such documents and materials as Confidential Information will be controlling absent contrary order of the Court. + +10. Confidential Information disclosed to the defendant, or Defense Counsel, respectively, during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall be maintained in a safe and secure manner; + +c) Shall be reviewed and possessed by the Defendant in hard copy solely in the presence of Defense Counsel; + +d) Shall be possessed in electronic format only by Defense Counsel and by appropriate officials of the Bureau of Prisons ("BOP"), who shall provide the defendant with electronic access to the Discovery, including Confidential Information, consistent with the rules and regulations of the BOP, for the Defendant's review; + +e) Shall be reviewed by the Defendant solely in the presence of Defense Counsel or when provided access to Discovery materials in electronic format by BOP officials; + +f) May be disclosed only by Defense Counsel and only to Designated Persons; + +g) May be shown to, either in person, by videoconference, or via a read-only document review platform, but not disseminated to or provided copies of to, Potential Defense Witnesses, to the extent deemed necessary by Defense Counsel, for trial preparation, and after such individual(s) have read and signed this Order acknowledging that such individual(s) are bound by this Order. + +11. Copies of Discovery or other materials produced by the Government in this action bearing "highly confidential" stamps or otherwise specifically designated as "highly confidential," and/or electronic Discovery materials designated as "highly confidential" by the Government, including such materials marked as "highly confidential" either on the documents or materials themselves, or designated as "highly confidential" in an index, folder title, or document title, are deemed "Highly Confidential Information." To the extent any Highly Confidential Information is physically produced to the Defendant and Defense Counsel, rather than being made available to the Defendant and Defense Counsel for on-site review, the + +Government shall clearly mark all such pages or electronic materials containing Highly Confidential Information with "highly confidential" stamps on the documents or materials themselves. + +12. Highly Confidential Information contains nude, partially-nude, or otherwise sexualized images, videos, or other depictions of individuals. + +13. Defense Counsel may, at any time, notify the Government that Defense Counsel does not concur in the designation of documents or other materials as Highly Confidential Information. If the Government does not agree to de-designate such documents or materials, Defense Counsel may thereafter move the Court for an Order de-designating such documents or materials. The Government's designation of such documents and materials as Highly Confidential Information will be controlling absent contrary order of the Court. + +14. Highly Confidential Information disclosed to Defense Counsel during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall not be disseminated, transmitted, or otherwise copied and provided to Defense Counsel or the Defendant; + +c) Shall be reviewed by the Defendant solely in the presence of Defense Counsel; + +d) Shall not be possessed outside the presence of Defense Counsel, or maintained, by the Defendant; + +e) Shall be made available for inspection by Defense Counsel and the Defendant, under the protection of law enforcement officers or employees; and + +f) Shall not be copied or otherwise duplicated by Defense Counsel or the Defendant during such inspections. + +15. The Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing any Confidential Information or Highly Confidential Information referenced in the Discovery, unless authorized by the Government in writing or by Order of the Court. Any such filings must be filed under seal, unless authorized by the Government in writing or by Order of the Court. + +16. The provisions of this Order shall not be construed as preventing disclosure of any information, with the exception of victim or witness identifying information, that is publicly available or obtained by the Defendant or her Defense Counsel from a source other than the Government. + +17. Except for Discovery that has been made part of the record of this case, Defense Counsel shall return to the Government or securely destroy or delete all Discovery, including but not limited to Confidential Information, within 30 days of the expiration of the period for direct appeal from any verdict in the above-captioned case; the period of direct appeal from any order dismissing any of the charges in the abovecaptioned case; the expiration of the period for a petition pursuant to 28 U.S.C. § 2255; any period of time required by the federal or state ethics rules applicable to any attorney of record in this case; or the granting of any motion made on behalf of the Government dismissing any charges in the abovecaptioned case, whichever date is later. + +18. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree in writing otherwise, or (b) this Order is modified by further order of the Court. + +19. The Government and Defense Counsel agree to meet and confer in advance of any hearings or trial to discuss and agree to any modifications necessary for the presentation of evidence at those proceedings. In the absence of agreement, + +Defense Counsel may make an appropriate application to the Court for any such modifications. + +SO ORDERED: + +Dated: New York, New York , 2020 + +> HONORABLE ALISON J. 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NATHAN, District Judge: + +Both parties have asked for the Court to enter a protective order. While they agree on most of the language, two areas of dispute have emerged. First, Ms. Maxwell seeks language allowing her to publicly reference alleged victims or witnesses who have spoken on the public record to the media or in public fora, or in litigation relating to Ms. Maxwell or Jeffrey Epstein. Second, Ms. Maxwell seeks language restricting potential Government witnesses and their counsel from using discovery materials for any purpose other than preparing for the criminal trial in this action. The Government has proposed contrary language on both of these issues. For the following reasons, the Court adopts the Government's proposed protective order. + +Under Federal Rule of Criminal Procedure 16(d)(1), "[alt any time the court may, for good cause, deny, restrict, or defer discovery or inspection, or grant other appropriate relief." The good cause standard "requires courts to balance several interests, including whether dissemination of the discovery materials inflicts hazard to others . . . whether the imposition of the protective order would prejudice the defendant," and "the public's interest in the information." United States v. Smith, 985 F. Supp. 2d 506, 522 (S.D.N.Y. 2013). The party seeking to restrict disclosure bears the burden of showing good cause. Cf. Gambale v. Deutsche Bank AG, 377 F.3d 133, 142 (2d Cir. 2004). + +First, the Court finds that the Government has met its burden of showing good cause with regard to restricting the ability of Ms. Maxwell to publicly reference alleged victims and witnesses other than those who have publicly identified themselves in this litigation. As a general matter, it is undisputed that there is a strong and specific interest in protecting the privacy of alleged victims and witnesses in this case that supports restricting the disclosure of their identities. Dkt. No. 29 at 3 (acknowledging that as a baseline the protective order should "prohibit[] Ms. Maxwell, defense counsel, and others on the defense team from disclosing or disseminating the identity of any alleged victim or potential witness referenced in the discovery materials"); see also United States v. Corley, No. 13-cr-48, 2016 U.S. Dist. LEXIS 194426, at \*11 (S.D.N.Y. Jan. 15, 2016). The Defense argues this interest is significantly diminished for individuals who have spoken on the public record about Ms. Maxwell or Jeffrey Epstein, because they have voluntarily chosen to identify themselves. But not all accusations or 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, particularly since such a statement might have occurred decades ago and have no relevance to the charges in this case. These individuals still maintain a significant privacy interest that must be safeguarded. The exception the Defense seeks is too broad and risks undermining the protections of the privacy of witnesses and alleged victims that is required by law. In contrast, the Government's proffered language would allow Ms. Maxwell to publicly reference individuals who have spoken by name on the record in this case. It also allows the Defense to "referenc[e] the identities of individuals they believe may be relevant ... to Potential Defense Witnesses and their counsel during the course of the investigation and preparation of the defense case at trial." Dkt. No. 33-1, 1 5. This proposal adequately balances the interests at + +stake. And as the Government's letter notes, *see* Dkt. No. 33 at 4, to the extent that the Defense needs an exception to the protective order for a specific investigative purpose, they can make applications to the Court on a case-by-case basis. + +Second, restrictions on the ability of potential witnesses and their counsel to use discovery materials for purposes other than preparing for trial in this case are unwarranted. The request appears unprecedented despite the fact that there have been many high-profile criminal matters that had related civil litigation. The Government labors under many restrictions including Rule 6(e) of the Federal Rules of Criminal Procedure, the Privacy Act of 1974, and other policies of the Department of Justice and the U.S. Attorney's Office for the Southern District of New York, all of which the Court expects the Government to scrupulously follow. Furthermore, the Government indicates that it will likely only provide potential witnesses with materials that those witnesses already have in their possession. *See* Dkt. No. 33 at 6. And of course, those witnesses who do testify at trial would be subject to examination on the record as to what materials were provided or shown to them by the Government. Nothing in the Defense's papers explains how its unprecedented proposed restriction is somehow necessary to ensure a fair trial. + +For the foregoing reasons, the Court adopts the Government's proposed protective order, which will be entered on the docket. + +This resolves Dkt. No. 29. + +SO ORDERED. + +Dated: July 30, 2020 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00084586/EFTA00084586.metadata.json b/marker2/ds9/EFTA00084586/EFTA00084586.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8b9d43cca900d37adf154d97ef93e0087ad43863 --- /dev/null +++ b/marker2/ds9/EFTA00084586/EFTA00084586.metadata.json @@ -0,0 +1,164 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084586.pdf", + "engine": { + "marker_major": "2", + "marker_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": 5481, + "elapsed_seconds": 6.38, + "image_assets": [ + "_page_0_Picture_1.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 + ], + [ + 281.79962158203125, + 72.08999999999999 + ], + [ + 281.79962158203125, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 72 + ], + [ + "Line", + 34 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "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 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 26 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 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": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 27 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "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/EFTA00084586" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084586/_page_0_Picture_1.jpeg b/marker2/ds9/EFTA00084586/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..89174075be5664d8ee83ec7130a057b781668dc5 --- /dev/null +++ b/marker2/ds9/EFTA00084586/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:be9d75e967a8cfcaa858c06f36b455beabacf5e81648b1b86c31a49d7cf4da2e +size 14840 diff --git a/marker2/ds9/EFTA00084589/EFTA00084589.md b/marker2/ds9/EFTA00084589/EFTA00084589.md new file mode 100644 index 0000000000000000000000000000000000000000..4144953e59304b7942533fbdc07778e8354e7576 --- /dev/null +++ b/marker2/ds9/EFTA00084589/EFTA00084589.md @@ -0,0 +1,117 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +UNITED STATES OF AMERICA GHISLAINE MAXWELL, Defendant. x x + +USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED:7/30/2020 + +## PROTECTIVE ORDER + +20 Cr. 330 (AJN) + +ALISON J. NATHAN, United States District Judge: + +WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely disclosed, the Government's ongoing investigation; (iii) would risk prejudicial pretrial publicity if publicly disseminated, and (iv) is not authorized to be disclosed to the public or disclosed beyond that which is necessary for the defense of this action, and other materials pursuant to Federal Rule of Criminal Procedure 16 ("Rule 16") and pursuant to any other disclosure obligations (collectively, the "Discovery"), which contain sensitive, confidential, or personal identifying information; + +WHEREAS, the Government seeks to protect sensitive, confidential, or personal identifying information contained in the materials it produces consistent with Rule 16 or other disclosure obligations; + +WHEREAS the Government has applied for the entry of this Order; + +IT HEREBY IS ORDERED: + +1. The Discovery disclosed to the defendant ("Defendant") and/or to the defendant's criminal defense attorneys ("Defense Counsel") during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall not be copied or otherwise recorded or transmitted by the Defendant, except to Defense Counsel, or except as necessary for the Defendant to take notes, which are not to be further transmitted to anyone other than Defense Counsel; + +c) Shall not be disclosed or distributed in any form by the Defendant or her counsel except as set forth in paragraph 1(d) below; + +d) May be disclosed only by Defense Counsel and only to the following persons ("Designated Persons"): + +i. investigative, secretarial, clerical, or paralegal personnel employed full-time, part-time, or as + +independent contractors by the defendant's counsel ("Defense Staff"); + +ii. any expert or potential expert, legal advisor, consultant, or any other individual retained or employed by the Defendant and Defense Counsel for the purpose of assisting in the defense of this case ("Defense Experts/Advisors"); + +iii. such other persons as hereafter may be authorized by Order of the Court ("Other Authorized Persons"); + +e) May be provided to prospective witnesses and their counsel (collectively, "Potential Defense Witnesses"), to the extent deemed necessary by defense counsel, for trial preparation. To the extent Discovery materials are disclosed to Potential Defense Witnesses, they agree that any such materials will not be further copied, distributed, or otherwise transmitted to individuals other than the recipient Potential Defense Witnesses. + +2. The Defendant and Defense Counsel shall provide a copy of this Order to any Designated Persons to whom they disclose Discovery materials. Prior to disclosure of Discovery materials to Designated Persons, any such Designated Person shall agree to be subject to the terms of this Order by signing a copy hereof and stating that they "Agree to be bound by the terms herein," and providing such copy to Defense Counsel. All + +such acknowledgments shall be retained by Defense Counsel and shall be subject to in camera review by the Court if good cause for review is demonstrated. The Defendant and her counsel need not obtain signatures from any member of the defense team (i.e., attorneys, experts, consultants, paralegals, investigators, support personnel, and secretarial staff involved in the representation of the defendants in this case), all of whom are nonetheless bound by this Protective Order. + +3. To the extent that Discovery is disseminated to Defense Experts/Advisors, Other Authorized Persons, or Potential Defense Witnesses, via means other than electronic mail, Defense Counsel shall encrypt and/or password protect the Discovery. + +4. The Government, the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses and their counsel, and Other Authorized Persons are prohibited from posting or causing to be posted any of the Discovery or information contained in the Discovery on the Internet, including any social media website or other publicly available medium. + +5. The Government (other than in the discharge of their professional obligations in this matter), the Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses and their counsel, and Other Authorized Persons are strictly prohibited from publicly + +disclosing or disseminating witnesses referenced in the prohibit Defense Counsel or the identity of any victims or Discovery. This Order does not Defense Staff from referencing the identities of individuals they believe may be relevant to the defense to Potential Defense Witnesses and their counsel during the course of the investigation and preparation of the defense case at trial. Any Potential Defense Witnesses and their counsel who are provided identifying information by Defense Counsel or Defense Staff are prohibited from further disclosing or disseminating such identifying information. This Order does not prohibit Defense Counsel from publicly referencing individuals who have spoken by name on the public record in this case. + +6. The Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing the identity of any victims or witnesses referenced in the Discovery, who have not spoken by name on the public record in this case, unless authorized by the Government in writing or by Order of the Court. Any such filings must be filed under seal, unless authorized by the Government in writing or by Order of the Court. + +7. Copies of Discovery or other materials produced by the Government in this action bearing "confidential" stamps, or designated as "confidential" as described below, and/or electronic Discovery materials designated as "confidential" by the Government, including such materials marked as "confidential" either on the documents or materials themselves, or designated as "confidential" in a folder or document title, are deemed "Confidential Information." The Government shall clearly mark all pages or electronic materials containing Confidential Information, or folder or document titles as necessary, with "confidential" designations. + +8. Confidential Information may contain personal identification information of victims, witnesses, or other specific individuals who are not parties to this action, and other confidential information; as well as information that identifies, or could lead to the identification of, witnesses in this matter. The identity of an alleged victim or witness who has identified herself or himself publicly as such on the record in this case shall not be treated as Confidential Information. + +9. Defense Counsel may, at any time, notify the Government that Defense Counsel does not concur in the designation of documents or other materials as Confidential Information. If the Government does not agree to de-designate such documents or materials, Defense Counsel may thereafter move the Court for an Order de-designating such documents or materials. The Government's designation of such documents and materials as Confidential Information will be controlling absent contrary order of the Court. + +10. Confidential Information disclosed to the defendant, or Defense Counsel, respectively, during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall be maintained in a safe and secure manner; + +c) Shall be reviewed and possessed by the Defendant in hard copy solely in the presence of Defense Counsel; + +d) Shall be possessed in electronic format only by Defense Counsel and by appropriate officials of the Bureau of Prisons ("BOP"), who shall provide the defendant with electronic access to the Discovery, including Confidential Information, consistent with the rules and regulations of the BOP, for the Defendant's review; + +e) Shall be reviewed by the Defendant solely in the presence of Defense Counsel or when provided access to Discovery materials in electronic format by BOP officials; + +f) May be disclosed only by Defense Counsel and only to Designated Persons; + +g) May be shown to, either in person, by videoconference, or via a read-only document review platform, but not disseminated to or provided copies of to, Potential Defense Witnesses, to the extent deemed necessary by Defense Counsel, for trial preparation, and after such individual(s) have read and signed this Order acknowledging that such individual(s) are bound by this Order. + +11. Copies of Discovery or other materials produced by the Government in this action bearing "highly confidential" stamps or otherwise specifically designated as "highly confidential," and/or electronic Discovery materials designated as "highly confidential" by the Government, including such materials marked as "highly confidential" either on the documents or materials themselves, or designated as "highly confidential" in an index, folder title, or document title, are deemed "Highly Confidential Information." To the extent any Highly Confidential Information is physically produced to the Defendant and Defense Counsel, rather than being made available to the Defendant and Defense Counsel for on-site review, the + +Government shall clearly mark all such pages or electronic materials containing Highly Confidential Information with "highly confidential" stamps on the documents or materials themselves. + +12. Highly Confidential Information contains nude, partially-nude, or otherwise sexualized images, videos, or other depictions of individuals. + +13. Defense Counsel may, at any time, notify the Government that Defense Counsel does not concur in the designation of documents or other materials as Highly Confidential Information. If the Government does not agree to de-designate such documents or materials, Defense Counsel may thereafter move the Court for an Order de-designating such documents or materials. The Government's designation of such documents and materials as Highly Confidential Information will be controlling absent contrary order of the Court. + +14. Highly Confidential Information disclosed to Defense Counsel during the course of proceedings in this action: + +a) Shall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this criminal action, and not for any civil proceeding or any purpose other than the defense of this action; + +b) Shall not be disseminated, transmitted, or otherwise copied and provided to Defense Counsel or the Defendant; + +c) Shall be reviewed by the Defendant solely in the presence of Defense Counsel; + +d) Shall not be possessed outside the presence of Defense Counsel, or maintained, by the Defendant; + +e) Shall be made available for inspection by Defense Counsel and the Defendant, under the protection of law enforcement officers or employees; and + +f) Shall not be copied or otherwise duplicated by Defense Counsel or the Defendant during such inspections. + +15. The Defendant, Defense Counsel, Defense Staff, Defense Experts/Advisors, Potential Defense Witnesses, and Other Authorized Persons are prohibited from filing publicly as an attachment to a filing or excerpted within a filing any Confidential Information or Highly Confidential Information referenced in the Discovery, unless authorized by the Government in writing or by Order of the Court. Any such filings must be filed under seal, unless authorized by the Government in writing or by Order of the Court. + +16. The provisions of this Order shall not be construed as preventing disclosure of any information, with the exception of victim or witness identifying information, that is publicly available or obtained by the Defendant or her Defense Counsel from a source other than the Government. + +17. Except for Discovery that has been made part of the record of this case, Defense Counsel shall return to the Government or securely destroy or delete all Discovery, including but not limited to Confidential Information, within 30 days of the expiration of the period for direct appeal from any verdict in the above-captioned case; the period of direct appeal from any order dismissing any of the charges in the abovecaptioned case; the expiration of the period for a petition pursuant to 28 U.S.C. § 2255; any period of time required by the federal or state ethics rules applicable to any attorney of record in this case; or the granting of any motion made on behalf of the Government dismissing any charges in the abovecaptioned case, whichever date is later. + +18. The foregoing provisions shall remain in effect unless and until either (a) the Government and Defense Counsel mutually agree in writing otherwise, or (b) this Order is modified by further order of the Court. + +19. The Government and Defense Counsel agree to meet and confer in advance of any hearings or trial to discuss and agree to any modifications necessary for the presentation of evidence at those proceedings. In the absence of agreement, + +Defense Counsel may make an appropriate application to the Court for any such modifications. + +SO ORDERED: + +Dated: New York, New York July 30 , 2020 + +Lc + +HONORABLE ALISON J. 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N.Y. April 9, 2019 11:45 a.m. + +HON. COLLEEN MCMAHON, + +Chief District Judge + +## APPEARANCES + +GEOFFREY S. BERMAN United States Attorney for the Southern District of New York + +Assistant United States Attorney + +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 + +(In the robing room) + +THE COURT: This is 19 Misc. 149, In Re Grand Jury Subpoena. I've had one conference with the government in this matter. You want to put your appearance on the record. + +Yes. Good morning, your Honor. for the government. + +THE COURT: , I now know a lot more about what's going on than I did the last time we were together. My question is this: I'll be very up-front with you. I want to make sure I'm not in a Chemical Bank kind of situation, so I would like to know about 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. + +Yes, your Honor. So with respect to this investigation, the investigation was opened in late November or early December, either on Friday, November 30, or Monday, December 3. + +THE COURT: OK. + +In the initial days and weeks of the investigation, we endeavored to identify information about the subject of the investigation, including, among other things, possible victims who we should speak to. In the process of doing so, we identified certain counsel that were identified as representing victims or witnesses either in public filings or + +CON F I bitNita SDNY\_GM\_00000902 + +1 2 3 4 5 in media reports. Boies Schiller was among those plaintiff attorneys. So following the opening of the investigation, we were in touch with Boies Schiller, among other plaintiff and witness counsel, in connection with their representation of witnesses or victims. + +6 7 8 9 10 11 12 13 With respect to Boies Schiller in particular, we quickly came to learn during the investigation that they had at the time either active or recently completed civil litigation and so asked them, as is our standard practice, told them, I should say, that we expected to make document requests. They generally advised us that they believed there was a protective order that would govern at least some of the materials, and that is why we ultimately made the application to the Court. + +14 15 16 THE COURT: OK. That's all I needed to know. I want to make two little changes in this opinion, and if you come back in an hour, you'll have it. + +17 OK. + +18 THE COURT: All right. + +19 Thank you, your Honor. + +20 THE COURT: And we are granting your request. + +21 Understood. Thank you, your Honor. + +22 THE COURT: OK. + +23 (Adjourned) + +24 + +25 + +CONFIbt ail-o3oo SDNY GM NI T IAL \_ \_00000903 \ No newline at end of file diff --git a/marker2/ds9/EFTA00084602/EFTA00084602.metadata.json b/marker2/ds9/EFTA00084602/EFTA00084602.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2a20473ac379bcb7f1a133b24da6a8cf16435551 --- /dev/null +++ b/marker2/ds9/EFTA00084602/EFTA00084602.metadata.json @@ -0,0 +1,154 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084602.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2926, + "elapsed_seconds": 1.08, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "APPEARANCES", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 296.692, + 363.69 + ], + [ + 388.0326232910156, + 363.69 + ], + [ + 388.0326232910156, + 379.45416259765625 + ], + [ + 296.692, + 379.45416259765625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 95 + ], + [ + "Line", + 47 + ], + [ + "Text", + 39 + ], + [ + "PageFooter", + 5 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 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", + 110 + ], + [ + "Line", + 55 + ], + [ + "Text", + 38 + ], + [ + "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", + 109 + ], + [ + "Line", + 53 + ], + [ + "Text", + 18 + ], + [ + "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/EFTA00084602" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084605/EFTA00084605.md b/marker2/ds9/EFTA00084605/EFTA00084605.md new file mode 100644 index 0000000000000000000000000000000000000000..3281b9c2070f46862950ca4a337e23098435f2ea --- /dev/null +++ b/marker2/ds9/EFTA00084605/EFTA00084605.md @@ -0,0 +1,29 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +IN RE GRAND JURY SUBPOENA + +X + +SEALED ORDER + +X + +19 Misc. 149 + +Upon the Affirmation and Application of the United States Attorney for the Southern District of New York, by Assistant United States Attorney pursuant to the All Writs Act, Title 28, United States Code, Section 1651, requesting that an Order be issued relieving Boies Schiller & Flexner LLP of their obligations under the protective order issued on March 18, 2016 in case v. Ghislaine Maxwell, et al., 15 Civ. 7433 (RWS) (S.D.N.Y.), for the limited and exclusive purpose of complying with grand jury process to provide materials to the Government in connection with a federal grand jury investigation: + +IT IS HEREBY ORDERED, that Boies Schiller & Flexner LLP is permitted to provide the Government with copies of materials generated, received, obtained, or otherwise possessed in connection with case v. Ghislaine Maxwell, et al., 15 Civ. 7433 (RWS), including discovery materials marked "CONFIDENTIAL" pursuant to the protective order dated March 16, 2016. Boies Schiller & Flexner LLP may provide + +CONFIDENTIAL SDNY\_GM\_00000904 + +these materials to the Government notwithstanding their obligations under the March 18, 2016 protective order. + +IT IS FURTHER ORDERED that, with the exception of a copy of this Order to Boies Schiller & Flexner LLP and the clerk of the court for files and testimony subject to this Order, this Order is to be sealed pending further order of this Court. + +Dated: New YoFk, New York + +April 1, 2019 leicackc + +THE HONORABLE COLLEEN MCMAHON CHIEF UNITED STATES DISTRICT JUDGE SOUTHERN DISTRICT OF NEW YORK + +CONFIDENTIAL SDNY\_GM\_00000905 \ No newline at end of file diff --git a/marker2/ds9/EFTA00084605/EFTA00084605.metadata.json b/marker2/ds9/EFTA00084605/EFTA00084605.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8040ebbe79803e2b5ebded611a61e2dcd8f53d9c --- /dev/null +++ b/marker2/ds9/EFTA00084605/EFTA00084605.metadata.json @@ -0,0 +1,104 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084605.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1689, + "elapsed_seconds": 0.7, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 70.49499999999999, + 72.08999999999999 + ], + [ + 287.9010925292969, + 72.08999999999999 + ], + [ + 287.9010925292969, + 98.713134765625 + ], + [ + 70.49499999999999, + 98.713134765625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Line", + 27 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 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", + 8 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00084605" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084607/EFTA00084607.md b/marker2/ds9/EFTA00084607/EFTA00084607.md new file mode 100644 index 0000000000000000000000000000000000000000..2e331b2183e0f2f438fce417ea280dea6731db61 --- /dev/null +++ b/marker2/ds9/EFTA00084607/EFTA00084607.md @@ -0,0 +1,49 @@ +To + +Cc + +Subject: FW: FBI Victim Services Division Briefing for Victims of Jeffrey Epstein + +Date: Mon, 10 Aug 2020 16:30:15 +0000 + +Attachments: contact\_list\_only\_31E-NY-3027571\_6.26.2020.xlsx + +Inline-Images: image002.jpg + +Hi - I hope everyone had a nice weekend. Below is the invite that was sent out to the attached guest list. Please let us know if you have any questions. + +Thanks- + +From: VictimServices + +Sent: Friday, September 27, 2019 5:13 PM + +To + +Subject: FBI Victim Services Division Briefing for Victims of Jeffrey Epstein + +![](_page_0_Picture_13.jpeg) + +Federal Bureau of Investigation Victim Assistance Program New York Division + +September 27, 2019 + +RE: Case Number: NY-3027571 + +Dea + +The FBI Victim Services Division invites you to attend a meeting with FBI Victim Services representatives and members of the FBI NY Field Office and the U.S. Attorney's Office for the Southern District of New York to learn more about the victim services that may be available to you. While we will not be able to provide specific details about the active investigation, we will provide you with information about the types of services we can provide and that you are entitled to, and Victim Specialists will be on site to try to address any specific questions you may have. + +These meetings will be held in two different locations, New York and Florida. Please choose which meeting you prefer to attend: + +Date: October 23, 2019 + +Time: 10:00 AM + +Location: 290 Broadway, New York, NY 10007 + +Participation is limited to you and one support person. If you are interested in attending, please respond by October 4, 2019 to VictimServices®fbi.ggi with your name, and if you choose, the name of one support person who will accompany you, as well as the meeting location you wish to attend. We will follow up with additional information to finalize your attendance. + +Thank you, + +FBI Victim Services Division \ No newline at end of file diff --git a/marker2/ds9/EFTA00084607/EFTA00084607.metadata.json b/marker2/ds9/EFTA00084607/EFTA00084607.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d3e5826c1ff668d7aa14d2323d6288755bde8802 --- /dev/null +++ b/marker2/ds9/EFTA00084607/EFTA00084607.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084607.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1894, + "elapsed_seconds": 1.01, + "image_assets": [ + "_page_0_Picture_13.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Line", + 30 + ], + [ + "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 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 12 + ], + [ + "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/EFTA00084607" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084607/_page_0_Picture_13.jpeg b/marker2/ds9/EFTA00084607/_page_0_Picture_13.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..106e8185012638588a15cbf81daaa115a24ef993 --- /dev/null +++ b/marker2/ds9/EFTA00084607/_page_0_Picture_13.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:f563857fba329572f9d5b6e8c498c1d1aff5b32c5d926b42e088db499790046c +size 8244 diff --git a/marker2/ds9/EFTA00084609/EFTA00084609.md b/marker2/ds9/EFTA00084609/EFTA00084609.md new file mode 100644 index 0000000000000000000000000000000000000000..7086bbd4d59f652992bfdb015d8403a8c11c4a51 --- /dev/null +++ b/marker2/ds9/EFTA00084609/EFTA00084609.md @@ -0,0 +1,65 @@ +![](_page_0_Picture_1.jpeg) + +August 10, 2020 + +Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 + +Re: August 3, 2020 Order (Doc. 1096) + +v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) + +Haddon, Morgan and Foreman, P.0 Laura A. Menninger + +150 East 10th Avenue Denver, Colorado 80203 Pll 303.831.7364 EX 303.832.2628 www.hmtlaw.com LMenninger4hrntlaw.com + +Dear Judge Preska: + +I write in response to the Court's Order of August 3, 2020 (Doc. 1069), the Order and Protocol for Unsealing Decided Motions (Doc. 1044) ("Protocol"), and to raise with the Court the legal effect of new information that came to the attention of counsel for Ms. Maxwell on Friday, August 7, 2020. + +New information: On Friday, August 7, 2020, counsel for Ms. Maxwell learned of critical new information that impacts both this action and U.S. v. Maxwell, 20 Cr. 330 (MN) (the "Criminal Action"). The information implicates Ms. Maxwell's right to due process and fairness in this civil action and affects the Second Circuit's review of the Court's unsealing order of July 23, 2020. Additionally, the information implicates her rights as a criminal defendant guaranteed under the Fourth, Fifth and Sixth Amendments. + +Counsel makes the representations about implications of the new information as an officer of this Court. At this time, counsel is not at liberty to disclose the information because it is subject to a protective order in the Criminal Action, which forbids its use "for any civil proceeding or any purpose other than the defense" of the criminal action absent "further order of the Court." Protective Order, 20 Cr. 330 (MN) at ¶'J 1(a), 18 (Exhibit A). As required by that Protective Order and Judge Nathan's Individual Practices in Criminal Cases, counsel initiated a conferral with the U.S. Attorney's Office over the weekend concerning a modification of the Protective Order to share the information with this Court and the Second Circuit. Barring agreement, Ms. Maxwell intends to seek modification of the Protective Order in the Criminal Action from Judge Nathan forthwith to permit sharing the information with this Court, ex parte and in camera if necessary, and with the Second Circuit (likewise under seal if necessary). + +August 10, 2020 + +Page 2 + +Ms. Maxwell requests a temporary stay of the unsealing process for approximately three weeks until the conclusion of (a) the conferral with the U.S. Attorney's Office to a modification of the Protective Order in the Criminal Action and, if necessary, an application and ruling by Judge Nathan on the issue, to permit the use of the information in this Court and before the Second Circuit (under seal in both courts, if necessary), (b) an application to this Court containing the new information in support of a request to stay the unsealing process until the conclusion of the Criminal Action, and (c) a ruling by this Court on the motion for stay. + +Streamlining of Unsealing Process: As directed by the Court, counsel for Ms. Maxwell conferred with plaintiff's counsel concerning various proposals to streamline the unsealing process. Subject to Ms. Maxwell's request to temporarily pause the process as described above, defense counsel has agreed to several potential modifications of the Protocol which we hope will ease the burden on the parties and the Court going forward, should the unsealing move ahead. Of note, and as Plaintiff will explain to the Court, the parties have agreed to notify all of the Non-Parties at once so that we can understand which Non-Parties object to the unsealing before deciding how to proceed with future redactions. Although this will give the Court and the Original Parties more information about the scope of objectors, there are limitations to the extent to which it will expedite the process. As counsel has made clear in the past, it will take significant effort by the Original Parties and their staff to put together the excerpts for any Non-Party who requests them because each Non-Party will be entitled to see his or her own information (but not that of other Non-Parties). After receiving a request from a Non-Party, we anticipate it will take up to a week per Non-Party to agree to the excerpts to send to them for review. But on balance we agree that having a sense of the number of participating Non-Parties will aid the Court in conducting future proceedings, we have agreed to Plaintiff's suggestion on that front. The parties can submit a proposed modification of the Protocol and Notice to the Court to reflect this agreement. + +We also have agreed, as the Court suggested, to shorten the time period for the Original Parties to object and to respond from 14 to 7 days. This would impact paragraphs 2(d), 2(e) and 2(0 of the Protocol. The parties can also submit a proposed modification of the Protocol to the Court. The parties also agreed to leave the time for Non-Parties to object at 14 days given some practical considerations applicable to them. + +Although the parties were able to reach some agreement, we cannot agree to all of Plaintiff's proposals and write separately to explain the basis for our disagreements. + +First, we carefully considered the Court's suggestion to reduce the number of pages of briefing to ten pages per side. Id. Our initial Objection (DE 1057) was 14 pages long; Plaintiff's Response was 19 pages. The Court concluded that our Objection was, in many respects, not specific enough. We would ask leave to at least have 15 pages to object to the five motions proposed below, with any response limited to the same. We will endeavor to keep it shorter than that, but also allow for more space to provide specifics to the Court. + +Second, we have obtained new contact information for Doe 1 from a separate civil suit. We believe that Doe 1 retains a right to notification and participation. We suggest + +August 10, 2020 + +Page 3 + +providing the Notice to Doe 1 at the new address for any future pleadings that implicate his or her deposition, which is currently subject to the Second Circuit's stay. + +Third, to prevent against some of the errors that occurred during the last round of unsealings, we request that the Protocol be amended to require the Responding Original Party who proposes unsealing to supply with their Response a proposed unredacted set of the pleadings at issue, for the Court's consideration and for the Objecting Original Party or Non-Party to have the right of reply. Preparing those redactions after the fact allows much ambiguity into the Court's ruling and we believe the Court's ruling should specify which redactions it is accepting or rejecting at the time of ruling. + +Finally, we request that the Court allow for the any objecting Non-Party or Original Party be given 7 days following any unseal order to apply for relief in the Second Circuit from the order prior to the documents being released. + +## Proposed Next Set of Docket Entries for Review: + +Given the Second Circuit's stay concerning Ms. Maxwell and Doe l's deposition transcripts and materials that quote from them, we propose that the Court deviate from the Doe 1 and 2 chronology (given that Doe l's deposition is sprinkled throughout those motions) and instead take the following five decided motions and their related pleadings. This list represents the first five chronological decided motions that (a) have sealed or redacted materials and (b) do not have attached or quote from documents subject to the stay. They are: + +- 75 Defendant's Motion to Compel Responses to Defendant's First Set of Discovery Responses to Plaintiff +- 139 Plaintiff's Brief in Support of the Privilege Claimed for In Camera Submission +- 155 Defendant's Motion to Compel Non-Privileged Documents +- 215 Sharon Churcher Motion to Quash Subpoena +- 231 Defendant's Motion to Reopen Deposition of Plaintiff + +Counsel for Ms. Maxwell is available for a telephone conference to discuss any of the foregoing, should the Court desire. + +Respectfully submitted, + +Laura A. Menninger + +CC: Counsel of Record via ECF \ No newline at end of file diff --git a/marker2/ds9/EFTA00084609/EFTA00084609.metadata.json b/marker2/ds9/EFTA00084609/EFTA00084609.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8bb8f20e9bef3e91536ce3576c91574909ef1242 --- /dev/null +++ b/marker2/ds9/EFTA00084609/EFTA00084609.metadata.json @@ -0,0 +1,168 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084609.pdf", + "engine": { + "marker_major": "2", + "marker_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": 8059, + "elapsed_seconds": 1.18, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Proposed Next Set of Docket Entries for Review:", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 118.116, + 290.78999999999996 + ], + [ + 361.2893981933594, + 290.78999999999996 + ], + [ + 361.2893981933594, + 306.3170471191406 + ], + [ + 118.116, + 306.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 94 + ], + [ + "Line", + 43 + ], + [ + "Text", + 10 + ], + [ + "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", + 93 + ], + [ + "Line", + 46 + ], + [ + "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 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 36 + ], + [ + "Text", + 11 + ], + [ + "ListItem", + 5 + ], + [ + "PageHeader", + 1 + ], + [ + "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/EFTA00084609" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084609/_page_0_Picture_1.jpeg b/marker2/ds9/EFTA00084609/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..1292162b40b2fb99d77ed965c0511ae8b466894b --- /dev/null +++ b/marker2/ds9/EFTA00084609/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:eec80266928cb0276ffe7dda4958b54aac298c59656fd48d28b1857d759f5027 +size 6531 diff --git a/marker2/ds9/EFTA00084612/EFTA00084612.md b/marker2/ds9/EFTA00084612/EFTA00084612.md new file mode 100644 index 0000000000000000000000000000000000000000..4a7a59228e8e3abd5e2025a05f65cb4ac59ea743 --- /dev/null +++ b/marker2/ds9/EFTA00084612/EFTA00084612.md @@ -0,0 +1,11 @@ +To: + +Subject: + +Date: Wed, 12 Aug 2020 16:09:00 +0000 + +Hi M, + +Plaintiff's Attorney (who represents several Epstein victims) asked me to reach out to you when I spoke with him yesterday. Apparently he represents a victim (I think named Mrs. )) of a CFU defendant of yours, and he's been trying to get in touch with you. He's been very helpful in arranging victim interviews for us, so I agreed to reach out. Mind if I send an email putting the two of you in touch? + +Thanks! \ No newline at end of file diff --git a/marker2/ds9/EFTA00084612/EFTA00084612.metadata.json b/marker2/ds9/EFTA00084612/EFTA00084612.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cc6410dc873aeafb11cc7d5a7057b2c7a7081fd0 --- /dev/null +++ b/marker2/ds9/EFTA00084612/EFTA00084612.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084612.pdf", + "engine": { + "marker_major": "2", + "marker_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": 471, + "elapsed_seconds": 0.48, + "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/EFTA00084612" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084613/EFTA00084613.md b/marker2/ds9/EFTA00084613/EFTA00084613.md new file mode 100644 index 0000000000000000000000000000000000000000..890e3046170ef3ddb81bfb5818ee15eb9d9b4b9c --- /dev/null +++ b/marker2/ds9/EFTA00084613/EFTA00084613.md @@ -0,0 +1,41 @@ +![](_page_0_Picture_83.jpeg) + +*United States Attorney +Southern District of New York* + +*The Silvio J. Mollo Building +One Saint Andrew's Plaza +New York, New York 10007* + +August 13, 2020 + +**BY FEDERAL EXPRESS** + +MDC—Metropolitan Detention Center +Legal Department +80 29th Street +Brooklyn, NY 11232 + +**Re: *United States v. Ghislaine Maxwell*, 20 Cr. 330 (AJN)** + +Enclosed is discovery pertinent to the following inmate: + +- • Ghislaine Maxwell: 02879-509 + +Please allow her access to the materials enclosed. + +Very truly yours, + +[REDACTED] + +[REDACTED] + +by + +[REDACTED] + +Assistant United States Attorneys + +[REDACTED] + +*Enclosure* \ No newline at end of file diff --git a/marker2/ds9/EFTA00084613/EFTA00084613.metadata.json b/marker2/ds9/EFTA00084613/EFTA00084613.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9ec53d79962d77bddecfff87d76c92a9908f8e6d --- /dev/null +++ b/marker2/ds9/EFTA00084613/EFTA00084613.metadata.json @@ -0,0 +1,115 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084613.pdf", + "engine": { + "marker_major": "2", + "marker_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": 643, + "elapsed_seconds": 3.75, + "image_assets": [ + "_page_0_Picture_83.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 318.85200000000003, + 25.11 + ], + [ + 462.06000000000006, + 25.11 + ], + [ + 462.06000000000006, + 40.5 + ], + [ + 318.85200000000003, + 40.5 + ] + ] + }, + { + "title": "BY FEDERAL EXPRESS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 153.09 + ], + [ + 206.856, + 153.09 + ], + [ + 206.856, + 167.67000000000002 + ], + [ + 68.544, + 167.67000000000002 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Text", + 29 + ], + [ + "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/EFTA00084613" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084613/_page_0_Picture_83.jpeg b/marker2/ds9/EFTA00084613/_page_0_Picture_83.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..ef04d05e79c155da0c375ae6e15988b5dd3103d2 --- /dev/null +++ b/marker2/ds9/EFTA00084613/_page_0_Picture_83.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:417ec9baf859d5b91298d14e042f90638b0295a03aa230620f60a046e4b448d7 +size 3425 diff --git a/marker2/ds9/EFTA00084614/EFTA00084614.md b/marker2/ds9/EFTA00084614/EFTA00084614.md new file mode 100644 index 0000000000000000000000000000000000000000..38231aa787ed46bc8b942dfd9f67a5dfbc6b43e4 --- /dev/null +++ b/marker2/ds9/EFTA00084614/EFTA00084614.md @@ -0,0 +1,4621 @@ +Date: 7/13/06 PALM BEACH POLICE DEPARTMENT Page: 1 Incident Report Program: CMS301L TiMe: 9:27:55 + +Case No + +SPECIAL NOTES : Occur To Date : Day Of Week . : Common/Location: City • Location Type : Beat. 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ID# . + +Other Phone Nbr: Residency Type : File Charges . : Victim Sobriety: Injury Type 1 Hospital ID . : Phys First Name: + +White 0 + +• + +Date: 7/13/06 Time: 9:27:55 PALM BEACH POLICE DEPARTMENT Page: 11 + +Incident Report Program: CMS301L + +Case No • 1-05-000368 + +Weight • 0 Other Phone Nbr: + +\*\*\*\*\*\*\*\*\*OTHER PERSON + +Case Number Street Number + +City + +Birth Date/Age Occupation . . Home Phone No + +Sex • Weight + +Other Phone Nbr: + +: 1-05-000368 + +• Female + +• n + +(Continued) + +Person Type . : OTHER PERSON + +INFORMAT - \*\*\*\*\*\*\*\*\* + +Last Name . . + +16 Employer? . + +Oper Lic No. + +Race + +Height • 0 + +Person Type . : OTHER PERSON + +. : . : + +• White + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*NARRATTVE 4 1 \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* Original Report LO Reported By: 9/20/05 + +Entered By.: 9/20/05 + +On 03/14/2005, I received a call from a woman who did not wish to identify herself (later identified as ). She st + +fourteen year old step daughter (later identified as + +possibly may have been molested in Palm Beach by a wea thy + +man. According to , she learned of the possible molestation by a third party. She explained that she had received a call from the + +mother of her stepdaughter's friend. The mother claimed to have + +overheard a convers•• . between her daughter and a male • nd; they were talking. about The conversation was about how had met with a 45- ear-old man and had sex with him and was paid for it. I advised that I would like to meet with her to obtain a more + +detailed statement and facts. + +to do and had to discuss the matter wit + +stated she did not know what + +husband. At this point + +did not provide me with a call number or any other information. She st that she would contact me once she had spoken + +with her husband and mother. + +On 03/14/2005 received + +right to sp Her mother + +They anreed to meet me + +a call from Mr. & Mrs They stated to their daughter via cell phone + +had been ma e aware of the case. + +e po ice department later this date. + +On 03/14/2005, Mr. accompanied by his wife + +came to the Palm beacn volice Department where they a vise + +me that they believed their fourteen year old daughter may have had some type of sexual relationship with an older male who resided in Palm Beach. Neither.knew the suspect's name or address. Both stated that their daughter did not talk to them about the incident, nor would + +she admit to it. + +identified his daughter as w/f, DOB resides with her biological mot er + +PALM BEACH POLICE DEPARTMENT Page: 12 + +Incident Report Program: CMS301L + +Case No • 1-05-000368 her sister res' currently attending + +> involuntary admitted juvenile educational aci ity. stays at the facilit during the week and comes home on the weeken . According to + +she was admitted to the school because of disciplinary + +problems that recently escalated. The facility also coordinates with + +the families to provide one on one as well as family counseling. + +(Liapizinued) + +and are + +wh' 's an + +According to Mrs. she b Sunday, Feb 6, 2005. A friend of their house and left. They believe with the older gentleman, though they s close by with her er. Mrs. + +was + +goes t + +that on Sunday, picked up and they met the man. Supposedly, t e man h has young girls come over to his house. + +way to make fast cash. The man starts with a them, he keeps the d and does more. The any information on other than she lives + +Mrs. + +found it the call between + +the in occurred on + +named picked her up at + +n + +initiated the relati ot have any proof. + +further explained that + +, a boy she was dating . Mrs. continued drove to Palm Beach where + +> t of money and often offers these girls a massa e. If he likes on did not have + +on + +talked of a conversation that she had with + +the mother of a former friend of She strange that they were no longer friends until she received from her mother tellinimiii of the conversation she overheard + +and a boy named + +told me of an incid ccurred on 0 2005. lb got into a fight at school ( HS). s. Assistant + +Principal, found over \$300.00 in purse. gave different explanations for the large sum of money. Initially the school administration thought ias drug related but then dismissed the claim. Since that day, Illildid not return to school; she ran away Thursday, 02/10th or Friday 02/11 and returned to her mother's house + +later that night after " t. It was not until after + +received the call from s mother, + +at she learned was the girl that got int + +fight with The fight was instigated when + +ik. accused of + +being a prostitute. + +, who has legal joint custody of his daughter lin signed the affidavit of prosecution indicating he wished to + +prosecute against the inappropriate sexual behavior with his + +fourteen-year-old daughter. + +Mr. stat t he had no objections wi ency speaking is daug about the incident. Mr. stated that mother is aware of the allegations and also was willing to + +• + +Date: 7/13/06 PALM BEACH POLICE DEPARTMENT Page: 14 Time: 9:27:55 Incident Report Program: CMS301L + +Case No • 1-05-000368 (Continued) + +stated the man told them that Epstein was not there but was + +expected back. He allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside. Shortly after, Epstein and a woman, described as white with blond hair entered + +the kitchen. believed the woman was Epstein's Assistant. + +added that the woman did not seem friendly and kept her responses short and direct. Epstein introduced hims as Jeff . got the impression that Epstein and riend knew each other. described Epstein as being approximately forty-five years old, a long face, and bushy eyebrows, with graying + +hair. + +and Epstein left the kitchen leaving and + +friend alone in the kitchen. They returned a s or time later. They + +all spoke briefly in the kitchen. While speaking to me, + +became upset and started to cry. stated the woman instructed her to follow her upstairs, which she did. According to , the woman led her to a room that had a massage table in it. The woman started to fix up the room, uttin the covers on the table and taking lotions out. She then told that Epstein would be up in a second. The woman left the room, and soon after, Epstein walked in and told to take off her clothes. As was telling me what had happened, she looked away fro ii- -90 with a pointed finger, repeatedly pressed it into her thigh. -d he was stern when he told her to take off her clothes. =aid she did not + +know what to do as she was + +stated she was •is usted by + +Epstein's actions •u •I• not say anything. According to + +Epstein told her that she "had a really hot body." Epstein excused himself and went to the bathroom where she believed he masturbated + +again. Epstein returned to the room and told + +done and gave e hundred dollars. They went down stairs + +where m liftili Epstein said good-bye and the asked how Mil go and asked what did she + +When told that E stein asked for a massage, + +allegedly statedL;1liow." stated they then went shopping. + +stated also iiiir, she tat did know not buwhy + +since she was confident that did not do anything. + +at he was + +described Epstein's house as a two story pink house with a + +Cadillac Escalade parked in the drivewa . There were gates leading into the property. From the kitchen, recalled walking up a flight of stairs, lined with photographs, to a room. Upon entering + +PALM BEACH POLICE DEPARTMENT Page: 15. + +Incident Report Program: CUS301L + +Case No • 1-05-000368 (Continued) + +the room there was a largeloathroom to the right. recalled a hot pink aniiiiiiiisofa in the room. There was a door on each side of the sofa. recalled there being a mural of a naked woman in the room, as well as several photographs of naked women on a shelf. + +stated Epstein did not chiiiiiiilfront of her but did take + +of is towel, recalled Epstein being hairy especial L y on his ches a-Igo Hari a hairline, that + +contingagLtaamsis buttocks. + +asked if she knew what being + +Mi no. then said that she t + +e was a "really built guy + +would explain that when she stated + +stated Epstein exposed himself when e too his towel off, + +placing it on the floor as he laid down on the table + +circumcised meant and she stated + +said Epstein was specific in his in truc ' n to her on how to + +massage, telling her to go clockwise, etc. recalled that Epstein got up from the table and went to the bathroom where she heard him making, what she believed to be sexual type of noises. (moaning) + +He then returned to the room where he again laid down on the t Epstein then turned over and instructed to massage As she did this, Epstein continued to make moaning noises. + +a so reca Epstein wing a not ce-• e rec eon + +his chest. • + +downstairs where she met liarli lunknown white female. + +Epstein then left the ro got dressed. She went back + +admitted to getting paid three hundred dollars in cash from Epstein. Before they left, Epstein asked r phone number. + +As they were leaving the house and how much she was paid. + +Its when she told her tha stated received onl + +stated that she believed + +bringing her. + +t that if they do this every Saturday, they could + +be rich; agreed. They then went shopp'n t h she is not sure whey i ly at TJ Maxx or Marshall's. stated she never saw as she got into a fight at school. She had not 'spoken with either as her mother took away her cell phone. + +to leave + +asked stated + +hundred dollars that day. + +. + +was + +e received three hundre paid two hundred dollars for + +he + +what had happened + +seemed upset or + +• • + +Date: 7/13/06 PALM BEACH POLICE DEPARTMENT Page: 17 Time: 9:27:55 Incident Report Program: CMS301L + +Case No • 1-05-000368 (Co rd) + +of Epstein to be used in a photo line up. I met with + +at which time she viewed the photo line up. She immediately + +recognized Epstein and pointed to him (Position #5). signed the photo line up under Epstein's picture. This signed line up was + +placed into evidence. + +On 03/18/2005, I met with placing a controlled call to residence ifor the purp + +spoke + +and asked if she could arrange another meeting with Jeff. + +stated that she would have to call him and make the arrangements. + +copy of this conversation was placed into evidence. + +03/19/2005, I ' and + +advised left the state to visit with her aunt and uncle. is scheduled to return to Florida on 03/27/2005 + +03/21/2005, I co rdinated wit PB BSF Unit and OCVAN to initiate + +surveillance on + +and was + +03/21/2005, Coordinated with Det. regarding trash pulls from 358 El Brillo. On this same I called to schedule an + +appointment to speak with . She stated the school guidance counselor was reluctant to have police presence at the school. I + +assured her that I would respond to the school in civilian clothes and + +an unmarked vehicle. + +called + +an appointment to see + +• ed a return phone call from + +would be attending the family therapy + +hark anti advised that I did not need to make + +stating lid. + +sessions with + +I received messages from + +I conducted a computer query on Epstein. The results of this query indicated the most recent driver's license on file for Epstein was for + +the state of Florida, which had expired. + +A cross reference of Epstein s residence, revealed the following affiliated nam + +Mark L. PrI rein /m dob + +Maxwell, uk/f, dob I + +history. + +Palm Beach, , dob + +& Gins aine N. + +. A computer query for both returned no + +On 03/23/2005, I spoke with - + +requested that she not discuss the daughter as I did not want t told at this time that and to the fact that AIM has decided + +cell phone wk + +incident with anyone including her + +vestigation compromised. I was have not been getting along due to continue living with her father. + +• + +Date: 7/13/06 PALM BEACH POLICE DEPARTMENT + +Time: 9:27:55 Incident Report + +Page: 18 Program: CMS301L + +Case No - 1-05-000368 + +iiiIMI + +investi ation. I received return phone calls from Mrs. + +' ed them that I would be contacting to dinate a t' eet wi + +was at the request of both and Mrs. that classroom and therapy schedule be disrupte as ittle also u dated them to the investigation thus far. Both + +stated t o objection to my meeting wit + +speaking with Ms. she identified the re11 nhone n as being the phone assigned to + +had no objections and provided consent to giving it to the + +poll ent for the use of placing controlled phon lls from it-. stated the phone had been taken away from as part + +of her un ent for not doing well in school. According to + +used to be an excellent student, but in the past two + +months has rritable, verbally abusive to the family and has run away. stated her daug ' ecent behavior is the opposite of what she normally is. stated they are going through family therapy sessions wit t e sc ool b of this had come up. Arrangeme ade for Det. Captain to retrieve + +the cell phone from at her place of employment. + +I called and requested to speak with Ms. . Upon speaking with Ms. she advised hat she was in the middle of therapy s ons and would call me once the + +sessions were completed. Ms. stated the sessions s ou d be concluded by 7:00 PM. At approximately 8:00PM I had called Ms. + +at which time I'left a message voice mail requesting a return phone call. I spoke with Ms. and advised her that I did not meet with her daughter and that I wou d again attempt to coordinate a the counselor so as not to disrupt IMOD s school sc had no objections. ortly after speaking with Ms. + +I received a call from Ms. fined the situation an + +requested a t' to meet wit reviewed s schedule and + +advised that would be available after 3:00PM. + +rn n1/z/1/inns, I met with Ms. and at + +. I reminded of her conversation wit + +During this time initiated a conversation with me ink + +she admitted that s e was not telling me everything that had ha ened during the time she was alone with Epstein. According to , + +nued) + +T is + +strict • le. I and In er of Ms. + +asked + +n + +I + +if Epstein ever asked her age and s e state• e had. + +stated she told him she was eighteen. When Epstein asked + +what school chi= urns in, responded she was in the twelfth grade at j. During Ilaminurse of'this incident, Mill stated Epstein told her that IIIIII had worked for him for years. + +We then continued wit trolled call to At + +PALM BEACH POLICE DEPARTMENT Page: 19 + +Incident Report Program: CMS301L + +Case No. . that + +cell phone, + +Olive Garden Restaurant, + +000368 + +was at working + +W/F, located on (Continued) + +could be reached on her oye at The + +in + +During the conversation between • + +and d what happened, st she a eard rumors t was going to press charges. asked if they, meaning arents, knew about Jeffery. + +claimed to have heard that father had found out about Jeffrey. told that they (her parents) did not know anything about Epstein. told that Ei eeded + +someone to work tomorrow and asked if she was avai ab + +stated she would call Epstein and then call + +hat + +During the course of these conversations with she would + +at times appear to be articulate and well spoken. She would then start to act in an immature manner b looking around, not paying attention, drawing on a paper. would offer me a high five whenever she claimed to have told me the truth in the details of the afternoon at Epstein's house. would sit in the chair, with her knees propped up to her chest as s e admitted that she did not tell me the all the details of her encounter with Epstein during our + +m eting. As a means of positive reinforcement I would high five + +On 03/31/2005, subpoena and Cingular Wireless, numbers) were drafted. + +requests for T-MailiallgWireless + +and phone + +On 04/01/2005, I met with m mherq of PP BSF Unit for the purpose of conducting surveillance on . Cross-reference supplement. + +On 04/01/2005, I met with Det. III. of the Palm Beach Police + +Department who provided me a copy o the concealed weapons permit for Mr. Epstein. It revealed Epstein had a valid permit. There was no + +current photo attached to the renewal notice. + +On this same . . + +described by + +date I queried various different web sites for a possible of the purple item retrieved from the trash pull from item was similar in description as the one + +and used by Epstein. + +I made contact with Spicygear.com and spoke with the owner John. I emailed a photograph of the item for his opinion. He identified the items as a Jelly Anal Wand of some sort. The item is easily available + +at sex shops in South Florida. + +04/06/2005, I conducted business queries into Epstein utilizing the internet. I located articles relating to financial reports. There + +was no local history. + +Date: 7/13/06 + +Time: 9:27:55 Incident Report + +PALM BEACH POLICE DEPARTMENT Page: 20 + +Program: CMS301L + +Case No • 1-05-000368 + +continued surveillance on the property. + +On 04/04/2005, and 04/01 f herself as + +(Continued) + +cop' ' it messages, dated.03/31 to . A female identifying + +states that she could pick up to take her to + +Epstein's house for an eleven o clock appointment. A copy of this was + +placed into evidence. + +On 04/05/2005, and me. There papers. There + +follo from + +a trash pull was conducted at by Det. were several messa itten on var forms of was a message from , indicating 11:00. The + +tional information o• + +• + +Friday 5:30PM; + +; message receipt dated 4 4 1:05- + +She is looking to speak to you .; + +On 04/06/ I faxed sub oena requests to SA + +E•stein + +office for + +and s •hone records. (Phone numbers + +• + +On 04/06/2005, I called , ext 311, and spoke with Princi al He confirmed that they, had a student by the name of . He requested a written request prior leasing any additional information. On this same date I + +faxed lid a re or student and parent information on + +. I advised that due to this being an open investigation + +he was not to discuss the matter with anyone. + +On 04/08/2005, I received a messa e from rovidin me the + +foll ' ' ation: , w/m DOB + +Parents name: + +work + +Det. ONO provided me with trash obtained from for 04/06 + +04/07/05. The following information was retrieved: Jet Aviation 800-538-0724 itinerary, indicating a departure date of 04/05/2005 at 4:00 PM with An Arrival in New Yo k city of 6.1SPM. Flight crew + +captain , co-captain, `, + +orrison. Call sign N908JE; a note stating hand written notes & messages 11-Gle , 3 September B & J, Big Screen x8, + +a after schagjad left message + +• IIIII works 4-9 Monday an es ay, eaves + +school @ 11:30 AM; will be here tomorrow @ 10:30 Am; Mrs. Business There was no trash for 04/08/05. + +04/22/05 received the results of a subpoena request from Bellsouth for + +sults only provided subscriber information. I + +flight engineer Bye J. thank you •30 chicken, + +• + +Date: 7/13/06 Time: 9:27:55 PALM BEACH POLICE DEPARTMENT Incident Report + +Page: 21 Program: CMS301L + +Case No • 1-05-000368 + +me as soon as the query was finished. + +Cross-referencing the names + +well as phone numbers, which were + +trash pulls, I identified t + +c• ainted w' + +bo wove t e ega age o + +(Continued) + +notes + +as via + +and + +obtained from do + +message i ' + +are + +On 05/03/2005, I ith and updated her on the investigation. state t t was doing well in the + +school. Her contact wi he outside is limited as they do not have access to the phones. 0 comes home on the weekends and she is not + +allowed to go anywhere a one. + +On 05/11/2005, I made arrangements to meet with and + +On Thursday, 05/12/05, I spoke with regarding the case. They will be moving to GA in July 2005. ey be very busy over the next few weeks but would be available via phone. Will coordinate + +a date to meet to discuss the matter further. + +During this week I conducted surveillance at Epstein s residence and at the airport, but there was nothing to indicate that Epstein was in + +town. + +Due to conflinting appointments, rescheduled until 06/02/2005, to meet + +with + +I also spoke with and updated her to the investigation. + +On 06/02/2005, I met with and advised that she could be reached via her cell phone until she is able to + +provide me with her new contact information. + +I also received a message from . Attempted call • + +but the line was busy. + +June 14, 2005, I received information that Epstein's plane was at + +Jet Aviation. I spoke with Det. regarding surveillance. + +I called the Olive Garden and asked for advised + +she was not working today. This would indicate that + +s + +as still + +employed there. + +On 07/07/ I faxed na requests to SA + +Epstein, and + +sub oe office for hone records. (Phone numbers + +The original + +subpoena requests only provided subscriber and billing information. + +Date: 7/13/06 + +Time: 9:27:55 Incident Report + +PALM BEACH POLICE DEPARTMENT Page: + +Program: + +22 + +CMS301L + +Case No 1-05-000368 misc. female hygiene + +> Track report residence is + +by officers who had conducted seen entering and leaving the (Continued) + +he trash. Based on a prior Auto + +sible subject residing at the fit the description provided + +surveillance in the area of a female + +residence. + +On 07/21/05, I received the Duces Tecum dated + +clerked by ASO + +On 07/26/2005, I received the results of Bell + +07/18/05, which was + +South Subpoena. + +On 08/04/05, I received DHL Express from T mobile with the results of + +the query. + +I spoke with who confirmed that was still living + +out of state. It appeared that all was going we . + +I left a message for at + +On 08/08/2005, I received the results of Cingular cell phone subpoena + +During the week of 09/08/2005, I checked and the Palm Beach International Airport but there was no direct indication that + +Epstein was in town. + +On 09/08/200s, I reviewed th notes of this file, as the case + +will be turned over to Det. + +On 09/11/2005, while on patrol, I conducted a check residence and found that it still had the hurricane drive by the Palm Beach International Airport later + +did not observe Epstein's plane. + +at Epstein's + +shutters on. On a that afternoon, I + +On 09/14/2005, I conducted a check at the Palm Beach International + +Airport but did not see Epstein s plane. + +On 09/19/2005, I spoke with to keep her updated a + +find out if there was any change of e n I was told no. I left a message for at + +in order to provide her with Detective s information. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 9/21/05 + +Entered By.: . 9/21/05 + +On September 19, 2005, I met with Officer and received the information pertaining to this case. Members of the Burglary Strike + +> ad previo en conducting surveillance on both Epstein and Officer assigned to monitor the E • home and + +Sgt and Officer were assigned to monitor . Both teams provided a surveillance log that will be placed into the + +Date: 7/13/06 PALM BEACH POLICE DEPARTMENT Page: 24 Time: 9:27:55 Incident Report Program: CMS301L + +Case No • 1-05-000368 + +property number 05-294 with the blank tape. + +(Continued) + +NA Reported By: 9/26/05 + +Entered By.: • 9/28/05 + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NARRA \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* + +Copies of the tapes that were submitted into evidence were requested. riairinn=ily, trash pulls were started ow 21, 2005. Sgt. + +made telephone contact with , Supervisor of + +the Sanitation Department, and requested that trash be collected at + +1-ha PII I-''i House located at 358 El Bril ach. Sgt + +met with Sanitation worker, and observed him + +enter the property at 358 El Brillo. Shortly therea ter, + +he r + +exited the property and placed white trash bags in the empty well in t rfla flf \*he truck. then drove away where he met with Sgt. I who removed the bags from the well and placed them into one large black trash bag. The bag was returned to the Police Station where I was waiting for him. Upon his arrival, we inspected the bags where several notes and papers were found. These + +notes con ' ames + +and + +'rls with times. Additionally,'there was a + +note from + +stated,"For a good time call + +t ey Els on and + +d, which ." Also, + +there was another telephone number note . Also found was a written note, which stated, can not come at 7 p.m. + +tomorrow because of soccer. These items were written on notepads that contain Jeffrey Epstein on the bottom of the notes. These items were placed into evidence for future follow up. I requested subpoenas for subscriber • tionpa6he telephone numbers listed n the + +> m and IIIII. The cellular telephones and are both assigned to Cingular Cellular Service. Other notes + +were found within the trash on Jeffrey Epst ' paper contained telephone numbers. One note had ' with + +written on it. This cellular number • gne to Cingu ar Ce ular Service. Another sheet had written which is assigned to Bell South Telecommunications. The subpoenas were picked up and submitted + +to Cingular and Bell South Telecommunication for subscriber + +information. + +On September 22, 2005, I was informed by Sgt. that there would be no trash pick up as it was recycle pick up day. A request for copies of the micro and standard size cassettes were requested from crime scene to familiarize myself with the interviews conducted. + +On September 23, 2005, the tapes were received and I beg become familiar with the interviews that were con had met + +with Town of Palm Beach Sanitation worker, an o him enter the property of 358 El Brillo. Sort y t ereafter, + +exited the property and placed e white trash bags in t e empty well in th -- of the truck. s then drove away where he met with Det. I'll'. who removed the ags rom the well and placed them into one large black trash bag. The bag was returned to the Police Station where I was waiting for him. Upon his arrival, we inspected + +• • + +Time: 9:27:55 + +Incident Report Program: CMS301L + +Case No 1-05-000368 (Continued) the bags where several notes and papers were found. The notes will be + +inspected for future use. The items collected were placed into + +evidence. + +It became evident that some of the recordings were recorded with background noise and some interference. The calls most...ire the control phone calls from the victim to the suspect . I obtained the graphic equalizer and discovered that the calls are able to be legible with the use of the equalizer by lowering the background noise and increasing voice gain. I also learned that a tape was broken during the coping of the tape. I returned the copy of the tape marked Property Number 05-243 to have it recopied to have an + +original in evidence and a working copy with the file. + +earching the file, it was discovered that the suspect, + +cellular cal er was + +oenaed incorrectly. The suspect and the original request was for + +I requested the information through Cingular Cellular + +Service o Febrilarv--2-ans-±-b-rough the present. The purpose was to have a record of calls to victim, Jeffrey Epstein and the frequency of calls. The request was submitted to the State + +Attorney's Office. + +Investigation Continues.... + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A T T V F. 3k F \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 10/06/05 + +Entered By.: . 10/06/05 + +On or about S 2005 at approximately 0915 hours, I + +r t + +and met with PB Sanitation worker had been previously notified to assist in trash + +pulls at the residen frey Epstein, 358 El Brillo, Palm Beach, Florida. I observed enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the + +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 + +was a total of 4 white in color plastic bags and each contained documentation and correspondence for 358 El Brillo and Jeffrey + +Epstein. All ts.of evidentiary value were removed and turned + +over to Det. for follow-up. + +On or about Srntemher 21 9005 at approximately 0900 hours, I + +and met with PB Sanitation worker had been previously notified to assist in trash pulls at + +the residenc Jeffrey Epstein, 358 El Brillo, Palm Beach, Florida. I observed enter the driveway of 358 El Brillo, where no trash was located wit in the receptacles. I left the area without incident + +• + +Date: 7/13/06 Time: 9:27:55 PALM BEACH POLICE DEPARTMENT Page: 26 + +Incident Report Program: CMS301L + +Case No • 1-05-0ua.a.. + +and notified Det. to that affect. + +(Continued) + +On or about September 27, 2005 at approximately 0915 hours, + +iiiii + +I observed + +nded to 358 El • lo an d met with PB Sanitation worker • + +enter the driveway of 358 illo and + +remove one plastic ag of trash and place it in the of an empty + +sanitation truck. + +I then followed to a predetermined location and seized the trash from the truck. ',trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was a total of 1 white in color plastic bag which contained correspondence for 358 El Brillo. All limits of evidentiary value were removed + +and turned over to Det. for follow-up. + +On or about Monday October 3, 2005 at approximately 0915 hour'. d to 358 El Br' met with PB Sanitation worker + +I observed O A, enter the driveway of 358 El Brillo and + +ve several plasticbags of trash and place the contents into the + +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 was 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. Inside of one of the white in color bags, I located 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 alts + +of evidentiary value were removed and turned over to Det. for + +follow-up. + +On or about Tuesday October 4, 2005 at approximately 0928 ho I + +d to 358 El Br\* met with PB Sanitation workeruilli + +. I observed 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 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 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. ents of evidentiary value + +were removed and turned over to Det. for follow-up. + +• • + +Date: 7/13/06 PALM BEACH POLICE DEPARTMENT + +Time: 9:27:55 + +Page: 28 + +Incident Report Program: CMS301L + +Case No 1-05-000368 (Continued) + +Upon s entry in the unmarked Detective vehicle, I placed a tape recorder within the vehic record any conversation in the vehicle. During the ride to the police station, advised + +she is attending Palm Beach Community College at the Palm Beach + +Gardens Campus and is majoring in journalism. + +Upon our arrival at the police station, was broug the interview room in the Detective Bureau. I explained to that I appreciated her willingness to assist us'and informed her that should she desire to leave at any time she may do so. I fur plained the interview room door is only closed for priv stated she understood. During the taped swor • iew, was asked how she came in contact with Epstein. stat when she turned + +Beach Resort in Rivera Beach. + +17 years of age she was approac a friend + +was asked if she wanted to make + +in the Canopy + +money. + +She was t would have to provide a massage and should make \$200.00. thought about the offer. agreed to meet with Jeffrey. (Unknown last name) and (Unknown last name) + +picked her up and she was taken to Epstein's house. Upon her arrival at the house, she was introduced to Epstein in the kitchen of the lime. She was also introduced to a white female known to her as + +She was led irs to the main bedroom known to her as Jeff + +Epstein s bedroom. arranged the massage table and covered the table with a sheet. She b t out the massage oils and laid them next to the massage bed. then left the room and informed her Jeff would be in a minute. Jeff entered the bedroom wearing only a tow lay on the table onto his stomach ed massage oil + +fore to rub on him. During the massage, stated, + +massage, Epstein pal or the massage. He explained, I know you re.not comfortable, but I'll ou if you bring some girls. He told her the younger the better. stated she once tried to bring ear-old female and Epstein stated that the female was too + +> was'asked how many girls she t in total to Epstein. d ' c rariari Rh° hrOlii ii + +and the victim in this case. + +I asked whi was the youngest. advised the victim was the youngest. stated every girl she brought knew what to + +expect whrn (-hru arrived. They were told they would provide a + +massage, I , and some touching. I asked her if the victim was aware. She stated every girl she brought knew what to expect. + +She explained she knew the victim wanted to make money. She + +Incident Report Program: CMS301L + +Case No • 1-05-000368 + +victim agreed and arrangements + +Epstein's house on a (later identified as + +upstairs. Whe kitchen area. to Epstein's. 'for the massage. + +happened. iiiiiictim told her about the massage and then they went shopping. stated the victim was the last person she brought to Epstein. She further state t she had changed her cellular number to avoid being contacted by . She continued that when Epstiii, + +announces to would contact istant that he is traveling to Peach, + +range girls for PvIt. i , later + +fied as Date of Birth , had told + +that Jeff likes to have his fun with the girls. + +(Continued) + +ade to bring the victiiiiii + +stated that she and + +picked up the victim at the + +victim s house. They traveled to Epstein's House and entered through + +the kitchegaaor. They met with the house chef and Epstein s + +assistant The v m was introduced to Epstein while they were in the kitchen area. led the victim upstairs and Epstein went + +assage was over, the victim returned to the + +stated she was paid \$200.00 for bring the victim stated the victimiiiiiiher she was paid \$300.00 in the vehicle, asked the victim what + +stated that once her + +Min, they disapproved o + +further stated that + +leaves m- the + +parents discovered that she was visiting e encounters with him and she stopped. still trio call the house and + +> were DOB + +, and DOB + +Sgt entered the room and explained that based on her own + +statements, she h ' icated herself with bringing underage girls to Epstein's house. was aware of what she had stat wished + +to assist further in hopes to receive a lesser charge. + +provided cellular telephone numbers for the girls she had mentioned previously. Additionally, she alagmgrovided possible addresses and areas in which they lived. As III'. was being taken home in the vehicle, a tape recorder was placed within the vehiciilio record any + +sations within the vehicle. During the drive to her home, made the comment i m like a Heidi Fliess. (Hollyw ram who + +sent girls to clients for sexual favors in California). was + +dropped off at her house without incident. + +Sgt and I went to + +Floriaa.yamaamat speak with . We met with Mrs. ( s Mother) at t door. We 'explained the ongoing investigation and felt that may have additional + +on as we had information that she had worked for Jeff. Mrs. introduced us to her husband and allowed ng entry intn the + +home. We sat " ing room and met with , + +firth As she was under the age of eighteen, Mrs. was advised we would be speaking with her. She expressed, + +. + +if her daughter had information she wanted to assist. As we + +interviewed I , she denied having any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff s + +• • + +Time: 9:27:55 + +Page: 30 + +Incident Report Program: CMS301L + +Case No (Continued) House with lila. approximately eight months ago and sat in the kitchen with the house chef but nothing hap s the parents were present during the interview, we felt that was withholding information from us. She made several comments as to she has put the entire incident behind her. I left my direct telephone number and + +r + +d should she wish to gnAnk with me again to telephone me. Sgt and I thanked Mrs. for her time and left the area. She stated she would ask her again after as to what happened at Epstein s house. I informed her that had my telephone + +number and hopefully she would call. + +attempted co We met wit + +her daughter. was at the Ma explained the ongoing investigation an elt the additional information as we had information that Jeff. We left our phone numbers and asked her to her daughter's return. We then left the area. + +On October 4, 2005, at app a voice mail message from with her daughter and s house. I contacted + +at o stated was a s not home. We may have she had worked for telephone me upon + +05 am, Sgt had retrieved She stated she had spoken ation as to what occurred at Jeff who sta er daughter was in the + +shower at the moment and would be traveling College. I inform I would be en route + +> Det. I drove to the and . During a sw + +state she was to en to the house by + +told she could make money working fo f. She was told she would have to provide a massage to Jeff. stated er arrival to + +the house she was brought to the kitchen area by + +They met with house chef and stayed in the kitchen. She was introduced to Jeff's assistant and was brought upstairs to the + +mater bedroom. prepared the room and massage table for a massage. Epstein entered the room and she provided a massage. + +sal s e + +involving Jeff. At the conclusio + +\$200.00 for the massage. I asked if she has a al training + +in massages to which she replied no. I asked her i re any monies for taking her to perform the maiiiii stated + +eceived money for t e re. stated she weiiiiith + +till to Orlando to attend home in + +home and met + +Nit tement, + +She was + +wler e ou .y e Incl en e massage, she was paid + +iiiiii iiiiiii + +and another girl, ff's ho + +stated she w ' d i kitchen with , while was taken upstairs by . stated she only did the massage once, as she was wierded out by the whole experience. At the conclus of the interview and the taligigas stopped, I was informed that had attempted to reach IIIII via cell phone. A voice mail message on October 4, at 10:59 am, revealed a female ce who identified herself as who requested her to call her reference the + +through its contents. + +with + +Exch n ad + +J.E dated 03 + +boarding pass copy for passenger, , Montg County, + +Health Department food service ID NO#40820 for + +and Ghislaine Maxwell notepaper with names and phone numbers + +Photocopie the trash collected were attached with the supplement. Detective was advised of the contents that were collected for + +Date: 7/13/06 PALM BEACH POLICE DEPARTMENT + +Time: 9:27:55. + +Page: 31 + +Incident Report Program: CMS301L + +Case No 1-05-000368 (Continued) + +police quest- g. This voice mail message was recorded onto a micro vided the incoming telephone n + +stated she ' ently told about + +t e police investigation because had called her to t about how she just received a rental car froth Jeff Epstein. + +had called her to tell her that she was given a rental car, a 2005 + +Nissan Sentra, to utilize to visit family and visit Jeff. asked her what wailing on ouse that the police w + +e asking questions. + +ill + +stated then called Jeff and + +and asked what was going on r nc e ongoing police + +investigation. According to , has since then been g to contact her ask about the police questions. I instruct not to contact and do not provide more information to as + +she would notify Jeff Epstein and what was transpiring. + +Investigation Continues... + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*NARRA 8 \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 10/07/05 + +Entered By.: . 10/07/05 + +On March 30, 2005, I was asked by Sgt. to conducting surveillance and trash pulls reference Detective + +conducting a criminal investigation involving Jeffrey Epstein. I was advised that Epstein was possibly engaging in sexual contact with + +young females. + +On March 30, 2005, + +Supervisor + +Way to begin on March 31, 2005. + +act with Town of Palm Beach Sa ' • n + +and requested trash pulls for + +On March 31, 2005 at 9:20 a.m., I responded to the area of 358 El Brillo W t with Town ohisliaeach sanitation employee, Jeffrey . I observed IIIIIIII enter the driveway of 358 El Brillo Way, collect the trash bags from Epstein's propert ace the contents into an empty sanitation truck. I followed to a nearby area, were he turned over seventeen white plastic trash bags, + +which were collected from Epstein's property. + +I took the trash bags to the + +, an + +29 05 at 8:15 p. + +sanitation department were I sifted + +'1 correspondence from Armani , Jeffrey E. Epstein notepaper + +important mes er addressed to m. reference , U.S Airways + +• • + +Date: 7/13/06 PALM BEACH POLICE DEPARTMENT Page: 32 Time: 9:27:55 Incident Report Program: CMS301L + +Case No • 1-05-000368 , (Continued) On March 31, 2005, Sgt .MI I requested that I set up a surveillance vehicle on El Brillo Way and conduct video surveillance of the front exterior of Epstein's residence. At 3:00 p.m., I set up a surveillance vehicle equipped with a video monitoring device. The surveillance vehicle was parked on El Brillo Way approximately fifty + +feet east of Epstein's driveway. The purpose of the video + +surveillance was to gather investigative intelligence by monitoring and recording all vehicle and pedestrian traffic entering and leaving + +Epstein's property. + +The video surveillance tapes were changed daily with a new Maxell + +T-160 VHS tape. Video surveillance was established for Epstein s from + +March 31, 2005 through April 05, 2005. On April 05, 2005, video + +e + +surveillaniss concluded. I reviewed the video tapes and advised Detectiv the surveillance videos yielded no evidentiary value + +On April 01, 2005 at 9:30 a.m., I responded to the area of 358 El o Way to meet with Town of Palm Beach sanitation employee, . While parked in the area of 358 El Brillo Way waiting to col h Pnetp.in e trash, I observed a white female, who I recognized as fragmlaxalgrida driver's license photograph. I made no contact with 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 vehicles appeared to be housekeepers, maintenance + +men, and gardeners. + +I met with Tglia.if Palm Beach sanitation employee, I observed enter the driveway of 358 El Br\* + +Way and collect the trash from Epstein s property. I followed + +to a predetermined area at which time I collected the trash bags rom the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. I collected mail correspondences addressrA Pn Jaffrav VE/Steil) antomntivo records and personal documents for I and as well as + +> Epst&tg.garapaper with the names and appointment times for and No last names or other personal information was + +written on the notepaper. + +While sifting through Epstein s trash, I also collected a three-inch + +purple finger size object, which had a broken end. The object + +appeared to be a broke piece from a sexual toy similar to a (Cyclone Vibrator) possibly used for rec atification. The sexual object was photographed for Detective lilt, packaged in a biohazard evidence bag (possible body fluids) and secured as investigative evidence. All collected from Epstein s trash were turned over to Detective + +for evidentiary purposes. + +On April 05, 2005 at ill... m i. + +sanitation employee, + +driveway of 358 El Bri iiiy and property. I followed to a + +met with Town.aL.galm Beach I observed enter the collect the trash from Epstein s predetermined area at which time I + +• + +Time: 9:27:55 + +Page: 33 + +Incident Report Program: CMS301L + +Case No • 1-05-000368 (Continued) + +collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. I collected mail correspondences addressed to Jeffrey Epstein as well as notepaper (Important Message) with names and + +telephone numbers. The following are items collected from Epstein s + +trash. + +P. ( blank piece paper ( + +black paper + +MSN Hotmail web page with email address ( .com) + +The following items were documented for Detectivellilli s + +investigation for evidentiary purposes. + +On April 06, 08, 11, 12, 13, 15, 2005, at approximately 9:30 a.m, I met with Town of Palm Beach sanitarinn emniflyees. I observed the + +employee enter the driveway of I way and collect the trash from Epstein's property. I followed the employee to a predetermined area at which time I collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, + +where I sifted through its contents. + +All of the documents collected from Epstei i trash during my assistance were turned over to Detective for evidentiary + +purposes. + +On June 14, 2005, Detective contacted me and advised that the airplane belonging to Jeffrey Epstein of 358 El Brillo Way + +was parked at the Palm Beach International Airport. + +Detective requested that I begin trash pulls for the purpose of + +gathering evidence and intelligence. + +ct with Town of Palm Beach Sanitation Office Supervisor and requested trash pulls for 358 El Brillo Way to begin + +on June 15, 2005. + +On June 15, 2005, I met with a sanitation employee. I observed the employee enter the driveway of 358 El Brillo Way and collect the trash from Epstein s property. I followed the employee to a predetermined area at which time I collected the trash bags from the sanitation truck. I transported the trash bags to the sanitation department, where I sifted through its contents. The trash yielded negative + +results and no evidence was collected. + +No further trash was collected throughout the week due to the fact that Epstein s security gates remained closed throughout the week; therefore, the sanitation employees were unable to gain access onto + +Date: 7/13/06 PALM BEACH POLICE DEPARTMENT + +Time: 9:27:55 + +Page: 34 + +Incident Report Program: CMS301L + +Case No • 1-05-000368 (Continued) + +All evidence and intelligence gathered by this officer has been turned over to the detective bureau and no further action has been taken by + +this officer. + +End of supplement. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*NARRA \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 10/07/05 + +Entered By.: . 10/10/05 + +On October 4, 2005, I made telephone contact with + +who had left several messages on voice mail. During the message, she advised she was not completely truthful when we met in person but would like to speak with me to advise what had happened. She further advised she did not want to speak of this incident in front of her + +imat • , I made telephone contact with t . During a taped recorded + +statement, stated the fol : Approximately a year ago, when she was sixteen years of ag her to Jeff's house twice. The first time she went, drove to the house. They entered through the kitchen area where she w troduced to and Jeff. She was taken upstairs to a bedroom by who set the room up with a massage bed and brought out the oils to use. Jeff then entered the rnn ing a towel. He lay on the table and picked out + +a lnti + +Both Jeffrey had a ver + +at which time she left without being paid. She met with who was sitting in the kitchen and told he ' o. + +ekiteceived no money for that day. also + +said that had told her if she was uncomfort le with what was going on, to let him know and he'll stop. She knew that the more + +you do the more you are paid. + +Several advised she agreed to be time by Once they arrived at the residence, + +ta + +sat econd + +e kitchen and took her upstairs to the master bedroom again. set the room up with a massage bed and brought out the oils to use. Jeff then entered the ring a towel. He lay on the table + +and picked out a lotion for to rub on him. At + +As was + +came upset again and + +told him she didn't want to be discontinued the + +was paid \$200.00. th downstairs where + +waiting for her. She told she w + +leave. said she never ret t se. + +stated she is aware that her friend, was also at the house and had a problem with Jeff. She provided a telephone number + +• + +Date: 7/13/06 PALM BEACH POLICE DEPARTMENT + +Time: 9:27:55 + +Page: 35 + +Incident Report Program: CMIS301L + +Case No. : 1-05-000368 (Continued) for . The interview was concluded and the micro cassettes were + +turn in as evidence. + +On Octobeilill researched the incoming telephone umber that + +had left a message. The telephone number, + +was assigned to ATT Cingular Cellular service. I prepared a subpoena + +request and faxed the request to the State Attorney s Office. Information requested was subscriber information as well as all incoming and outgoing calls for the months of September and October + +2005. . + +tat her residence in Beac . and I dr s a et with + +and ' she resides in + +h. + +ter researche + +agreed to algaal6with us in the kitchen area. During a sworn + +taped statement, IIIIII stat I wing: On or about November 2004, she was approached by and asked if she wanted to make money. She agreed and ld she would provide a massage to wealthy man in Palm Beach. Milli picked her up and drove her to a + +house in Palm Beach. She was brripechl- inrn rha kitc o house. She further stated that I' ) and (II) went with them. They were brought int itchen where she was + +introduced to Jeff and other females. stated she was + +introduced to a helper of Jeff; the fema e was described as white + +female (unknown n with blond hair. She stated that the assistant was familiar with . The assist up the massage table and put out lotions to be used. She told Jeff would available in a minute. Jeff entered the room wearing on y a towel. Jeff on the + +e table and sicked a lotion to rub on his thi•hs and + +an• remove• imse rom e e. a wa over o w e e e shower was and opened the glass door. Shil ed as he was taking a shower in her direct view. When I asked how old she was when this occurred, she stated glagmlaid just turned seventeen. At the conclusion of the shower, IIIIII was paid either \$350.00 or \$400.00. She stated she wasn't sure, biamkagws it was close to \$400.00. At the + +conclusion of the interview, IIIIII stated she never returned to provide a massage for Jeff. She advised she was ashamed and + +uncomfortable with the situation. + +PALM BEACH POLICE DEPARTMENT Incident Report + +e area and responded to the + +and all the ab vp-mAntinni.d girls had + +attended. I met with School Police Officer, T + +T was lnoking for a previous qturient who attended + +I inquired about h I further explained + +that I was working a case in which most of the girls I hav + +interviewed are eithe + +one as wel and found + +• + +Date: 7/13/06 Time: 9:27:55 + +Page: 36 Program: CMS301L + +Case No. . 1-05-000368 + +and I then 1 School where + +frontinnrsd) + +elenlained + +and turned on soft music. room wearing only a towel. J his legs, under hi tocks, + +get comfortable. advisee did not remove her clothes. She was wearing tight jeans and a cropped tank top exposing belly + +area. During the massage + +s or victims and felt that may be researched his previous student records + +She attended the same year and graduated + +in the same as the other girls. I was provided the last known + +address of . + +At approximate) at her residence, . As was + +seventeen years of age, I had notified her mother, Mrs. , that she would be interviewed reference an ongoing + +investigation in Palm Beach. I assured her that her daughter was not a suspect. I explained the possibility of ing either a witness + +or victim. Mrs. advised she wanted I iii to coopera + +minted to the interview. During a sworn taped statement, + +stated the following: at the ag during the month of + +September 200 e was approached by chance to make money. was friends with the friends of and knew the + +eople. + +did for Jeff. + +h previously told by her frimagg whs.... + +cal + +and scheduled the appointment. + +erson i to IIIII as + +picked up and drove her + +to Palm Beach to a street called Brillo Way. They drove to the end of the street and entered a large drivew hey entered the kitchen + +f the e and met with Jeff. ail" was introduced to Jeff. led upstairs to the main bedroogimizad and set up the room + +with a massage table and set- the oils. IIIIII dimmed the lights + +exited the room and Jeff entered the icked oils and instructed her to rub and chest area. Jeff asked her to + +I asked + +difference between circumcised and not c' knew and advised Jeff was circumcised. massage and left the area. She met with + +kitchen area and left the house. + +if she knew the + +i + +cised. She explained + +llilli + +as paid \$200.00 for who was waiting in + +she the the + +then explained she never provided another ag Jeff. She + +did however, go to the house with and ( ) as they + +PALM BEACH POLICE DEPARTMENT Page: 37 + +Incident Report Program: CMS301L + +Case No • 1-05-000368 + +iend of + +went to work ff. + +sat in the kitchen area wit to that while they waited for the them, as it was almost lunchtime. As massage, they left the area. I asked + +woul ected of her when she provided a massage. yes, told her that a massage woyilgimlie expected + +and possibly some touching involved. IIIII has no formal training in + +providing massages. + +laspoke about a third + +drove an girl, + +(Continued) + +advised she was present when She advi e lover and wait for . advised chef prepared lunch for wa shed with the if old what + +e went to ' house. + +is friend, + +Jeff's house. stated she knew that had mad + +providing girls for Jeff and she wanted to do the s + +• the en ar e house and introduced + +and took upstairs to bedroom. + +advised she doesn t know wh + +' + +pened as did nom + +what happened in the room. received \$100. going with her to J ouse and recommending unable to remember s telephone number. The + +concluded and we left the area. + +Investigation Continues... + +to + +about for was + +interview was + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*NARRA \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 10/09/05 + +Entered By.: . 10/10/05 + +On October 6, 2005, Det. and I went to Lynn University located + +in Boca Raton. We met with Dean of Students, Paul Turner. I + +explained to Mr. Turner that we were invest" agile within the Town of Palm Beach and felt that a s t, , may have information. Turner confirmed that is a student and currently on the soccer team for Lynn University. She was in computer claim, + +the time of our arrival. Turner sent a security guard to locate in class aiiiiiing her to the office. Mr. Turner allowed us to + +interview in an empty conference room. + +At 11:45 am I met with and explained to her why we there + +to interview here advised she was aware of the ongoing + +igation. IIIII stated she had previously spoken with + +who told e was interviewed by d i l + +workg + +eurin a sworn + +taped statement, ted she knew that ed for Jeff in Palm Beach. advised she has been there many times for + +massages. le ad her if she had for raining in providing + +massages, stated she did not. advised she was told what was expected of her by providing massages and would have to remove clothing but if she felt magamfortable just to say so and Jeff would stop pushing the issue. IIIII began providing massages and advised she kept her clothes on. She considered Jeff a pervert who kept + +PALM BEACH POLICE DEPARTMENT Incident Report + +Page: 38 Program: CMS301L + +Case No • 1-05-000368 (Continued) pushing to go further and further. explained she would keep telling him she had a boyfriend and t t would not be right to her + +bo friend. + +Jeff would t nally, left + +into + +get away with more and more on each massage. + +drove her to the house for the original massage. her cell phone number and every time Jeff would come would call her for an appointment. Each time she + +went, would meet her at the kitchen door . She would bring + +her upstairs and prepare the mass + +I asked if he knew her real + +age, stated Jeff didn t care. The most recent massage she + +provided was on October 1, 2005. During the massage she asked Jeff if she could borrow one of his vehicles to visit her family and boyfriend + +in Orlando. Jeff had told she could borrow + +was asked if he ever used a + +vibrator on her. was aware of the vibrator but advised she never would allow him to use the vibrator on her. She described the vibrator as a large white vibrator with a huge head on the tip of the + +vibrator. She sgagga he kept the vibrator in a closet near the massage table. IIIII advised she had been doing the massage for approximately two years, which meant she would have started doing + +massages for Jeff at the age of sixteen. + +stated she was contacted by on October 3, 2005. had + +informed her that Jeff had rented her a nagMissan Sentiiiiid she + +should come by the house to l it up. IIII informed she would + +have the car for a month. stated Jeff knew her car was not working properly and had mi appointments in the past because of her car being inoperable. IA explained the car is currently parked next to field. I asked her if ¢he (WRY' took any one to the house. explained she took , a friend'of hers who has returned to Orlando to at college. I asked she ever allowed + +mit another female in the room. IIIII advised no one was bro • to the room with her. At the conclusion of the interview, Det. and I went to the a and located the Silver Nissan Sentra bearing Florida tag . The vehicle is. registered to Dollar rent a car + +out of the Palm Beach International Airport. + +Talimnhnna remtact was made with + +I explained to her that I was following up on this case + +and provided a complete update on the case. + +the victim's mother, at + +• • + +Date: 7/13/06 PALM BEACH POLICE DEPARTMENT + +Time: 9:27:55 + +Page: 39 + +Incident Report Program: CNIS301L + +Case No • 1-05-000368 (Continued) + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A . \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 1O/21/05 + +Entered By.: . 1O/21/05 + +On October 10 9009 at annroximately 2:30 p.m., I made tel ne contact with I . During a taped conversation, was told of an ongoing investigationiiiwhich I felt she had information pertaining to Jeffrey Epstein. explained she met Ep en just sixteen years of age. She was approached by + +, a ' nd who also had previously gone to pnRrain's house for + +massages. advis.......was working at the Mall when she was approached. , told her that she would have to provide + +ssage to Epstein and she would have to perform this massage naked. thought about the offer and stated she could make \$200.00 for minutes of work. She.agreed to perform the aaaaage and set the appointment for her that same day. IIII reme + +was a weekend as she only worked at the mall on th...lekends. + +took her to ...house where she was introduced to J Epsteinis took her upstairs to a master bedroom. + +, + +assistant. + +explained that as she was walking up the stairs she observed several + +'Iliographs of naked women along the walls and tables of the house. further explained that she was brought into the bedroom where prepared the room by setting up the massage table and provided + +t e oils for her to rub on Epstein. + +Epstein entered the room. and introduced elf. Epstein lay on the table and told her to get comfortable. could remember if he was naked or if he entered the room with a towel. stated she + +stated she had been to his house undreds of times over a two-year period. ...claimed to have made thousands of dollars during her + +visits. stated she could not remember how many times exactly she + +went to Epstein's home but said it was a lot. + +became more upset, crying hysterically and stat + +and instructed + +could not ggatinue + +and wanted some time to regain her composure. I explained to to take her time. After taking several minutes to regain her composure I + +• + +Date: 7/13/06 .PALM BEACH POLICE DEPARTMENT + +Time: 9:27:55 Incident Report + +Page: 40 Program: CMS301L + +Case No 1-05-000368 (Continued) + +explained that I would travel to meet with her in person T felt she + +had additional information to provide. met with Sgt. + +explained the importance to meet with agreed and made arraignments for Det. + +in Jacksonville, Florida. + +2005, at 4:10 p. + +li d'wanted to have present for + +support. she wanted fined to her that I did not have oblem as + +wanted + +long as + +present during the inte stated she + +wanted her present. I explained that as was present she was not allowed to comment or ',any questions during the interview. She + +was only there to comfort should the interview upset her. + +During a sworn taped statement, explained how everything b She said she was brought through the kitchen area where she met + +lob + +for th ' st time. She was led to the master bedroom, Epstein s room. explained that as she was walking up the stairs she + +observe sever otographs of naked women along the walls and tables of the house. further explained that she was brought into the bedroom, where prepared the room by setting u e massage table and provided the oils for her to rub on Epstein. explained she remembered the steam room area, which contained two large showers. Epstein entered the room from the steam room area and introduced + +elf + +person. Sgt. and I to meet with + +massage + +was over. of the m e, 200.00. The walk gether 'rs where and were waiting. y ell', stated received an unknown amount of money for + +taking her to Epstein. Epstein instructed to leave her cellular telephone number so that he could contact her when he is in town. + +explained that she continued to go to Epstein s house and became + +a regular at the house. She could not provide an exact number but claimed she had been their hundreds of times. She claimed sexual + +activities did not occur every time she was th she went to dinners and parties with Epstein. + +things began to escalate more than included bringing in his assistant, + +Epstein had purchased her from her family in Yugosl bragged he biiiiht her into the United States to be + +sex slave. + +There were times explained that e encounters + +explained + +avia. Epstein his Yuctoslavian + +PALM BEACH POLICE DEPARTMENT Incident Report + +Page: 41 Program: CMS301L + +Case 00368 + +Each time someth new was introduced additional and offered for to allow the acts to happen. + +exp acne• t at Epstein's penis was •e orme• exp acne• a + +penis was oval shaped. She claimed when Epstein's penis was erect, it was thick toward the bottom but was thin and small toward the head + +portion. She called it egg-shaped. + +her became a ri would arrive at the house a.. .alk herself + +upstairs, where + +continued that t xual encounters withl + +and Epstein were wai + +, Epstein and + +would + +advised one day, ( was unable to state and exagL date when this incident occurred), she came to the house after IIII had informed + +her that Epstein had arrived. Sh rived at the house and went + +upstairs to the advised she immediately removed + +Epstein apologized or + +actions and subsequently paid her a thousand dollars for that sh rtly thereafter, Epstein gave + +her personal use. + +IS visit + +Date: 7/13/06 PALM BEACH POLICE DEPARTMENT + +Time: 9:27:55 Incident Report + +Page: 43 Program: CMS301L + +Case No • 1-05-000368 (Continued) + +La usg. antarAA onto :the property, we encountered the house manager, + +who was in the guest portion of the house. The + +guesthouse s was made. I + +rya onntart + +ectio doors and no f + +wit nit: Date of Birth , Fl DL + +, and informed him of the searc warrant for the + +premises. The members of the Police Department entered the residence and announced we had a search warrant. A safety searc e and + +ited the home. I read the search warrant to as Mgr videotaped the search warrant execution. Several interior + +decorators were located on the property. I spoke with Mark Zeff, of + +in New York. Mr. Zeff stated he is the designer for + +Mr. Epstein's homes. He advised he was contacted in March of 2005 to do a complete overhaul on the house. He advised he was on the phone with Mr. Epstein when officers announced the search warrant. Mr. Epstein was then made aware of the search warrant. Mr. Zeff advised, + +his contact with Epstein is strictly business and he has nevi. + +M + +essed Epstein with any girls except for his assistants, or + +I then interviewed of Mr. Estes stated he has worked for Zeff he personally worked on the New York Epstein. He has previously met with assistants in New York and in Florida. + +Epstein everywhere he goes. + +in New York. + +for seven years. He advised Palm e for Mr. and , Epstein's Estes stated they travel with + +Stviewed of + +stated she just arrived from Scotland and has worked with Zeff + +for only one month. She stated she has never met Epstein and has not + +seen him. The interview was then concluded. + +I then + +Moh + +of + +City. stated he has been Epstein's Architect for seven years. He further stated he deals " ein's assistants and speaka 't ein on the phone. stated he mainly speaks + +illi + +, Epstein s main assistant, who travels with Epstein. + +stated he only has contact with Epstein when his services + +are needed. + +At approximately 10:30 am, I was informed that the videotaping was concluded. I entered the residence and located two covert (hidden) cameras. The first camera was a covert wall clock in the garage area. + +I traced the wire behind the clock and removed the RCA wire and unplugged the camera. The other covert camera was located within a desk clock beside Epstein's desk. I traced the wire behind the clock and unplugged the RCA wire. I could not locate another camera. I + +then began with the search of the residence for the specified + +evidence. + +• • + +Date: 7/13/06 PALM BEACH POLICE DEPARTMENT + +Time: 9:27:55 Incident Report + +Page: 44 Program: CMS301L + +Case No 1-05-000368 (Continued) marked to be retrieved by the evidence custodian. In the master desk + +with Epstein's notepads marked Jef in we locat of transcript from School for + +. Also in the room, was the dresser armoire where we ocated a bottle of peach flavored Joy Jelly (Sexual Lubricant). Additionally, there were several photographs of young naked teenage girls within the + +closet, which was consistent with what the witnesses said. The + +massage table was also located within the master bedroom. Video tapes were located beside the television, which were also collected. An itemized list of the property and locations was prepared on the + +property receipts. At approximately 2:55 pm, the house was secured; + +the exit of the residence was videotaped. Upon our exit• of the property, I encountered Atty. Guy Fronstein who advised he was + +representing Mr. Epstein. He provided a business card and provided + +his assistance with the investigation. + +Due to Hurricane Wilma, which struck South Florida causing massive power outages, the courthouse was closed due to the lack of power. was previously told that the Chief Judge had extended the filing deadlines due to the hurricane and the Courthouse being closed. On October 27, and 28, 2005 the courthouse was closed and I could not file the search warrant and inventory at the clerk's office. On October 31, 2005, I responded to the courthouse and filed the + +papekwork along with an order to seal, signed by Judge Johnson, to + +deny any release of any paperwork on this case. + +INV CONTINUES.. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 10/20/05 Entered By.: . + +. + +11/07/05 + +On October 20, 2005, a ximately 8:30 a.m., Thursday morning, I was advised by Captain that a search warrant would be executed and that I was to assemble the Crime Scene Investigative Team and stand by the south ide of the building ready to go. I designated Evidence Specialist to handle the inventory return, the documentation of the property receipts and the collectio Ing of the evidence at the scene. I further instructed CSI , ID + +Ila to accompany us and perform the role of photograp Ing t e scene and e.. m e taken into custody by the affiant, + +Detective + +My responsibility was to go through from the reading of the warrant to the final exit from the residence and perform a video recording of the + +reading of the warrant, the initial walk through of the residence showing the current condition and then finally a walk through of the + +residence at the time of the police exit. + +ted out towards the residence, which was located at and arrived at approximately 9:33 a.m. The searciiiiii + +conducted, items were collected by Evidence Specialists + +Date: 7/13/06 PALM BEACH POLICE DEPARTMENT Page: • 45 Time: 9:27:55 Incident Report Program: CMS301L + +Case No • 1-05-000 (Continued) + +photographed by CSI and then videotaped by myself. T was concluded at approximately 3:05 p.m. whereupon Detective + +and I were the last two officers in the house. Upon securing the residence with the gentleman who identified himself to + +Detective as the lawyer for the defendant and he was informed that the residence was secured and that copies of the inventory return had been left on the first floor table of the personal assistant's + +office. + +Detective and I returned to Police Headquarters and secured + +for the day. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*NARRA \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 11/07/05 + +Entered By.: . 11/07/05 + +IIIIIII T AqiqTqrl efective in the execution of + +Way, Palm Beac , Florida, 33480. + +On October 20, 2005, a search warrant at + +Upon the announcement of the search warrant, immediate contact was made with three white males who came out of the hnugin nr at, rounding structures. Those males were identified as I I, Daniel Estes, and Mark Zeff. As other members of the police department + +cleared the home, I kept watch over these three males. house + +was cleared, those males were turned over to Detective + +Detective and I were assigned to assist in the search of the main house, the cabana and the servant's quarters. We started in the + +garage. All areas of the garage were searched to include four vehicles. These vehicles were three black Mercedes Benz cars registered to Jeffrey Epstein. The fourth vehicle was a Harley Davidson motorcycle, green in color, registered to Jeffrey Epstein. + +Nothing was recovered from the garage. + +A towel closet and pantry located off the kitchen were searched and + +yielded negative results. + +The kitchen was searched and taken into evidence was a phone message + +book that was located near a house phone. + +North of the kitchen was an office room which contained a computer. + +The room had a closet that • d a locked gun locker. Tim combination was entered by in the presence of Sgt. the safe was opened. Items were taken from the room. See the + +completed property receipt for a detailed list. + +and + +A green bathroom located on the first floor was searched and nothing + +was taken. + +Date: 7/13/06 PALM BEACH POLICE DEPARTMENT Page: 46 Time: 9:27:55 Incident Report Program: CMS301L + +Case No • 1-05-000368 (Continued) female from the waist up. See the property receipt for details. + +Isearched two bedrooms and their adjoining bathrooms, which were located on the second floor on the East side of the house. In the + +Northeast bedroom closet I found adult sex toys called Twin Torpedoes. Soap made in the shape of apenis and vagina were also found in these + +upstair bedrooms. See the property receipt for details. + +Isearched the pool cabana located on the South side of the pool. Photos were taken from the wall. See the property receipt for + +details. + +Iassisted in the search of I I living quarters. Numerous CD s along with amessage book was seized. See the property receipt for + +details. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported.By: 11/08/05 + +Entered By.: . 11/08/05 + +On November 1, 2005, I was contacted by Atty. Gus Fronstin, who advised he was willing to assist with the investigation. Atty. Fronstin advised he would try to have his client, Jeffrey Epstein available to be interviewed. I explained I would be interested in conducting an interview with his client as well as other employees that are employed within the house. Atty. Fronstin advised he would + +return my call once he received confirmation on the interviews. + +On November 6, 2005, I attempted contact with at her residence. I left a business card for her to return my call. Upon retur • olice department, I had rer-iyind n ri-liephone call from . I returned her call at I I and spoke with e made arrangements to respond to the station to provi ean interview. At approximately 3:30 pm, she arrived at the Palm Beach Police Station with her boyfrieniiiiiir boyfriend was allowed to sit in the lobby area while Ms. was interviewed. + +Itook Ms to the Detective Bureau Interview room. I closed the door for privacy and explained to her that I appreciated her coming to + +the police station for the interview. During the sworn taped statement, she advised she was at Jeffrey Epstein s house o + +pvit ( imately two months ago, she was approached by a girl, + +who was dating her roommate, to make some quick money. + +advised she was in need to make some quick cash to make the r + +. She agreed to go to the house. She had been told by + +emassage would have to be done in her underwear. She + +walked into the kitchen area and took the stairs upstairs. + +drove with her and brought her into the houseilliily advised + +further stated she was brought into amaster.bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroom. Epstein entered the room wearing only a towel and + +PALM BEACH POLICE DEPARTMENT Incident Report + +Date: 7/13/06 Time: 9:27:55 + +Page: 47 Program: CMS301L + +Case No • 1-05-000368 (Cont' + +introduced himself as Jeff. advised she recalled she and + +I + +aske no. + +She and continued t ssage until + +the last ten mils of the massage, Epstein, told to leave the + +room so that could finish the massage. + +if she had any formal massage training and she replied + +got dressed and Epstein turned over onto his . Epstein then + +on previ an• went into t ower area. go •resse + +met with provided in the kitchen area. in came into the kitciiiiii + +for providi + +\$200.00 for b g and paid \$200.00 to + +massage. was told to leave ephone + +number with, his assistant for future contact provided her cellular telephone number for future contact. was asked if she was recently contacted about this investigation by anyone from + +the Epstein organization. She repli work. She stair was called by + +is + +for her to to work + +for Epstein. state t e term used by to provide the massage in underwear. advised she decline , as she was not + +comfortable in providing that type of work. The interview was + +concluded and the videotape was placed into evidence. + +Investigation Continues.. + +e was called but it was for + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 11/10/05 + +Entered By.: . 11/10/05 + +On November 7, 2005, I made telephone contact with o + +advised she would be able to et with me at her home. Det. + +veled to her home in Be ade contact with + +Wit During a swot em stated she met Jeffrey Epstein through woul approach females who wished to work state she was asked to work for him but declined. explained that work means give massages. She was asked y formal training in p g massages to which she said no. said she accompanied and other females + +Time: 9:27:55 Incident Report + +Program: CMS301L + +Case No 1-05-000368 inued) + +who were taken to Epstein s house to provide massages. + +• + +further stated she had been to tiiiiiise app o es in + +r year \$hp accompanied with + +, the 14-year-old victim, and Each time the girls were taken over they were previously told they would have to provide a massage, . It was also told that + +should Epstein require them to do anything extra were not table just to tell him and he would stop. stated received \$200.00 for each girl she brought over to massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, she replied, the victim, as she stat as fifteen years old at the most; she looked really young. further stated e e + +she went to the house, she sat in thekitchen and waited with + +• + +until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked ' ere + +was anything that caught her attention within the home. + +stated there were a lot of naked girls in photographs throughout the house. The interview was concluded and the tape was turned into + +evidence. + +Investigation Continues.. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 11/10/05 + +Entered By.: 11/10/05 + +Det. and I attempted contact with + +Beach. I left my business card at her front door. Ms + +returned my call and arranged a meeting with me at the Palm Beach + +epartment for November 8, 2005. At approximately 2:00pm, arrived at the Palm Beach Police Department. She was brought + +into the interview room and the door was closed for privacy'. She was + +told that I appreciated her coming to the police station for + +questioning regarding an on going investigation. She was told that I was investigating a crime involving Jeffrey Epstein and knew, based on + +the investigation, that she had ers with him in the past. During a sworn taped statement, stated she had met Epstein mil + +' timirs ago. She was first introduced to Epstein by + +approached her about working for Epstein and + +providimassage to him for \$200.00. The arrangements were made + +coullisake he day the arra Ne m + +took + +ade + +. + +nements P. + +also attended + +School and was familiar with Epstein. + +recalled she was brought there and en through the + +kitchen d + +brought her upstairs as she obse + +hi,' with an assistant and another + +assistant. + +several photographs of naked females throughout the house. + +stated ' came in the room, wearing only a towel, and laid on the table. stated he picked out the oils he wanted her and + +Date: 7/13/06 Time: 9:27:55 PALM BEACH POLICE DEPARTMENT Incident Report + +Page: 49 Program: CMS301L + +Case No 00368 + +clothing. + +Iiiiiii + +stated she had returned sev + +Each time she returned more things happened. same thing would happen. Epstein would walk we + +(Continued) + +es after that. stated that the + +Additionally she never looked blow + +his waist.. She claimed that Epstein would convince her to remove her + +clothes. + +she provided a massage + +formal training in providing a two females during h 'sits + +illifht a gir School. + +and + +brought. Additionally, wa very beginning. The interview wa + +into evidence. + +Investigation continues... + +. Every time ed she has no brought + +ges. from + +200.00 for eac girl s e + +s given \$200.00 for taking her in the s concluded and the tape was placed + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 11/13/0S + +Entered By.: . 11/14/05 + +MMIIMII II e po ice station On November 8, 2005, I made tel e contact with IIM, W/F, + +at her residence. responded to t + +for an interview reference an ongoing investigation. At approximately 2:30 pm, she arrived at the Palm Beach Police Station and was brought into the interview room for the interview. The door was closed for privacy and she was told that I apprecisgaher cooperation in this case. During a sworn taped statement, I'll§ stated she had met + +Jeffrey Epstein approxi iiii yeiiligo. She was approached by a subject known to her as . had her if she wanted to make money provi g ein. had heard that several girls from Schoo were doi is + +making money. She agr d was taken to the house by + +had introduced her to and Epstein and brought her upstairs to a master bedroom and Master bathroom wh ia massage table was prepared and the proper •' wer- en out. left the room and waited downstairs for stated Epstein entered the room wearing a + +once that occurr the massage was over. S e e t the whole + +situation was weird but she ad d she was paid \$200.00 for pilling the massage. She also stated received \$200.00 for bring to + +Epstein. + +• S + +Date: 7/13/06 PALM BEACH POLICE DEPARTMENT Page: 50 Time: 9:27:55 Incident Report Program: CMS301L + +Case No. . . . + +ne occasion, + +d) + +received \$350.00 for her massagem..Lasked her + +if she had any formal training in providing massages, stated she + +did not. + +cont • to state on one oth- casion, Epstein introduced his + +tant, , into the mas + +wit + +ed the last time she spoke with anyone at the Mc was during the weekend of October 2 or 3, 2005. stated + +she ha ple + +and + +Epstein house. She provided the + +names o (unknown last nAmm.) Tt c bould + +noted, had been previously identified as L and had been previously interviewed. The interview was concluded and the + +videotape was placed into evidence via the locker system. + +On November 9, 2005, Sgt and I traveled to + +Florida in hopes to interview , the + +former houseman of Epstein's home. As no one was home, a busi n\_ar\_d was eft for him to return my call. to + +in Miami in hopes to interview , a former + +ouse man of Epstein. We did not locate them at home. I left a + +business card for him to return my call. + +w traveled to Lynn University Deallietudents, Mr. it We requested to speak with . was re + +interviewed, as she still was i session of thiliiiral car that Epstein had acquired for her. stated that, Epstein's assistant, had called her on her cellu lar telephone and informed her that rental was extended for her. stated she had paid an\_ additional \$625.00 for her to keep the rental an extra month. + +was asked if she had any additiiiiii contact with either Epstein or anyone from his organization. stated she did not, other than the telephone informing her that she could keep the car for an extra month. did not provide any additional information. + +On November 10, 2005, at approximately 9:47 am, d + +telephoned reference my business card found on his door. + +ilk + +Case No • 1-05-000368 (Continued) the previous houseman left. stated that it was his + +responsibility to keep the identity of the masseuses private. Mr. + +ad a massage in the morning and one in the afternoon. Mr. stated he would rather speak about this in private. He + +e would come to the police station to speak with me. + +stated he would return my call on Monday, November 14, 2005. + +I then made telephone contact with . He advised he found my card on his door an d to know what I needed to speak with him about. I explained to that I wilamijaducting an investigation on his former employer, Mr. Epstein. I'll'. stated he would return my + +call shortly as he was in the middle of a project at his ho received a telephone call from Attorn ld Morrell from + +Mr. Morrell stated he represented Mr. and did not want me speaking with his client. I then made telephone contact with the State Attorney s Office and confirmed that subpoenas would be issued + +to the former employees to assist in the investigation. + +I then made telephone contact with Attorney Guy Fronstin, attorney for Mr. Epstein. I explained to Mr. Fronstin that I would like to speak + +with Mr. Epstein. He stated Mr. Epstein is not in residence in + +Florida at this time and would check with him to ascertain if he could be here by Wednesday November 16, 2005 for an interview. Mr. Fronstin stated he would return my call should Mr. Epstein decide to come in to + +the police station for an interview. + +Investigation continues. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 11/15/05 + +Entered By.: 11/16/05 + +and I tr + +and spoke with She was + +o o e ongoing investigation involving Epstein. advised she had gone to the house on several occasions. During a sworn taped + +statement, she advised she start ' g to the house approxi one ye nd was brought by (Unknown last name). + +stated ought her into the and she was introduced to a + +master bedroom bathroom. + +. , + +stated she met Jeffrey in the + +girl name Once she brought her upstairs into a + +bathroom. He lay on the table and picked the massage oils. She + +Epstein removed himself from the massage table and paid her \$300.00 + +for the massage. + +st + +six times. + +notified by , Epstei ' 'stant, that Epstein was in town and would like her to work. stated she returned to the house and was again led upstairs by . She provided the massage, clothed. + +had only been at the house approximately five or said each time she went to the house she was + +PALM BEACH POLICE DEPARTMENT Incident Report + +Page: 52 Program: CMS301L + +Case . : 1-05-000368 + +advised it wasn't really weird until later on. + +as e if she ever removed her clothing to provide a massa + +wanted hen t + +stated she was notified by + +e to work. She + +for her services. + +ued) + +She was paid \$300.00 + +stated lilt last time she went to provide , she + +was notified by to come to the house and work. stated she was now dating her current boyfriend and did not feel comfortable going. She recalled it was approximately January 2005. She said she went, already thinking that this would be the last time. She went upstairs and went into the master bathroom. She met with Epstein, who was ' only a towel as he entered the room to lie on the table. stated Epstein caught her looking at the clo + +s + +several occasions. Epstein asked her if she was in a + +her boyfriend was in the car waiting for her. further + +stated that Epstein got upset, as she wasn't enjoying the massage. told him that she didn't want to continue and she would not be Epstein told her to leave as she was ruining his massage. I + +asked her if she had any contact with Epstein's or she + +stated she received \$200.00 from West--• in Beach and + +Okeechobee Blvd as a Christmas gift. iced s e ad no + +formal training in provide any massages. also stated she was + +sixteen years old when she first went to Epstein's house. + +At ' tely 4:22 pm, I made telephone contact with at . She agreed to meet with me at a public place. + +suggested she come to the police station for an interview. i did not want to meet at the police station. I recommended we meet at the Palm Beach Gardens Mall in the food court area. She agreed and an appointment was made for November 15, 2005 at 5:00 pm at the food + +court. + +Investigations Continue. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*.\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 11/16/05 + +Entered By.: 11/17/05 + +10/20/2005, I assisted executing a search warrant at + +Way in the Town of Palm Beaciallifich County Florida under + +Case No • 1-05-000368 + +(Continued) + +Detective and I searched the pantry room that is west + +next to the kitchen. This room had all white cabinets with a dark grey and black counter top. We did not find anything in this room. + +We searched the yellow and blue room that is west next to the + +pantry room. This room had a very large statue of man with a bow. Taken into evidence from this room were nine photographs in frames of + +various women. + +We searched the main entrance foyer that is to the north of the + +yellow and blue room. This room contained two bamboo chairs and + +ottomans with cushions. It also contained a round table with numerous + +books. + +We searched another blue room that is west of the foyer. This room had a stereo system and book shelves that were from the floor to + +the ceiling. Taken into evidence from this room were eight + +photographs in frames of various women and/or Epstein, the owner of + +the residence. + +We searched the room to the west of the blue room that has sliding glass doors that lead out to the pool. In this room in a + +dresser were two DVD's and two VCR tapes. These items were taken into + +evidence. + +searched a 2004 black Chevy Suburb g Florida tag + +, registered to Jeffrey Epstein DOB , which was located + +co he east side of the driveway facing south. I found a Thrifty + +rental agreement between the passenger Qinnl- and rho iddle The name on the rental agreement was from + +Palm Beach Garden PlnrinA 3410. The phone number on the ntal re agreement was I The rented was a white 2005 Chrysler Sebring bearing Florida tag . The vehicle was rented on 9/25/05 at 17:58 hours and was returned on 9/26/05 at 16:52 + +hours. T ur numbers of the credit card used are . + +Detective found a piece of paper in the middle console that + +sed the cash in here to fill up the tank and was signed by + +ched the 2005 black Cadillac Escala aring Florida + +tag , registered to Jeffrey Epstein dob , which was locate on the west side of the driveway facing south. I did not find + +anything in this vehicle. + +All of the items that were taken into evidence were photographed + +in the place they were located and then turned over to crime scene. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 11/17/05 + +Entered By.: 11/17/05 + +Case No 1-05-000368 + +needed to speak with her p telephoned her father, Mr. + +explained to him I spoke with Mr. + +to s ' h his daughter in reference to an ongoing investigation. Iiiiiiii Mr. advised he had no problem with us speaking with his + +daug ter. + +(Continued) + +n Nnvemher is 2nns nar, and + +r We met with , a + +seventeen-year old juvenile who was • chool this day due to a cold from which she was suffering. was told that I needed to speak with her in reference to an ongoing investigation involving a subject she would know as Jeffrey Epstein. Prior to speaking with her, I explained that because of the fact that she is a minor, I + +> o speaking with her. She , on his cell phone and and I were there to speak with her. + +on the telephone and informed him I needed + +During a sworn taped statement, stated she met Jeffrey Epstein over UP'Ar Ann She was sixteen years of age and was + +approached by who informed her t he could make monies providing a massage to Epstein for \$200.00. ha rmed her that she would have to ptovide this massage topless. de the arrangements with Epste\* his assistants and took to the house. Dorschel stated nd she entered through a glass door that led into a kitchen. took her upstairs, to a master bedroom + +and master bathroom. She recalled the bathroom had a large pink + +couch, sauna and mat h' + +over ont + +wit Epste n in t e providing the massage. received monies for the + +Forty minut and requested + +e for + +to the massage, Epstein turned + +stairs in the kitchen + +. . + +sage. + +got dressed and met + +. She was paid \$200.00 dol ifor stated she was aware that also + +same thing. + +ecoilime she went to the house she was again approached by + +as • e wanted to return to the house to provide + +er massage; a greed and t ements wratiaade by + +for her to return to the house. stated IIIII drove her + +to t e house and knocked on the same glass door that leads to the kitchen area. Tisere allowed entry into the house by one of the staff members. led her upstairs to the master bedroom and + +Case No • 1-05-000368 master bathroom area. + +(Continued) + +left this time to do th + +got dressed and met with who wa in the + +itc en area. She received \$200.00 for the massage. said she' neve ed to the house and had no desire to return to the + +house. was asked if she received any forme + +training. She advised she had 1 training. was asked if Epstein knew her real age. stated he knew as he asked her questions about herself sirlanro no was aware she attended + +and is still attending School. + +The interview was concluded. I suggest inform her parents of what occurred at the Epstein house. stated she would tell her father as he was unaware this had occurred. I left my business card for any questions they may have. We left the area and returned + +to the police station. The tape was placed into evidence. + +Investigation Continues. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 11/17/05 + +Entered By.: . 11/17/05 + +On November 15, 2005, Officer and I r AAnol F^ \*he Palm Beach + +Gardens Mall food court s to meet with At + +approxi 5:10 p.m., arrived and met with us at the food court. provided a sworn taped statement in which she stated she had een at the Epstein house over fifty times. Sh going to Epstein's house when she turned eighteen years was asked if she knew of the on-going investigation. stated she was aware there was an investigation as she had been told by other girls that were interviewed. Additionally, she has had several + +telephone conversations with Epstein's assistants as to what had been + +going on during the investigation. + +I asked how she was introduced to Epstein. stated she did not want to disclose who brought her to the house but she would + +this was done at Epstein's direction. + +When I asked her if there had + +been any vaginal intarnmuras with Rnetain ah, ctatad ahc Aid not have + +stated not every time she went involved sexual favors. + +Sometimes she would just talk with him and get paid. I asked much she was paid each time she went to Epstein s residence. + +stated she got paid \$300.00 every time she went to the told to bring other girls to him to provide massages. stating that she does what she doeiiiiii did not want to anyone else to do what she does. stated she had + +any formal training in providing massages. + +I showed position a photo line up in which + +Case No • 1-05-000368 (Continued) + +respon other questions. When I asked her what happened at the + +house, stated everything happened. It all beg n with the + +appened. + +All + +.th him. + +She was declined + +introduce + +never received + +was placed in + +'ately + +She signed the photo line-up un•er + +s photo as the person she identified. We then left the + +mall and returned to the police station. The photo line up and tape + +were placed in to evidence. + +Investigation Continues... + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 11/29/05 + +Entered By.: . 12/01/05 + +On November 17, 2005, I received a phone message from Atty. Guy + +Fronstin who advised to call his cellular phone reference his client Jeffrey Epstein. I telephoned his cell phone and t a message for him to return my call. I did not receive a call on Thursday, November 17, 2005. On Friday, November 18 2005, I retrieved another voice mail from my work phone from Mr. Fronstin advising he would not produce his client Jeff Epstein for any statement. Fronstin stated he had spoken with ASA Belohlavisnd expressed Mr. Epstein has a passion for massages. I called ASA Belohlavek and confirmed that + +Case No - 1-05-000368 (Continued) + +massages. + +He was asked if he remembered any names of the girls that massaged Epstein. He tried t er and was unable to provide any exact names of any girls. was about any contact with anyone from the Epstein organization. said he did speak with Mr. + +Epstein shoiiiilifter my initial contact with him to find out what was going on. also stated that approximately on November 11, 2005, he was contacted by a private investigator from the Law Office of Roy Black. The investigator had called hi et with him to ascertain what he was going to tell the police. stated they met at the + +Carrabba s Restaurant in Boynton Beach and ed the same + +questions I was asking him. I informed Mr. and Mr. Morrell that as this is an ongoing investigation and anything we discuss should be confidential. They both acknowledged the fact that the information would be kept confidential. It should be noted that a + +court reporter was present during the interviews and would be + +providing a copy of the statements to me when they become available + +On November 21, 2005, I received a voice mail from Mr. Fronstin who + +advised he would not be making Mr. Epstein available for any + +statements. He did have some words that he wanted to relay on behalf of Mr. Epstein. I telephoned his office and left a message for him to + +return my call. + +On November 29, 2005, I received a call back from Mr. Fronstin who left a voice mail after hours on November 28, 2005, advising he would return my call during normal business hours to speak with me reference + +the case on November 29, 2005. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 11/29/05 + +Entered By.: 12/01/05 + +On November 29, 2005, at approximately 2:30 p.m. I received a telephone call on the department issued cell phone. Mr. Fronstin stated he was calling to relay information that Mr. Epstein wished he could relay. Mr. Fronstin stated that he would not allow Mr. Epstein to speak with me at this time. He further stated that Mr. Epstein is very passionate about massages. He continued that Mr. Epstein had allegedly donated over \$100,000 to the Ballet of Florida for massages. The massages are therapeutic and spiritually sound for him that is why he has had many massages. Mr. Fronstin stated he appreciated the + +way the investigation has not been leaked out into the media. I explained to Mr. Fronstin that it is as important to protect the innocent if the allegations are not substantiated. Mr. Fronstin was told of the allegations that the private investigators assigned to the + +case have been portraying themselves as police officers. + +Additionally, I explained that my cell phone had been called by the private investigators. Mr. Fronstin advised he was not aware of that and advised they were under the direction of Attorney Roy Black in + +Case No • 1-05-000368 (Continued) Miami. Mr Fronstin further stated Epstein had originally called Mr. Dershorwitz in Boston, who recommended Roy Black in Miami, who asked Mr. Fronstin to assist. I informed him that if and when any charges would be presented I would notify him. The call was then terminated. + +Investigation continues. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*NARRA \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* + +NA Reported By: + +• + +12/15/05 + +Entered By.: . 12/16/05 + +A review of the telephone message books, which were obtained during the search warrant, was conducted in which various messages from different dates were made to Jeffrey Epstein. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages was time of the day that they called for confirmation of "work." Other names and telephone numbers + +were located in which the body of the messages were, "I have gi him" or "I have 2 girls for him." These messages were taken by for Jeffrey Epstein. Based on the context of the body of the messages, I requested subpoenas for subscriber information on the + +telephone numbers and the time frame involved. Copies of the messages + +were made for evidentiary purposes. + +I obtained Royal Palm School yearbooks for 2005, 2004 and 2003. I first reviewed the 2005 yearbook and loca na mnnt of rho + +girls I had spoken with. Additionally, I located + +Based on the corrected name spelling, I was able to 1- •er to her residence in Lnwahatrhac3 ()T.) TIPOAMIlgir 8, 2005, De I responded to at her home. She advised she is attending an• is participating in the early release program so s e can ma ntain her part time job. As she is still a minor, I left my business card to have her mother return my call to request an interview with her + +daughter. We then left the area. + +I also had previo telephone numbe + +ed the telephone number for " " and A subpoena had been issued for the + +lephone numbe ered to + +query of revealed + +Det. and I attempted and ' ently residing at + +results. I left my business card on call. We then responded to I also attempted contact with + +Mr. with negative results. I left my business card for him to + +It + +Case No 1-05-000368 (Continued) + +n nPOPMhAr a 7005, I received a telephone call from + +'s mother, who i e aware of the on going + +investigation in Palm Beach. advised she was told of + +everything that occurred at Epstein's house involving Epstein and his staff. She advised she would allow me to question her daug out + +what occurred an ooperate with the investigation. + +provided me with cellular telephone number to schedule an appointment for an official interview. I telephoned her cellular telephone and made a tentative appointment for Monday,. December 12, + +2005. + +WM received a telephone call from , father of + +, who stated he found the business card on his door. I expla..that I was conducting an investigation and needed to speak + +with as she m information that could assist in the + +investigation. Mr. stated that his daughter no longer resides with him and has her own trailer in another trailer park. He advised + +he would tell her to call me. + +On December 12, 2005, due tn a onnflirt with schedules, arrangements were made to meet with o• day, December 13, 2005 at 5:00 pm. On December and I traveled to Loxahatchee et with During a sworn taped + +statement, stated that when she was sixteen years nl e was + +taken to Epstein's house to provide a massage + +stated it was before Christmas last year when roached her and asked if she needed to make money for Chris stated + +she did and agreed to de a massage for money. made + +arrangement ke I'll'. to the house and drove to the house to "work." stated she could not remember the street name but would be ab e to drive to the street. They drove to the last house on the street and pulled in the last house on left side. They walked up the driveway and entered through a side gate which led to a kitchen door...), knocked on the door and were encountered by an employee who described as a "Spanish looking lady." They informed her that they were expecte were then encountered by a white female with long blond hair. was unable to remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom throom. The massage table was already set up in the bathroom. described the bathroom as a large spacious bathroo steam room and shower beside it with a sink to the right. was introduced to Jeff who was on the phone when she enteril.... eff was wearing a white towel and l is stomach so that may massage his feet and calves. started the + +massage with the massage oil Jeff chose and r e is feet calves ......I got off the phone alagmrequested she massage his well. began rubbirile III. and got to the small of his During the rubbing of his Jeff asked her to get comfortable. + +411 - PALM BEACH POLICE DEPARTMEN, + +Case ed) + +, Jeff asked her quetinnc Ahni + +remembered telling him she attendedl + +Sc ool. Jeff asked her if she was sexually active. Before + +• answer, he also asked what sexual positions does she enjoy. + +Jeff told her there was \$200.00 dollars for her on the + +ser res within the master bathroom. Jeff also her that there was an additional \$100.00 that was to be given to for bringing her there to massage him. Jeff told her to leave her telephone number with his assistant as he wanted to see her again. Jeff stated his + +assistant would contact her to work again soon. + +Mid her if she ever rec y formal massage training to which stated she did not. stated it was the only time she + +ever went to work for Jeff and knew happened to her was wrong. + +"stated she no longer speaks to because she was upset that took her there. She further stated that she had never been contacted for any additional work. The interview was terminated and + +we left the area. + +Investigation Continues... + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A • \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 12/18/05 + +Entered By.: 12/19/05 + +Case No 1-05-000368 (Continued) + +On 102005 at approx 0930hrs I assisted with the execution of a + +search warrant at 358 El Brillo Ave, Palm Beach. + +Initially I was assigned to enter the residence and conduct a sweep e premises for safety purposes. I then accompanied CSEU tech while she photographed the exterior of the house. Once this was ciiiiiie I was assigned to search certain areas of the house + +with Det. as part of the search warrant. + +We began in the garage, searching three Mercedes Benz vehicles, a + +Harley Davidson motorcycle and adjacent closets in the garage. + +Nothing of evidentiary value was located. + +we then searched two closets off the kitchen area on the east + +side. These can best be described as pantry or storage closets. + +Nothing of evidentiary value was obtained. + +A small office with adjoining bath was then searched. In the bath + +area I located a phone message book with recent messages. This item was seized as evidence. Please note this bath and shower area are not used as designed but are storage areas containing a variety of items to include a gun safe in the shower and assorted household items. + +We then searched a bath area and closet at the base of the main + +stairs in the foyer. Inside the closet two massage tables were + +located as well as partial nude female photographs. These items were later seized as evidence. Nothing of evidentiary value was noted in + +the bathroom. + +We then searched two bedrooms upstairs on the east side of the + +residence. Located in the bath room of the south bedroom was penis shaped soap. Located in the bedroom of the northern bedroom was penis and vagina shaped soap as well as an adult sex toy. These items were + +seized As evidence. + +We then searched the pool cabana located in the south west corner + +of the• property. Several photographs of nude females were seized as. + +evidence. + +w ssigne by with a person I believe was iii Mr. was in the residence at the + +beginning o t i e search warrant. He was present during the warrant service and subsequent search. I stood by with him until the search was completed and I departed the residence. I had no conversation + +with him regarding the reason for our presence. + +Regarding seized evidence, all items were photographed in place + +and then collected by CSEU personnel. + +This concludes my involvement in this case. + +Case No • 1-05-000368 (Continued) + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 12/21/05 + +Entered By.: 12/21/05 + +On Thursday, October 20, 2005 at approximately 0936 hours, I assisted in the execution of a search warrant located at 358 El Brillo Way, Palm Beach, Florid ' Jeffrey Epstein. I was instructed by Case Agent Det. , to secure all computer and media + +related material from the residence. + +Upon my arrival I was directed by Det. to a room designated as the Kitchen Staff Office. I observed a, Silver in color, CPU with the left side cover removed, exposing the CPU s hardware sitting on floor next to a glass type desk. The CPU had no discernable identifiers or features indicating a make or model. This CPU was powered off with the power cord not plugged in. The keyboard and mouse were atop the CPU. It should be noted that the CPU w t connected to a monitor, + +a l' + +printer, or other media device. On the Panel of the CPU, I observed an A/V card with RCA jacks attar e . This type of hardware would allow audio and video to be downloaded onto the CPU s hard disk. The ends of the RCA jacks were unattached at the time of the search + +and no external camera was located within this room. + +The CPU was located on the right side of a desk that held a flat panel LCD screen. The desk also held another keyboard and mouse, indicative + +of a second computer; however, no other computer was found. It + +appeared as though a second computer had been recently removed as the cables ends from the monitor, keyboard and mouse were in the same + +area. A further search of the room revealed no media storage devices, + +i.e. CD s, Floppy Disks, Zip Disks, etc. This type of media is commonly stored in an area where computers are placed, yet no media + +was found. + +After completing a search of this room, I secured the CPU and turned all items over to the Evidence Custodian for future forensic analysis + +via a property receipt. + +I was then directed by Det. to a room designated as the Garden Room, where I observed a wooden desk facing west. The desk held a flat screen LCD monitor, keyboard, mouse, media card reader and + +printer; however, no CPU was located. All of the cables were removed from an area where a computer had once been. A search of the desk + +area revealed no signs of any media devices. + +Det. directed me to a third location designated as the Cabana room, which is detached from the residence and located just south of the pool. In the South East corner of the room, I observed an office type setting, with an L-shaped desk holding a flat screen LCD monitor, keyboard, mouse and printer; however, no CPU was located. All of the cables were removed from an area where a computer had once been. A search of the desk area revealed no signs of any media devices. + +Date: 7/13/06 PALM BEACH POLICE DEPAR Time: 9:27:55 Incident Report + +Case No • 1-0c-annien + +cellular phone occurred at 1:02 pm. + +Page: Program: 65 + +CMS301L + +(Continued) + +The call durations + +were one minute or less. The t e was within thirteen minutes + +apart. It should be noted that s residence was in close + +proximity to the v is. The next call occurred at 5:50 pm when the victim telephoned s residence. Several calls were fter + +the above mentioned calls both incoming and outgoing + +Further analy ' ed no telephone calls to either cellular telephone or residence were registered prior to February 6, + +2005. + +I also conducted an analysis on the telephone calls from The subscriber information confirmed that the number is + +registers to Paul A Lavery from Hialeah, Florida. The address was + +crossed referenced to the Office of Kiraly and Riley Private + +Investigators. I researched the web page www.rileykiraly.com which also showed various cases in which they assisted. I also located another web site under www.coralspringssparklandrotary.org in which Mr. Riley attended a Miami Rotary meeting and confirmed Atty. Roy + +Black is among his clientele. + +elenhnnp ralla revealed T.A rv\_had telephone contact with + +and either just after I attempted to + +interview them, or just prior. A background was conducted on Lavery which revealed he holds a current Private Investigator License. A criminal arrest record revealed he had been previously arrested for + +possession of cocaine and solicitation of prostitution. + +I also researched the girls using www.myspace.com. This web site is a + +new social networking service that allows members to create unique personal profiles online in order to find and communicate with old and new friends. The site allows one to establish your own myspace.com page and decorate the page 1 ' + +, and + +I received a Cingular Wireless packet which contained a CD which nntained t e results of the subpoena request for verbatim calls on + +An analysis will be conducted in the near future on the + +phone numbers called. + +Investigation Continues. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*NARR A \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 12/27/05 + +Entered By.: 12/29/05 + +Upon doing research on the message b + +warrant T located the identity + +was registered to seventeen years old and is attending the vered in the search " The telephone number + +> is . I + +Incident Report Program: CMS301L + +Case No 1 nq nnriqgp (Continued) responded to Lakes Boulevard, also known as th + +> ll. I located the Simon Youth Foundation. I located inside the foundation and informed her that I was + +investigati against Jeffrey Epstein and knew she had been at the house. started to cry and advised she had put that part of her life behind her. I explained that although she is seventeen + +years old I needed to inform her parents that she would be + +interviewed. She provided her home telephone number. I attempted contact and left voice mail messages at the house to speak with her + +parents. + +De at her residence located at . I attempted to interview her about Jeffrey Epstein. She advised she is so in love with Jeff + +Epstein and would do anything for him. She further explained that she would not speak with us about him either negative or positive. She asked us to leave her property. I informed her that although she did not wish to speak with us, I had sufficient information at this point in the investigation to know she was at Epstein's house and provided girls to Epstein to work. I also explained that prior to rrival + +illresidence I had telephone contact with he + +, who was told she would be interviewed. is currently seventeen years old and as a juvenile, parents notification would be required. We then left the area and returned to the police + +station. + +mi t + +the police station, I left another m sage for + +'s parents. .1 began an Cel one. The telephone number is assrAe to + +the financially responsible party is Jeffrey Epstein o III in New York City, New York. The time frame which was + +subpoenaed was September 2005, through October 2005. There were + +eighty seven pages of calls made either to the cell phone or from the cell phone. The local (561) numbers were analyzed. A spread sheet was prepared and placed into the attachment file of who was called. + +The unknown numbers were researched using FoneFinder.com and subpoenas were requested to determine subscriber information. This was done to + +fy additional victims or witnesses. The analysis revealed that had called the victim/witnesses frequently when Epstein was in + +the Town of Palm Beach to "work." T firms what the girls interviewed had previously stated. would notify them when + +Epstein was in town and their willingness to "work." The CD was placed + +into evidence. + +Investigation Continues. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*NARRA \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 1/03/06 + +Entered By.: 1/03/06 + +Incident Report Program: CMS301L + +Case No • 1-05-000368 (Continued) + +observed a Red Explorer W/F driver le e area, Tan subcompact on roadway and a Red Neon bearing FL tag Then observed 3 W/Fs, approximately 16 to 18 years of age jogging. All 3 Wiles ran into + +the driveway. There were 2 with blond hair and one hair. + +On Sunday, 04/03/05, I continued survei + +in roadway an ck at 358 El Brillo. At + +0719 hours I observed a Tan Honda Civic + +Caddy Escalade. At 0934 hours, I observe a Tan Honda Civic in + +c roadway and a Black Caddy Escalad veway. At 1057 hours I + +observed only the Tan Honda Civic + +• I + +On Tuesday, 04/05/05, I continued sury ce at 358 El Brillo. At 1052 hours, I observed a &gagliiplorer in roadway, a Green Exp earing FL tag IIIIII in roadw Grey Altima bearing FL tag in roadway, White Ford Truck in roadway, Black Mercedes in driveway being washed by a B M and an unknown dark car parked in the garage. At 1059 hours a Blue Chevy Suburban drove to the house of 358 El Brillo and n the driveway. At 1119 hours, I observed the White Fort Truck leave the area and the drive + +was the pool man. + +At 1126 hours, I observed a Grey unknown make/model car park in roadway. W/M got out of the car and walked to a house on the south side of El Brillo. At 1406 hours, I observed a Red Explorer parked on + +roadway and a large white box truck parked behind the surveillance + +suburban. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*NARRA \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 1/03/06 + +Entered By.: . 1/03/06 + +On 03/31/05, at approximately 1500 hours while conducting surveillance at 358 El Brillo, I observed a Black Cadillac Escalade, unknown tag, a + +... + +Chevrolet Suburban, unknown tag, a Black Mercedes 5600 FL tag parked in the east dr' ext to the 3-car garage. There + +was a Tan Honda Civic FL tag parked on the street in front of + +the residence. + +At approximately 1700 hours, I observed the Black Suburban, Black + +Escalade, Black Mercedes and Tan Honda Civic parked in the same place. + +At 1750 hours, there was no change in vehicles. At 1840 hours, I observed the Black Escalade, Black and Black Mercedes along with a Silver Hyundai Accent FL tag parked in the east + +driveway and a Red Ford Explorer FL tag parked on the street in + +front of the residence. + +At 2000 hours, I observed the Black Escalade, Black Suburban parked in the ease driveway and the Red Explorer and Tan Civic parked on the + +street. + +Case No • 1-05-000368 (Continued) + +purchase several gif vide them as tips to the girls. I asked what kind of gifts. stated he purchased IPODS, jewelry, + +anything the girls wou want. + +stated the amount of girls + +approximately fift seemed to know at + +When asked to identi y these girls, + +the moment but knew he wrote their names down on a journal he kept + +during his employ with Mr. Epstein. He kept a journal in the event he + +needed to explain either to Mr. Epstein or his assistants what was done at the house or who visited the house as he stated he was + +in-charge of Mr. Epstein's personal security while in Palm Beach. I informed him I would need to view this journal to which he stated he would research the book and contact me to provide the book. The interview was concluded and left the area. I returned back to the police station where the micro cassett ed into evidence. At approximately. 7:20 pm, I was notified located the journal + +and would call me on January 5, 2005 to provide the journal. + +Investigation Continuesaa + +came to the house was knew each other and all + +> 1 who Mr. Epstein was. stated he could not at + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 1/09/06 + +Entered By.: . 1/10/06 + +On January 5, 2006, I attempted to meet with to recover the folder or journal in which he kept the notes that were given to him during his employ with Mr. Jeffrey Epstein. He kept this folder to justify what he did during his employ should the need arise + +to justify what occurred with the monies he had to keep or any + +questions as to the petty cash he withdrew from the household account fro . At approximately 10:00 pm, I attempted contact with Mr. and discovered he was assisting his wife ace of + +employment and would not be able to meet with me. Mr. + +stated he would meet with me on January 6, 2006, in Broward County, in + +the morning hours. + +On January 6, approximately 9:00 am, I received a telephone call from Mr. who advised he had the file in hand and would be traveling n with me in Broward County. At 10:50 am, I met with at the parking lot of Bank of America in Boca R to Road and Military Trail (known as the Polo Center). produced a green folder which contained documents, + +a note wit Mr. Ep tlinnaru wir4 direction t ' er + +bucket of roses to I School after (III) high school drama °lie. Also in that same note was direction to rent a car for ( ) and direction to extend the rental + +contract. I returned to the Palm Beach Police Station and placed the + +folder into evidence. + +I received a fax from Verizon from the subpoena request sent on + +Date: 7/13/06 + +• • + +Time: 9:27:55 + +PALM BEACH POLICE DEPARTMENT Incident Report + +Page: 73 Program: CMS301L + +Case No • 1-05-000368 + +01-04-06, for telephone number + +registered to Dr Perry Bard, from West chiropractor and has an office located Palm Beach. The cellular number is Dr + +number. + +Palm Ram oh flr + +(Continued) + +. The phone number is + +RArd is a + +in West + +Bard's personal cellular + +n ,Tannary 9 900 , Det.' and I tray + +in an attempt to locate , who had + +been previously seen on the property and identified through her Florida Drivers License and Florida license Plate. A business card was left for her to return my W traveled o the Simon Youth Foundation and located agreed to speak with us and in a private room within the school provided us a + +taped statement. + +During the statement, advised that when she was fifteen or + +, + +sixteen yeami he en to Jeffrey Epstein's house by her associate stated this occurred late May 2004 or early June 2004. She was told she could model lingerie for money for a wealthy Palm Beacher. She remembered they traveled by yellow cab from their residence in West Palm Beach to Epstein's house. She remembered encountering Epstein at the front door during the evening + +hours. + +He introduced himself and brought them into the kitchen so that the + +ould prepare somethi em to eat. After having a meal, and Epstein brought upstairs to a master bedroom which + +had a large bathroom. She observed a large style shower, sauna and there was a large massage bed also in the bathroom. Epstein d a + +room within the bathroom and came out wearing o wel. + +said they would pAggiga a massage on his feet. asked why they are doing this. IIIIII told her this was part of tine and told + +her to rub his d calves. Epstein had told to get + +comfortable. ued rubbing Epstein's eet. At + +Epstein's dir + +Epstein had to • er t at + +there was two hundred dollars for her on the dresser. He told her that she could not tell what happened at the house or bad + +things could happen. stated she went to Epstein's house three + +Case No • 1-05-00036 (Continued) or four times total. was very scared and felt very nervous. + +She knew because of Epstein's money he was powerful. After the + +massage, Epstein ordered his houseman at the time to drive the girls home. The employee was to drop off the girls at their house and watch + +them go inside their house. + +could not seer who the houseman was. She stated Epstein + +and his assistant would call her at her father's house to + +arrange for her to come and "work." She advised • e she returned + +to the house, Epstein wo + +She was paid \$200. + +went. Each time she went she was reminded not to happened at the house and that she would be co, + +began to purposely miss the calls when call her. She once brought a friend, + +work for Epstein. She was paid \$200.00 for bringing + +stated she no longer retuned to work for Epstein. Sheer state + +e wanted to notify the police of what happened at the house. stated she was scared of what could have happened to her or + +her family if she notified authorities. + +On January 10, 2006, I received the results from t + +BellSouth t o Mr. number is assigned to Mr. + +Beach Gardens. I also received t confirmed the money order sent to + +Mnal-4,iii in Maw York City. The "wire" was sent + +in New York City on December 23, 2004 at 12:05 pm. + +nt of \$222.00 was charged to PrInewi 'S credit card so that could receive \$200.00 in Beach. The twenty-two + +dollars was for processing and local fees to send ey via + +Western Union. A copy of the check presented to + +attached to the receipt of the wire. This confirmed w at advised she received as ,a Christmas bonus from Epstein. + +00 eac time s e speak of what ed again. She or Epstein would + +name. to + +Investigation continues. + +from + +The + +at er in Palm + +estern Union which from Jeffrey y Jeffrey Epstein of + +Sig + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A \*\*\*\*\*\*\*\* \*\*\*\*\*\*\*\*\*\*,r\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* \*\*\*\*\* NA Reported By: 1/10/06 + +Entered By.: 1/10/06 + +and reviewed the Cingular eaLs\_Enrauhscribe + +I received + +a + +to i. + +Epstein of ty. houseman/house mans Way in The second number, is assigned to + +Wireless results from the + +for telephone numbers The first number, + +f Jeffrey + +is the current + +3480. of + +Case n • 1-AR-Anng6A + +revealed she is a licensed Massag conditional/active license number + +. Research conducted on + +iinued) + +a Florida + +had been previously Requests for copies + +of the reports involving the arrests were reques Palm + +Beach County Sheriff's Office. assigned to Thomas Rofrano of + +Research on Mr. Rofrano, revealed that he is a F or ca C iropractic + +Physician. + +Vehicles that were previously documented on the + +surveillance was being conducted were res Chevrolet Camaro, bearing Florida license + +property in which a young white female was seen + +nducted which revea + +La o + +property while + +I determined a tan + +, was seen on the entering the Epstein at the vehicle is + +h ers, + +esi ng with her father in Lake + +Worth. Research on revealed she was recently involved in a traffic stop in Lake Clarke Shores in May 19, 2005. A request to + +discover any information from the stop was requested. + +I spoke with ASA Daliah Weiss who informed me that + +will be available for an interview tomorrow at the State Attorney's Office in West Palm Beach at 1:30 pm. I informed her that I would be + +at her office for the interview. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* N A R R A \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 1/23/06 + +Entered By.: • 1/23/06 + +was + +licensed massage therapist hw o had previous y property when physical surveillance was done. on going investigation and I felt she may hay to the case. During a sworn taped statement, + +Epstein three r2InrC nan when mhnline Maxwell approac ed her while she was attending I College to work around Epstein's house. Maxwell had told her that they neede irls to work at the house to answer phones and run errands. accepted the job an working at Epstein's house on El Bri Palm Beach. + +it was a part time job during the time she went to + +College. She continued going to Epstein's ho + +would be notified when Epstein would travel to Palm B, + +advised she would be notified by Maxwell, Epstei assistant, when he would travel to Palm Beach. + +began providing massages + +at + +identified as a + +on Epstein's was told of the ation pertaining stated she met + +Conti and + +what occurred during the + +stated she + +to Epstein before she became a massage + +iving massages not o Epstein but to his ass was asked about + +massages. , + +state as she was twenty + +Case No + +three years between two any trouble + +I asked if Epstein. Epstein took She received + +1-05-000368 (Continued) + +old when she met Epstein, anything that happened was + +consenting adults. I explained to her that she.was not in + +however a of this investig + +ever received any gifts, or any gratuities from advised aside from b inn raid well, she advised care of her tuition from College. a rental car for a week w en her scooter broke down. + +Additionally she received other gifts from Epstein. Epstein also recommended her to another client who resides at Breakers Row in Palm Beach. The client she was referred to was "Glenn" unknown last name, + +and his wife, who she provided a massages to. The statement was + +concluded and placed into evidence upon our return to the Palm Beach + +Police Department. + +was also previously seen on the property when there wallitilical While at the police station, I researched Florida tag which + +being done at the properly. The vehicle • egistered of Lake Worth, Florida. c r. and the + +vehicle revealed that his- daughter, , ha een driving + +the vehicle and was cited for unlawful speed n Lake Clark Sho, + +ehicle is a tan, hpvrnier Camaro, 2-do + +, resides at space page called + +illirspace.com In her web page, shows various photos of photographed at a beach. An interview is forthcoming. + +th, + +A review of the video disks which was extracted at the Palm Beach County Sheriff's Office Computer Crime Unit revealed that only one + +hidden camera was functional at the time. Several image workyagat, hig nffire were seen. Additional footage of + +and I'll. I was seen. There was other footage o females seen. The identity of the females is unknown. at this time, until such + +time as I meet with certain females to show the video footage to + +that + +confide ' ct, Shin the video. At this time it appears + +and are seen sitting with Epstein beside + +his desk in the evening hours. Due to poor lighting, a direct + +confirmation cannot be made at this time. + +to + +Inv. Continues. + +Case No • 1-05-000368 (Continued) + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*NARRA \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*t\*\*\*\*\*\* NA Reported By: 1/30/06 + +Entered By.: 1/30/06 + +n Jnnnary 9S 9 M16, Det + +and met with + +year, when she was seventeen + +through her former roo + +Epstein at the time. and when they modeled. explained + +made arrangements to arrived and met Epstein andmiiilir Beach Mall together and went shopping. stated last + +ge, met Jeffrey Epstein + +was allegedly dating + +once cohabitated together called her on her telephone + +dvised her that she was in Palm Beach and requested to se + +at Ep 's house. + +went to + +advised that + +m and + +she had received money from Epstein to go to the mall. They visited Victoria's Secret and purciiiii undergarments from the store utilizing given by Epstein. advised she purchased one item and purchase various items. The money used to purchase the items + +was the money given by Epstein. + +continued shopping and having + +and he has been paying all of her bills. stated explained how she and Epstein + +they met in New York and had been dating ever + +a day together. + +been datiiimiacliller claimed advised + +since. ThrrmiTter + +returned to Epstein' ome and encountered Epstein. He had a brief + +out her modeling career. He knew of her + +modeling career from . He requested to see her modeling + +olio and explained that he coul p her with modeling jobs. had her book with her to show IIIII and showed the book to + +• . He commented negatively about her photographs and portfolio. + +felt uncomfortable with the comments made as she had been working with other professional modeling companies who had offered her + +work from her photographaommapstein requested to see what was + +purchased at the mall. IIIII took out the undergarments which were purchased. She immediately showed Eiiiiin different s urchased. + +Epstein then requested to view what purchased. was + +reluctant to show the outfit however since it was Epstein's money that purchased the il...she pulled list of the bag. Epstein asked her to try it on: looked at who told her "yeah, try it on." Feeling compelled to try the undergarment outfit on; she went to + +another room and put on the bra and panty set. She walked out to the living room where they were sitting, and modeled the suit. She then ack into the other room and chan ack into her clothes. returned into the room an d," she would be going home. scheduledanother day for to return for massages with her. + +stated within t ame week, she returned to meet with and have a massage. had told her that she would be unable to with her as she would be going on a bike ride with Epstein. + +explained she could stay at the house and take advantage of the + +massage. + +conversation with + +Date: 7/13/06 IMBEACH POLICE DEPARTMENT Page: 78 Time: 9:27:55 Incident Report Program: CMS301L + +Case Mn . . : 1-05-000368 + +stated she met with an unknown m + +remembered that the door to t + +but not locked. As the therapist was working opened by Epstein and entered into the room. + +conceal herself as Epst + +session. E eventually prelim o + +her + +the house. + +(Continued) the + +room was closed , the door was + +was trying to + +s talking to her ab hischiropractic her . + +Epstein as e applied + +shoulder and her waist. stated Epstein "popped" + +emoved her sel + +l + +f the to le, got dressed and left + +further state had attempted to call her + +several occasions tomjamite her o Epstein's house to which + +'m busy." IIIII advised she has not had contact with ei er Jeffrey Epstein. It should be noted that her mother, was present during the interview. The interview was + +concluded and we thanked them her for their time. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*NARRA \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 1/31/06 + +Entered By.: • 1/31/06 + +On 7=nnnrxt 97 00iiiii iade telephone contact with I , at . is a licensed massa aplst who had + +frequented the home of Jeffrey Epstein. ms. has been unable to meet with me in Palm Beach County, and because s e lives and works in Por cie, a telephone interview was conducted. I explained to Ms. that there was an on going investigation involving Jeffrey + +Epstein. + +stated she knows Epstein and has been ed by him for approximately three years. Epstein has paid erform Swedish Massages (Deep Tissue) on him and other guests. explained that approximately three year ago she met Ghislaine Maxwe and Jeffrey Epstein through a mut end. Epstein and Maxwell were looking for a massage therapist. stated si t time, she is notified when Epstein is coming to Palm Beach. d she comes to his house and provides the massage or massages explained she has also massaged his guests and assistants. continued that she is + +paid \$100.00 and hour for the massage. + +I asked if anything oc during the massage that would have made her feel uncomfortable. stated she only provided massages and that was it. She never was approached for anything else. I asked if Epstein ever asked her to rub his chest she statue would not rub his chest as that is not part of her massage. explained that she was not Epstein's type. The girls she wou Epstein's house were very thin, beautiful and without tattoos. explained she has several tattoos that are visible. Maxwell andEpstein have + +commented negatively about her tattoos previously when she has + +Date: 7/13/06 AL BEACH POLICE DEPARTMENT!' Page: 79 Time: 9:27:55 Incident Report Program: CMS301L + +Case No • 1-05-000368 (Continued) + +stated she only provided massages for Epstein an + +and + +' + +associates nothing happened during those massages. • stated as she does Swedish style massages, the patient is usual a y sore after the massages. I thanked her for her assistance and the interview was + +concluded at this time. + +I recei.vflA = fare-I-mile from T-Mobile number which is assign + +Epstein, who resides in Lake Wo + +dialed on several occasions by . A background on indicated he has a va ' pilot license First Class for the + +Southern FAA Region, has another historical FAA license for + +Airline Transport Pilot. + +Cell + +to ep + +telephone , pilot for Mr. + +one number was + +Investigation Continues. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*NARRA \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 2/14/06 + +Entered By.: . 2/16/06 + +uary 3, 2006, I had made arrangements to meet with + +on. At approximately arrived at the police + +she stated she met + +1:00pm, station. + +Epstein when she turned eighteen years + +Epstein's house to provid May of 2005. She advised + +to provide a massage for \$200.00. Epstein's house to provide a massage. the house on man occasions durin• the + +t the Palm Beac and her friend, + +During an interview with + +if she ha + +that she did not. + +to the house to "work." + +house. She advis + +house to "w + +her friend was still w r lobby of the police station. I thanked for + +cooperation and escorted her to the lobby. + +old and was brought to + +She advised this occurred on + +informed her if she wanted eed and was brought to stated she to + +massa•e sessions. + +. I as e + +al massage training to which she replied + +then asked if she ever brought anyone stated she brought two people to the + +eceived money for bringing people + +tated she brought a gir and + +in t e er ime and her + +Case No • 1-05-000368 (Continued) brought her to the interview room and explained to her that I was + +conducting an investigation on Jeffrey Epstein + +information ni2.1-r=lnlna t-o the investigat herself as I and resides in + +advised approximately ayear provide a massage for money. + +b + +felt it was aquick way + +to the house by + +WWI + +assistant. + +It she may have identified , Florida. She + +litewas broug t to Epstein's house to + +stated she ded to make money and + +some money. stated she was + +and was introduced to Epstein and his + +vi + +She was pai er money an le the + +area. advised it occurred one time and she n returned to + +Epstein's house. The interview was concluded and was escorted to + +the lobby. + +• + +Ilocated a telephone number for ted to contact his several occasions. I cal eand spoke with Ms. who advised she would speak wit me in eerfield Beach where she resides. Due to a scheduling conflict, we were unable to + +meet. I informed her I would contact her to schedule another appointment to speak with her about this investigation. Ihave attempted to meet with her and make telephone contact with negative + +results. + +with + +met with at + +was identified as Epstein's pilot. I spoke + +who advised he has been employed with Epstein since 1991. + +sboth.planes for Epstein depending where he wants to o. + +was asked about passengers in the plane he flie8. + +stated unless Epstein flew to his island off of St Thomas, be no way of knowing wli61,166.passengers were. I menti + +to Ohio, where IIIIIII flew to Ohio to pick up + +l + +he ed flying on several occasions an + +remember + +know who the passengers are. When he prepares the passenger mante and his assistants he knows by name, and stated he would list either female or male pass—eadisaingn the manifests only to keep acount on the passengers. Mrs. EMI= came into the living room and recommended that her + +husband consult with an attorney. Mr. + +with the family airmrsirsita to inform him ot is questioning. I explained to Mr. IIIIIII that he was not the suspect in thi investigation and ceased all questions. Based on the fact + +could not advise who passengers were in the plane, I then le e + +area. + +stated once he is in the cockpit, + +agreed he would speak + +t ere would arecent + +he does not + +T. 4-+.11"/ " .- to locate at + +Ileft my business card for her to re sula my call. On + +February 14, 2006, at 12:06 pm, I received acall I= from Ms. + +Beach. I respo + +. During the int + +stated she knew I would be speaking with her. stated she + +introduced to Epstein when she turned eighteen years old. + +pa ghe was sure of her age as it was her senior year in + +School. She advised she was brought there to + +ma e money and was told she would have to provide a massage to this each guy. She remembered she met Epstein and his assistant in itchen area. She stated she was to one of her + +got ready for the massage. He exited his bathroom na edtaild + +riends, . She stated she went upstairs with + +ound. Epstein asked her if being naked offended her. + +stated it made her able. Epstein then puts'. + +towel and lay on the table. stated she rubbed his and + +g s r e m + +\$200.00 for the massage and told her to leave the house. + +P.Irp" rerurn d to the house. She did advise of e she went with + +however she waited in the car for she did not + +want to go into the house. clusion of visit with Epstein they left the area. stated she had heard fkom other girls that have gone to the house that Epstein now required them to do the massage naked and allow him to touch th ' \*r. private areas for monies. The interview was concluded as did not have any + +other information to provide. + +I then learned from the original victim, II, the defense attorney had learned of her identity. I spoke with the father of the victim,, who + +stated there has been a private investigator on his house + +photographing his family and cha • • tors who come to the house. He provided a Florida License ofs . This vehicle is registered to Ivan Robles of West Palm Beach. Robles is a private investigator intern who is licensed by the state. I informed the State Attorney's + +Office of the above information. + +I received the Grand Jury subpoenas to be delivered to three victims for a Grand Jury session to be held on April 18, through April 20, + +2006. + +Investigation continues. + +\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*NARRA \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* NA Reported By: 4/14/06 + +Entered By.: 4/18/06. + +The Grand Jury Subpoenas were personally served to the individuals they were issued to. On April 5,m&006, at approximately 7:30 p.m., I + +personally served the parents of II, who had informed me that the private investigators were still photographing the family. On April + +Case No • 1-05-000368 (Continued) in inns at approximately 2:30 p.m., I served II at her residence in Beach. The subpoena was given to her mother, II . + +Ilearned through one of the victims lIl that she was personally contacted through amaource that has maintained contact with Epstein. The source assured II she would receive monetary comp sation for her assistance in not cooperating with law enforcement. II also stated she was told, "Those who help him wile compensated and those who + +hurt him will be dealt with." I told that tampering with a + +witness/victim is an arrestable offense an ery serious. I asked her who approached her during this encounter. originally was reluctant to provide the name of the person who approached her to offer her not + +to testify because she felt they were still friends. + +On April 11, 2006, Det Itraveled --A -1-\*- - 4 th the victim, identified e, Florida , W/F, + +, as the person who approached her in Beach while + +she was home during Spring Break in March 2006. oslated she did not want to pursue the intimidation charges on II was + +concerned that the defense attorney was given a copy o the report as "srin things she had told me in confidence were repeated to her by Prior to our departure, the victim was given a copy of her subpoena for the Grand Jury which was scheduled to commence April 18, + +2006. + +Upon our return from Tallahassee, I notified the State Attorney's Office of what was told to me. I also notified them that the + +subpoenas were delivered to the witnesses and they would be calling for arrangements for the date and time needed for the Grand Jury. I spoke with ASA Weiss and informed her of the possible intimidation by + +the defense. + +On April 13, and April 14, 2006 I attempted contact on several occasions with ASA Weiss and ASA Belohlavic to ascertain when the victims needed to report for Grand Jury testimony. Messages were left on their voicemail. On April 17, 2006, during the hours of 9:00 am and 11:30 am, Iagain left messages for ASA Weiss and ASA Belohlavic for either of them to return my call as I had not heard from the State + +Attorney's Office as to the time and date of the Grand Jury. + +At approximately 12:30 pm, I went to the State Attorney's Office and located ASA Weiss and ASA Belohlavic in their offices. I entered ASA Belohlavic's office who informed me that she was going to return my call. She explained that an offer was made to the defense, Atty Guy + +Fronstin and Atty Alan Dershowitz. The offer is 1 count of Agg Assault with intent to commit a felony, five years probation, with + +adjudication withheld. Epstein would have to submit to + +psychiatric/sexual evaluation and no unsupervised visits with minors. When asked about the all the other victims, ASAJelohlavic stated that was the only offer made as to one victim, II. ASA Belohlavic cell phone rang and went to voice mail. She checked her voice mail and played the message on speaker. The caller identified himself as + +Case No • 1-05-000368 + +Entered By.: + +(Continued) + +6/06/06 + +On May 22 2006, I received several phone calls throughout the day from Mr. IL who st d he had been followed aggressively by a private + +investigator. Mr. stated that as he drove to and from work and + +running errands throughout the county, the same vehicle was behind him ru other vehicles off the road in an attempt not to lose sight of + +Mr. 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.mmLmialso explained to him that there was + +a meeting scheduled with ASA IIII Belohlavek and Attorney Jack + +Goldberger at Mr. Krischer's iiiice scheduled on June 1, 2006 at 9:00 am. I attempted to call ASA BeIohlavek to inform her of the + +private investigators following Mr. however; she was on her vacation + +during the week of May 22 through May 30 2006. + +On May 23, 2006, I received other phone calls from Mr. and Mrs. I who advised they were able to acquire the private investigators license plate information. The subj t following them was again d/iving very + +aggressively and caused Mrs. to run off the road. Mrs. M. the vehicle is a green Chevy Monte Carlo bearing Florida tag The vehicle is registered to Zachary Bechard of Jupiter Florid + +Bechard is employed with Candor Investigations from Jupiter, Florida. Bechard is a licensed Private Investigator in the state of Florida. + +Since the overy of the threat made against one of the victims in + +this case (mg d TroemoArad subpoenas for all calls made to and received from during the month of March 2006 for her cell phone and home phone. I had confirmed with Florida State + +University the exact dates of Spring Break for 2006.. The Spring Break was from March 4, 2006 through March 12, 2006. I received a subpoena from Sprint/Nextel with all calls made during the month of March 2006. I reviewed the 989 calls made and re d during the month of March 2006. I observed on March 7, 2006, made and received thirty + +five calls during that day. + +Date 7-Mar-06 Time 11:03 AM + +Seconds 492 + +In/Out Outbound + +To/From 561XXXX + +7-Mar-06 11:16 AM 6 Inbound 561XXXX + +7-Mar-06 11:22 AM 887.2 Inbound 561XXXX + +7-Mar-06 11:37 AM 48 Outbound + +7-Mar-06 11:39 AM 28.2 Inbound + +7-Mar-06 12:02 PM 727.2 Inbound + +The table reflects the date of the calls, time of day (EST), duration \ No newline at end of file diff --git a/marker2/ds9/EFTA00084614/EFTA00084614.metadata.json b/marker2/ds9/EFTA00084614/EFTA00084614.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..37b366ad49fd8bd385037dde70d28d0e56da4d0c --- /dev/null +++ b/marker2/ds9/EFTA00084614/EFTA00084614.metadata.json @@ -0,0 +1,2065 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084614.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + 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file mode 100644 index 0000000000000000000000000000000000000000..fad0a6a08200b74452f8cbdbfa6b6f0f7b52168b --- /dev/null +++ b/marker2/ds9/EFTA00084701/EFTA00084701.md @@ -0,0 +1,116 @@ +**From:** "[REDACTED]" <[REDACTED]> +**To:** "[REDACTED]" <[REDACTED]>, "[REDACTED]" +<[REDACTED]> +**Cc:** "[REDACTED] (USANYS) [Contractor]" <[REDACTED]>, "[REDACTED] +(USANYS)" <[REDACTED]> + +**Subject:** RE: Invitation to view the folder "Epstein (Kristina Hendrickson)" + +**Date:** Wed, 19 Aug 2020 17:27:09 +0000 + +**Inline-Images:** image001.jpg; image002.jpg; image003.png + +I'm sorry, a very brief follow-up to the below – the other file listed in the screen-shot email below in addition to the ones I mentioned, the "IR\_MED" doc, was also already in the share, here: + +![](_page_0_Picture_79.jpeg) + +--- + +**From:** [REDACTED] +**Sent:** Wednesday, August 19, 2020 12:52 +**To:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] (USANYS) [Contractor] <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]> +**Subject:** RE: Invitation to view the folder "Epstein (Kristina Hendrickson)" + +The short answer is that for me, the link to download the .vsf file is no longer active. We certainly could re-request it from AmEx if that's useful. The longer answer is, though, and with apologies for the slight delay this morning (confirming all this took a while), we actually already addressed this (or tried to) back in July 2019. When the .vsf files didn't work, I contacted AmEx and they sent the below email: + +From: kristina.l.hendrickson@aexp.com tti Print + +Authenticated by americanexpress.com Valid Signature (Help) + +To: + +Sent: Sat Jul 13, 2019 11:02 PM + +Subject: RE: Epstein + +Attached: IR\_MED-1BQH60C3X60-0001\_Completed Level 2 Review\_071219.PDF (1,735 kb) - View, Download Key Transactions.xlsx (144 kb) - View, Download Epstein Mainframes & Additional Accounts (not card accounts).zip (755 kb) - View, Download + +Hi Alex, + +I am not sure why the .vsf file won't open but I will send the documents through email. Again, the documents I provide are for investigative use and not for court proceedings. + +I am going to send a total of three emails including this one which will be the files from the AmexDrive that you were not able to access minus the below files. Did Yui Chow send you the documents listed below? If you don't have the documents listed below, I will have to send them via USB drive since they are too large to send through email. + +![](_page_1_Figure_10.jpeg) + +Nearly all of those files referenced are already in the share. To go through them, for the sake of a fully complete record, the following folder contains 11 of the 13 excel docs, with the exceptions of the first entry (the first Business Plum) and the fourth from the bottom (the "edited" centurion card): + +[Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Investigation\# 2018 SDNY investigation\Subpoena Returns\American Express \(AMEX\)\2019-07-12 \(Friday 08.55\).production \(produced\)](#) + +To the extent we want to go back to AmEx to ask for them to email those two Excel files, we can do that. (Alternatively, is there anything wrong with just producing the .vsf file to defense counsel?? If it's just similar to a .zip file, I imagine they have a better ability to open it than we do. I wouldn't have an issue with that.) + +The .zip folder listed in that email has the following contents, all of which are also in the above folder: + +![](_page_2_Picture_16.jpeg) + +The final attachment is an Excel file titled "Key transactions." I think it's possible we didn't include save that in the subpoena returns folder because it was analysis that AmEx did of particular people, rather than primary source documents that were responsive to the subpoena. But it's attached here in case you guys think that should be produced nevertheless. + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Wednesday, August 19, 2020 10:32 +**To:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] (USANYS) [Contractor] <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]> +**Subject:** FW: Invitation to view the folder "Epstein (Kristina Hendrickson)" + +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. Will and I are working with Eric 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, +Maurene + +--- + +**From:** [REDACTED] +**Sent:** Wednesday, August 19, 2020 10:23 AM +**To:** [REDACTED] (USANYS) <[REDACTED]> +**Cc:** [REDACTED] (USANYS) [Contractor] <[REDACTED]> +**Subject:** FW: Invitation to view the folder "Epstein (Kristina Hendrickson)" + +From: Kristina.L.Hendrickson@aexp.com + +Sent: Saturday, July 13, 2019 1:57 PM + +To: + +Subject: Invitation to view the folder "Epstein (Kristina Hendrickson)" + +![](_page_3_Picture_4.jpeg) + +EXPRESs AMEXDRIVE + +## Invitation to view shared folder + +Kristina Hendrickson used AmexDrive to share a folder with you. To view the shared folder, click on the button below. + +Epstein (Kristina Hendrickson) + +Sharing expires on Jul 12, 2020 + +We will be happy to answer any questions you may have. + +The AmexDrive Team + +htlps://square.americanexpress.comicommunityltools-programs/amexdrive + +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 ptevu, mute divulgation, duplication, utilisation ou distribution du courrier 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. 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sha256:8e205576c2a45686934c35364960a948bbf79b7a3c30b270259f5e3799971636 +size 3716 diff --git a/marker2/ds9/EFTA00084706/EFTA00084706.md b/marker2/ds9/EFTA00084706/EFTA00084706.md new file mode 100644 index 0000000000000000000000000000000000000000..a659d2339d58e802e0153f2dcb626d4cf9ec8b8b --- /dev/null +++ b/marker2/ds9/EFTA00084706/EFTA00084706.md @@ -0,0 +1,57 @@ +From: IJSANYS)" ci + +To: ' + +Subject: RE: share access + +Date: Tue, 21 Jul 2020 13:07:12 +0000 + +Thanks, appreciate it! + +From: + +Sent: Tuesday, July 21, 2020 9:05 AM + +To USANYS) + +Su ject: RE: share access + +Those both make sense—let me know if you have trouble finding them on the share. Attached is an update memo we put together in December 2019 summarizing the post-Epstein indictment investigation to date. Might be helpful to get a fuller picture of the case. + +From USANYS) + +Sent: Monday, July 20, 2020 8:25 PM + +To: + +Subject: RE: share access + +I'm planning to read ta memo and plea submission, and will read the Maxwell pros memo. Is there anything else that you think might be helpful to review to catch up on? Thanks in advance. + +From: (USANYS) + +Sent: Monday, July 20, 2020 7:24 PM + +To: + +Subject: RE: share access + +Thanks! + +From: + +Sent: Monday, J + +To: + +Cc: (USANYS) + +Subject: share access + +Hi + +Would it be possible to please gives access to the USv.Epstein-2018R01618 share? + +he PC chiefs and brass previously got access to the share, so I figure it makes sense for you to be added in case you need to review anything there. + +Thanks, \ No newline at end of file diff --git a/marker2/ds9/EFTA00084706/EFTA00084706.metadata.json b/marker2/ds9/EFTA00084706/EFTA00084706.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..13ca324b5a9ba17ba75a674715bf484f9d553c66 --- /dev/null +++ b/marker2/ds9/EFTA00084706/EFTA00084706.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084706.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1134, + "elapsed_seconds": 1.27, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 36 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00084706" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084707/EFTA00084707.md b/marker2/ds9/EFTA00084707/EFTA00084707.md new file mode 100644 index 0000000000000000000000000000000000000000..ca9576be5b25f90033393dd1bbf7d49c06ee1066 --- /dev/null +++ b/marker2/ds9/EFTA00084707/EFTA00084707.md @@ -0,0 +1,41 @@ +From: ' cl To: a)" 11 + +Subject: RE: Maxwell Discovery + +Date: Tue, 21 Jul 2020 19:40:11 +0000 + +Nope. + +From: + +Sent: Tuesday, July 21, 2020 3:29 PM + +To: > + +Subject: RE: Maxwell Discovery + +Any response? + +From: + +Sent: Thursday, July 16, 2020 3:41 PM + +To: (NY) (FBI) ; > + +Subject: Maxwell Discovery + +Would you two be available for a call the week of July 27th to discuss discovery for Maxwell, please? and I will need to make sure we have the entirety of any FBI or NYPD file related to the Epstein investigation, so that we can review those files for any disclosures that need to be made to Maxwell. We'd like to discuss when you're both in the office. + +In the meantime, would you be able to provide us with the below materials so we can prepare some initial discovery productions to Maxwell, please? My hope is that the below materials should be fairly straightforward to gather and provide to us, but please let me know if any of these items would take more than a couple weeks to send to us. + +- All 302s from all FBI searches, including all searches of Epstein's NY residence, and all searches of Epstein's USVI residence +- All photographs from all FBI searches, including all searches of Epstein's NY residence, and all searches of Epstein's USVI residence +- All search warrant returns +- All CART paperwork regarding the extraction of data from all devices seized during the investigation +- All 302s and photographs from Maxwell's arrest +- All phone records gathered regarding Maxwell, including subscriber information and any other information obtained through administrative subpoena, toll records, pen data, historical cell site records, GPS data, and triggerfish data +- All 302s regarding the extraction of data from any seized devices and the review of images (both digital and hard copy) seized during the investigation, including from Epstein's properties. Relatedly, we will need to provide a list or other form of inventory to defense counsel informing them how many images were seized and where they can be reviewed (we can discuss this further on our call). + +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/EFTA00084707/EFTA00084707.metadata.json b/marker2/ds9/EFTA00084707/EFTA00084707.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9e564cab18d53c85d76e86e297d45c7b692015e3 --- /dev/null +++ b/marker2/ds9/EFTA00084707/EFTA00084707.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084707.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2181, + "elapsed_seconds": 0.92, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 86 + ], + [ + "Line", + 42 + ], + [ + "Text", + 18 + ], + [ + "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": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 9 + ], + [ + "Text", + 5 + ], + [ + "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/EFTA00084707" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084709/EFTA00084709.md b/marker2/ds9/EFTA00084709/EFTA00084709.md new file mode 100644 index 0000000000000000000000000000000000000000..eb604e9d5d827ee52f91263752860ff3c11de411 --- /dev/null +++ b/marker2/ds9/EFTA00084709/EFTA00084709.md @@ -0,0 +1,31 @@ +From: To: + +Subject: FW: Victim notification letter + +Date: Thu, 23 Jul 2020 02:20:09 +0000 + +Embedded: Fwd:\_Victim\_Notification\_Letters.msg + +This is in relation to the attached, which =forwarded to me from his phone so asked me to send it along to the full team. + +I could do a call anytime before our 4:30 on Tuesday. + +From: + +Sent: Wednesday, July 22, 2020 15:44 + +To: + +Subject: Victim notification letter + +Hey guys, + +has been in contact withad i lately as they have been requesting some sort of victim notification letter from the FBI for each of their victims that we have formally interviewed. 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 toMand 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 \ No newline at end of file diff --git a/marker2/ds9/EFTA00084709/EFTA00084709.metadata.json b/marker2/ds9/EFTA00084709/EFTA00084709.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..47936cc8ea9a8bf17adbdc494cdc8529b3ad9b65 --- /dev/null +++ b/marker2/ds9/EFTA00084709/EFTA00084709.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084709.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1762, + "elapsed_seconds": 0.95, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 33 + ], + [ + "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/EFTA00084709" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084710/EFTA00084710.md b/marker2/ds9/EFTA00084710/EFTA00084710.md new file mode 100644 index 0000000000000000000000000000000000000000..0fbb782fdbf71df56a60f05bbb84b929ed355139 --- /dev/null +++ b/marker2/ds9/EFTA00084710/EFTA00084710.md @@ -0,0 +1,13 @@ +From: aM t' + +To:' + +Subject: Final Memos + +Date: Thu, 23 May 2019 13:42:02 +0000 + +Importance: Normal + +Attachments: SDNY \_ Memo \_ to\_ DAG\_ - \_ GSB \_Recused.5.22.19v2.docx; SDNY\_Memo\_to\_AG.GSB.cases.5.23.19.v3.doex + +M , Would you please take one last careful look? Check Epstein especially since you had not seen that. Thanks \ No newline at end of file diff --git a/marker2/ds9/EFTA00084710/EFTA00084710.metadata.json b/marker2/ds9/EFTA00084710/EFTA00084710.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4f75d0708c9954890683349e8aee7183730c67d8 --- /dev/null +++ b/marker2/ds9/EFTA00084710/EFTA00084710.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084710.pdf", + "engine": { + "marker_major": "2", + "marker_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": 330, + "elapsed_seconds": 0.41, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 11 + ], + [ + "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/EFTA00084710" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084711/EFTA00084711.md b/marker2/ds9/EFTA00084711/EFTA00084711.md new file mode 100644 index 0000000000000000000000000000000000000000..e7bcbad9e3b0c6980f38540a8197a437a11d9d3f --- /dev/null +++ b/marker2/ds9/EFTA00084711/EFTA00084711.md @@ -0,0 +1,81 @@ +## LAW OFFICES OF BOBBI C. STERNHEIM + +![](_page_0_Picture_2.jpeg) + +![](_page_0_Picture_3.jpeg) + +November 3, 2021 + +Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 + +> Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) + +Dear Judge Nathan: + +Counsel for Ghislaine Maxwell renew our request that the Court release the names of potential jurors, for attorneys' eyes only, as soon as the written questionnaires are distributed. Based on the Court's statement during the October 21 teleconference, it was counsel's understanding that juror names would be provided to counsel on the Juror Sheet to be inserted in the questionnaire. In responding to the Court's order regarding approval of the video to be played to prospective jurors, the government importuned the Court to deny counsel the opportunity to properly vet jurors at this critical state of the proceeding. Not knowing the names of the potential jurors will prevent the parties from conducting necessary background research on the jurors in advance of voir dire so that they may evaluate potential challenges and strikes. Due to the large number of potential jurors (600), waiting until voir dire to release the names of the jurors will make it virtually impossible for the parties to conduct any meaningful research to uncover issues that may require follow-up questions, lead to additional cause challenges, or enable the parties to exercise their peremptory challenges in an informed manner. + +Recently, in Sines, et at v. Kessler, et at, 17-CV-72 (KNM) (W.D. Va.), the civil case brought against the organizers of the Unite the Right rally in Charlottesville, Virginia, the United States District Court for the Western District of Virginia ordered a semi-anonymous jury (jurors were publicly referred to by number only) and released the names of all potential jurors to counsel, plus all pro se defendants (including Richard Spencer and Christopher Cantwell), who are allegedly prominent white supremacists, neo-Nazis, and the leaders of hate groups that planned, promoted, and executed the violent acts in Charlottesville. (See Exhibit A, annexed.) The defendants in Sines included factions of the Ku Klux Klan. The concerns for juror privacy in Sines dwarf any conceivable concerns in this case and Sines is also the subject of extensive ongoing publicity. We submit that withholding the names of 600 jurors until the day of jury selection will deprive Ms. Maxwell of her right to be tried by a fair and impartial jury and is a procedure that would violate due process in this particular case.' + +"An impartial jury is one in which all of its members, not just most of them, are free of interest and bias." United States v. Parse, 789 F.3d 83, III (2d Cir. 2015). In Parse, a case before Judge Pauley sub nom United States v. Daugerdas, a jury convicted defendant Parse and three of his co-defendants of numerous financial fraud and tax evasion charges. 789 F.3d at 86. After trial, all defendants moved pursuant to Fed.R.Crim.P. 33(a) for a new trial on the ground that one of the jurors, Juror No. 1 (Catherine M. Conrad), "had lied and withheld material information during voir dire and was biased against defendants. Judge Pauley appointed Bobbi C. Sternheim, Esq. to represent the juror and conducted an evidentiary hearing in which the juror was examined, and in a detailed thorough opinion (see United States v. Daugerdas, 867 F.Supp.2d 445 (S.D.N.Y.2012) found it "undisputed that Conrad lied extensively during voir dire and concealed important information about her background" (id. at 451), her level of education, place of residence, criminal history, and other matters. Parse, 789 F.33 at 87-90. + +&#x27; We are unaware of any other recent high-profile case in which a written juror questionnaire was used and the Court withheld the names of the jurors from counsel following the completion of the questionnaires. + +Judge Pauley granted a motion for a new trial as to Parse's three co-defendants but held that Parse had waived his right to an impartial jury because his attorneys had sat on background research collected before and during trial that suggested Conrad's voir dire answers were false. Id. at 101. On appeal, the Second Circuit "had no difficulty with the ruling of the district court in the present case that the jury empaneled to hear the case against these defendants was not an impartial jury." Id. at III. Moreover, the Second Circuit reversed Judge Pauley's ruling that Parse had waived his right to an impartial jury, and vacated Parse's conviction. Id. at 118. + +The result in Parse was that a three-month trial, with 41 witnesses and some 1,300 exhibits, was undone by the falsehoods of one juror during voir dire—falsehoods that could have been uncovered by thorough background research and prompt action by the parties. Numerous bar associations have recognized that trial counsel is expected to conduct intemet research on potential jurors. Some bar associations have opined that professional standards of competence and diligence may require such research. For example, just weeks after Judge Pauley conducted a post-conviction evidentiary hearing in Parse, the New York City Bar Association stated the following in Formal Opinion 2012-2: + +Just as the intemet and social media appear to facilitate juror misconduct, the same tools have expanded an attorney's ability to conduct research on potential and sitting jurors, and clients now often expect that attorneys will conduct such research. Indeed, standards of competence and diligence may require doing everything reasonably possible to learn about the jurors who will sit in judgment on a case. + +Similarly, in 2014, the American Bar Association recognized the "strong public interest in identifying jurors who might be tainted by improper bias or prejudice," and therefore opined that it was proper for counsel to research "a juror's or potential juror's Internet presence, which may include postings by the juror or potential juror in advance of and during a trial. . . ." See Standing Committee on Ethics and Professional Responsibility, Formal Op. 466 at 1-2, Am. Bar Assn. (2014); see also New York State Bar Association, Dec. 8, 2015 Report of the Social Media Committee of the Commercial and Federal Litigation Section, at 15 ("[I]t is not only permissible for trial counsel to conduct Internet research on prospective jurors, but it may even be expected."). + +Other courts have acknowledged that using the intemet to conduct background research on prospective jurors is a "rudimentary practice" during jury selection. United States v. Stone, No. 19-0018 (ABJ), 2020 U.S. Dist. LEXIS 67359, at \*93 (D.D.C. Apr. 16, 2020); see also Carino v. Muenzen, No. A-5491-0811, 2010 N.J. Super. Unpub. LEXIS 2154, at \*27 (Super. Ct. App. Div. Aug. 30, 2010) (trial judge erred in preventing counsel from using the internet during jury selection). It is so routine that a party who fails to uncover disqualifying information about a potential juror, despite a reasonable opportunity to do so, risks waiving the right to use that information in post-conviction proceedings. Stone at \*90 (denying motion to vacate conviction and for a new trial because, inter alia, "the defense could have discovered the [foreperson's social media] posts as early as September 12, 2019, the day counsel received access to the completed juror questionnaires, including the foreperson's, which had her name printed legibly on the signature page."). + +Having additional time to conduct background research on each of the venirepersons is the best way to ensure a fair and impartial jury. Balancing the need to protect juror privacy against Ms. Maxwell's right to a fair and impartial jury weighs in favor of releasing the names of potential jurors to counsel upon the completion of their written questionnaires, not at voir dire. + +Respectfully submitted, + +/s/ + +BOBBI C. STERNHEIM + +Enc. + +cc: All counsel of record + +## EXHIBIT A + +## UNITED STATES DISTRICT COURT WESTERN DISTRICT OF VIRGINIA CHARLOTTESVILLE DIVISION + +ELIZABETH SINES, et at, + +v. + +JASON ICESSLER, et at, + +Plaintiffs, + +Defendants. + +CASE No. 3:17-cv-00072 + +ORDER + +JUDGE NORMAN K. MOON + +Upon this Court's own motion, upon notice that Plaintiffs' counsel may seek to designate certain non-lawyers within their list of six (6) persons to be provided electronic access to the July questionnaires, and otherwise finding good cause shown, the Court hereby AMENDS Pretrial Order1 3, (Dkt. 1172) as follows: + +Plaintiffs, and Defendants represented by counsel collectively, may each designate no more than six (6) persons, which may be comprised of (1) current counsel of record or (2) third parties working under their direction, who are formally engaged and supervised by the attorneys of record, and for whom such attorneys of record will be responsible, and who will have signed the Court's protective order, Dkt. 167, so long as such persons include at least one attorney admitted to practice in the Western District of Virginia, to be provided electronic access by the Clerk to receive and review copies of the jury questionnaires, on a rolling basis. A list including names and occupations of prospective jurors, and information matching such prospective jurors with the questionnaires pursuant to Dkt. 1204 1 2, will also be provided to such specifically designated persons by Plaintiffs and represented Defendants, no more than five (5) days before trial. Jury questionnaires and such occupation list, and any information contained therein, are + +subject to the Court's orders regarding confidentiality in Dkt. 1172 and 1204, and shall not be disclosed to any other person without prior authorization of Court. + +Any pro se Defendant—upon completing a declaration stating, under penalty of perjury, they will not disclose the contents of such questionnaires or the jury occupation list provided to such pro se Defendant to any other person—may review the questionnaires and jury occupation list onsite in the Clerk's Office. A paper copy of the completed questionnaires and the jury occupation list customarily made available to pro se litigants will be maintained in the Clerk's Office. + +If any party requests specific access to the confidential juror questionnaires in excess of the provisions outlined above and in Dkts. 1172 and 1204, they shall file a motion to that effect. In all other respects, this Court's Orders of Dkt. 1172 and 1204 shall remain unchanged and in force. + +It is so ORDERED. + +The Clerk of the Court is directed to send a certified copy of this Order to the parties. + +Entered this 19th day of October, 2021. + +/24.nr i )R AN K. 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0000000000000000000000000000000000000000..cca0aaae50128153c5e8f833c356dd76c2ce8706 --- /dev/null +++ b/marker2/ds9/EFTA00084711/_page_0_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:e182b1bc8697d7cb1f60d66a5dc4039707dcea1c24b535bbd43ec5aa0ea8dc76 +size 3239 diff --git a/marker2/ds9/EFTA00084711/_page_0_Picture_3.jpeg b/marker2/ds9/EFTA00084711/_page_0_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..2fb0af7e704db84572811cc3135dbf0183c64ddd --- /dev/null +++ b/marker2/ds9/EFTA00084711/_page_0_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:484df9630a45f04fea3e169ed603ae23e52df09746e54934fe77d58cf98deae9 +size 3037 diff --git a/marker2/ds9/EFTA00084718/EFTA00084718.md b/marker2/ds9/EFTA00084718/EFTA00084718.md new file mode 100644 index 0000000000000000000000000000000000000000..440049fb83fcbeeead8651c406947a866963b419 --- /dev/null +++ b/marker2/ds9/EFTA00084718/EFTA00084718.md @@ -0,0 +1,33 @@ +To: + +Subject: [EXTERNAL] Notes on the News: Millions of Workers Must Get Vaccinated by Jan. 4 or Test Weekly + +Date: Thu, 04 NOV 2021 21:24:28 +0000 + +Trouble viewing this email? View in web browser ) + +![](_page_0_Picture_5.jpeg) + +The Wall Street Journal. + +![](_page_0_Picture_7.jpeg) + +![](_page_1_Picture_0.jpeg) + +![](_page_2_Picture_0.jpeg) + +![](_page_3_Picture_0.jpeg) + +![](_page_4_Picture_0.jpeg) + +## Jeffrey Epstein's accusers are seeking justice in the trial of Ghislaine Maxwell. + +A medical examiner determined the disgraced financier died by suicide more than two years ago. Now, accusers say they see an opportunity for closure when Ghislaine Maxwell—Epstein's longtime friend, confidante and employee who is accused of sex trafficking—goes on trial this week. Prosecutors have accused her of grooming girls for Epstein, including by befriending them and taking them shopping or to the movies. During a hearing Monday, Maxwell said she had committed no crime. She is charged with crimes including enticing a minor to travel to engage in illegal sex acts and transporting a minor with the intent to engage in criminal sexual activity. The indictment cites four anonymous women prosecutors say Maxwell groomed as teenagers for Epstein between 1994 and 2004. + +![](_page_6_Picture_0.jpeg) + +![](_page_6_Picture_1.jpeg) + +![](_page_7_Picture_0.jpeg) + +![](_page_7_Picture_1.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084718/EFTA00084718.metadata.json b/marker2/ds9/EFTA00084718/EFTA00084718.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b625e12ca4878be7bbe0f681fd4da167f4cba6e6 --- /dev/null +++ b/marker2/ds9/EFTA00084718/EFTA00084718.metadata.json @@ -0,0 +1,307 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084718.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1378, + "elapsed_seconds": 0.83, + 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sha256:5849104748d74a6155c2ac9c8c5f3bd810b573aee87c85a348c33f104e5b3733 +size 16488 diff --git a/marker2/ds9/EFTA00084726/EFTA00084726.md b/marker2/ds9/EFTA00084726/EFTA00084726.md new file mode 100644 index 0000000000000000000000000000000000000000..ef0d1c1a401adc69ccf6374f7176cdb035638069 --- /dev/null +++ b/marker2/ds9/EFTA00084726/EFTA00084726.md @@ -0,0 +1,195 @@ +![](_page_0_Picture_0.jpeg) + +November 1, 2021 + +VIA EMAIL + +![](_page_0_Picture_7.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) + +> 150 East lOth Avenue Denver, Colorado 80203 + +www.hrnflaw.com + +Dear Counsel: + +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. + +Dr. is the Distinguished Professor of Ps ±ological Science and Law at the University of California, Irvine School of Law. Dr. 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. 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. 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. + +# M.D., M.P.H., PH.D. + +Dr. 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. 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 & 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 will be qualified as an expert in the areas of psychiatry and behavioral science. Dr. curriculum vitae is attached as Exhibit B. Attached as Exhibit C is a list of material reviewed by Dr. + +His testimony may include, but will not be limited to, the following: + +# a. Opinions about Dr. 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. MIIII. . Grooming and Seduction, 33 J. Interpersonal Violence, 28, 31 (2018). Dr. 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 an articular population of alleged victims, patients, or plaintiffs—including those whom Dr. 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. 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. 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. 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. 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. 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. 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. 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, pu rtedl obtained from relatives, and asked to try to remember these experiences. Research by has revealed how subtle information introduced after an event may alter the memory of that event. 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. + +Dr. performed an independent medical and psychiatric evaluation of in 2009. Dr. 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. M. + +Dr.. 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. He will testify about the facts and circumstances surrounding the evaluation, disclosures made by Ms. and the fact that Ms. did not identify Ms. Maxwell as a perpetrator of any abuse. + +D. + +Professor 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 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 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. + +Mr. 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. 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. 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. may testify in rebuttal to any testimony offered by the government through . As trial preparation proceeds, the defense will update the topics for Mr. if any arise. + +F. + +Mr. was a Special Agent with the United States Department of the Treasury, Internal Revenue Service, Criminal Investigation ("IRS-CI") for over twenty-five years. During his tenure at IRS-CI, Mr. I= led the New York Asset Forfeiture Task Force and participated in numerous criminal investigations involving complex fraud, corruption, briberya\_tax evasion, money laundering, and asset forfeiture. Since retiring from the IRS in 2013, Mr. has worked as a financial investigator and consultant for several private investigation companies and government enforcement agencies. He currently runs his own private financial investigation and consulting company called JDL Services, Inc. Mr. 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 Mr. will testify about his review of certain financial records provided by the government in discovery. Specifically, Mr. 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. + +Mr. 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 journal pages by witness . 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 quality.lVIr. as an expert to offer the proposed testimony. Nevertheless, we hereby notice Mr. as a potential expert witness in an abundance of caution. + +November 1, 2021 + +Page 14 + +H. + +Ms. is a Forensic Document Examiner who worked for and received specialized training from the United States Secret Service as a Document Analyst. Ms. 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 to journal pages by witness . 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. 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, + +Jeffrey S. Pagliuca + +Enclosures \ No newline at end of file diff --git a/marker2/ds9/EFTA00084726/EFTA00084726.metadata.json b/marker2/ds9/EFTA00084726/EFTA00084726.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e8a7a88c82c56506d626208476966120e5a2503d --- /dev/null +++ b/marker2/ds9/EFTA00084726/EFTA00084726.metadata.json @@ -0,0 +1,728 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084726.pdf", + "engine": { + "marker_major": "2", + "marker_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": 43279, + "elapsed_seconds": 2.27, + "image_assets": [ + "_page_0_Picture_0.jpeg", + "_page_0_Picture_7.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "I. 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Maxwell - Redacted MILs + +Date: Fri, 05 Nov 2021 03:06:21 +0000 + +Attachments: Government Motions.zip; Defense\_Motions.zip + +Chambers, + +Attached please find revised proposed redactions to the parties' motions in limine. The parties propose to seal the same exhibits as before, which are set forth below for the Court's convenience. + +## Government Motions + +Government proposes to seal defense exhibits A through D, F, H, and I + +## Defense Motions + +The Government proposes to seal the following: + +- Defense Motion 4 Exhibits A and B +- Defense Motion 7 Exhibit 1 and 2 +- Defense Motion 8 Exhibit A +- Defense Motion 9 Exhibit A +- Defense Motion 13 Exhibit +- Defense Reply Brief Exhibits A through D + +The defense joins that request as to exhibits 4-A, 4-B, 7-1, and 13. + +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/EFTA00084740/EFTA00084740.metadata.json b/marker2/ds9/EFTA00084740/EFTA00084740.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f3177be2a6e3aaa934872ef440a17440f2ea79c7 --- /dev/null +++ b/marker2/ds9/EFTA00084740/EFTA00084740.metadata.json @@ -0,0 +1,113 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084740.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1047, + "elapsed_seconds": 0.86, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Government Motions", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.823999999999998, + 289.98 + ], + [ + 132.4067840576172, + 289.98 + ], + [ + 132.4067840576172, + 302.96759033203125 + ], + [ + 31.823999999999998, + 302.96759033203125 + ] + ] + }, + { + "title": "Defense Motions", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.823999999999998, + 330.48 + ], + [ + 112.53678894042969, + 330.48 + ], + [ + 112.53678894042969, + 343.46759033203125 + ], + [ + 31.823999999999998, + 343.46759033203125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 60 + ], + [ + "Line", + 29 + ], + [ + "Text", + 15 + ], + [ + "ListItem", + 6 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00084740" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084741/EFTA00084741.md b/marker2/ds9/EFTA00084741/EFTA00084741.md new file mode 100644 index 0000000000000000000000000000000000000000..286beb021af6aa25b8d36e8ede268732fcee54a5 --- /dev/null +++ b/marker2/ds9/EFTA00084741/EFTA00084741.md @@ -0,0 +1,31 @@ +From: ' (USANYS)" To: " USANYS " SANYS)" Cc: ' 4 + +Subject: RE: Bail Oppo Draft + +Date: Mon, 08 Nov 2021 02:26:23 +0000 + +Attachments: Bail\_Oppo\_v2\_(LP).docx + +Thank you so much for putting this together. We are so so appreciative of you doing this and all of the support. In unsurprising news, this was excellent. We only made a few small edits in track changes in the attached. please let us know if you plan to review. + +Thanks again! + +From: (USANYS) a > + +Sent: Friday, November 5, 2021 2:14 PM + +To: < (USANYS) + +Subject: Bail Oppo Draft + +Submitted for your review! (I saved this locally on my comp, so I wouldn't mess up your shared organization) + +Deputy Chief, Public Corruption Unit + +Southern District of New York + +Office: + +Ce + +Email: \ No newline at end of file diff --git a/marker2/ds9/EFTA00084741/EFTA00084741.metadata.json b/marker2/ds9/EFTA00084741/EFTA00084741.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..40d02142f385ca52ba09c5cce8d755704214e963 --- /dev/null +++ b/marker2/ds9/EFTA00084741/EFTA00084741.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084741.pdf", + "engine": { + "marker_major": "2", + "marker_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": 737, + "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", + 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/EFTA00084741" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084742/EFTA00084742.md b/marker2/ds9/EFTA00084742/EFTA00084742.md new file mode 100644 index 0000000000000000000000000000000000000000..5d7b2457fc106ad3e884ebc976bca9a094f5156f --- /dev/null +++ b/marker2/ds9/EFTA00084742/EFTA00084742.md @@ -0,0 +1,55 @@ +## Public Corruption Unit Short Form Updates December 6, 2018 + +## A. SIGNIFICANT DEVELOPMENTS IN CASES + +![](_page_0_Picture_3.jpeg) + +![](_page_0_Picture_5.jpeg) + +![](_page_1_Picture_6.jpeg) + +![](_page_1_Picture_7.jpeg) + +![](_page_1_Picture_8.jpeg) + +![](_page_1_Picture_9.jpeg) + +![](_page_2_Picture_7.jpeg) + +- • [Redacted] + THE SIGN OF THE LAW. + +![](_page_2_Picture_9.jpeg) + +- • [Redacted] + +[Redacted text block] + +- • [Redacted text block] + +[Redacted text block] + +OF HIS CHOPS TO FEEL HE MIGHT BE IN CH + +- • [Redacted text block] + +- • [Redacted text block] + +--- + +[Redacted text block] + +![](_page_4_Picture_73.jpeg) + +- • [Redacted] +- • In re Jeffrey Epstein, 2018R01618 (AUSAs [Redacted]): + Along with the FBI, we are investigating allegations that, over the course of a decade or more, Jeffrey Epstein sexual abused dozens of minors, including minors who were transported to/from New York for the purpose of being sexually abused. In 2008, Epstein resolved a then-pending federal investigation being run by the U.S. Attorney's Office for the Southern District of Florida with a Non-Prosecution Agreement (the "Florida NPA"). The Florida NPA, which is by its terms binding only that office, purported to immunize not only Epstein, but a number of his alleged co-conspirators, including a "booker" based in New York and responsible for scheduling Epstein's "massages" with under-aged girls. With the assistance of the FBI, we have obtained and are reviewing various documents from the original investigation, and are beginning to identify victims based in New York. We also plan to begin looking into complaints and allegations of potential misconduct that post-date the Florida NPA. + +**B. UPCOMING TRIALS** + +- • [Redacted] +- • [Redacted] +- • [Redacted] +- • [Redacted] +- • [Redacted] +- • [Redacted] \ No newline at end of file diff --git a/marker2/ds9/EFTA00084742/EFTA00084742.metadata.json b/marker2/ds9/EFTA00084742/EFTA00084742.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..191da0a862be88a13bd65304df6bbd8cb4dd8347 --- /dev/null +++ b/marker2/ds9/EFTA00084742/EFTA00084742.metadata.json @@ -0,0 +1,270 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084742.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1802, + "elapsed_seconds": 46.45, + "image_assets": [ + "_page_0_Picture_3.jpeg", + "_page_0_Picture_5.jpeg", + "_page_1_Picture_6.jpeg", + "_page_1_Picture_7.jpeg", + "_page_1_Picture_8.jpeg", + "_page_1_Picture_9.jpeg", + "_page_2_Picture_7.jpeg", + "_page_2_Picture_9.jpeg", + "_page_4_Picture_73.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Public Corruption Unit \nShort Form Updates \nDecember 6, 2018", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 241.74, + 70.47 + ], + [ + 369.64799999999997, + 70.47 + ], + [ + 369.64799999999997, + 114.20999999999998 + ], + [ + 241.74, + 114.20999999999998 + ] + ] + }, + { + "title": "A. 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SIGNIFICANT DEVELOPMENTS IN CASES + +![](_page_0_Picture_2.jpeg) + +![](_page_1_Picture_4.jpeg) + +![](_page_1_Picture_5.jpeg) + +![](_page_2_Picture_0.jpeg) + +![](_page_2_Picture_1.jpeg) + +![](_page_3_Picture_0.jpeg) + +![](_page_4_Picture_0.jpeg) + +- In re Jeffrey Epstein 2018R01618 (AUSAs ): Along with the FBI, we are investigating allegations that, over the course of a decade or more, Jeffrey Epstein sexual abused dozens of minors, including minors who were transported to/from New York for the purpose of being sexually abused. In 2008, Epstein resolved a then-pending federal investigation being run by the U.S. Attorney's Office for the Southern District of Florida with a Non-Prosecution Agreement (the "Florida NPA"). The Florida NPA, which is by its terms binding only that office, purported to immunize not only Epstein, but a number of his alleged co-conspirators, including a "booker" based in New York and responsible for scheduling Epstein's "massages" with under-aged girls. With the assistance of the FBI, we have obtained and are reviewing various documents from the original investigation, and are beginning to identify victims based in New York. We also plan to begin looking into complaints and allegations of potential misconduct that post-date the Florida NPA. + +## B. 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We are uploading a zip file containing the discovery materials to USAfx. Additionally, please find attached one additional page of discovery, which has been marked attorney's eyes only. Please contact us with any questions or if you have any difficulty accessing the production. Regards, + +Paralegal Specialist + +U.S. Attorney's Office I SDNY + +1 St. Andrew's Plaza + +New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00084753/EFTA00084753.metadata.json b/marker2/ds9/EFTA00084753/EFTA00084753.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3c98848cfff30e0749c00a1b65068fad1357f775 --- /dev/null +++ b/marker2/ds9/EFTA00084753/EFTA00084753.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084753.pdf", + "engine": { + "marker_major": "2", + "marker_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": 0.75, + "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/EFTA00084753" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084754/EFTA00084754.md b/marker2/ds9/EFTA00084754/EFTA00084754.md new file mode 100644 index 0000000000000000000000000000000000000000..02376860e5180161315557fc44e13031e297d98c --- /dev/null +++ b/marker2/ds9/EFTA00084754/EFTA00084754.md @@ -0,0 +1,23 @@ +| Anonymous Identifier | Attorney | Cooperator | +|----------------------|---------------------|------------| +| Employee 1 | Sam Gregory | | +| Em lo ee 3 | Howard Schwartz | | +| Employee 4 | Matthew Meyers | | +| Employee 11 | Don DuBoulay | | +| Em lo ee 16 | Bernard Udell | | +| Employee 22 | Edward Hayes | | +| Employee 27 | Natali Todd | | +| Employee 29 | Timothy Parlatore | | +| Inmate I | Rob Georges | Yes | +| Inmate 2 | Andy Patel | | +| Inmate 3 | Telesforo Del Valle | | +| Inmate 4 | Barry Goldberg | | +| Inmate 5 | Xavier Donaldson | Yes | +| Inmate 6 | Matthew Kluger | | +| Inmate 7 | Chris Flood | | +| Inmate 8 | Christine Delince | Yes | +| Inmate 9 | Ernest Hammer | Yes | +| Inmate 10 | Marlon Kirton | Yes | +| Inmate 11 | Javier Solano | | +| Inmate 12 | James Neuman | | +| Inmate 13 | Margaret Shalley | | \ No newline at end of file diff --git a/marker2/ds9/EFTA00084754/EFTA00084754.metadata.json b/marker2/ds9/EFTA00084754/EFTA00084754.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7c637c7d1ddc8fc562d05295c32074e51b98fca0 --- /dev/null +++ b/marker2/ds9/EFTA00084754/EFTA00084754.metadata.json @@ -0,0 +1,58 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084754.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1379, + "elapsed_seconds": 0.34, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 94 + ], + [ + "Line", + 47 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "Table", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00084754" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084755/EFTA00084755.md b/marker2/ds9/EFTA00084755/EFTA00084755.md new file mode 100644 index 0000000000000000000000000000000000000000..4b6316e9acd585c6bd2bad1112f841a7c2051b53 --- /dev/null +++ b/marker2/ds9/EFTA00084755/EFTA00084755.md @@ -0,0 +1,59 @@ +![](_page_0_Picture_110.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 14, 2020 + +**BY USAfx** + +Montell Figgins, Esq. +Law Offices of Montell Figgins +17 Academy Street, Suite 305 +Newark, NJ 07102 + +**Re: *United States v. Michael Thomas*, No. 19 Cr. 830** + +Dear Counsel: + +This letter provides additional discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure. This letter and the materials identified herein are subject to the protective order entered in this case on December 16, 2019, and have been designated as "Protected Materials" as defined in the order where noted below. Accordingly, the materials and information identified herein shall not be disclosed to any third party or referenced publicly except as set forth in the protective order. + +| Description | Bates Numbers | Classification Pursuant to Protective Order | +|-------------|----------------------------------|---------------------------------------------| +| [Redacted] | SDNY_00008724 –
SDNY_00013257 | Confidential 2 | + +![](_page_0_Picture_121.jpeg) + +2 Due to their format, text and native files in the bates range SDNY\_00008724 – SDNY\_00013257 do not bear a physical "CONFIDENTIAL" stamp. The files are nevertheless classified as confidential under the protective order. + +| | SDNY_000 13258 — SDNY_000 13324 | Confidential | +|------------------------|---------------------------------|----------------------| +| I sSDNYy | : 000 13325 4 | — Confidential | +| D I I | | 24 | +| I sSDNYy | __0001134295 — | Confidential | +| I sSDNY_000173473501 I | y_ | — Confidential | +| Ss | Y_00011775627 | — Confidential | +| DNNt I | 77 | | +| I sDNy_ SD | Y0001776871 | — Confidential | +| I I SDNY_00017772 | | Attorney's Eyes Only | + +Additionally, the Government is producing he following materials only to your client: + +| Description | Bates Numbers | Classification Pursuant to Protective Order | +|-------------|-------------------------------------|---------------------------------------------| +| | SDNY_MT_00000177 – SDNY_MT_00000197 | | +| | SDNY_MT_00000198 – SDNY_MT_00000205 | | +| | SDNY_MT_00000206 – SDNY_MT_00000210 | | +| | SDNY_MT_00000211 | | + +Very truly yours, + +AUDREY STRAUSS Acting United States Attorney for the Southern District of New York + +By: /s/ + +Assistant United States Attorneys \ No newline at end of file diff --git a/marker2/ds9/EFTA00084755/EFTA00084755.metadata.json b/marker2/ds9/EFTA00084755/EFTA00084755.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8c126d7ff20d5a251cde3fd70473bb0c46a5874a --- /dev/null +++ b/marker2/ds9/EFTA00084755/EFTA00084755.metadata.json @@ -0,0 +1,162 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084755.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3120, + "elapsed_seconds": 5.88, + "image_assets": [ + "_page_0_Picture_110.jpeg", + "_page_0_Picture_121.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 318.85200000000003, + 24.299999999999997 + ], + [ + 461.448, + 24.299999999999997 + ], + [ + 461.448, + 38.88 + ], + [ + 318.85200000000003, + 38.88 + ] + ] + }, + { + "title": "BY USAfx", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 167.67000000000002 + ], + [ + 126.68399999999998, + 167.67000000000002 + ], + [ + 126.68399999999998, + 181.44 + ], + [ + 68.544, + 181.44 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 31 + ], + [ + "Text", + 15 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageFooter", + 4 + ], + [ + "Picture", + 3 + ], + [ + "Table", + 2 + ], + [ + "Footnote", + 2 + ], + [ + "PictureGroup", + 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", + 98 + ], + [ + "Line", + 40 + ], + [ + "Text", + 6 + ], + [ + "Table", + 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/EFTA00084755" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084755/_page_0_Picture_110.jpeg b/marker2/ds9/EFTA00084755/_page_0_Picture_110.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..066a41ec2314740d55b2c303b5f957edcf6b2977 --- /dev/null +++ b/marker2/ds9/EFTA00084755/_page_0_Picture_110.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:40fd7ddf379cd2fcf0d6e170fe40bbb2fc0f672ea43ad125d07850984864438d +size 3022 diff --git a/marker2/ds9/EFTA00084755/_page_0_Picture_121.jpeg b/marker2/ds9/EFTA00084755/_page_0_Picture_121.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..15f960917de2f3c2b338bfb70d8e59fc5eb52111 --- /dev/null +++ b/marker2/ds9/EFTA00084755/_page_0_Picture_121.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:49606bd3902c4c0069f14e3558103b0abc909d9f39b25996cd4a0b3e5549c572 +size 15895 diff --git a/marker2/ds9/EFTA00084757/EFTA00084757.md b/marker2/ds9/EFTA00084757/EFTA00084757.md new file mode 100644 index 0000000000000000000000000000000000000000..17138a3e6afa9094fecffc43498e3dce379b3158 --- /dev/null +++ b/marker2/ds9/EFTA00084757/EFTA00084757.md @@ -0,0 +1,51 @@ +From: ' To: ' Cc: + +Subject: RE: Grand Jury Materials for Federal Investigation + +Date: Thu, 15 Oct 2020 20:49:23 +0000 + +Hi a + +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 KBursteinamypalmbeachclerk.com + +Clerk & Comptroller Palm Beach County Serving the Citizens of Palm Beach County 301 N. Olive Ave., 9th Floor ch, FL 33401 Direct + +www.mypalmbeachclerk.com + +Tell us how we're doing at www.mypalmbeachclerk.com/survey. + +;,,'http://www.twitt er.com/ClerkPBC Ihttp://www.face book.com/ClerkP ;Lihttp://www.myp almbeachclerk.co + +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: + +Sent: Thursday, October 15, 2020 4:25 PM + +To: + +Cc + +Subject: Grand Jury Materials for Federal Investigation + +\*\*\*\*\*\* Note: This email was sent from a source extemal 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/EFTA00084757/EFTA00084757.metadata.json b/marker2/ds9/EFTA00084757/EFTA00084757.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f549864f55394e3865b2063fd1caf9b1e5ee9536 --- /dev/null +++ b/marker2/ds9/EFTA00084757/EFTA00084757.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084757.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2734, + "elapsed_seconds": 0.95, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 80 + ], + [ + "Line", + 39 + ], + [ + "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", + 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/EFTA00084757" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084759/EFTA00084759.md b/marker2/ds9/EFTA00084759/EFTA00084759.md new file mode 100644 index 0000000000000000000000000000000000000000..dd3e86ae8c801bd98288ee320ff7d07614ea0136 --- /dev/null +++ b/marker2/ds9/EFTA00084759/EFTA00084759.md @@ -0,0 +1,11 @@ +To: + +Subject: Epstein + +Date: Tue, 18 Dec 2018 19:08:56 +0000 + +Importance: Normal + +■just **FYI, we are going to start contacting attorneys for the victims to set up interviews.** + +**Sent from my iPhonc** \ No newline at end of file diff --git a/marker2/ds9/EFTA00084759/EFTA00084759.metadata.json b/marker2/ds9/EFTA00084759/EFTA00084759.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..640758ce2275f6784260789918347ddb76c85338 --- /dev/null +++ b/marker2/ds9/EFTA00084759/EFTA00084759.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084759.pdf", + "engine": { + "marker_major": "2", + "marker_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": 203, + "elapsed_seconds": 0.43, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 16 + ], + [ + "Line", + 8 + ], + [ + "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/EFTA00084759" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084760/EFTA00084760.md b/marker2/ds9/EFTA00084760/EFTA00084760.md new file mode 100644 index 0000000000000000000000000000000000000000..b1059b597da2051e6154d2e9ec71b39ba39ac5bc --- /dev/null +++ b/marker2/ds9/EFTA00084760/EFTA00084760.md @@ -0,0 +1,47 @@ +To: + +Subject: FDIC Staffer `Accidentally' Took Bank Secrets, Jury Told + +Date: Wed, 05 Dec 2018 09:51:49 +0000 + +![](_page_0_Picture_4.jpeg) + +aw360 White + +Collar WHITE COLLAR + +## The Data-Driven Lawyer + +I + +Meet the 2018 award winners and get insights into their innovative practices. mi! + +Wednesday, December 5, 2018 ;Follow Law360 + +## TOP NEWS + +![](_page_0_Picture_12.jpeg) + +![](_page_0_Picture_13.jpeg) + +## Epstein Ducks Victim Testimony With Eve-Of-Trial Settlement + +Convicted billionaire sex offender Jeffrey Epstein on Tuesday settled a dispute with the attorney who represented his teenage victims, avoiding a trial that was to have featured testimony from the women. Read full article + +![](_page_0_Picture_16.jpeg) + +![](_page_0_Picture_17.jpeg) + +c 1Law360 b Pro Say Podcast + +![](_page_0_Picture_19.jpeg) + +Listen to our new podcast here + +![](_page_1_Picture_5.jpeg) + +NOTE: ALL TOPOGRAPHIC FIGURES ARE SUBJECT TO THE FOLLOWING CONDITIONS: THEY MUST BE TAKEN TO THE NEXT PLANTATION AND ARE TO BE PRESERVED AS PRESENT UNTIL THEIR RECORDED INFORMATION IS REVIEWED. + +![](_page_2_Picture_0.jpeg) + +![](_page_3_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084760/EFTA00084760.metadata.json b/marker2/ds9/EFTA00084760/EFTA00084760.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9bb97f2613cb4577cf0e6e9c9b08a7907f9a670f --- /dev/null +++ b/marker2/ds9/EFTA00084760/EFTA00084760.metadata.json @@ -0,0 +1,236 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084760.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + 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sha256:8d24fbb9a074675528579f6d84ead99f40f25f1fc73ca7d7beb06a98a9782c17 +size 38237 diff --git a/marker2/ds9/EFTA00084764/EFTA00084764.md b/marker2/ds9/EFTA00084764/EFTA00084764.md new file mode 100644 index 0000000000000000000000000000000000000000..cd7f5622b0dffda486688e0fb18daa103c956a50 --- /dev/null +++ b/marker2/ds9/EFTA00084764/EFTA00084764.md @@ -0,0 +1,21 @@ +From: ' To:" Cc: ' ligisIYS)" >, ' (USANYS)" + +Subject: RE: Question re AJN/Maxwell Suppression Hearing + +Date: Tue, 15 Jun 2021 18:19:28 +0000 + +Attachments: !Memo\_of Law\_ISO\_Motion\_to\_Suppress\_Evidence\_Obtained\_from\_BSF\_Subpoent(Un redacted).pdf; Ex.\_D\_Sealed.pdf; Ex.\_E\_Sealed.pdf; Ex.\_G\_Sealed.pdf; !Memo\_of Law\_ISO\_Motion\_to\_Suppress\_BSF\_Subpoena\_Under 4A,\_5A,Martindelli Unredacted).pdf; 2021.02.26\_Govemment\_Omnibus\_Opposition\_to\_Maxwell\_Defense\_Motions\_FINAL\_U NREDACTED.pdf; Exhibit\_6.pdf; Exhibit\_7\_(Confidential).pdf; Exhibit\_4.pdf; Exhibit\_5\_(Confidential).pdf + +Per our discussion, I am attaching: (1) Maxwell's two briefs raising the suppression argument; (2) the transcript of the McMahon proceedings and her opinion (Ex D, E, G); (3) our brief (see pp 59-115); and (4) the exhibits we attached to our motion (Ex 4-7). Judge Nathan has said that she will resolve the suppression motions "at a later time" ahead of trial. Thanks very much. + +From: Sent: Tuesday, June 15, 2021 10:09 AM To: Cc: (USANYS) ; Subject: RE: Question re AJN/Maxwell Suppression Hearing (USANYS) + +Sure, set a time other than 2:00. I'm in the office. Or Webex + +From: Sent: Tuesday, June 15, 2021 9:11 AM To: Cc: (USANYS) ; Subject: Question re AJN/Maxwell Suppression Hearing (USANYS) + +Hi ME, + +We had an issue come up related to the upcoming suppression hearing (no date set yet, although we expect one) related to that we'd like your thoughts on. Let us know a convenient time to stop by over the next few days, thanks. + +U.S. Attorney's Office Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00084764/EFTA00084764.metadata.json b/marker2/ds9/EFTA00084764/EFTA00084764.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4198c047ace15b5ae24faf38a349cebf56d066b0 --- /dev/null +++ b/marker2/ds9/EFTA00084764/EFTA00084764.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084764.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1597, + "elapsed_seconds": 0.67, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Line", + 36 + ], + [ + "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/EFTA00084764" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084765/EFTA00084765.md b/marker2/ds9/EFTA00084765/EFTA00084765.md new file mode 100644 index 0000000000000000000000000000000000000000..1e60a00f52aded627a5994b5007d69a274289000 --- /dev/null +++ b/marker2/ds9/EFTA00084765/EFTA00084765.md @@ -0,0 +1,439 @@ +## EXHIBIT D + +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x + +In re: Grand Jury Proceedings + +Before: + +x + +Ex Parte Conference + +New York, N.Y. March 26, 2019 4:04 p.m. + +HON. COLLEEN McMAHON, + +District Judge + +## APPEARANCES + +GEOFFREY S. BERMAN United States Attorney for the Southern District of New York BY: Assistant United States Attorney + +1 (In the robing room) + +2 3 THE COURT: The following proceeding is being conducted ex parte and under seal. + +4 5 6 7 8 The problem is, it's not being conducted in a matter, and that is one of my first questions to Mr. : Why was this not filed on the Court's docket with a miscellaneous number? We don't file things under U.S. Attorney numbers. This should have been brought as a miscellaneous matter. + +9 10 MR. : So, your Honor, it was originally submitted with Judge Sweet -- + +11 12 13 14 15 16 17 18 19 THE COURT: I understand what he did, but I will tell you that in the opinion that will never issue, because Judge Sweet died, but he had written, and now I'm stuck with this, Judge Sweet questioned why you had not made this an "In re: The Matter of Application of the Grand Jury" or something or other, with a proper miscellaneous docket number. The fact that it would have gone to Judge Sweet doesn't mean anything. I have no way to docket USAO No. 2018R01618. That's your reference number, not ours. + +20 21 22 MR. : I understand, your Honor. I think we had understood that the submission should be made to the court that had entered the protective order and that -- + +23 24 THE COURT: That's true, but that doesn't mean it doesn't get a miscellaneous docket number. + +25 The first thing that's going to happen, this is going + +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 + +to be re-legended and it's going to get a miscellaneous docket number. + +MR. : Understood, your Honor. I apologize for that oversight. + +THE COURT: It's okay. + +All right. Now my second question, which is a procedural question, the government here has moved for relief on behalf of a third party to whom a grand jury subpoena has issued, and that third party would like to be relieved of its obligations under the protective order, and that third party is a law firm full of brilliant lawyers that are fully capable of making a motion bringing a proceeding to be relieved from the provisions of the protective order. Why are you doing this for them? + +Why doesn't Boies Schiller make an application for permission to be relieved from the protective order? Because it thought it was going to violate some duty that it had to its client in the underlying actions? Did they give you a reason why they weren't willing to come to court and -- + +MR. : No, your Honor. So I can't speak to why Boies Schiller in particular didn't make their own application. + +THE COURT: Because I understand that you don't think that Martindell is applicable here, but I do, and now I'm the judge. I wish I weren't. You know that the Second Circuit has + +1 2 3 4 very clearly said that, and Judge Broderick said in Chemical Bank the proper procedure is for somebody to make a motion to be relieved from the terms of the protective order. And it ain't you; it's somebody who's subject to the protective order. + +5 + +6 7 MR. : I think a little bit of context may help explain how the procedure developed, your Honor. + +8 9 10 Originally we had submitted an All Writs Act application to Judge Sweet, which we believe was appropriate given the sort of catch-all function of that -- + +11 12 13 THE COURT: Yes, I understand that, but it still has to have a docket number in order to be a proceeding in this court. + +14 15 16 17 18 19 MR. : Totally understand, your Honor. But just with respect to our supplemental submission, Judge Sweet had reached out to us and asked us to submit an argument in connection with our application, and so I think whether that was sort of past experience or his preference, that is why we proceeded -- + +20 21 22 23 24 25 THE COURT: So here's why I'm being so persnickety. Forgive me. Not only do I have to like come up to speed pretty quickly, but you know -- I assume you know, but I certainly know, and everybody who follows civil litigation knows -- that Judge Sweet is about to get reversed in connection with this protective order in the Second Circuit. I mean, I don't have + +1 2 3 4 5 6 7 8 9 10 11 12 that on any authority other than my reading of the tea leaves after the extensive press reporting and the fact that the Second Circuit has already issued an order giving the parties until last week to say why the summary judgment papers and all the supporting papers should not be unsealed by the Second Circuit and indicating that there would be a further order with respect to all the rest of the, I don't know, 150 or so sealed documents in connection with the underlying litigation, but you can hear it in the questioning, you can read it in the press reports, you can intuit it from the order. I don't know if you've seen the Second Circuit's order that issued last week, but -- + +13 MR. : I have, your Honor. + +14 15 16 17 18 THE COURT: Okay. You can intuit that something kind of unfavorable to Judge Sweet is happening, it's in the process of happening, it seems to me it's about to be happening, in connection with this protective order and its enforceability. Doesn't seem that way to you, Mr. + +19 20 MR. : Your Honor, I've read the same articles and -- + +21 THE COURT: I mean, really, Mr. + +22 23 24 25 MR. : So I would say, your Honor, that I would expect that any order to disclose materials that were filed in connection with, for example, the summary judgment papers, if in fact they are released or if in fact the + +1 2 3 protective order is overturned in some way, that those would be redacted as to individuals' names, personally identifying information + +4 THE COURT: Probably. + +5 MR. : -- which I would expect, your Honor. + +6 7 8 I don't believe that any indication is that the underlying discovery materials are likely to be unsealed, and I'm not sure whether that's at issue, but in any event -- + +9 10 11 12 13 14 15 16 THE COURT: I don't think it is. I think the only thing that's at issue in the case that the Second Circuit has heard is the publicly -- only here, not publicly -- filed litigation documents, which is essentially a lawsuit, a libel action that has been filed and litigated under seal. It was settled by terms that would have expired because the protective order doesn't extend until it goes on to a trial, but there wasn't a trial. + +17 And I'm struggling with this for two reasons. + +18 19 20 21 22 23 24 25 First of all, it's like how much deference to give to this protective order that was issued by some judge, not myself, on the basis of I don't know what, except that from the questions that the Second Circuit asked about the litigation documents, it seemed like they were being critical of Judge Sweet for not having a particularized inquiry into each document that was sought to be filed in accordance with the protective order as to why this contained confidential + +1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 information and what was confidential about this, and just reading the tea leaves, I'm thinking to myself, what am I supposed to do with this protective order that looks like it stands on precarious footing to begin with? Is this the so-called improvidently granted protective order? How could I know that? I'm trying to go back in the files to see what Judge Sweet relied on in granting the protective order. I have no idea if there was an opinion. Ihave no idea if there was -- I mean, he recited the magic words at the beginning of the protective order. But, you know, he was doing this for five years, and he's dead, and I can't ask him. And his law clerks weren't around when he did it, although they're trying to help me find stuff in the files. So I'm just trying to figure out if there's something that's going to happen in the Second Circuit that would help you out here or that would further your investigation in a way that would make it not necessary to deal with it. + +18 19 20 21 MR. : Your Honor, I'm very sympathetic to that consideration. I think that even were the Second Circuit to unseal the entirety of what I believe is at issue, which is, as the Court noted, as the Court just noted + +22 23 24 25 THE COURT: 150 litigation documents, and I don't think the Second Circuit is going to take the time that would be required to make the inquiry. I'm going to guess that, you know, some poor schlub in the district court is going to have + +1 to do that. And I hope it's not me. But -- + +2 3 4 5 MR. : And I believe it will apply to the docketed filings in the case and not, for example, the underlying discovery materials, deposition materials, investigation materials. + +6 THE COURT: Okay. + +7 8 9 10 11 12 MR. : And so I think that, unfortunately, for the circumstances, for perhaps all of us, that even were the Second Circuit to grant sort of the most expansive invalidation of the protective order or sort of release of these materials, that our application would still be relevant and pending and active. + +13 14 THE COURT: Would still be relevant and pending and active. Okay. + +15 16 17 18 19 20 21 22 23 24 25 And you can't explain to me why Boies Schiller didn't make a motion. Because there's no question in my mind that were this to be disclosed to the parties -- and I appreciate that we're not going to do that, but were this to be disclosed to the parties, Maxwell would protest, and the first thing that Maxwell would do would be to say the government lacks standing, it's not a party of the protective order, the issue can be litigated, if Boies Schiller chooses to make a motion to seek to be relieved from the protective order, or to quash the subpoena or to do something, but the government has no standing. it hasn't moved to intervene in the civil action. + +1 2 3 4 5 6 7 It hasn't done any of those things. So under Martindell, the government lacks standing, because remember, in Martindell, the government only had standing because all the parties were familiar with the government's application. It wasn't a secret. I don't know why it wasn't a secret, but it wasn't a secret. And nobody objected. And so they said, ah, okay, objection to standing waived. + +8 9 10 11 12 13 14 So, you know, once again, Judge Sweet, I can tell you, was somewhat troubled by the procedural posture of the case even though, as I understand it, he was perhaps partly to blame for the procedural posture of the case, but it's not like Boies Schiller came in here and asked for relief from the protective order. And I am curious about why Boies Schiller didn't do that. + +15 16 17 18 19 20 MR. : Your Honor, what I can tell you about that is we, the government, thought that we were in a position to make the application via the All Writs Act submission that we originally made, that that would be an appropriate vehicle for the relief that we, as the government, were seeking in connection with the protective order. So I'm not sure -- + +21 22 23 24 25 THE COURT: You're seeking to have a third party, to have Boies Schiller, who were counsel for the plaintiffs in the Maxwell action, be relieved from the protective order, but if there's anybody on this planet who is capable of asking, "Please relieve us from the strictures of this protective + +1 order," it is David Boies and his partners. I mean, really. + +2 3 MR. : I'm sure you're right, your Honor, and -- + +4 5 THE COURT: They don't need the government's protection. + +6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 MR. : Not that I don't begrudge the dozens of hours that I have spent on it in lieu of Boies Schiller, but I think -- and with apologies of perhaps being persnickety myself, but the relief that we are seeking is not precisely to allow Boies Schiller to do something but rather for the modification of the protective order that would then allow that, but we did think that we were able to make the application via the All Writs Act, and I think it was our general understanding from Judge Sweet's response asking us for support for our submission, rather than, for example, denying it based on lack of standing at the outset or simply asking us to have Boies Schiller make the application. I don't know what, if any, difference there would be in terms of the legal analysis from Boies Schiller, but I can say that I think the current posture does allow the government to explain why the investigation is extraordinary in the sense of how other decisions and courts have described it and where we, the government, are better able to explain -- + +24 25 THE COURT: But what do you mean by what you just said? I mean, you have an investigation into an allegation of + +1 2 3 4 5 human trafficking. I have no idea if you're up against a statute of limitations so that I could take the time that really is needed to kind of grapple with the procedural issues, because you haven't told me that you're up against a statute of limitations. + +6 7 8 9 10 11 12 MR. : I can tell your Honor -- I'm sorry. I didn't mean to interrupt. But I can tell you that, as most of our investigations do, this is moving sort of as fast as possible. This was a significant application that we thoroughly considered before making and made originally nearly two months ago, so we are hopeful to get an answer soon. Nevertheless, let me say that -- + +13 14 15 THE COURT: Unfortunately, but for the dead judge opinion and the Supreme Court last month, you would have gotten an answer, but -- + +16 17 18 19 MR. : That said, I would not describe this as an emergency application. There's not a particular day by which we are requesting a response. We had hoped to hear back from Judge Sweet -- + +20 THE COURT: Before. + +21 MR. : Before. Yes, your Honor. + +22 THE COURT: Would that that had happened. + +23 24 25 MR. : And if I may, just very briefly. I think with respect to the postural question, particularly regarding Boies Schiller, Boies Schiller simply isn't in a + +1 2 position to be able to describe the investigation in the way that we have in our submission. + +3 4 5 THE COURT: Well, that's clear. That's clear. I mean, were I Boies Schiller, I would have -- never mind. We won't say what I would have done. + +6 7 8 9 10 11 So I'm looking at the protective order itself, and of course not having been privy to any of the materials in the case -- and they're all under seal, so, I mean, I can dissolve the seal and get them, but there are 150 documents there that are under seal for filings, there are multiple documents that are under seal. + +12 13 MR. : Not to mention all the underlying materials, of course. + +14 15 THE COURT: Not to mention all the underlying materials. + +16 17 18 19 20 21 22 So you argue there isn't any truly confidential material in this, this isn't a trade secrets case, and obviously it's not a trade secrets case. It's a libel case. It would seem that the most scurrilous of accusations would have already floated across the face of the complaint. But since Maxwell can't object, how can I know that all this is about is information that would be, you know, embarrassing? + +23 24 25 MR. : I would point the Court in the first instance to the definition of "confidential materials" in the protective order itself, which describes "confidential + +1 2 3 materials" as "information that is confidential and implicates common law and statutory privacy interests of plaintiff " + +4 5 THE COURT: I have absolutely no idea what that means, and you don't either, and none of us does. + +6 7 8 9 MR. : I don't, your Honor, but I think we argued in our submission that it, at least on its face, does not implicate the type of materials that are confidential business materials, trade secrets -- + +10 THE COURT: Ordinarily the subject of -- + +11 12 MR. : -- ordinarily the subject of the considerations developed in some of the cases that we cited. + +13 THE COURT: Okay. + +14 15 16 17 18 19 20 21 22 MR. : And I should also say that in responding to the subpoena, Boies Schiller has the ability to say that they will not produce certain materials because they are privileged, because they believe that there is some larger overarching confidentiality issue, at which point we would be in a different posture. I am not aware that they have identified any materials as confidential that they would withhold, but I do note that we would not ask for and would not expect to receive privileged materials. + +23 24 THE COURT: Okay. Did you provide Judge Sweet with a proposed order? + +25 MR. : We did, yes, your Honor. + +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 + +THE COURT: Could I see what you provided Judge Sweet. + +MR. : Yes, of course. + +And your Honor, just for the record, I'm handing over what was our initial sealed affirmation and application to the Court for an order under the All Writs Act, and that includes an affirmation and application that I signed with an exhibit attached of the original protective order, followed by which is a proposed order for entry by Judge Sweet, which we of course would be happy to submit to the Court in Word form or in revised form, subject to the Court's views. + +THE COURT: Right. I just wanted to see if it had a certain provision. + +MR. : If there is a provision that the Court thinks would address some of these issues, we would of course be happy to hear it. + +THE COURT: Of course I'm not Judge Sweet, so I don't know exactly what was going on in his head. + +I assume it would be the government's position that reliance on the nondisclosure of confidential materials to law enforcement in connection with a grand jury subpoena that has been duly authorized would be unreasonable. It wouldn't be reasonable reliance to assume that the protective order could never be modified to allow -- I mean, the parties to this negotiated the protective order, and the protective order does not contain the provision that is in every protective order I + +1 2 3 sign, which is, you can disclose it without the permission of the Court if, you know, law enforcement puts a gun to your head and says produce it. That's not in here. + +4 MR. : That's right, your Honor. + +5 6 THE COURT: I don't know. It's my understanding that it may have been negotiated out. + +7 8 9 10 11 MR. : It may have been. I will only say that I believe that I'm on less firm ground than in the cases that we discussed specifically, but I believe that the converse would be void for public policy; in other words, you would not be able to put in -- + +12 THE COURT: That was my question. + +13 14 MR. : -- you may not disclose this to law enforcement even given a duly authorized grand jury subpoena. + +15 16 17 18 19 20 21 22 THE COURT: Thank you for saying the words "void for public policy," because I was going there. I take it it would be the government's position that because it would be void as against public policy to absolutely prohibit the disclosure of information to law enforcement, that if a party were to say, "But I relied on this, that it would not be disclosed to law enforcement," that that would not, in your view, be reasonable reliance. + +23 24 25 MR. : Yes, your Honor, I think that's correct, and I think that that is borne out by the opinion in Chemical Bank, which essentially says: You should have asked, + +1 2 3 4 but of course this is fine for you to disclose this information to the government based on the validly issued grand jury subpoena, I think for the same type of reasons that the Court is describing. + +5 6 THE COURT: Okay. So let me see what other million questions that I have. + +7 8 9 10 11 12 13 14 15 16 17 18 19 It's a general subpoena. Did you take them for all discovery materials? I mean, everything that's in Boies Schiller's files, other than privileged documents, which of course you don't exclude from your subpoena but presumably they will exclude from their production. But it's literally everything. So remember, I know very little about the Maxwell case, both because it wasn't my case and, to the shock of nearly everyone that I talk to, we're all too busy to worry about some litigation that's being handled by somebody else; and second, it seems to have been litigated entirely under seal so how could I have found out anything about it. Everything I know about this case I learned from reading about the Second Circuit argument. Literally, everything. + +20 21 22 23 24 25 So what assurance do I have that so broad a grand jury subpoena -- given that I have these competing interests between the terms of the protective order and the government's interest in conducting an investigation, what assurance do I have that you need all that stuff, that that's all somehow going to be relevant to your investigation? That is a concern from me + +1 because I don't know anything about the case. + +2 3 4 5 6 7 MR. : Okay, your Honor, and I think the answer to that is in a couple parts. The first is, I would point the Court towards some of the opinions that have talked about the government's investigative ability and authority being broad, and it is the case that sometimes we issue grand jury subpoenas -- + +8 THE COURT: But that was true in Martindell too. + +9 10 11 12 13 14 15 16 17 18 19 MR. : Yes, of course, your Honor, but I just need to say that it is entirely possible that, in any grand jury subpoena, that materials will come back that are not helpful to our investigation, are not relevant, for whatever reason, that it was, however unintentionally, overbroad or included unnecessary aspects. Here, we are essentially unable to significantly narrow the request for information in part for exactly the reasons that you describe. We have either little or no additional information than the Court does in terms of what materials there are, who was deposed, and that is in marked contrast to some of the other cases. + +20 THE COURT: Every other case in the whole world. + +21 22 MR. : Of course, your Honor. Exactly. For exactly the reasons we described. + +23 24 25 So what I can say in terms of assurance is, we are not sort of an ordinary third-party intervenor. All of these materials will be subject to the extraordinary protections of + +1 2 3 4 5 Rule 60. We will be extremely restricted in our use of them. To the extent that we receive materials that otherwise wouldn't have been narrowly connected with our investigation, they will not go anywhere that they shouldn't; they will not be treated in any way they should not be. + +6 7 THE COURT: Let me ask a question that you may not wish to answer, and I'll appreciate it if you don't. + +8 9 10 11 I know who the target of your investigation is, at least the one that you've identified. Is there any expectation that these materials would be used to commence criminal proceedings against either of the parties to the libel case? + +12 13 14 15 16 17 MR. : I can say that just as a general matter, that any materials that we gather in any part of any investigation that appear to give rise to criminal liability for individuals implicated in those materials could cause us to proceed with an investigation of any such individual. That's a little broad, your Honor, obviously, but -- + +18 19 THE COURT: Oh, no. I understand what you're saying. And I think Judge Sweet had some concerns about that. + +20 21 22 MR. : But I don't think that there's any additional protection for the parties of the lawsuit as opposed to nonparties' information. + +23 24 25 THE COURT: They're the ones who relied on the protective order. Of course you say it's not reasonable to rely, but they're the ones who relied on the protective order + +1 2 3 4 5 in order to give whatever in discovery they gave, whether it was deposition testimony they gave or -- then again, I can't fathom why anybody who has any criminal exposure would not have taken the Fifth Amendment in response to questions in a civil deposition, but I don't know. + +6 7 8 9 10 11 12 13 14 15 MR. : So just taking that very briefly in order, your Honor, I do not know, but I think it is entirely possible that what we are seeking is page after page of people taking the Fifth. That is entirely possible. But to the extent that it is not or there are other materials -- and this may be bad for our argument, but in all transparency and candor, I think there may be other individuals who also relied on the protective order. In other words, anyone other than the parties who were deposed may have, in theory, and perhaps unreasonably, relied on it. + +16 17 THE COURT: For example, the target of your investigation. + +18 19 20 21 22 23 MR. : For example, the target of our investigation. But I don't think that the parties would be differently situated in terms of their rights, and there are certainly many cases that talk about how the government has the ability to grant immunity in a criminal investigation, but not, of course, through restricting materials -- + +24 25 THE COURT: But that's the whole point of the government needing to follow the procedure, the proper + +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 + +procedure of either having the target of the subpoena make a motion to quash or a motion for relief or the government moving for relief to intervene, instead of engaging in self-help. There isn't an application like this in any case except the Chemical Bank case, and in the Chemical Bank case, it all was ex post facto and it all happened. + +MR. : Right. And I'll just note, without wanting to be defensive at all about the posture -- I understand the Court's questions about that -- I cannot recall whether it was Martindell or one of the other cases, but one of the original cases in this line, one of the issues was that the court had gotten on the phone with the judge and requested it, you know, sort of informally, right? + +THE COURT: Yes. + +MR. : Despite our errors in the precise procedure, we did want to have a formal application with reasons and then subsequently, at the request of Judge Sweet, supporting law. And so I do apologize for the precise posture. We took the approach that we did in the hopes that we could avoid the types of problems that had been engendered by other types of applications which I think were made by the government in other cases, and so that's what we did here as well. + +THE COURT: Okay. All right. Well, I'll tell you one thing that I am going to do. I am going to ask the clerk of the court to assign a miscellaneous number to this case and + +1 2 3 4 5 everything will be filed under seal, and it will be "In Re Grand Jury," you know, the usual, and it will have the treatment that "In Re Grand Jury" materials get, and everything will be filed under seal. But that way I at least have a place to put this, okay? + +6 7 8 9 10 MR. : I appreciate that, your Honor. I think we had expected that had the order been either granted or denied, that consistent with our usual All Writs application, that it would have then been identified with a number, but frankly, I'm not in the clerk's office, so -- + +11 12 13 14 15 16 17 18 19 THE COURT: Okay. But it has to have one, and I'm particularly acutely desirous of making sure that this is filed under a docket number with this court because I am concerned about the way everything has happened to date, given the Second Circuit's kind of, it seems to me, obvious displeasure with the fact that this whole thing has been litigated under seal. So grand jury material, absolutely. But let's be sure that there is a docket, you know, that we don't have something that's off the radar screen. + +20 21 MR. : Totally understood, your Honor, and I appreciate that, and we're grateful to the Court for that. + +22 23 24 THE COURT: Great. Okay. And you'll get your answer by early next week. I have to go to the annual meeting of the chief district judges. + +25 MR. : I don't envy the Court that. + +THE COURT: It would be fine, but my biggest problem, frankly, is I don't know when Judge Sweet's funeral is and I'm trying to figure out when I need to be here for Judge Sweet's funeral. + +MR. : We're very grateful -- + +THE COURT: This goes to the top of the pile. I appreciate that this should have been dealt with sooner, and I'm sorry that it wasn't dealt with a week sooner or you would have had an answer. + +MR. : We're grateful for the Court's attention and certainly appreciate the opportunity to explain how we ended up here. + +THE COURT: Okay. 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Sent: Tuesday, March 8, 2016 12:28 PM To: Cc: Subject: RE: + +If you haven't already seen it, the Lag reported today on Jeffrey Epstein's continued relationships with young women. + +htto•//oagesix com/2016/03/08/jeffrey-eosteins-east-side-mansion-houses-russianplaymates/ + +Best, Pete + +From: Peter Skinner Sent: Monde February 29, 2016 10:13 PM To: Cc: Sigrid McCawley Subject: Re: + +am adding Lo this email chain as well. As we mentioned earlier today, Sigrid is one of the lead attorneys on the case and knows both and the facts very well. Please include Sigrid in any follow-up that you may. + +Best, Pete + +From: Date: Monday, February 29, 2016 at 10:03 PM To: + +Cc + +Subject: + +Thank you again for meeting with us today. We very much appreciate your time. I am attaching the following documents for your review: + +- 1. Complaint in the defamation case against Ghislaine Maxwell (just today, Judge Sweet denied Maxwell's motion to dismiss today); +- 2. Declarations that filed in the CVRA case; +- 3. The Rule 56.1 statement recently filed in the CVRA case; +- 4. The redacted 302 + +Please let us know what other information we can provide or if you have any further questions. + +Best, + +Pete + +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 errci, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. tv.1] \ No newline at end of file diff --git a/marker2/ds9/EFTA00084788/EFTA00084788.metadata.json b/marker2/ds9/EFTA00084788/EFTA00084788.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9c476e9de3d2b3e9028fad83bd964bf61df728d2 --- /dev/null +++ b/marker2/ds9/EFTA00084788/EFTA00084788.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084788.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2072, + "elapsed_seconds": 0.6, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "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 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 19 + ], + [ + "Text", + 9 + ], + [ + "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/EFTA00084788" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084790/EFTA00084790.md b/marker2/ds9/EFTA00084790/EFTA00084790.md new file mode 100644 index 0000000000000000000000000000000000000000..a66fbc9d773004b7e81ccb092c8d6c763aeb5b9a --- /dev/null +++ b/marker2/ds9/EFTA00084790/EFTA00084790.md @@ -0,0 +1,41 @@ +From: + +To: + +Subject: FW: Contact Info Daniel Siad (from Brunel) + +Date: Thursday. December 6. 2018 1:40:33 PM + +Attachments: 7016050? 191023 resiyed fog + +FYI + +From: + +Sent: Tuesday, May 3, 2016 12:02 PM + +To: + +Cc: + +Subject: Fwd: Contact Infc + +Yesterday I spoke of whorri l describes as a "scout" or recruiter of girls and/or women for J. Epstein. Attached to this incoming email from Brunel is the contact information he has for + +Best regards, + +Stan + +From: + +To: + +Sent: 5/3/2016 11:13:15 A.M. Eastern Daylight Time + +Subj: (no subject) + +Sent from my Samsung Galaxy smartphone. + +![](_page_1_Picture_0.jpeg) + +CONFIDENTIAL \ No newline at end of file diff --git a/marker2/ds9/EFTA00084790/EFTA00084790.metadata.json b/marker2/ds9/EFTA00084790/EFTA00084790.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1996a7b6ba0435bd2aff52d35a8b21187daf5991 --- /dev/null +++ b/marker2/ds9/EFTA00084790/EFTA00084790.metadata.json @@ -0,0 +1,86 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084790.pdf", + "engine": { + "marker_major": "2", + "marker_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": 613, + "elapsed_seconds": 1.18, + "image_assets": [ + "_page_1_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Text", + 24 + ], + [ + "Line", + 23 + ] + ], + "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 + ], + [ + "Picture", + 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/EFTA00084790" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084790/_page_1_Picture_0.jpeg b/marker2/ds9/EFTA00084790/_page_1_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..f15a3851d1a0afff700623b84023bee5eea76c02 --- /dev/null +++ b/marker2/ds9/EFTA00084790/_page_1_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:06d6114bfbdfaca21966be9736a8b89089ffce40e185f92587607f1d7b192501 +size 242132 diff --git a/marker2/ds9/EFTA00084792/EFTA00084792.md b/marker2/ds9/EFTA00084792/EFTA00084792.md new file mode 100644 index 0000000000000000000000000000000000000000..16df4d4757c13edd116440f06066916fe04e4eb6 --- /dev/null +++ b/marker2/ds9/EFTA00084792/EFTA00084792.md @@ -0,0 +1,276 @@ +① + +P. Skinner +Brad Edwards +Stan Pottinger + +2/29/16 + +[REDACTED] (notes) + +Re: + +BE - rep. +SP - rep. + +[REDACTED] + +[REDACTED] + +Long history of litigation + +BE + +- - Int. inv. into Jeffrey Epstein was done by local Palm Beach PD $\Rightarrow$ 2005 +- - randed up app. 24 girls molested by JE +- - represented about 10 girls +- - JE's MO - w/ adults they'd tell B yr. old girl "Came to rich guy's house to give paid massage. JE raked - stars" as massage extraordinary downed of sex acts (i.f. you want & do x). After paid 200/300 - their offered 800-300 finders flee. Victims recruited other victims. Mother complained + involved PD. +- - PD turned case over to FBI + USAD. Most of girls (appr. 40+) in FL. Nuflight (ogs. Issued GJ subpoenas. Epstein + 4 named co-conspirators) +- - Entered into a non pns w/ guilty plea to state cf. to 2001-2007 procury. moral tr prost. + immune fing. fed. pros. for sex crimes comm. in FL. O low 2001 + 2007 +- - Jeny Lefcart, Jay Leftcowitz, Ken Sturr, Roy Black, Martin Winberg, Gry Lewis - never Jeny shared contact +- - SDFL - at of Palm Beach [REDACTED] Alex Arosh US Airty. +- - Limited to FL in pns. + +- - US Attorney has said could be prosecuted elsewhere. +- - Agent under 2255 if victim elect to proceed under 2255 + friend civil remedies Epstein must pay stat. min. 50K or 150K. At least 12 proceeded under that provision + +- - Named [REDACTED] - adult recriter +- [REDACTED] - recruited as minor, became recruiter +- [REDACTED] - recruiter +- [REDACTED] - asst. in NY - recruiters + +Brislaine Mapwell - daughter of Robert Mapwell - head recruiter + +- - Evidence = 2000C [REDACTED] - her case unknown (? time) +- - NO END + +- - One of Epstein's bi, Jean Luc Bunnel, has helped get girls. He is wanting to cooperate. Wouldn't cooperate duny inv. Was served for dep. duny civil case in JUL & he no - showed. In JUL + +- - Bunnel swed JE for obstruction of justice - fold him not to go to deportion. He says lawyer paid by Epstein duped him into missing dep. + +Shill represent [REDACTED] Bunnel hired Joe Titone in Miami for lawsuit. Titone contracted Bond Edwards + two of them met. Bond into Shill to Titone. Titone says her client has photographic entered. Doesn't know ages of girls, maybe yourself, and that Bunnel took photo w/o knowledge of suspects. Titone doesn't know how to handle this Bunnel wants Epstein prosecuted + want it. + +(3) + +- - Bannel doesn't want to implicate himself. +- - recently denied photos to Stan @ Boies Schiller office - Epstein's ably is there. + +- - Bannel told friend Alan UNU that he has photos - made yrs ago. + +lives in Paris + +man + +- - Titane said Bannel has friend named Michele Kadosh in MIAmi - filed + rabbi - said to Titane Bannel told me he has photos. + +- - Kadosh spoke w/ abby in Paris for Bannel who advised him that if he has photos he should destroy them @ once. + +- - Bannel met Stan + Boies together few days later + offered to show computer. Then he canceled + went back to Paris + then to Asia on business. + +- - Hope to go to Paris + have computer inserted by prof. firm. + +Bannel is afraid of being presecuted. + +![](_page_2_Picture_21.jpeg) + +- - retired summer 2000 @ age. 16 [redacted] - about to two 17 + +- - taken to NY for training by Maxwell (Epstein - how to sence men) + +- - in Cini base, got records corr. her as his phone + +- - she goes to private island Little St. James - USVI + +- few mines off st. Am + +- - [redacted] said that in affidavit - sametime happening + +- - 2000-2002 was live in sex slave - svc. Epstein + others. + +- - Promised educ. in major. then + +- @ & told by Epstein too old + +- [REDACTED] + +- filed cont bawsuit in 2015 - defamation. suit against Maxwell + +- she went public by atty. declaration in FL suit. + +- FL suit - probano - crime returns rights ongot - against USAD b/c they didn't intention ails + +- [REDACTED] moved to join those suits + +- in 2011 a British reputer find her + intentioned her about Prince Andrew. Also said met Bill Clinton, -said was Epstein sex slave + +- 2011 was first atty of her. + +- FBI went + intentioned [REDACTED] - FL FBI - + +302 FBI FL wants to pursue inv. + +Agents [REDACTED] + +[REDACTED] + +- was long w/ parents + +- dad worked @ Maralaga + +- dad dropped her off @ Epstein's house + +- family undertolled her to leave. + +- in 2000 Epstein was appr. 402-50s. + +- Dad aborted [REDACTED] + lent her at to dad's bifs. Two men + +- May have sold her swopped daughters @ age 7. Ended after a few years. + +- Sent to family member (aunt) in CA @ 13 + +- she ran away to SF + +- lived w/ parents + ran away again. + +- - long series of events on street in Miami +- - sugar daddy boyfriends as man away + +B/W 13 + 16, picked up in 1998 by Ron Epstein. 11/11/99, picked FBI paternal home, mad her, arrested her, he went just for runage contract. + +@ Josh + +- Noting since 2007 other than FBI Act. + +- - 2010 - civil depos. A Epstein former latter [redacted] Bel. Epstein + Morewell were gays to kill him. Downloaded their blonde book. Board went to FBI, made contacted calls, they arrested him + he went to prison for destruction. Pled to carp. agent + blew dead b/c he was selling. Ak-472s. +- - tried to sell book. Replaced law it all unkept in recorded mtgs. FBI agent ranked +- - [redacted] died in jail. +- - Agent fled afraidant in destruction car. +- - Epstein's lawyers said his property + +1997-2005 flight logs + manifests + +CP - [redacted] + +CP? + +- - Have been told Epstein had photos in base in PB + NY + USVT +- - One photo is a photo of [redacted] w/ another girl - roked + in sexual pose - on his weall - artistic - mistake agents + +- Photos of rated girls on Maxwell's comp. + +\* SW executed an PB house. College of photos included nude girls incl. clients. Epstein topped off. All compters were gone. + +[REDACTED] says camerad all over NY house. She believes they were used for extortion or birn by Epstein. When leaf out to other men had to repair back. + +- Videos recording in bathroom. - recording? security? + +- Maxwell + Bunkel took sexually explicit photos of her regularly + +- Maxwell gave photo to Epstein for body @ age 16. + +- Photo hing in one of the homes + +- Saved as computers. + +[REDACTED] + Bill Renly / Steve Coiraly > Black's investigations + +- Subp. issued for computers + +Registered as sex offender in PL +↳ level 3 + +USMS + +Registered in NY + +Reparty by mute jet + +[Sex acts on planes -] + +Manhattan + +(7) + +Highly probable witness - Hollywood address +[redacted] - abused by Epstein since +age 15. In FC + on planes. + +Naw pregnant + +Chris Armenka - aky or LOA - says she wants +to be not in public about part. + +[redacted] wants prosecution. Naw has children + feels able to do +something about it. + +From 2014/2015, she believed it was summer 1999. +As it turns out, it was summer of 2000. + +She has bewared against Mojavell for defamation. Then +is defease. + +She wants settlement / neg. into non-profit to help girls +in same situation + +- of its net. + +- award of awareness. + +Her father / negotiated a settlement w/ Epstein + she +has a confidentiality provision limiting amount. +Epstein's attorneys reached at + neg. settlement. + +Did EBI search his planes? Did they find hidden +cameras? + +Cancer active pedaphile. + +Pitch to other prosecutors? no + +Book deal? not now + +- 20/20 interview last spring > ABC listed it - lawyers piled it +Bill Clarken "two women not under age @ USN" hat they still +have it + +Have parties of diary + +(8) + +- - Scotland Yard investigation - all about Prince Andrews strategy - will send me contact info. +- - ACTIVE - They audio-recorded interview. +- - They will send me attendants & deportions + +- - Bland, part. size & shape. +- - Wanted to have baby w/ her - +- - Same MO w/ one other crisis - 17 yr. old - emails w/ her +- - As young as 12 but younger the better. + +[REDACTED] emailed Epstein + +Hailand - own charges & handling note w/ name of girl - until by Max well. + +![](_page_8_Picture_18.jpeg) + +**Brad Edwards** +Trial Attorney + +Farmer, Jaffe, Weissing, +Edwards, Fistos & Lehrman, P.L. + +[Redacted] +Fort Lauderdale, FL 33301 +[Redacted] + +[WWW.PATHTOJUSTICE.COM](http://WWW.PATHTOJUSTICE.COM) + +**STAN POTTINGER** + +J. STANLEY POTTINGER PLLC + +[Redacted] + +NEW YORK, NY 10022 USA + +[Redacted] \ No newline at end of file diff --git a/marker2/ds9/EFTA00084792/EFTA00084792.metadata.json b/marker2/ds9/EFTA00084792/EFTA00084792.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c7e40919502113602cedc646395edd429ad889a6 --- /dev/null +++ b/marker2/ds9/EFTA00084792/EFTA00084792.metadata.json @@ -0,0 +1,317 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084792.pdf", + "engine": { + "marker_major": "2", + "marker_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": 8133, + "elapsed_seconds": 8.56, + "image_assets": [ + "_page_2_Picture_21.jpeg", + "_page_8_Picture_18.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "STAN POTTINGER", + 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Mediu Building One Saint Andrew's Plaza New York. New York 10007 + +February 28, 2019 + +### TO BE FILED UNDER SEAL + +## VIA EMAIL + +The Honorable Robert W. Sweet United States District Court Southern District of New York United States Courthouse New York, New York 10007 + +Re: In re Application to Unseal Civil Discovery Materials, USAO No. 2018R01618 + +Dear Judge Sweet: + +The Government writes respectfully in connection with its sealed application and proposed order pursuant to the All Writs Act, Title 28, United States Code, Section 1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP the "A in connection with the matter v. Ghislaine Maxwell, et al. (a), (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. + +# Background + +As described in the Application, the Government has served a grand jury subpoena (the "Subpoena") upon Boies Schiller & Flexner ("Boies Schiller") requiring the production of copies of discovery and related materials related to the Litigation. The Subpoena was validly issued pursuant to an ongoing investigation into Jeffrey Epstein and others, for possible violations of Title 18, United States Code, Sections 1591 and 1594(c) (unlawfully trafficking minors) and Section 2422(b) (unlawfully enticing minors) (the "Investigation"). The production of materials pursuant to the Subpoena is solely for the purposes of the Investigation, and is subject to the protections and restrictions of Fed. R. Crim. P. 6(e). + +The Government has been advised that Boies Schiller, which is counsel for plaintiffs in the Litigation, does not intend to contest the Subpoena. However, the Government is advised that although Boies Schiller would not otherwise contest compliance with the Subpoena, it believes that a protective order entered in the Litigation (the "Protective Order") may preclude compliance. + +Accordingly, the Government respectfully requested that the Court issue an order permitting Boies Schiller to comply with the validly-issued Subpoena. + +# Discussion + +Where, as here, a grand jury subpoena has validly issued, and the recipient of the subpoena is not contesting compliance—but rather seeking authorization to comply with the subpoena—a court should grant such permission through limited modification of an applicable protective order, absent countervailing interests not present in this case. As described below, a court can and should modify a protective order, or permit limited relief from it, to allow the recipient of a grand jury subpoena to comply with such a subpoena under the circumstances presented here. + +The Court is best guided by the decision in Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 (S.D.N.Y. 1994), which rejected an application for a party in civil litigation to be held in contempt for complying with a grand jury subpoena despite the existence of a protective order, without first obtaining authorization from the court, because the court would have granted such authorization had it been sought. Chemical Bank, 154 F.R.D. at 93. As that court explained: + +> The role of the federal courts in law enforcement, exemplified by the Federal Criminal Code (Title 18, USC) and in enforcing Grand Jury subpoenas argues in favor of making significant information available to enforcement authorities absent a countervailing showing that the need for the information for such purposes is outweighed by the need for protecting expectations of confidentiality under Fed. R. Civ. P. 26(c). + +Id. at 94 (citing United States v. Davis, 702 F.2d 418, 421-22 (2d Cir. 1983) (finding that the "conflict between protection of private material used in a civil proceeding and public need in a criminal prosecution" posed in that case was "easily resolved" and explaining that "[a]bsent applicable grounds for exception, such as a previously asserted Fifth Amendment privilege, no shiled protects the civil evidence" in that case "from compellable production before the grand jury which subpoenaed it"). The court in Chemical Bank chastised the relevant party for responding to the grand jury subpoena without authorization specifically because such disregard was "entirely unnecessary and inappropriate" due to the readily available remedy of a modification of the applicable protective order. Chemical Bank, 154 F.R.D. at 93. The court also explicitly noted that such formal judicial approval could be obtained ex pane if sufficient reason for doing so was shown. Id. + +Chemical Bank further described the types of interests that otherwise might be implicated in connection with a Rule 26(c) protective order, none of which are implicated here. Id. at 94 ("There is no indication that any difficult balancing under Fed.R.Civ.P. 26(c) would have been necessary of interests of law enforcement against protection of technological trade secrets, currently sensitive customer lists, or contemporarily sensitive competitive information which could benefit rivals, since no such information has been claimed to have been contained in any of the discovery materials in this case.") (citations omitted).' + +&#x27; Notably, here, and in contrast to other cases further described below, the Government's specific knowledge of the subject matter of discovery materials is relatively limited, due to the confidential nature of the Litigation; however, the Protective Order itself indicates that discovery materials + +Indeed, the Chemical Bank opinion specifically rejected judicial protection for the type of information the Protective Order appears to cover in the Litigation: + +> Avoiding embarrassment may be a reason for a party to seek confidentiality. It is not by itself a valid reason for courts to uphold confidentiality as against a legitimate law enforcement need for the information. Courts must honor restrictions laid down by the Fourt or Fifth Amendment or applicable statutes. But aside from those restrictions, hiding possible criminal violations from law enforcement authorities is hardly a ground for judicial protection of confidentiality. + +Chemical Bank, 154 F.R.D. at 94 (emphasis added). Although parties may rely on confidentiality agreements and protective orders generally, such classification "is not binding on the court" and the "risk of disclosure is well known to the Bar, in part because disclosure may be required where such information is needed for judicial decisions, to the basis for which the public should have access. Id. (collecting cases). + +Under some circumstances, courts in this Circuit have applied a balancing test to evaluate the government's ability to obtain access to materials covered by a protective order. Specifically, in Martindell v. International Tel. and TeL Corp., 594 F.2d 291 (2d Cir. 1979), the government informally—and without use of a grand jury subpoena—sought access to discovery materials from a civil litigation. The Court held that the Government was not entitled to the materials unless it could show either that the protective order was improvidently granted or some extraordinary circumstance or compelling need for the material; see also In re Grand Jury Subpoena Duces Tecum Dated Apr. 19, 1991 ("Subpoena Duces Tecuni"), 945 F.2d 1221, 1224 (2d Cir. 1991) (in connection with bankruptcy proceeding, and citing Martindell, vacating denial of a motion to quash a grand jury subpoena seeking production of documents subject to protective order and remanding for determination of showing that the order was improvidently granted or of extraordinary circumstance or compelling need). + +As an initial matter, the Court need not employ the Martindell balancing test here. This is so for two reasons. First, Martindell and cases employing its balancing test generally relate to motions to quash or other challenges to a grand jury subpoena, or else instances where the Government sought protected information without such grand jury process. See Martindell, 594 F.2d 291 (in which the government informally, and without use of a grand jury subpoena, sought access to discovery materials); Subpoena Duces Tecum, 945 F.2d at 1224 (vacating denial of a motion to quash a grand jury subpoena). Here, there is no such deficiency in the form of request nor a challenge by the recipient of the subpoena. Indeed, in Chemical Bank, which cited + +such as documents and depositions are not likely to include the kind of confidential business information that Chemical Bank describes as having the potential to give rise to "difficult balancing." See id.; see also M, Protective Order ("Prot. Order") (Dkt. 62) at 2 (defining "confidential" information simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). + +Martindell, the district court opined that had the Government obtained judicial relief to issue an uncontested subpoena for documents—precisely the scenario here—such relief would be appropriate. Chemical Bank, 154 F.R.D. at 94. + +Second, any presumption against modification of a protective order is unreasonable where, as here, the protective order is on its face temporary or limited. Such protective orders "that are on their face temporary or limited may not justify reliance by the parties [and] in such circumstances reliance may be unreasonable." S.E.C. v. TheStreet.com, 273 F.3d 222, 230-31 (2d Cir. 2001). "Where a litigant or deponent could not reasonably have relied on the continuation of a protective order"—for example, where such an order was limited to the pretrial stages of litigation—"a court may properly permit modification of the order." Id. (citing In re "Agent Orange" Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987)); see also Allen v. City of New York, 420 F.Supp.2d 295, 301 (S.D.N.Y. 2006) (Mag. J. Gorenstein) (analyzing the differently-situated interests of civil litigants but where, as here, the relevant protective order specified that a party could object to the designation of a document as confidential, and was also temporary or limited on its face). In such a case, "'[w]hether to lift or modify a protective order is a decision committed to the sound discretion of the trial court."' TheStreet.com, 273 F.3d at 231 (modification in original) (citing In re Agent Orange, 821 F.3d at 147) (additional citations omitted). Here, the parties in the Litigation explicitly contemplated the public disclosure of such information at trial by the very terms of the Protective Order, thereby establishing precisely the kind of temporal limit described above. See Prot. Order at 5 ("This Protective Order shall have no force and effect on the use of any CONFIDENTIAL INFORMATION at trial in this matter."). The parties could not have—as, for example, they might in a bankruptcy proceeding such as in Subpoena Duces Tecwn—relied upon the Protective Order to indefinitely keep the relevant materials hidden. + +In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counsel for the victims of the suspected crimes being investigated have indicated a willingness to voluntarily comply with the Subpoena, the "sound discretion of [this] court," TheStreet.com, 273 F.3d at 231, militates overwhelmingly toward limited, narrow modification of the Protective Order to permit compliance with the Subpoena.2 This is consistent with the grand jury's "wide ranging authority to inquire into suspected violations of the criminal law; and to effectuate such investigations it may compel the production of documentary evidence or the testimony of witnesses, as it deems necessary." Id. at 421-22; see Branzburg v. Hayes, 408 U.S. 665, 688 (1972) ("Although the powers of the grand jury are not unlimited and are subject to the supervision of a judge, the longstanding principle that `the public . . . has a right to every man's evidence,' except for those + +2 The Government notes that any materials produced pursuant to a grand jury subpoena fall under the protections and restrictions set forth in Fed. R. Crim. P. 6(e), and further notes and emphasizes that the proposed order accompanying the Application provides no additional exception or modification to the Protective Order as to the recipient of the subpoena other than the narrow, limited ability to comply with grand jury process. The Protective Order will remain otherwise intact and fully enforceable. + +persons protected by a constitutional, common-law, or statutory privilege is particularly applicable to grand jury proceedings.") (citations omitted)? + +Finally, even were the Court to apply the Martindell test here,4 despite the significant distinguishing factors described above, this Investigation is a paradigmatic example of extraordinary circumstances. In the first instance, unlike in Subpoena Duces Tecum, the posture of the Application does not involve a motion to quash. Of course, should this Court permit Boies Schiller to respond, Boies Schiller would have the right to move to quash—including, for example, if a grand jury subpoena made any improper requests, such as for materials subject to privilege. But it is not anticipated that Boies Schiller will do so. + +Additionally, as set forth in the Application, the existence and scope of the Investigation in this district is not publicly known. While counsel for certain victims are aware of the Investigation, neither Epstein nor other subjects of the investigation are believed to be similarly aware. Accordingly, the ordinary exercise of grand July power to "subpoena witnesses to testify, regardless of whether they have already testified or furnished documentary evidence in civil litigation," Martindell, 594 at 296, would implicate and invite the very risk of disclosure—and the possibility of alerting potential criminal targets that they are under investigation, causing them to destroy evidence, flee from prosecution, or otherwise seriously jeopardize the Investigation—that caused the Government to proceed via subpoena and its related Application. Cf. Subpoena Duces Tecum, 945 F.2d at 1224 (in which the party that moved to quash the relevant subpoena argued that the government could not meet its burden of showing need for deposition testimony until it had at least called the witness before the grand jury). + +The subject matter of the Litigation also demonstrates the extraordinary circumstances of the Government's Investigation and Application, insofar as the materials at issue here appear not to be of the sort that ordinarily would provide protection against Government investigation. See + +3 To read Martindeli more broadly would not only be contrary to the opinion itself, as described above, but would risk rendering that opinion in even further conflict with the well-reasoned decisions of numerous other Circuits. In particular, the Fourth, Ninth, and Eleventh Circuits have each adopted a per se rule favoring enforcement of a grand jury subpoena even where a protective order exists. See In re Grand Jury Subpoena, 836 F.2d 1468, 1477 (4th Cir.), cert. denied, 487 U.S. 1240 (1988); In re Grand Jury Subpoena Served on Meserve, Mumper & Hughes, 62 F.3d 1222, 1226-1227 (9th Cir. 1995); In re Grand Jury Proceedings (Williams), 995 F.2d 1013, 1020 (11th Cir. 1993) (expressly criticizing the Martindell test and stating that it "is administratively unworkable," "defies construction," and "places prosecutors in untenable positions"). In the First and Third Circuits, a grand jury subpoena overrides a protective order unless the party seeking to quash the subpoena shows "exceptional circumstances that clearly favor subordinating the subpoena to the protective order." In re Grand Jury Subpoena (Roach), 138 F.3d 442, 445 (1st Cir.), cert. denied, 524 U.S. 939 (1998); In re: Grand Jury, 286 F.3d 153, 157-158 (3d Cir. 2002). The Government is aware of no case in those circuits where the presumption was rebutted and the grand jury subpoena was not enforced. + +4 An application of the Martindeli test would not in any event preclude the provision of a list of witnesses deposed, see 594 F.2d at 293, and of pre-existing documents collected or produced in the course of discovery, see id. at 297 n.8. + +Chemical Bank, 154 F.R.D. at 94 (describing such materials a "technological trade secrets, currently sensitive customer lists, or contemporarily sensitive competitive information which could benefit rivals"). Rather, the Government seeks materials that relate to among the gravest criminal offenses it investigates—the sexual exploitation of minors—which materials, if revealed, would tend to inculpate and/or embarrass some parties to the Protective Order. Indeed, by the very terms of the Protective Order, the confidential materials appear to be of the category for which "[a]voiding embarrassment . . is not by itself a valid reason for courts to uphold confidentiality as against a legitimate law enforcement need for the information." Id.; see also Prot. Order at 2 (designating as "confidential" only information that is "confidential and implicates common law and statutory privacy interests of the plaintiff and defendant"). "Aside from those restrictions [laid down by the Fourth or Fifth Amendment or applicable statutes], hiding possible criminal violations from law enforcement authorities is hardly a ground for judicial protection of confidentiality." Chemical Bank, 15 F.R.D. at 94. + +Finally, this is unlike a case in which the contours of the civil litigation are publicly apparent. Cf. Subpoena Duces Tecum, 945 F.2d at 1223 (noting that a "lengthy report" of the bankruptcy examination in that case "was made available to the public"). In Subpoena Duces Tecum, for example, not only was the government apparently unconcerned with the confidentiality of the grand jury investigation, but the government knew from a lengthy public report precisely what it might replicate through a grand jury investigation. Id. Not so with respect to the Litigation, which resulted in no such report, no trial, and limited public filings. + +For all of these reasons, and for the reasons set forth in the Application, the Government respectfully requests that the Court grant the Application. + +Respectfully submitted, + +MAN ey Assi ttorney Tel.: + +By: + +Enclosure \ No newline at end of file diff --git a/marker2/ds9/EFTA00084801/EFTA00084801.metadata.json b/marker2/ds9/EFTA00084801/EFTA00084801.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cb5a8a7e71485fdbd4302d15ed1ff32c2ab84e2e --- /dev/null +++ b/marker2/ds9/EFTA00084801/EFTA00084801.metadata.json @@ -0,0 +1,366 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084801.pdf", + "engine": { + "marker_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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+ "debug_data_path": "debug_data/EFTA00084801" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084801/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00084801/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..42898ce704cc0e4dc2f2c09f63110358b4d5df74 --- /dev/null +++ b/marker2/ds9/EFTA00084801/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:670b72d9d4a7cf8913988d34eccb8923f10f3255a40b0907c398f1ef8541d17f +size 3519 diff --git a/marker2/ds9/EFTA00084807/EFTA00084807.md b/marker2/ds9/EFTA00084807/EFTA00084807.md new file mode 100644 index 0000000000000000000000000000000000000000..5aae50e1c919535c084998317d735f6441afd196 --- /dev/null +++ b/marker2/ds9/EFTA00084807/EFTA00084807.md @@ -0,0 +1,61 @@ +To: + +Subject: The Daily 202: The One Big Thing missing from Biden's strategy on domestic extremism + +Date: Wed, 16 Jun 202115:49:31 +0000 + +![](_page_0_Picture_4.jpeg) + +Sign up for this newsletter Read online + +![](_page_0_Picture_7.jpeg) + +The Washington Post + +![](_page_0_Picture_9.jpeg) + +The Daily 202 + +Intelligence for leaders. + +Presented by Facebook + +![](_page_0_Picture_13.jpeg) + +![](_page_1_Picture_0.jpeg) + +![](_page_2_Picture_0.jpeg) + +![](_page_3_Picture_0.jpeg) + +![](_page_4_Picture_0.jpeg) + +## Lunchtime reads from The Post + +- "What offenses did Jeffrey Epstein, Ghislaine Maxwell, commit in Britain? New report forces police to review + +claims," by Jennifer Hassan: "British police say they will review allegations made in a recent Channel 4 News investigation that convicted sex offender Jeffrey Epstein and his former partner, Ghislaine Maxwell, sexually abused, trafficked and groomed multiple women and girls in Britain over a period of lo years. The claims, of which there are at least half a dozen but the broadcaster said could be `much higher,' aired on Tuesday, prompting fresh calls for the Metropolitan Police Service to fully investigate the Epstein scandal which has thrust Britain's Prince Andrew, the second-eldest son of Queen Elizabeth II, into the spotlight due to his ties to the disgraced U.S. financier." + +![](_page_5_Picture_1.jpeg) + +![](_page_6_Picture_0.jpeg) + +![](_page_7_Picture_0.jpeg) + +![](_page_8_Picture_0.jpeg) + +![](_page_9_Picture_0.jpeg) + +![](_page_10_Picture_0.jpeg) + +![](_page_11_Picture_0.jpeg) + +![](_page_12_Picture_0.jpeg) + +![](_page_13_Picture_0.jpeg) + +• a • • a • • • • • + +![](_page_14_Picture_0.jpeg) + +![](_page_15_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084807/EFTA00084807.metadata.json b/marker2/ds9/EFTA00084807/EFTA00084807.metadata.json new file mode 100644 index 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Epstein/Maxwell + +Yes, thanks + +On Jun 18, 2021, at 5:11 PM, wrote: + +Ok. Have you reviewed the documents I recently created? + +On Jun 18,2021 4:28PM,S"c wrote: HIM, + +Would you have some time on Monday to chat about the images from the CDs recovered from Epstein's NY house again, please? In particular, our vendor (PAE) sent us the attached spreadsheet, and it would be really helpful to talk through it with you. + +Thanks so much, + +Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00084829/EFTA00084829.metadata.json b/marker2/ds9/EFTA00084829/EFTA00084829.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b4e4f256547a4445d73d6a04dddc7f161955a693 --- /dev/null +++ b/marker2/ds9/EFTA00084829/EFTA00084829.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084829.pdf", + "engine": { + "marker_major": "2", + "marker_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": 921, + "elapsed_seconds": 0.64, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 74 + ], + [ + "Line", + 30 + ], + [ + "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/EFTA00084829" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084830/EFTA00084830.md b/marker2/ds9/EFTA00084830/EFTA00084830.md new file mode 100644 index 0000000000000000000000000000000000000000..026195a230baec3d56b515c2bad4e9a6fc57a9a3 --- /dev/null +++ b/marker2/ds9/EFTA00084830/EFTA00084830.md @@ -0,0 +1,191 @@ +Account Number-FINANCIAL TRUST COMPANY, INC. + +## Gift Processing + +The holiday season will soon be here. If you plan to make securities gifts this year, please notify us before December 1, 1999. This will provide us with sufficient time to process your request and meet the year-end deadline. + +JPMorgan + +Confidential Page 1 of 7 + +# Asset Account Portfolio + +October I - October 31, 1999 + +## Table of Contents + +| | Page | +|----------------------|------| +| Portfolio Summary | 2 | +| Cash and Short Term | 3 | +| Trade Activity | 4 | +| Account Transactions | 5 | + +## Account Officers + +Service Specialist: SCOTT/DENCKER + +FINANCIAL TRUST COMPANY, INC. + +C/O AMERICAN YACHT HARBOR + +## Overview + +# Portfolio Summary + +| | Market Value USD
Oct 31 | Tax
Cost USD | Estimated Annual
Income USD | Yield
% | +|------------------------------|----------------------------|---------------------|--------------------------------|------------| +| Cash & Short Term | 6,700,000.00 | 6,700,000.00 | 361,800.00 | 5.4 | +| Total | 6,700,000.00 | 6,700,000.00 | 361,800.00 | 5.4 | +| Accrued Income | 75,196.71 | | | | +| Total Portfolio Value | 6,775,196.71 | | | | + +## Asset Allocation + +![](_page_1_Figure_11.jpeg) + +as of January 1 1999 + +| Currency | Ditching* Ren | +|----------|---------------| +| AST | 13.7603 | +| BEF | 40.3399 | +| DEM | 1.9558 | +| ESP | 166.386 | +| FIM | 5.9457 | +| FRF | 6.5596 | +| IEP | 0.7875 | +| ITL | 1,936.2700 | +| LUF | 40.3399 | +| NLG | 2.2037 | +| PTE | 200.4820 | + +**Cash and Short Term** + +**Summary by Maturity** + +| | Current Market Value
USD | Estimated Annual Income
USD | +|--------------------|------------------------------------|---------------------------------------| +| Less Than 3 Months | 6,700,000.00 | 361,800.00 | +| Total | 6,700,000.00 | 361,800.00 | + +Current yield is displayed for instruments with no maturity and YTM on market is displayed for instruments that mature. + +**Cash and Short Term by Type** + +| 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 INSTITUTIONAL PRIME MONEY
MARKET FUND | USD | 6,700,000 | 1.00 | 1.00 | 6,700,000.00 | 6,700,000.00 | | 361,800.00 | 5.40 | +| 7-Day Annualized Yield: 5.34%
616918-20-7 | | | | | | 75,196.71 | | | | +| Total Cash and Short Term | | | | | 6,700,000.00 | 6,700,000.00 | 0.00 | 361,800.00 | 5.40 | + +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. + +10 1999 + +Account Number FINANCIAL TRUST COMPANY, INC. October 01, 1999 - October 31, 1999 + +\ 0 r • V a 'II • e ar N •e '0 k + +Asset Account Portfolio + +# Trade Activity + +JPMorgan + +Page 4 of 7 + +## 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 + +Amount USD + +## Trade Activity by Type + +| Trade | Semement | | | | | | | +|-------|---------------|----------|--------------------------------------|----------|--------------|----------|-------------------------------| +| Date | Date | Type | DeacriptIon | Currency | Culinary | Falcate* | Marker Coat/Proceeda | +| | | | | | | | Tax Cost DeWitt Osa USD | +| | Oct 1 Oct 1 | Purchase | J P MORGAN INSTITUTIONAL PRIME MONEY | USD | 20,000,000 | | 1.00 - 20,000,000.00 | +| Oct 4 | Oct 4 | Purchase | J P MORGAN INSTITUTIONAL PRIME MONEY | USD | 5,000,000 | 1.00 | 5,000,000.00 | +| | Oct 19 Oct 19 | Sale | J P MORGAN INSTITUTIONAL PRIME MONEY | USD | - 18,300,000 | 1.00 | 18,300,000.00 - 18,300,000.00 | + +10 1999 + +Account Number FINANCIAL TRUST COMPANY, INC. October 01, 1999 - October 31, 1999 + +Mo ran Guaranty. Trust Corn any of Ness York + +Asset Account Portfolio + +# Account Transactions + +JPMorgan + +Page 5 of 7 + +## Cash Activity Summary + +| Beginning Balance Credits | Amount INS Petted USD .00 | Amount yes, to Dare USD' | +|-------------------------------|---------------------------|--------------------------| +| Sales. Matunbes, Redemptions | 18,300,000.00 | 18,300,000.00 | +| Miscellaneous Receipts Debits | 25,000,000.00 | 25,000,000.00 | +| Purchases of Securities | - 25,000,000.00 | - 25,000,000.00 | +| Miscellaneous Disbursements | - 18,300,000.00 | - 18,300,000.00 | +| Ending Balance | .00 | | + +Year to date information is calculated on a calendar year basis. + +## Activity by Date + +| Settlement Date | Type | Quantity | Description | Amount USD | +|-----------------|---------------|------------|-------------------------------------------------------------------------------------------------------------------------|-----------------| +| Oct 1 | Purchase | 20,000,000 | J P MORGAN INSTITUTIONAL PRIME MONEY MARKET FUND
J.P.MORGAN SECURITIES INC AS AGENT
@ 1.00
TRADE DATE 10/01/99 | - 20,000,000.00 | +| Oct 1 | Misc. Receipt | | FUNDS TRANSFERRED TO BRKRG
AC# [REDACTED] (PRN) FROM
BRKRG AC# [REDACTED] (PRN) | 20,000,000.00 | + +10 1999 + +Moroan Guaranty Trust (omnan of Nen York + +Account Numbed Asset Account Portfolio FINANCIAL TRUST COMPANY, INC. October 01 1999 - October 31 1999 + +JPMorgan + +Page 6 of 7 + +# Activity by Date + +| Settlement Date | Type | Quantity | Description | Amount USD | +|-----------------|--------------------|--------------|-------------------------------------------------------------------------------------------------------------------------|-----------------| +| Oct 4 | Purchase | 5,000,000 | J P MORGAN INSTITUTIONAL PRIME MONEY MARKET FUND
J.P.MORGAN SECURITIES INC AS AGENT
@ 1.00
TRADE DATE 10/04/99 | - 5,000,000.00 | +| Oct 4 | Misc. Receipt | | FUNDS TRANSFERRED TO BRKRG
AC# ██████████ (PRN) FROM
BRKRG    AC# ██████████ (PRN) | 5,000,000.00 | +| Oct 19 | Sale | - 18,300,000 | J P MORGAN INSTITUTIONAL PRIME MONEY MARKET FUND
J.P.MORGAN SECURITIES INC AS AGENT
@ 1.00
TRADE DATE 10/19/99 | 18,300,000.00 | +| Oct 19 | Misc. Disbursement | | TRANSFERRED BY WIRE TO
BEAR STEARNS
FAO GHISLAINE MAXWELL | - 18,300,000.00 | + +continued + +Account Number [REDACTED] +FINANCIAL TRUST COMPANY, INC. + +Asset Account Portfolio +October 01, 1999 - October 31, 1999 + +**In Case of Errors or Questions About Your Electronic Transfers.** + +Telephone us at 1 (800) 576-6221 or write us at 500 Stanton Christiana Road, 1/OPS, Newark, DE 19713-2107 as soon as you can, if you think your statement is wrong or if you need more information about a transfer on the statement. We must hear from you no later than 60 days after we sent you the FIRST statement on which the error or problem appeared. (1) Tell us your name and account number. (2) Describe the error or the transfer you are unsure about, and explain as clearly as you can why you believe it is in error or why you need more information. (3) Tell us the dollar amount of the suspected error. If you contact us orally, you must send us your complaint or question in writing within 10 business days in order to preserve your rights. We will investigate your complaint and will correct any error promptly. If we take more than 10 business days to do this (20 days for purchases using VISA Check Card or for international transactions), we will credit your account for the amount you think is in error, so that you will have the use of money during the time it takes us to complete our investigation. + +**In case of errors or questions about your statement, including your line of credit.** + +If you think that your statement is incorrect or if you need more information about a transaction on your statement including a line of credit transaction, you must write to us on a separate sheet describing the error and send it to: J.P. Morgan, Private Client Services, 345 Park Avenue, New York, NY 10154-1002. We must hear from you no later than 60 days after the statement on which the error or problem appeared is sent. You can telephone us at 1-800-576-6221 but doing so will not preserve your rights. + +In your letter, please provide the following information: (1) your name and account number; (2) the dollar amount of the suspected error; and (3) 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 J.P. Morgan Funds or The J.P. Morgan Institutional Funds or The American Century Funds** + +The J.P. Morgan, J.P.Morgan Institutional, and American Century mutual funds are distributed by Funds Distributor, Inc. J.P. Morgan Investment Management Inc. and American Century Investment Management serve as investment advisors to their respective fund families. Shares of the funds are not bank deposits and are not guaranteed by any bank, government entity, or the FDIC. Return and share price will fluctuate and redemption value may be more or less than 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. 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Mob Building One Saint Andrew's Plaza New York. New York 10007 + +August 13, 2020 + +## VIA ECF + +The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 + +Re: United States v. Chislaine Maxwell, 20 Cr. 330 (AJN) + +Dear Judge Nathan: + +The Government respectfully submits this letter in opposition to the defendant's letter of August 10, 2020 (the "Defense Letter" or "Def. Ltr."), requesting that the Court order the Government to disclose the names of certain Government witnesses 11 months prior to trial, and requesting that the Court intervene in the protocols and individualized inmate determinations of the Bureau of Prisons. Both applications should be denied. + +#### A. The Defendant's Demand That the Government Name Certain Trial Witnesses + +For the third time in as many weeks, the defendant and her counsel have applied to the Court for relief that is premature, meritless, or both. See Order dated July 23, 2020 (Dkt. 28) (denying the defendant's request that the Court enter an order prohibiting the Government and attorneys for non-parties from making extrajudicial statements "concerning this case"); Order dated July 30, 2020 (Dkt. 37) (denying the defendant's application for a protective order that would allow the defense to publicly name and identify victims). In the defendant's most recent application, she asks the Court to order that the Government disclose a partial witness list, in the form of identifying certain victims referenced in the Superseding Indictment (the "Indictment"), fully 11 months prior to trial. This request is at best premature given that the production of discovery, on the schedule agreed to by the defendant, has just begun. Moreover, the parties have had no discussions about—let alone asked the Court to set—a schedule for pretrial disclosures, including for witness lists and 3500 material. + +In the first instance, the defendant complains about the status of discovery production, arguing that "almost six weeks since" the arrest of the defendant, the Government is "just now beginning to produce Rule 16 discovery, despite confirming to the Court that discovery would begin as soon as the Court entered a protective order." Def. Ltr. at 2. The suggestion that the Government somehow delayed that initial production is nonsense. As the Court is aware, the + +August 13, 2020 + +Page 2 + +protective order was docketed on Friday, July 31, 2020'—the timing of which was principally the result of the defendant's own refusal to agree to the terms of the proposed protective order. The Government then promptly produced an initial discovery production totaling more than 12,000 pages the following Wednesday, August 5, 2020. Additionally, the Government continues to produce discovery and earlier today made a second production, as the Government advised defense counsel last week it intended to do, totaling more than 150,000 pages, principally consisting of financial records.2 Although the Government expects to continue to produce a large amount of electronic discovery, the two productions already made constitute the vast majority of initial discovery, including search warrant applications and subpoena returns, which the Government has now produced more than a week in advance of its deadline of August 21, 2020, and approximately 11 months prior to trial. + +In sum, the Government has acted expeditiously in meeting its initial discovery obligations, providing more than 165,000 pages of discovery materials in less than two weeks following the entry of the protective order—all of which was accompanied by detailed indices describing the general topics and sources of the materials. + +Against this backdrop, the Defense Letter claims that over the course of just five days, defense counsel determined, having "expeditiously reviewed [the discovery] for high level content," Def. Ltr. at 2, that they cannot possibly investigate the charges against their client based on the materials provided thus far, and asking the Court to order the Government to provide the defendant with a partial witness list. That request should be denied. + +Tellingly, the defendant cites no authority that requires the relief requested at this stage in the litigation—i.e., prior to the completion of discovery and approximately 11 months before trial—nor is the Government aware of any. For example, in the lead case cited by defense counsel, United States v. Cannone, 528 F.2d 296, 301 (2d Cir. 1975), although the opinion acknowledged the ability of district courts to compel disclosure of the identity of government witnesses, the Second Circuit reversed for abuse of discretion the district court's decision to do so in that case because the defendant there, as here, had made "only an abstract, conclusory claim that such disclosure was necessary to its proper preparation for trial." Id. at 301-02. In United States v. Rueb, 00 Cr. 091 (RWS), 2001 WL 96177, at \*8 (S.D.N.Y. Feb. 5, 2001), while the Court ordered the Government to provide the defendant with its witness list, it did so one month before trial, following the completion of discovery production and in the context of pretrial motions. Those circumstances plainly are not present here. Finally, in United States v. Warne, a Western District of New York opinion from 2009 that has never been cited by another court, although the Court + +The Defense Letter states that the protective order was "entered" by the Court on July 30, 2020. While that is the date the protective order was signed by the Court, it was posted to the docket on July 31, 2020. + +2 The Government's most recent discovery transmittal letter also included the months and years of birth of the three victims identified in the Indictment, to enable the defendant to evaluate whether she will make any motions or legal arguments—more than four months in advance of the deadline for any such motion—relating to the ages of the victims. + +August 13, 2020 + +Page 3 + +ordered disclosure of a certain victim identity shortly after the indictment, the Court noted that the Government had already confirmed to the defendant the identities of three of the four relevant victims, and that a fourth victim, whose identity was at issue, was the subject of a charge that failed to identify the date of her alleged rape or any prior encounters between the victim and the defendant. 2009 WL 427111, at \*2. None of those facts are present here—by contrast, here, the Indictment particularly describes relevant time periods and events, including referring to the defendant's conversations with victims, interactions with victims, and specific relevant locations.3 + +To the extent the defendant is arguing that she cannot identify the nature of the charges against her, the proper vehicle for such an argument is a motion for a bill of particulars. Any such motion can be made in December with all other motions and following the completion of discovery. While the Government anticipates opposing such a motion as baseless on the facts of this case, the Government respectfully submits that in any event such a motion could not be meaningfully evaluated at this stage, prior to the completion of discovery. See United States v. Mahabub, 13 Cr. 908 (AJN), 2014 WL 4243657, at \*2 (S.D.N.Y. Aug. 26, 2014) (denying a motion for a bill of particulars that sought, among other things, the "alleged victim and noting that "[a] bill of particulars is not required unless the charges of the indictment are so general that they do not advise the defendant of the specific acts of which he is accused. The government can also discharge its obligation to disclose this information by other means, such as by presenting evidence in discovery. . . . A bill of particulars is not meant to provide the details of the government's evidence, or to be used as an investigative tool.") (emphasis added, quotations and citations omitted); see also United States v. Thompson, 13 Cr. 378 (AJN), 2013 WL 6246489, at \*7 (S.D.N.Y. Dec. 3, 2013) (denying a motion for a bill of particulars and noting that such motions are not "a general investigative tool, a discovery device or a means to compel the government to disclose evidence or witnesses to be offered prior to trial") (emphasis added) (quotations and citation omitted); cf. United States v. Sindone, 01 Cr. 517 (MBM), 2002 WL 48604, at \*2 (S.D.N.Y. Jan. 14, 2002) (denying a motion for a bill of particulars to identify "the unnamed alleged victim(s)" but instructing the government to disclose the name of any victim it did not intend to call as a witness at trial by 14 days prior to the start of trial). + +Alternatively, to the extent defense counsel is unable to assess or comprehend the discovery produced by the Government, the Government is more than willing to discuss with the defense + +3 Defense counsel's invocation of the protective order in support of its argument, Def. Ltr. at I, 3, should be of little comfort. The Government is deeply concerned by the recent actions of the defendant's counsel who represent her in both this criminal matter as well as in certain civil matters, and who in a recent public filing in a civil case referred to their receipt of sealed materials in discovery in this case. In particular, the defendant's counsel publicly claimed in a civil filing that they purportedly had received "critical new information" from the criminal case that it could not disclose "because it is subject to a protective order in the Criminal Action," and further noting publicly a desire to seek modification of the protective order in this') use such materials in the civil case, which the protective order expressly precludes. See v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) (Dkt. 1100). Moreover, even assuming the defendant intends to scrupulously adhere to the terms of the protective order, that would not change the relevant legal standards, which weigh heavily against granting the requested relief. + +August 13, 2020 + +Page 4 + +any such issues as the discovery process continues. To date, the defendant has yet to ask the Government a single substantive question about the discovery. The Government is also prepared to engage in good faith discussions with the defense about an appropriate schedule for disclosure of 3500 material, exhibit lists, and witness lists, all of which the Government expects to produce reasonably in advance of the trial date in July 2021 to permit the defense to investigate witnesses. But particularly given the nature of the charges, the Government's strong desire to protect the privacy of the alleged victims, and the lack of any legal precedent for the defendant's request, the Government respectfully submits that at the present time—eleven months prior to trial, nearly three months prior to the discovery deadline, and more than four months prior to the pretrial motions deadline—there is no basis for the defendant to demand the Government disclose the identity of its witnesses. + +# B. The Defendant's Request that the Court Dictate the Conditions of Her Confinement + +The defendant's requests with respect to the conditions of her confinement at the Metropolitan Detention Center ("MDC") are similarly premature and unavailing, and her request that the Court dictate the terms of her confinement to the Bureau of Prisons ("BOP") should also be denied.' + +As an initial matter, the defendant's argument that she is being treated "worse" than other inmates is incorrect. There is no merit to her complaints about being monitored by staff, as it is entirely appropriate for BOP to carefully monitor any inmate, particularly a new inmate who has never before been incarcerated and who faces the strong likelihood of serving many years in prison. Additionally, like all inmates, the defendant may be subject to observation or searches of her person or space as appropriate.5 It is otherwise entirely unclear what specific "privileges given to other pretrial detainees" the defendant believes she is being denied. + +More generally, the defendant, like all pretrial inmates, is subject to an individualized assessment by the BOP with respect to his or her placement in a facility. Here, for reasons including safety, security, and the orderly functioning of the facility, BOP has made the determination that, at present, the defendant should not be fully integrated into the dorm-style accommodations of the general population. The Government understands from BOP that it will + +4 Once again, defense counsel has rushed to seek Court intervention on issues they have made little or no meaningful effort to address with the Government or, in this case, the BOP. The Government learned of the defendant's specific objections to her conditions of incarceration for the first time from the Defense Letter, and has since conferred with BOP to understand and to address the issues as appropriate. Moreover, as noted below, the defendant filed the instant challenge to the GOP's plan to permit her time to review discovery before the BOP had a chance to implement (and ultimately modify) that plan. + +5 Defense counsel claims that prison staff "constantly observe" the defendant "including her phone conversations with defense counsel." This is misleading. As with all inmates, the defendant is able to speak to her counsel behind a closed door, in an area that is visible—but not audible—to MDC staff. Among other reasons, this is so MDC staff can ensure that inmates do not complete calls with their counsel and then call other individuals on a non-recorded line. + +Page 5 + +continue to evaluate where the defendant should be housed within the facility and that the defendant will be placed into the general population if and when BOP is assured that such placement would not pose a threat to the orderly operation of the institution. The defendant identifies no basis for the Court to disturb that determination by the BOP, particularly given that, as detailed below, her housing assignment will not negatively affect her ability to review discovery in this case. + +Regarding the defendant's request in connection with access to discovery, the Government understands from BOP that the defendant had not even yet received her copy of the Government's first discovery production at the time the Defense Letter was filed—she received the materials on Tuesday, August II. While it is correct that GOP's initial plan was to provide three hours per day of access to the discovery—the same access that is granted to every other pretrial inmate, including those with trial dates scheduled for far earlier than July 2021-as of earlier this week, and given the volume of expected discovery, BOP informed the defendant that she will have the opportunity to access to her discovery from 7:00 a.m. to 8:00 p.m. every day of the week. Although this arrangement will be subject to continued evaluation on an ongoing and individualized basis, and is subject to ordinary considerations of prison operations, BOP intends to provide that access on an ongoing basis to the extent it remains reasonably practicable to do so. Accordingly, this application should be denied as moot. + +# C. Conclusion + +For the reasons set forth above, the defendants' requests, as set forth in the Defense Letter, should be denied. + +Respectfully submitted, + +AU REY STRAUSS + +Act n United States Attorney + +Assistant United States Attorneys + +Southern District of New York + +Tel: + +Cc: All counsel of record, via ECF \ No newline at end of file diff --git a/marker2/ds9/EFTA00084837/EFTA00084837.metadata.json b/marker2/ds9/EFTA00084837/EFTA00084837.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ca7e5098268262406abdeacb3fe7a9879afe769c --- /dev/null +++ b/marker2/ds9/EFTA00084837/EFTA00084837.metadata.json @@ -0,0 +1,340 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084837.pdf", + "engine": { + "marker_major": "2", + "marker_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": 15660, + "elapsed_seconds": 1.21, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 319.464, + 56.7 + ], + [ + 463.6681213378906, + 56.7 + ], + [ + 463.6681213378906, + 71.103515625 + ], + [ + 319.464, + 71.103515625 + ] + ] + }, + { + "title": "VIA ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 198.45000000000002 + ], + [ + 124.17471313476562, + 198.45000000000002 + ], + [ + 124.17471313476562, + 212.853515625 + ], + [ + 68.544, + 212.853515625 + ] + ] + }, + { + "title": "A. 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NATHAN, District Judge: + +On August 10, 2020, the Defendant filed a letter motion related to two issues. Dkt. No. 38. First, the Defendant seeks an order directing the Government to disclose to defense counsel immediately the identities of the three alleged victims referenced in the indictment. Second, the Defendant seeks an order directing the Bureau of Prisons ("BOP") to release the Defendant into the general population and to provide her with increased access to the discovery materials. For the reasons that follow, Defendant's requests are DENIED without prejudice. + +## I. The Disclosure of Alleged Victims' Identities + +The Defendant first seeks an order directing the Government to disclose to defense counsel immediately the identities of the three alleged victims referenced in the indictment. Dkt. No. 38 at 1. Her request is premature. Production of discovery, which may itself identify alleged victims and relevant witnesses to the defense, has just begun. Moreover, the parties have not yet engaged in discussions regarding an appropriate schedule for pretrial disclosures, including witness lists and § 3500 material. The Court is mindful of the factors pointed to by the Defendant—in particular the fact that charges in this matter relate to conduct that allegedly took place many years ago—and anticipates that such a schedule would require the disclosure of + +alleged victims and witnesses substantially in advance of trial. But that alone does not justify such relief at this very early stage. Following the close of discovery, the parties should meet and confer on an appropriate schedule in light of all relevant factors. If the parties are unable to reach agreement as to a pretrial disclosure schedule, the Defendant may renew her request. The denial is therefore without prejudice. + +## II. The Defendant's Conditions of Confinement + +In her August 10, 2020 letter motion, the Defendant also sought "an order directing [BOP] to release Ms. Maxwell into the general population and provide Ms. Maxwell with increased access to the discovery materials while she is detained so that she can meaningfully participate in the preparation of her defense." Dkt. No. 38 at 1. The Government responded that the BOP has modified the conditions of Ms. Maxwell's confinement so that she has access to discovery materials thirteen hours a day, seven days a week. Dkt. No. 41 at 5. The Defendant's reply credited the GOP's change in policy but nonetheless asked the Court to "confirm these changes in an order to the BOP" and "that the Court order the BOP to grant Ms. Maxwell the same privileges given to other detainees." Dkt. No. 42 at 4-5. + +The Court denies this request. The BOP is providing the Defendant with conditions that allow her access to discovery materials so that she can meaningfully participate in the preparation of her defense. Further action by the Court as this juncture is therefore unnecessary. Should facts on the ground change such that the Defendant is not being provided sufficient access to her legal materials, defense counsel may seek intervention by the Court. + +The Defendant also requests that the Court order BOP that Ms. Maxwell "be monitored in the same manner as other pretrial detainees and that the Court order the BOP to grant Ms. + +Maxwell the same privileges given to other detainees." Dkt. No. 42 at 5. In a footnote, the defense clarifies that "[a]s long as Ms. Maxwell is monitored in the same manner, and receives the same privileges as other pretrial detainees, it is not necessary to move her to the general population." Dkt. No. 42 at 5 n.4. + +The Court sees no basis for granting the Defendant's request for an order directed to BOP. First, the Government has assured the Court that "[a]s with all inmates, the defendant is able to speak to her counsel behind a closed door, in an area that is visible—but not audible—to MDC staff," thereby ensuring that Ms. Maxwell's ability to communicate with her counsel is in no way interfered. Dkt. No. 41 at 4 n.5. And as to the more general implementation of surveillance procedures, the Court credits GOP's duty to ensure the safety and security of the Defendant as justifying the measures BOP has adopted. See Bell v. Wolfish, 441 U.S. 520, 547 (1979) ("Prison administrators ... should be accorded wide-ranging deference in the adoption and execution of policies and practices that in their judgment are needed to preserve internal order and discipline and to maintain institutional security."). Nor does the Defendant provide any basis for the Court to conclude that the level of surveillance is punitive. Dkt. No. 42 at 5. Though pretrial detainees "may not be punished prior to an adjudication of guilt in accordance with due process of law," Wolfish, 441 U.S. at 535, it does not follow that surveillance measures are punitive just because the Defendant deems them "onerous." Dkt. No. 42 at 4. The Defendant has provided the Court with no evidence, and no reason to believe, that the surveillance measures are motivated by improper purposes. + +As a result, Defendant's request is denied. To ensure that Ms. Maxwell is able to continue to adequately participate in her defense, however, the Court hereby ORDERS the Government to provide written status updates every 90 days detailing any material changes to the + +conditions of Ms. Maxwell's confinement, with particular emphasis on her access to legal materials and ability to communicate with defense counsel. + +### **III. Conclusion** + +For the reasons stated above, Defendant's requests contained in Dkt. No. 38 are DENIED without prejudice. Following the close of discovery, the parties shall meet and confer on an appropriate schedule for pre-trial disclosures, including the disclosure of § 3500 material, exhibit lists, and witness lists, taking into account all relevant factors. The Government is hereby ORDERED to submit written status updates every 90 days detailing any material changes to the conditions of Ms. Maxwell's confinement, with particular emphasis on her access to legal materials and ability to communicate with defense counsel. + +SO ORDERED. + +Dated: August 25, 2020 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00084842/EFTA00084842.metadata.json b/marker2/ds9/EFTA00084842/EFTA00084842.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d1acea37205a5543a8e132d8e5902e3a89bbb57f --- /dev/null +++ b/marker2/ds9/EFTA00084842/EFTA00084842.metadata.json @@ -0,0 +1,269 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084842.pdf", + "engine": { + "marker_major": "2", + "marker_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": 6473, + "elapsed_seconds": 4.23, + "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 + ], + [ + 281.8329772949219, + 72.08999999999999 + ], + [ + 281.8329772949219, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + }, + { + "title": "I. 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a/marker2/ds9/EFTA00084846/EFTA00084846.md b/marker2/ds9/EFTA00084846/EFTA00084846.md new file mode 100644 index 0000000000000000000000000000000000000000..39cf2e2f958c93736deca00ffa9a9153ed491ba9 --- /dev/null +++ b/marker2/ds9/EFTA00084846/EFTA00084846.md @@ -0,0 +1,51 @@ +To: + +Subject: 'Intoxicated' NY Judge Shoved Officer, Invoked Ties To Power + +Date: Wed, 14 Oct 2020 07:37:32 +0000 + +![](_page_0_Picture_4.jpeg) + +NEW YORK + +How does your salary stack up to your peers? + +a + +Take our survey. + +Wednesday, October 14, 2020 ,Follow Law360 + +![](_page_0_Picture_9.jpeg) + +TOP NEWS + +![](_page_0_Picture_11.jpeg) + +![](_page_0_Picture_12.jpeg) + +Ghislaine Maxwell's Bid To Seal Depo Resonates In 2nd Circ. + +A Second Circuit panel offered measured support Tuesday for Ghislaine Maxwell, the former girlfriend of Jeffrey Epstein charged with helping the deceased financier abuse underage girls, in Maxwell's challenge to an order calling for the release of a deposition at the heart of her case. + +Read full article » + +![](_page_0_Picture_20.jpeg) + +2 Lex Machina + +![](_page_0_Picture_14.jpeg) + +aw360 Rising Stars + +![](_page_0_Picture_16.jpeg) + +![](_page_1_Picture_0.jpeg) + +![](_page_2_Picture_0.jpeg) + +![](_page_3_Picture_0.jpeg) + +![](_page_4_Picture_0.jpeg) + +![](_page_5_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084846/EFTA00084846.metadata.json b/marker2/ds9/EFTA00084846/EFTA00084846.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cd638dc5f04aef8aa129f55c45974fed6c221212 --- /dev/null +++ b/marker2/ds9/EFTA00084846/EFTA00084846.metadata.json @@ -0,0 +1,221 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084846.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": 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girlfriend of Jeffrey Epstein charged with helping the deceased financier abuse underage girls, in Maxwell's challenge to an order calling for the release of a deposition at the heart of her case. + +Read full article » + +![](_page_0_Picture_17.jpeg) + +![](_page_1_Picture_2.jpeg) + +![](_page_2_Picture_0.jpeg) + +![](_page_3_Picture_0.jpeg) + +![](_page_4_Picture_2.jpeg) + +We hope you found this message to be read in + +![](_page_4_Picture_4.jpeg) + +![](_page_5_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084852/EFTA00084852.metadata.json b/marker2/ds9/EFTA00084852/EFTA00084852.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..08be2da8b461d8dc15e4950bccf7c1a37840611d --- /dev/null +++ b/marker2/ds9/EFTA00084852/EFTA00084852.metadata.json @@ -0,0 +1,221 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084852.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": 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If so, can we add it and change the entry to "? Otherwise, looks good to me. + +From: (USANYS) [Contractor] < + +Sent: Wednesday, October 14, 2020 9:05 AM + +To: (USANYS) + +Cc: (USANYS) + +Subject: Re: Discovery review project + +Nothing specific -just to give it the final go-ahead in case there is anything you feel needs to be changed. The only difference from the previous version is the addition of as employee 30. + +On Oct 14, 2020, at 9:02 AM, (USANYS) wrote: + +Yes, please. And what would you like us to review in the index? + +From: (USANYS) [Contractor] < + +Sent: Wednesday, October 14, 2020 9:01 AM + +To: (USANYS) < >; (USANYS) + +Subject: RE: Discovery review project + +One more thing — we previously discussed making a note on the cover about the text/native files from the Relativity export being confidential given they do not bear physical stamps. Do we still want to do this before sending the letters? + +From: (USANYS) [Contractor] + +Sent: Wednesday, October 14, 2020 8:49 AM + +To: (USANYS) ; (USANYS) + +Subject: RE: Discovery review project + +From: (USANYS) < Sent: Tuesday, October 13, 2020 7:55 PM To: (USANYS) (Contractor] c > Subject: RE: Discovery review project (USANYS) + +Here are the final cover letters. You can send them to defense counsel and give them USAfx access whenever it is ready. Thanks a lot. + +From: (USANYS) [Contractor] Sent: Tuesday, October 13, 2020 1:08 PM To: (USANYS) Cc: (USANYS)< > Subject: RE: Discovery review project + +Redactions and stamping are all set. Everything is currently being zipped for upload to USAfx. I've drafted up cover letters to both Noel and Thomas. They are attached and saved on the shared. + +From: (USANYS) Sent: Tuesday, October 13, 2020 12:10 PM To: (USANYS) [Contractor] cz > Cc: (USANYS)< > Subject: RE: Discovery review project + +Great! + +From: (USANYS) [Contractor] Sent: Tuesday, October 13, 2020 12:01 PM To: (USANYS) Cc: (USANYS) Subject: RE: Discovery review project + +Once I apply the redactions and stamp those documents, the production will be ready to go out. I will let you know once that is finished. + +From: (USANYS) Sent: Tuesday, October 13, 2020 11:42 AM To: (USANYS) [Contractor] Cc: (USANYS) c > Subject: FW: Discovery review project + +As per the attached, there are no additional redactions in the two outstanding FOIA email files. Let us know where the discovery stands. + +Thanks, + +From: (USANYS) Sent: Friday, October 09, 2020 4:06 PM To: (USANYS) + +Hi + +I apologize for the delay, I've reviewed the two files please see attached V3 of the spreadsheet. + +I am flagging 2 parts I was uncertain about, similar to earlier. (See below & in the spreasheet) + +On Emails 2\_Part 4: I did note the same category as earlier with an email chain from Tartaglione's counsel regarding leak/retaliation at MCC of a news story of Tartaglione questioned about attack on Epstein, and also on pg. 104 where Epstein informs a psychologist that Tartaglione discussed potentially injuring him without a guards' report. + +But both of those I was a bit uncertain whether they should be withheld. + +Hope this helps! + +From: (USANYS) Sent: Friday, October 9, 2020 10:39 AM To: a, (USANYS) Cc: (USANYS) c > Subject: Re: Discovery review project + +Perfect. + +Sent from my iPhone + +On Oct 9, 2020, at 10:38 AM, a, (USANYS) < wrote: + +Hi + +Yes of course! I'm in class right now, but I should be able to work on this afternoon, and hopefully turn it back around by around 3pm if that's okay? + +From: (USANYS) Sent: Friday, October 9, 2020 10:32 AM To: (USANYS) Cc: (USANYS) < Subject: RE: Discovery review project + +There are replacements for the two corrupt files in the same shared directory you used before. Would you be able to take a look at those today and add them to this version of the spreadsheet (which has a few edits from what you sent)? + +From: (USANYS) Sent: Wednesday, October 07, 2020 12:02 PM To: (USANYS) Cc: (USANYS) Subject: RE: Discovery review project + +Hi + +Okay, I finished up the remaining (pending the 2 pdfs I cannot open). I also noticed an error in the previous excel sheet, please utilize V2 moving forward (attached). + +I grouped & highlighted 3 portions of different PDFs that, potentially could be withheld, as they're email correspondence regarding Tartaglione but in relation to an Epstein incident. I tried to better define them in the spreadsheet and color coded by grouping. For the most part, each group is the same email chain, albeit with a response or two added. + +From: (USANYS) Sent: Wednesday, October 7, 2020 10:42 AM To: (USANYS) Cc: (USANYS) Subject: RE: Discovery review project + +Thanks for this. I will ask our paralegal to check out the damaged documents. + +From: (USANYS) Sent: Wednesday, October 07, 2020 10:38 AM To: (USANYS) Cc: (USANYS) Subject: RE: Discovery review project + +Hi + +Following up with a quick update, I've got 6 PDF's left to review. Wanted to flag that for some reason 2 of the PDF's (Emails 2\_Part4 & Emails 3\_Part 2) will not open and I get a "document is damaged" error from Adobe. I've tried logging out of the portal and restarting computer but no luck so far. + +I'm attaching the current spreadsheet so you can see how I've gone about flagging portions of the PDFs. I've noted a few uncertain areas in the notes where it may be Tartaglione issue but related to Epstein/request to be interviewed or for preservation. + +Hope this is on the right track! + +From: (USANYS) Sent: Friday, October 2, 2020 2:12 PM To: (USANYS) Cc: (USANYS) Subject: Discovery review project + +As we discussed, I would like you to review the email files only in the folder listed below. Please identify any pages in the documents that relate solely to (1) the conditions of confinement for Tartaglione or (2) emails with II I regarding Touhy. You should create a document (spreadsheet maybe) that identifies the name of the PDF file and the pages that fall in each category, so that the paralegals can redact those pages. + +Here's where you will find the documents: + +You only need to review the emails, not the other documents in the folder. + +Let me know if you have any questions or issues once you start working on the project. Let's aim for the end of the day on Wednesday. + +Thanks for your help, + +Assistant United States Attorney United States Attorney's Office Southern District of New York + +Tel: + +Fax: \ No newline at end of file diff --git a/marker2/ds9/EFTA00084858/EFTA00084858.metadata.json b/marker2/ds9/EFTA00084858/EFTA00084858.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..181cd538e3373828c358a195906e8ebff7af969d --- /dev/null +++ b/marker2/ds9/EFTA00084858/EFTA00084858.metadata.json @@ -0,0 +1,174 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084858.pdf", + "engine": { + "marker_major": "2", + "marker_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": 6533, + "elapsed_seconds": 1.48, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "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 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 87 + ], + [ + "Line", + 39 + ], + [ + "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": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "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": 3, + "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 + } + }, + { + "page_id": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 16 + ], + [ + "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/EFTA00084858" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084863/EFTA00084863.md b/marker2/ds9/EFTA00084863/EFTA00084863.md new file mode 100644 index 0000000000000000000000000000000000000000..c57156d4f3b6b6e7ca409216391d826197be5f04 --- /dev/null +++ b/marker2/ds9/EFTA00084863/EFTA00084863.md @@ -0,0 +1,119 @@ +Christian R. Evercle11 +1 (212) 957-7600 ccvcrdclIgathcngresscr.com + +October 13, 2020 + +## 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) + +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(aX1)(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.rntdailvnews.com/new-vork/nvjeffrey-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. + +[REDACTED], [REDACTED], [REDACTED] + +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, + +/s/ Christian Everdell + 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describe the property to be searched ) or identify the person by name and address) ) + +2 electronic devices seized on July 6, 2019 from Jeffrey Epstein; ) 33 electronic devices seized on July 11, 2019 from 9 East 71st + +Street, New York, NY; 27 electronic devices seized on August 12, 2019 , ) + +from Little Saint James in the Virgin Islands + +Case No. 20 MAG 6719 + +## 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 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): + +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 + +(not to exceed 14 dap) + +ef 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. + +O 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 justifying, the later specific date of + +Judge's signature + +Date and time issued: 6/26/2020 9:11 am + +#### Return + +| Case No.: | Date and time warrant executed: | Copy of warrant and inventory left with: | +|-------------|---------------------------------|------------------------------------------| +| 20 MAG 6719 | | | + +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. Date: of perjury that this inventory is correct and was returned along with the original warrant Executing officer's signature Printed name and title + +![](_page_2_Picture_0.jpeg) + +2017.08.02 + +![](_page_3_Picture_0.jpeg) + +![](_page_4_Picture_0.jpeg) + +![](_page_5_Picture_0.jpeg) + +![](_page_6_Picture_0.jpeg) + +### 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 concernin the identity or location of co-conspirators of JEFFREY EPSTEIN, including and GHISLAINE MAXWELL. +- 3. Evidence concernin 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/EFTA00084871/EFTA00084871.metadata.json b/marker2/ds9/EFTA00084871/EFTA00084871.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2a2035eceb4029c371154e81bbceeffc4e173c86 --- /dev/null +++ b/marker2/ds9/EFTA00084871/EFTA00084871.metadata.json @@ -0,0 +1,452 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084871.pdf", + "engine": { + "marker_major": "2", + "marker_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": 6177, + "elapsed_seconds": 2.46, + "image_assets": [ + "_page_2_Picture_0.jpeg", + "_page_3_Picture_0.jpeg", + "_page_4_Picture_0.jpeg", + "_page_5_Picture_0.jpeg", + "_page_6_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 169.524, + 65.1243896484375 + ], + [ + 443.9737854003906, + 65.1243896484375 + ], + [ + 443.9737854003906, + 87.427734375 + ], + [ + 169.524, + 87.427734375 + ] + ] + }, + { + "title": "SEARCH AND SEIZURE WARRANT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 194.00400000000002, + 223.56000000000003 + ], + [ + 417.5921936035156, + 223.56000000000003 + ], + [ + 417.5921936035156, + 239.49200439453125 + ], + [ + 194.00400000000002, + 239.49200439453125 + ] + ] + }, + { + "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": [ + [ + 274.176, + 520.02 + ], + [ + 337.90631103515625, + 520.02 + ], + [ + 337.90631103515625, + 532.6040649414062 + ], + [ + 274.176, + 532.6040649414062 + ] + ] + }, + { + "title": "II. 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Motto Building One Saint Andrew's Plaza New York. New York 10007 + +## MEMORANDUM + +To: Case File, USvEpstein, 2018R01618 + +From: + +Subject: Search Warrant Responsiveness Review Protocol for Image and Video Files from Epstein Devices + +Date: October 19, 2020 + +This memorandum is intended to memorialize the protocol for conducting a responsiveness review of image and video files obtained pursuant search warrants in the above-referenced investigation. + +## BACKGROUND + +In July of 2019, the Federal Bureau of Investigation ("FBI") executed multiple search warrants on the New York residence of Jeffrey Epstein. During those searches, the FBI seized dozens of electronic devices. Pursuant to the warrants authorizing those searches, the FBI extracted data from those electronic devices. In August of 2019, the FBI executed a search warrant on the Virgin Islands residence of Jeffrey Epstein. During that search, the FBI seized approximately dozens of additional electronic devices. The FBI subsequently obtained a warrant authorizing the search of those devices. + +During the initial review of data from the devices seized during the New York and the Virgin Islands searches, the FBI and U.S. Attorney's Office identified materials relevant to its investigation of Ghislaine Maxwell. On June 26, 2020, the FBI obtained a new warrant (the "Warrant") authorizing review of the data from a total of 62 devices seized from both the New York and Virgin Islands searches of Epstein's residence (the "Devices"). Following the issuance of the Warrant, the FBI provided the U.S. Attorney's Office with copies of all documents extracted from the Devices. The U.S. Attorney's Office then began conducting a privilege review of those documents, some of which has been completed and some of which remains ongoing. Upon completion of the privilege review, the AUSAs responsible for the prosecution have been conducting a responsiveness review by running search terms designed to capture documents that are responsive to the Warrant. + +On July 2, 2020, Maxwell was arrested on Indictment 20 Cr. 330 (MN), charging her with crimes involving the sexual abuse of minors. Judge Nathan has ordered that all discovery be completed by November 9, 2020. The AUSAs responsible for the prosecution are in the process of producing responsive documents from the Devices to Maxwell. + +In addition to documents, the FBI also extracted image and video files from some of the Devices. The FBI and U.S. Attorney's Office intend to review those image and video files for materials that are responsive to the Warrant. In order to meet the November 9, 2020 discovery deadline, this review needs to be completed by October 31, 2020 to allow adequate time to stamp and load responsive files onto drives for production to the defense. + +## RESPONSIVENESS REVIEW: + +The purpose of this responsiveness review protocol is to guide the review and seizure of image and video files obtained pursuant to the Warrant. Before any member of the review team undertakes the work set forth herein, he/she must review the search warrant and accompanying affidavit pursuant to which the materials were produced or seized. + +Each member of the review team will be assigned to conduct a file-by-file review of the images and videos from a particular subset of the Devices. Files falling into any of the following categories shall be considered responsive to the Warrant: + +- Any image or video of Jeffrey Epstein +- Any image or video of Ghislaine Maxwell +- Any image or video of any female appearing to be under the age of 30 +- Any travel documents, such as passports, visas, or immigration forms +- Any screenshots of communications with or regarding females +- Any screenshots of social media posts featuring or regarding females + +Upon identifying any file that falls within one of the above categories, the reviewer shall take the following steps: + +- If the image or video contains partial or full nudity, mark the file RESPONSIVE HIGHLY CONFIDENTIAL +- If the image contains no nudity of any kind, mark the file RESPONSIVE CONFIDENTIAL + +Reviewers from the U.S. Attorney's Office should complete this review as follows: + +- Create a local folder (not on a shared network drive) for each device reviewed, identified by the device's "NYC" serial number. +- Within each device folder, create one subfolder entitled RESPONSIVE HIGHLY CONFIDENTIAL, and one subfolder entitled RESPONSIVE — CONFIDENTIAL. +- Review the files from each assigned device on the drive provided. Copy any responsive files into the appropriate subfolder for each device reviewed. +- Upon completion of review, all folders entitled RESPONSIVE HIGHLY CONFIDENTIAL will be copied onto an external drive and provided to the FBI for secure storage. HIGHLY CONFIDENTIAL materials should not be saved onto the U.S. Attorney's Office network or produced directly to defense counsel. The FBI will maintain HIGHLY CONFIDENTIAL materials and make them available to the defense for review. + +- Upon completion of review, all folders entitled RESPONSIVE CONFIDENTIAL will be kept separated by device number and produced as CONFIDENTIAL discovery to defense counsel. + +Reviewers from the FBI should use the CAIR system to complete this review.' Upon completion of the review, the FBI will take the following steps: + +- Securely save all files marked RESPONSIVE- HIGHLY CONFIDENTIAL within the FBI, keeping the files separated by device. The case agent will memorialize this process and the location of these materials in a 302 report. +- Provide a copy of all files marked RESPONSIVE CONFIDENTIAL to the U.S. Attorney's Office, keeping the files separated by device. The U.S. Attorney's Office will produce these files as discovery to the defense. + +At the conclusion of the review, the U.S. Attorney's Office will delete or return all copies of the full image and video files from all Devices. Also at the conclusion of the review, the FBI will lock off access to the full data extractions of all Devices. This process will ensure that the FBI and U.S. Attorney's Office will only be able to review, access, and use the portions of the Devices identified as responsive to the Warrant for further investigation and prosecution. If it is determined that there is a need to review items not identified as responsive, the FBI will need to seek a new warrant to review the full contents of any of the Devices. + +If reviewers have an uestions or would like to discuss the rotocol or review, they should contact AUSA by calling Mellphone at or emailing her at . Reviewers are encouraged to contact AUSA at any time and with any questions or concerns, no matter how small. + +All other data review in connection with the above-referenced warrants should be conducted using Relativity. 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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 folloKing 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/EFTA00084883/EFTA00084883.metadata.json b/marker2/ds9/EFTA00084883/EFTA00084883.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..79ef68a1a35b782c3f52dd6efc7189dd1b9d53d5 --- /dev/null +++ b/marker2/ds9/EFTA00084883/EFTA00084883.metadata.json @@ -0,0 +1,1086 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084883.pdf", + "engine": { + "marker_major": "2", + "marker_version": 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b/marker2/ds9/EFTA00084901/EFTA00084901.md @@ -0,0 +1,39 @@ +To: (USANYS)" cU + +Subject: RE: + +Date: Mon, 13 Apr 2020 13:27:17 +0000 + +I agree. I think rather than it be a free flow, we call on people to give specific updates on things pushing forward (Epstein team, for example; maybe maybe 1-2 others?). + +Also, do we have things we should be nudging on? for example? It's been a month now since IM and I talked about drafting a complaint, and I've heard nothing since. + +From: (USANYS) n + +Sent: Monday, April 13, 2020 9:17 AM + +To: (USANYS) cfl + +Subject: RE: + +Probably a good idea — let's do it for next week. Would want to choreograph it carefully so that it doesn't run on and on, which would frustrate people esp with childcare issues. + +From: (USANYS) + +Sent: Monday, April 13, 2020 9:07 AM + +To: (USANYS) < + +Subject: RE: + +Yep, sounds good. Do we also want to try to organize a unit meeting at some point? Would it be helpful for folks to hear what others have been up to? I don't otherwise think we have a real need for one, it would just replace the ordinary banter about cases that typically just happens in the office... + +From: (USANYS) + +Sent: Monday, April 13, 2020 9:04 AM + +To: (USANYS) + +Subject: + +I'm going to send a unit email just asking what people have upcoming this week, ok? \ No newline at end of file diff --git a/marker2/ds9/EFTA00084901/EFTA00084901.metadata.json b/marker2/ds9/EFTA00084901/EFTA00084901.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e652ba83264ed62d2921491b8e8642bc178ff985 --- /dev/null +++ b/marker2/ds9/EFTA00084901/EFTA00084901.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084901.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1224, + "elapsed_seconds": 0.99, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 29 + ], + [ + "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/EFTA00084901" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084902/EFTA00084902.md b/marker2/ds9/EFTA00084902/EFTA00084902.md new file mode 100644 index 0000000000000000000000000000000000000000..09adbc2ac72301b49a452fdc931fc18b8dfaf6dd --- /dev/null +++ b/marker2/ds9/EFTA00084902/EFTA00084902.md @@ -0,0 +1,41 @@ +To: + +Subject: Trump Vows Openings By May, Blames WHO For Pandemic + +Date: Wed, 15 Apr 2020 08:49:35 +0000 + +![](_page_0_Picture_4.jpeg) + +Wednesday, April 15, 2020 + +TOP NEWS + +;2,Follow Law360 + +W;,Law360 Practice Groups of the + +![](_page_0_Picture_10.jpeg) + +![](_page_1_Picture_0.jpeg) + +![](_page_2_Picture_0.jpeg) + +## PERSONAL INJURY + +## 11th Circ. Says Epstein Victim's Rights Weren't Squashed + +A divided Eleventh Circuit panel on Tuesday denied a petition from a victim of Jeffrey Epstein challenging a nonprosecution deal reached with the billionaire sex offender, saying her rights as a victim were not violated by the deal because federal prosecutors never actually brought charges against Epstein. + +Opinion attached I Read full article » + +## INTERNATIONAL TRADE + +![](_page_4_Picture_0.jpeg) + +![](_page_5_Picture_0.jpeg) + +![](_page_6_Picture_0.jpeg) + +![](_page_7_Picture_0.jpeg) + +![](_page_7_Picture_1.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084902/EFTA00084902.metadata.json b/marker2/ds9/EFTA00084902/EFTA00084902.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5fc5e0b8268e152411e48e5fe2823e3756ee167a --- /dev/null +++ b/marker2/ds9/EFTA00084902/EFTA00084902.metadata.json @@ -0,0 +1,352 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084902.pdf", + "engine": { + "marker_major": "2", + "marker_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": 909, + "elapsed_seconds": 0.95, + "image_assets": [ + "_page_0_Picture_4.jpeg", + "_page_0_Picture_10.jpeg", + "_page_1_Picture_0.jpeg", + "_page_2_Picture_0.jpeg", + "_page_4_Picture_0.jpeg", + "_page_5_Picture_0.jpeg", + "_page_6_Picture_0.jpeg", + "_page_7_Picture_0.jpeg", + "_page_7_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "PERSONAL INJURY", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 33.660000000000004, + 268.92 + ], + [ + 146.1685333251953, + 268.92 + ], + [ + 146.1685333251953, + 283.5841064453125 + ], + [ + 33.660000000000004, + 283.5841064453125 + ] + ] + }, + { + "title": "11th Circ. 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+![](_page_0_Picture_4.jpeg) + +NEW YORK + +Friday, April 17, 2020 ,Follow Law360 + +## TOP NEWS + +![](_page_0_Picture_9.jpeg) + +## Epstein's Ex Not Likely To Toss Battery Suit, Judge Says + +A Texas woman who says deceased financier Jeffrey Epstein and his former girlfriend, British socialite Ghislaine Maxwell, subjected her to sexual battery likely has plausible claims against Maxwell, a Manhattan federal judge said Thursday. + +Read full article + +![](_page_0_Picture_13.jpeg) + +LAW FIRMS + +![](_page_0_Picture_15.jpeg) + +![](_page_1_Picture_0.jpeg) + +![](_page_2_Picture_0.jpeg) + +![](_page_3_Picture_0.jpeg) + +![](_page_4_Picture_0.jpeg) + +![](_page_5_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084910/EFTA00084910.metadata.json b/marker2/ds9/EFTA00084910/EFTA00084910.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8cfa5510ffb28cfa5668700da4bc830fc7114e1e --- /dev/null +++ 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It + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Date: Mon, 20 Apr 2020 21:51:57 +0000 + +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:a (USANYS) (USANYS) Cc: (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. (M, M, and are signed off on the letter and gathered the documents.) + +Thanks, + +From: Sent: Friday, January 3, 2020 8:49 PM To: a, (USANYS) Cc:a (USANYS) ci ); I c >; (uSANYS) ; (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +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 M. + +thanks again, + +From: (USANYS) < + +Sent: Friday, January 03, 2020 12:55 + +To: + +Cc: I=M, (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). + +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: (USANYS) ; I >; (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: )°c + +Sent: Thursday, January 2, 2020 7:10 PM + +To: (USANYS) I + +Cc: I=M, (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: S (USANYS) Sent: Thursday, January 02, 2020 10:01 To: Subject: Jeffrey Epstein-Related Touhy Requests (USANYS) + +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 reqnests 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 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); Tulle 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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Please let me know if I can be of any help in explaining this or narrowing it. + +Many thanks, + +Danielle + +Danielle Ivory Reporter The New York Times 620 Eighth Avenue New York, NY 10018 + +![](_page_0_Picture_8.jpeg) + +Aug. 13, 2019 + +Bureau of Prisons OGC EFOIA@BOP.GOV + +## FREEDOM OF INFORMATION ACT REQUEST + +Dear FOIA Officer: + +# Requested records + +"Records" means information of any kind, including writings (handwritten, typed, electronic or otherwise produced, reproduced or stored), letters, memoranda, correspondence, notes, applications, completed forms, studies, reports, reviews, telephone conversations, faxes, emails, documents, photographs, + +minutes of meetings, records of meetings in any form, and any other compilation of data from which information can be obtained. All of the foregoing are included in this request if they are in the possession of or otherwise under the New York Times requests for Records of the following type in the possession, custody, or control of OSHA. + +Pursuant to the Freedom of Information Act, 5 U.S.C. Section 552 et seq ("FOIA"), I request copies of (or access to) documents about Jeffrey Epstein who died at the Metropolitan Correctional Center (MCC) on Aug. 10, 2019, specifically (hereafter described as "the records"): + +- (1) The 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 10. +- (2) All quarter entries (showing which cells he was housed in) for Jeffrey Epstein at MCC. +- (3) The CIM Clearance and Separatee data sheet for Jeffrey Epstein at MCC. +- (4) The chronological disciplinary records for Jeffrey Epstein at MCC. +- (5) The intake screening form for Jeffrey Epstein at MCC. +- (6) The security designation records for Jeffrey Epstein at MCC. +- (7) The inmate profile for Jeffrey Epstein at MCC. +- (8) All incident reports related to Jeffrey Epstein at MCC. +- (9) All medical reports related to Jeffrey Epstein at MCC. +- (10) The signed visitor log for Jeffrey Epstein at MCC. +- (11) Documents showing when MCC staff held meetings regarding Jeffrey Epstein, and who attended. +- (12) All records generated from the meeting at MCC during which it was decided that Jeffrey Epstein would be taken off suicide watch. +- (13) The Post-Watch report compiled in order to take Jeffrey Epstein off suicide watch. +- (14) The overtime sign-up sheets for the Special Housing Unit (9 South) at MCC for Aug. 9 and 10, and on July 22 and 23. +- (15) Documents showing which staff were augmented at MCC and what positions they worked in on Aug. 9 and 10, and on July 22 and 23. + +The Bureau of Prisons web-based inmate locator shows that only one Jeffrey Epstein is listed in the BOP system, so identifying the correct Jeffrey Epstein should not be a problem for the bureau. + +I am a reporter for The New York Times, an accredited and recognized newsgathering organization. I request the Records to inform the public about matters of public concem. + +#### ONGOING LAW ENFORCEMENT PROCEEDINGS/INVESTIGATIONS + +As to any records located in the investigative files of pending investigations, you may not assert Exemption 7(A) without conducting a document-by-document review to determine whether release of the records would interfere with ongoing law enforcement proceedings. + +The United States District Court of the District of Columbia recently "remind[ed] the FBI of its obligation to conduct record-level reviews at the administrative level before refusing to produce records contained in its investigative files." Tipograph v. Dept of Justice, 83 F. Supp. 2d 234 (D.D.C. Mar. 18, 2015) + +In addition, the FOIA Improvement Act of 2016 added a provision instructing federal agencies to withhold records only when their release would work some foreseeable or is prohibited by law, not just because they may technically be exempt. + +Even if the records might otherwise be exempt, an agency may withhold them only if their disclosure would actually harm the interest protected by the exemption, or if it is prohibited by some other law. 5 U.S.0 552(a)(8). The agency does need to identify what reasonably foreseeable harm would flow from release of the information being withheld, consider partial disclosure of the information, take reasonable steps to segregate and release nonexempt information. + +## RESPONSE TIME + +FOIA requires that your agency respond to this request within 20 business days. This request is segregable, and your agency may not withhold entire records because of one section that you believe is exempt from disclosure. Under federal law, if you choose to withhold any such parts of the records from disclosure, you must specify in a written response the factual and legal basis for withholding any part of the Records. + +## ESTIMATED DATE OF COMPLETION + +I respectfully request that you provide me with a reasonably estimated date of completion. See 5 U.S.C. § 552(a)(7)(B)(ii). If the estimated date of completion is being significantly delayed because of a portion of the request needs to be processed by another agency, please inform me which agency that is and whether it has provided you with an estimated date of completion. + +#### FORMAT OF REQUESTED RECORDS + +I am further requesting that the Records be provided to me on computer files in the same format as they are currently maintained at the agency, pursuant to Burka v. Dept. of Health & Human Svcs., 87 F.3d 508 (D.C. Cir. 1996). As you know, providing documents electronically is cheaper than mailing hard copies. + +## FEE WAIVER + +I respectfully request that you waive all fees in connection with this request as provided by 5 U.S.C. § 552(a)(4)(A)(iii). FOIA was designed to provide citizens a broad right to access government records. + +FOIA's basic purpose is to "open agency action to the light of public scrutiny," with a focus on the public's "right to be informed about what their government is up to." U.S. Dep't of Justice v. Reporters Comm. For Freedom of Press, 489 U.S. 749, 773-74 (1989) (internal quotation and citations omitted). + +In order to provide public access to this information, FOIA's fee waiver provision requires "[d]ocuments shall be furnished without any charge or at a [reduced] charge ... disclosure of the information is in the public interest because it is likely to contribute significantly to public understanding of the operations or activities of the government and is not primarily in the commercial interest of the requester." 5 U.S.C. § 552(a)(4)(A)(iii). + +#### EXPEDITED PROCESSING + +There is extreme public interest in records concerning the prison stay and death of Jeffrey Epstein, who was accused of sexually abusing scores of women and underage girls. Not only has a person died in federal custody, but the death has generated multiple conspiracy theories implicating government works at the highest levels and taxpayer money. Disclosure of the records request is in the public interest because disclosure is likely to contribute significantly to the understanding of the operations or activities of the government. In addition, as one of the largest circulation newspapers in the United States, The New York Times plays an important role in sharing information with the public and helping the public understand how the federal government works. Disclosure of the records is not primarily in the commercial interest of myself or The New York Times but is intended to facilitate reporting on the + +operations of government. + +Please contact me if I may assist in your office's response to this request. + +Yours, + +Danielle Ivory + +Danielle Ivory The New York Times + +![](_page_4_Picture_7.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084920/EFTA00084920.metadata.json b/marker2/ds9/EFTA00084920/EFTA00084920.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6121f456626122352ed70b95a4ae5de0f67d34ea --- /dev/null +++ b/marker2/ds9/EFTA00084920/EFTA00084920.metadata.json @@ -0,0 +1,433 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084920.pdf", + "engine": { + "marker_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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Please let me know if I can be of any help in explaining this or narrowing it. + +Many thanks, + +Danielle + +Danielle Ivory Reporter The New York Times 620 Eighth Avenue New York, NY 10018 + +![](_page_0_Picture_8.jpeg) + +Aug. 13, 2019 + +Bureau of Prisons OGC EFOIA@BOP.GOV + +### FREEDOM OF INFORMATION ACT REQUEST + +Dear FOIA Officer: + +### Requested records + +"Records" means information of any kind, including writings (handwritten, typed, electronic or otherwise produced, reproduced or stored), letters, memoranda, correspondence, notes, applications, completed forms, studies, reports, reviews, telephone conversations, faxes, emails, documents, photographs, + +minutes of meetings, records of meetings in any form, and any other compilation of data from which information can be obtained. All of the foregoing are included in this request if they are in the possession of or otherwise under the New York Times requests for Records of the following type in the possession, custody, or control of OSHA. + +Pursuant to the Freedom of Information Act, 5 U.S.C. Section 552 et seq ("FOIA"), I request copies of (or access to) documents about Jeffrey Epstein who died at the Metropolitan Correctional Center (MCC) on Aug. 10, 2019, specifically (hereafter described as "the records"): + +(1) All video camera footage at MCC pertinent to the Jeffrey Epstein suicide and the first suicide attempt. + +(2) All BOP documents pertaining to Jeffrey Epstein's suicide and first suicide attempt. + +(3) All BOP documents, including email correspondence and meeting minutes, pertaining to the decision to remove Jeffrey Epstein from suicide watch. + +(4) All BOP special investigation reports mentioning Jeffrey Epstein. + +(5) All BOP correspondence with the U.S. Attorney's Office regarding Jeffrey Epstein. + +The Bureau of Prisons web-based inmate locator shows that only one Jeffrey Epstein is listed in the BOP system, so identifying the correct Jeffrey Epstein should not be a problem for the bureau. For this request, records generated by BOP employees based in New York, Texas, and in Washington, DC, should be searched. + +I am a reporter for The New York Times, an accredited and recognized newsgathering organization. I request the Records to inform the public about matters of public concem. + +## ONGOING LAW ENFORCEMENT PROCEEDINGS/INVESTIGATIONS + +As to any records located in the investigative files of pending investigations, you may not assert Exemption 7(A) without conducting a document-by-document review to determine whether release of the records would interfere with ongoing law enforcement proceedings. + +The United States District Court of the District of Columbia recently "remind[ed] the FBI of its obligation to conduct record-level reviews at the administrative level before refusing to produce records contained in its investigative files." Tipograph v. Dept of Justice, 83 F. Supp. 2d 234 (D.D.C. Mar. 18, 2015) + +In addition, the FOIA Improvement Act of 2016 added a provision instructing federal agencies to withhold records only when their release would work some foreseeable or is prohibited by law, not just because they may technically be exempt. + +would actually harm the interest protected by the exemption, or if it is prohibited by some other law. 5 U.S.0 552(a)(8). The agency does need to identify what reasonably foreseeable harm would flow from release of the information being withheld, consider partial disclosure of the information, take reasonable steps to segregate and release nonexempt information. + +#### RESPONSE TIME + +FOIA requires that your agency respond to this request within 20 business days. This request is segregable, and your agency may not withhold entire records because of one section that you believe is exempt from disclosure. Under federal law, if you choose to withhold any such parts of the records from disclosure, you must specify in a written response the factual and legal basis for withholding any part of the Records. + +## ESTIMATED DATE OF COMPLETION + +I respectfully request that you provide me with a reasonably estimated date of completion. See 5 U.S.C. § 552(a)(7)(B)(ii). If the estimated date of completion is being significantly delayed because of a portion of the request needs to be processed by another agency, please inform me which agency that is and whether it has provided you with an estimated date of completion. + +# FORMAT OF REQUESTED RECORDS + +I am further requesting that the Records be provided to me on computer files in the same format as they are currently maintained at the agency, pursuant to Burka v. Dept. of Health & Human Svcs., 87 F.3d 508 (D.C. Cir. 1996). As you know, providing documents electronically is cheaper than mailing hard copies. + +### FEE WAIVER + +I respectfully request that you waive all fees in connection with this request as provided by 5 U.S.C. § 552(a)(4)(A)(iii). FOIA was designed to provide citizens a broad right to access government records. + +FOIA's basic purpose is to "open agency action to the light of public scrutiny," with a focus on the public's "right to be informed about what their government is up to." U.S. Dep't of Justice v. Reporters Comm. For Freedom of Press, 489 U.S. 749, 773-74 (1989) (internal quotation and citations omitted). + +In order to provide public access to this information, FOIA's fee waiver provision requires Idjocuments shall be furnished without any charge or at a [reduced] charge ... disclosure of the information is in the public interest because it is likely to contribute significantly to public understanding of the operations or activities of the government and is not primarily in the commercial interest of the requester." 5 U.S.C. § + +552(a)(4)(A)(iii). + +#### EXPEDITED PROCESSING + +There is extreme public interest in records concerning the prison stay and death of Jeffrey Epstein, who was accused of sexually abusing scores of women and underage girls. Not only has a person died in federal custody, but the death has generated multiple conspiracy theories implicating government works at the highest levels and taxpayer money. Disclosure of the records request is in the public interest because disclosure is likely to contribute significantly to the understanding of the operations or activities of the government. In addition, as one of the largest circulation newspapers in the United States, The New York Times plays an important role in sharing information with the public and helping the public understand how the federal government works. Disclosure of the records is not primarily in the commercial interest of myself or The New York Times but is intended to facilitate reporting on the operations of government. + +Please contact me if I may assist in your office's response to this request. + +Yours, + +Danielle Ivory + +Danielle Ivory + +![](_page_3_Picture_10.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084925/EFTA00084925.metadata.json b/marker2/ds9/EFTA00084925/EFTA00084925.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ebce208f6c104662599d7666a06c7a7ea6f8754b --- /dev/null +++ b/marker2/ds9/EFTA00084925/EFTA00084925.metadata.json @@ -0,0 +1,395 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084925.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": 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b/marker2/ds9/EFTA00084929/EFTA00084929.md @@ -0,0 +1,89 @@ +From: Ivory. Danielle' IIIIIIIIIIIIIIIIIIIIIIIII To: + +[REDACTED] + +**Subject:** RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +**Date:** Wed, 28 Apr 2021 16:03:52 +0000 + +--- + +Received. Thank you. + +-Laura + +**From:** [REDACTED] + +**Sent:** Tuesday, April 27, 2021 9:35 PM + +**To:** Laura Menninger + +**Cc:** [REDACTED] (USANYS) <[REDACTED]> +[REDACTED] + +**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, + +[REDACTED] + +[REDACTED] + +Southern District of New York + +1 St. [REDACTED] Plaza + +New York, NY 10007 + +[REDACTED] + +--- + +**From:** [REDACTED] + +**Sent:** Friday, April 23, 2021 1:44 PM + +**To:** Laura Menninger + +**Cc:** [REDACTED] (USANYS) <[REDACTED]> +[REDACTED] +[REDACTED] + +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, + +[REDACTED] + +[REDACTED] + +Southern District of New York +1 St. [REDACTED] Plaza +New York, NY 10007 + +[REDACTED] + +--- + +**From:** [REDACTED] + +**Sent:** Friday, April 23, 2021 12:13 PM + +**To:** Laura Menninger <[REDACTED]> + +**Cc:** [REDACTED] (USANYS) <[REDACTED]> +[REDACTED] +[REDACTED] +[REDACTED] +(CIV) <[REDACTED]> + +**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 Menninger < + +Sent: Wednesday, April 21, 2021 1:42 PM + +To: + +Cc alIUSANYS) + +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 I -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. Nlenninger I Partner Haddon. Mor an & Foreman, P.C. + +![](_page_3_Picture_8.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084933/EFTA00084933.metadata.json b/marker2/ds9/EFTA00084933/EFTA00084933.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..298f449ab2e84ddb951091372729452a96f71a8e --- /dev/null +++ b/marker2/ds9/EFTA00084933/EFTA00084933.metadata.json @@ -0,0 +1,162 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084933.pdf", + "engine": { + "marker_major": "2", + "marker_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": 8428, + "elapsed_seconds": 83.79, + "image_assets": [ + "_page_3_Picture_8.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 63 + ], + [ + "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": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Text", + 32 + ], + [ + "Line", + 30 + ], + [ + "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": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 39 + ], + [ + "Text", + 9 + ], + [ + "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": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 50 + ], + [ + "Line", + 25 + ], + [ + "Text", + 8 + ], + [ + "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/EFTA00084933" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084933/_page_3_Picture_8.jpeg b/marker2/ds9/EFTA00084933/_page_3_Picture_8.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..3b83022eda3d980f66479b6a94273a4d67c23f4c --- /dev/null +++ b/marker2/ds9/EFTA00084933/_page_3_Picture_8.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:2e878d23f64f83eff1423efbea508e6e80fefd39cca9a3196fff7073850ab09a +size 2987 diff --git a/marker2/ds9/EFTA00084937/EFTA00084937.md b/marker2/ds9/EFTA00084937/EFTA00084937.md new file mode 100644 index 0000000000000000000000000000000000000000..7d54e19ad5155af421f31307301057f6f10c9575 --- /dev/null +++ b/marker2/ds9/EFTA00084937/EFTA00084937.md @@ -0,0 +1,147 @@ +To: "Stein, Gary" + +Cc: MEW (USANYS)" + +Subject: RE: Professional Children's School + +Date: Mon, 26 Apr 2021 13:38:13 +0000 + +Hi Gary, + +Thanks for speaking earlier this month. Have you been able to locate a records custodian? Not time sensitive if you're still working on it, but I wanted to check in. + +Thanks very much, + +From: Stein, Gary + +Sent: Wednesday, April 7, 2021 1:56 PM + +To: I < > + +Cc: < >; (USANYS) < + +Subject: RE: Professional Children's School + +Thanks= I too am pretty wide open tomorrow afternoon. Want to say 2 pm? + +Gary Stein + +Partner + +my pronouns: he/him/his + +Schulte Roth & Zabel LLP www.Srz.COM + +From: + +Sent: Wednesday, April 7, 2021 1:33 PM + +To: Stein, Gary + +Cc: (USANYS) + +Subject: Re: Professional Children's School + +Not a problem— what time works for you? I'm fairly open tomorrow afternoon. + +On Apr 7, 2021, at 1:24 PM, Stein, Gary wrote: + +Apologies - can we move this call to Thursday afternoon? + +Schulte Roth & Zabel LLP wwwsrz.corn + +From: + +Sent: Tuesday, April 6, 2021 5:01 PM + +To: Stein, Gary + +Cc: ) c )'; (USANYS) + +Subject: RE: Professional Children's School + +Thanks very much. Let's plan for 9:30 on Thursday morning, if that works for you. We can use this conference line: + +Dial-in: + +Access code + +From: Stein, Gary + +Sent: Tuesday, April 6, 2021 4:39 PM + +To: + +Cc: Sullivan, Elizabeth + +Subject: RE: Professional Children's School + +Sure. Wednesday afternoon (other than 3 to 4 pm) or Thursday morning? + +Gary Stein Partner + +my pronouns: he/him/his + +Schulte Roth & Zabel LLP www.sa.corn + +From: + +Sent: Tuesday, April 6, 2021 1:03 PM + +To: Stein, Gary + +Cc: Sullivan, Elizabeth + +(USANYS) + +Subject: RE: Professional Children's School + +Hi Gary, + +Hope you're doing well. Are you available for a brief call sometime this week? We'd like to follow up with you about this matter. + +Thanks very much, + +New York, NY 10007 + +From: Stein, Gary + +Sent: Saturday, February 22, 202011:11 PM + +To: I •c > + +Cc: Sullivan, Elizabeth c:a.; + +Subject: Re: Professional Children's School + +I'll let you know. + +Gary Stein + +Partner + +Schulte Roth & Zabel LLP + +919 Third Avenue. New York NY 10022 + +On Feb 22, 2020, at 11:05 PM, ca wrote: + +## -CAUTION: EXTERNAL EMAIL + +Gary, + +I got your voicemail the other day, thank you — thanks for checking again on the possibility of any records relating to tuition payments, etc. The one follow-up question we have, which I think was not covered by the initial subpoena, is whether PCS currently has any records of third-party payments, donations, sponsored scholarships, or other similar financial transactions in the period of 1997 to 2000? If — similar to student financial records — those are no longer available, that would be helpful to know; alternatively, if they are (or might be) available, we can send an updated subpoena asking for any such records relating to Jeffrey Epstein. Please let us know? + +ass + +Assistant U.S. Attorney Southern District of New York + +NOTICE This e-mail message is intended only for the named recipient(s) above. 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 e-mail and any attachment(s) is strictly prohibited. If you have received this e-mail in error, please immediately notify the sender by replying to this e-mail and delete the message and any attachment(s) from your system. Thank you. + +NOTICE This e-mail message is intended only for the named recipient(s) above. 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 e-mail and any attachment(s) is strictly prohibited. If you have received this e-mail in error, please immediately notify the sender by replying to this e-mail and delete the message and any attachment(s) from your system. Thank you. + +NOTICE This e-mail message is intended only for the named recipient(s) above. 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 e-mail and any attachment(s) is strictly prohibited. If you have received this e-mail in error, please immediately notify the sender by replying to this email and delete the message and any attachment(s) from your system. Thank you. + +NOTICE This e-mail message is intended only for the named recipient(s) above. 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 e-mail and any attachment(s) is strictly prohibited. If you have received this e-mail in error, please immediately notify the sender by replying to this e-mail and delete the message and any attachment(s) from your system. Thank you. \ No newline at end of file diff --git a/marker2/ds9/EFTA00084937/EFTA00084937.metadata.json b/marker2/ds9/EFTA00084937/EFTA00084937.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..40386f3dbca1ae77127a48c8eb960f00787565ac --- /dev/null +++ b/marker2/ds9/EFTA00084937/EFTA00084937.metadata.json @@ -0,0 +1,172 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084937.pdf", + "engine": { + "marker_major": "2", + "marker_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": 5030, + "elapsed_seconds": 1.72, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "-CAUTION: EXTERNAL EMAIL", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 37.944, + 405.0 + ], + [ + 186.25936889648438, + 405.0 + ], + [ + 186.25936889648438, + 417.8340759277344 + ], + [ + 37.944, + 417.8340759277344 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 33 + ], + [ + "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", + 71 + ], + [ + "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": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 34 + ], + [ + "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 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 16 + ], + [ + "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/EFTA00084937" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084941/EFTA00084941.md b/marker2/ds9/EFTA00084941/EFTA00084941.md new file mode 100644 index 0000000000000000000000000000000000000000..9486ccae811f04a34f37d7b4e4a6116a5e848530 --- /dev/null +++ b/marker2/ds9/EFTA00084941/EFTA00084941.md @@ -0,0 +1,127 @@ +From: 1111.1=1S> To: S., Cc: IIIMaNtal=a + +Subject: RE: FW: U.S. v. Maxwell S2 20 Cr. 330 (AJN) + +Date: Wed, 28 Apr 2021 20:40:57 +0000 + +Importance: High + +Attachments: Ltr to\_Hon\_Nathan\_04.28.21—.pdf + +\*\* High Priority \*\* + +Hi everyone, + +Please see attached for submission. + +Best, + +>>> PM >>> Hi EIM, " 4/27/2021 6:21 + +I understand you spoke with and earlier today -- sorry I couldn't join, I was stuck in a witness interview. Just wanted to let you know that we are happy to review a draft of the letter you plan to file tomorrow if that would be useful. Also always happy to get on another call if anything else comes up. + +Thanks, + +Ori inal Messa e + +From: Sent: Tuesday, April 27, 2021 1:27 PM To: Cc: (USANYS) Subject: RE: FW: U.S. v. Maxwell S2 20 Cr. 330 (AJN) + +Thanks-- could we talk in about 10 minutes? + +Original Messa e + +From: Sent: Tuesda Aril 27 2021 1:14 PM To: alMil. >; Cc: (USANYS) + +are you available now? if so please cal + +27/2021 12:39 PM + +>>> + +In light of the Court's order directing a response by tomorrow, please let us know if you have time to speak sooner. + +Thanks, + +Ori inal Messa e + +From: + +Sent: Tuesda Aril 27. 2021 8:05 AM + +To: + +Cc: + +• (USANYS) + +Subject: Re: FW: U.S. v. Maxwell S2 20 Cr. 330 (AJN) + +Let's aim for tomorrow. We have the Assistant Director here today so I may be a little tied up. How does 11:30 sound? + +x4744 + +>>> " 4/26/2021 7:11 + +PM >>> + +Hi MIE, + +We just received the attached letter, which was filed with Judge Nathan this evening. Is there a good time for a call this week to discuss, please? + +Thanks, + +Assistant United States Attorney + +Southern District of New York + +1 St. Andrew's Plaza + +New York, NY 10007 + +212-637-2324 + +From: BOBBI C STERNHEIM + +Sent: Monday,A ril 26, 2021 7:05 PM + +To: + +Cc: Christian Everdell , Laura Menninger , Jeff Pagliuca Subject: U.S. v. Maxwell S2 20 Cr. 330 (AJN) + +Good evening- + +Attached please find a courtesy copy of today's ECF filing. + +Regards- + +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.conailto:bcstemheim@mac.com> + +\*\*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. \ No newline at end of file diff --git a/marker2/ds9/EFTA00084941/EFTA00084941.metadata.json b/marker2/ds9/EFTA00084941/EFTA00084941.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ed78687f5441a626c466da2f0762fe634d247354 --- /dev/null +++ b/marker2/ds9/EFTA00084941/EFTA00084941.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084941.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2995, + "elapsed_seconds": 1.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 74 + ], + [ + "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", + 63 + ], + [ + "Text", + 31 + ], + [ + "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": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "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/EFTA00084941" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084944/EFTA00084944.md b/marker2/ds9/EFTA00084944/EFTA00084944.md new file mode 100644 index 0000000000000000000000000000000000000000..1be6d3c18ec793231830298b04ea148c4bbdc0e6 --- /dev/null +++ b/marker2/ds9/EFTA00084944/EFTA00084944.md @@ -0,0 +1,41 @@ +From: )" < + +To: Nathan NYSD Chambers + +C , Jeff Pa liuca + +Subject: RE: Memorandum Endorsement in 20-cr-330, US v Maxwell + +Date: Wed, 28 Apr 2021 21:41:58 +0000 + +Attachments: Ltr to\_Hon\_Nathan\_04.28.21--.pdf + +Good afternoon, + +Attached is a letter from MDC legal counsel, in response to the Court's April 27, 2021 Order. Because the MDC is not a party to this case, this letter has not been filed on ECF, but the Government has no objection to the public docketing of this letter. + +Respectfully, + +Assistant United States Attorney Southern District of New York + +FrollEn + +Sent: Tuesday, April 27, 2021 10:56 AM + +Tcn > ; Nathan NYSD Chambers + +Cc: Jeff Pagliuca •:= >•; Laura Menninger c s; + +Subject: Re: Memorandum Endorsement in 20-cr-330, US v Maxwell + +Good morning- + +MDC Brooklyn has received this and will respond accordingly. Thank you. + +luper.,Py L Attorney MCC NY + +>> > Nathan NYSD Chambers < Good morning, > 4/27/2021 10:50 AM > » + +Please find attached a memorandum endorsement signed by Judge Nathan, which will be filed on the public docket shortly. Please confirm receipt. + +Respectfully, The Chambers of the Hon. J. Nathan \ No newline at end of file diff --git a/marker2/ds9/EFTA00084944/EFTA00084944.metadata.json b/marker2/ds9/EFTA00084944/EFTA00084944.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..164745c7ddd2e16ed398f61d9851e2c11e2e59de --- /dev/null +++ b/marker2/ds9/EFTA00084944/EFTA00084944.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084944.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1135, + "elapsed_seconds": 1.0, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 29 + ], + [ + "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", + 17 + ], + [ + "Line", + 8 + ], + [ + "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/EFTA00084944" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084946/EFTA00084946.md b/marker2/ds9/EFTA00084946/EFTA00084946.md new file mode 100644 index 0000000000000000000000000000000000000000..bce73c3deb4eb9d3b66d150a36e35778e31276cc --- /dev/null +++ b/marker2/ds9/EFTA00084946/EFTA00084946.md @@ -0,0 +1,137 @@ +From: ' (USANYS)" USANYS)" Cc: at r>, ' )II + +Subject: RE: VNS + +Date: Fri, 26 Jul 2019 13:59:31 +0000 + +Attachments 0190726095441587 DRAFT.pdf; US\_v.\_Epstein\_-\_Updated\_Victim\_List.xlsx + +Hi attached is the updated victim list. There are 2 victims that are highlighted that we don't have contact info. Another victim highlighted in blue looks like has opted out of notifications. + +Can I send the letters out under these circumstances? + +Thanks, + +Victim-Witness Assistant U.S. Attorney's Office — SDNY 1 St. Andrews Plaza New York, NY 10007 Office- + +From: Sent: Friday, July 26, 2019 9:38 AM To: (USANYS) <= >; (USANYS) < Cc: >; Subject: RE: VNS + +Just checking on the status of the letters— given the court conference next week, we wanted to make sure these went out. FBI tells us that the info should be updated in VNS, if you're able to check. + +Thanks! + +From: (USANYS)< > Sent: Tuesday, July 23, 2019 4:45 PM To: I Cc: < >; (USANYS) < Subject: RE: VNS + +Thanks . Let me contact FBI. I'll get back to you. + +From: Sent: Tuesday, July 23, 2019 4:42 PM To: (USANYS) ‹ > Cc: II < + +Hi M, + +Thanks for making those changes. Looks like you weren't able to get contact information for several of the victims. What is the easiest way to accomplish that—do you want to touch base with our case agents? Or should we take certain steps? Thanks. + +From: (USANYS) + +Sent: Tuesday, July 23, 2019 4:23 PM + +To: + +Cc: >; + +(USANYS) < + +Subject: RE: VNS + +attached is the updated victim list. Please look it over and let me know if it's accurate. + +Also attached is the notification that will be sent to these victims. Can it go out? Thank you. + +From: + +Sent: Friday, July 19, 2019 5:25 PM + +To: (USANYS) < =>; (USANYS) < + +Cc: II >: + +Subject: RE: VNS + +Apologies—there is one more victim who should be added: that's also represented by Thanks. + +From: + +Sent: Friday, July 19, 2019 5:21 PM + +To: (USANYS) ; (USANYS) < > + +Cc: MEn + +Subject: RE: VNS + +Hi=, + +Thanks! I know everyone has been moving quickly on this, so understandably there are some errors in the system. Is it possible to make the following corrections to the VNS system? In addition, I've listed below several victims who should be added— are you able to coordinate with FBI to get their contact information, or should we ask them to add them to the system? + +![](_page_1_Picture_25.jpeg) + +[REDACTED] + +- [REDACTED] + +**Victims to add:** + +- [REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +**From:** [REDACTED] (USANYS) <[REDACTED]> + +**Sent:** Friday, July 19, 2019 5:05 PM + +**To:** [REDACTED] <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]> + +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: VNS + +Hi [REDACTED], you're welcome! Please see attached. The list was pulled from VNS and I edited it the best I can. Let me know if you want it in a Word version and I'll work on that next week. + +[REDACTED] + +Victim-Witness Assistant +U.S. Attorney's Office - SDNY +1 St. Andrews Plaza +New York, NY 10007 +Office: [REDACTED] + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Friday, July 19, 2019 4:41 PM + +**To:** [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]> + +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** VNS + +[REDACTED] and [REDACTED] + +Thanks for putting together the next round of notifications. Would it be possible to email us the list of victims you have indexed (and their attorneys, for notification purposes)? Because of the volume of victims, it would be great if we could double check that everything made it into the system, and also check some of the spellings. + +Thanks! + +[REDACTED] + +[REDACTED] +Assistant United States Attorney +Southern District of New York +One Saint Andrew's Plaza +New York, NY 10007 +[REDACTED] + +![](_page_3_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084946/EFTA00084946.metadata.json b/marker2/ds9/EFTA00084946/EFTA00084946.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..aba295cab84dff495c7e4b643e4683344bf38f4b --- /dev/null +++ b/marker2/ds9/EFTA00084946/EFTA00084946.metadata.json @@ -0,0 +1,179 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084946.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3810, + "elapsed_seconds": 6.89, + "image_assets": [ + "_page_1_Picture_25.jpeg", + "_page_3_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Victims to add:", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 31.212, + 107.73000000000002 + ], + [ + 104.03999999999999, + 107.73000000000002 + ], + [ + 104.03999999999999, + 119.88 + ], + [ + 31.212, + 119.88 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 78 + ], + [ + "Line", + 36 + ], + [ + "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", + 70 + ], + [ + "Line", + 33 + ], + [ + "Text", + 25 + ], + [ + "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": "surya", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Text", + 57 + ], + [ + "Line", + 29 + ], + [ + "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": 3, + "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/EFTA00084946" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084946/_page_1_Picture_25.jpeg b/marker2/ds9/EFTA00084946/_page_1_Picture_25.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..5bc7b43a70623cb8559b536342224066eac787ef --- /dev/null +++ b/marker2/ds9/EFTA00084946/_page_1_Picture_25.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:2b8e95d0aadaaa57c146067a97950a420ea69ce3ab7d5562f2d4c1ac144fdb55 +size 18504 diff --git a/marker2/ds9/EFTA00084946/_page_3_Picture_0.jpeg b/marker2/ds9/EFTA00084946/_page_3_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..0e81ff5a0895d8953eb0521fb8ea966a2458cc70 --- /dev/null +++ b/marker2/ds9/EFTA00084946/_page_3_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:a4ddaad32ad00e45aaf295174fc7fc4040766169103a9a21491691b799297314 +size 1729 diff --git a/marker2/ds9/EFTA00084950/EFTA00084950.md b/marker2/ds9/EFTA00084950/EFTA00084950.md new file mode 100644 index 0000000000000000000000000000000000000000..71b77ab1e0659bd3d1e05b087d588f95ffe53ad5 --- /dev/null +++ b/marker2/ds9/EFTA00084950/EFTA00084950.md @@ -0,0 +1,59 @@ +![](_page_0_Picture_136.jpeg) + +DRAFT + +**U.S. Department of Justice** +Southern District of New York +One St. Andrews Plaza +New York, NY 10007 + +![](_page_0_Picture_139.jpeg) + +July 26, 2019 + +![](_page_0_Picture_141.jpeg) + +Re: United States v. Defendant(s) Jeffrey Epstein +Case Number 2018R0 [REDACTED] + +[REDACTED] : + +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. I am contacting you because you were identified by law enforcement as a victim or potential victim during the investigation of the above criminal case. + +Defendant Jeffrey Epstein was arrested and charged as the result of a criminal investigation conducted by the United States Attorney's Office for the Southern District of New York. The main charge is categorized as Project Safe Childhood. Additional information regarding the case is set forth below. The lead prosecutors on the case are [REDACTED], [REDACTED], and [REDACTED]. + +**Victim's Rights** + +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. If you want to inform the prosecutors of your views regarding any aspect of the case, please contact one of the prosecutors listed above or me at [REDACTED] + +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.lf 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. + +## Hearing Information + +On July 18, 2019, Judge Richard Berman ordered defendant Jeffrey Epstein detained pending trial. + +A status hearing is scheduled before Judge Richard Berman for July 31, 2019, 11:00 AM at Courtroom 17B, 500 Pearl Street, New York, NY 10007 for defendant Jeffrey Epstein. The purpose of this hearing is to determine if there are issues that the Court needs to address and to schedule any necessary future court dates. + +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. + +## Information Regarding the Victim Notification System (VNS) + +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. + +For many VNS registrants email will provide the most timely notification. VNS does not currently have an email address for you. You can provide VNS an email address by accessing the VNS Internet Web page using the login information provided below. By entering your email as part of the VNS registration process future notifications will be delivered by email, except in rare circumstances when you might also receive a letter from VNS. In order to continue to receive notifications, it is your responsibility to keep your contact information current. + +You will use your Victim Identification Number (VIN) and Personal Identification Number (PIN) I. anytime you contact the Call Center and the first time you log into VNS on the website. 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 + +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, + +Geoffrey S. Berman United States Attorney + +![](_page_2_Picture_3.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00084950/EFTA00084950.metadata.json b/marker2/ds9/EFTA00084950/EFTA00084950.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2bd3cbbdb284b6f1b4ae37dfce20ae513f8ba7a5 --- /dev/null +++ b/marker2/ds9/EFTA00084950/EFTA00084950.metadata.json @@ -0,0 +1,213 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084950.pdf", + "engine": { + "marker_major": "2", + "marker_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": 7331, + "elapsed_seconds": 10.8, + "image_assets": [ + "_page_0_Picture_136.jpeg", + "_page_0_Picture_139.jpeg", + "_page_0_Picture_141.jpeg", + "_page_2_Picture_3.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { 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4330 diff --git a/marker2/ds9/EFTA00084953/EFTA00084953.md b/marker2/ds9/EFTA00084953/EFTA00084953.md new file mode 100644 index 0000000000000000000000000000000000000000..31390f9f7eb72697e02f13cea75a303259a3e585 --- /dev/null +++ b/marker2/ds9/EFTA00084953/EFTA00084953.md @@ -0,0 +1,17 @@ +From: ' To: ' Cc: MIIMIr + +Subject: RE: 7/23 Tartaglione/Epstein video + +Date: Mon, 30 Dec 2019 17:24:02 +0000 + +Great, thanks. + +From: Sent: Monday, December 30, 2019 12:20 PM To: Cc: Subject: RE: 7/23 Tartaglione/Epstein video + +After defense requested that the video be preserved (unbeknownst to us), had SIS save a copy of a few hours from 7/22 into 7/23. That video has been preserved. They gave us a copy on 12/20, but it didn't have the player we needed and =couldn't convert it for us. So we are waiting for them to get us a new copy with the player. We don't know what it shows yet, but SIS has confirmed that it works because they've seen it on their own systems. Will give you a copy as soon as we have it. + +From: Sent: Monday, December 30, 2019 12:18 PM To: Cc: Subject: 7/23 Tartaglione/Epstein video + +What's the latest on this, who has it, and what does it show? Thanks so much + +Assistant United States Attorney Southern District of New York Tel: \ No newline at end of file diff --git a/marker2/ds9/EFTA00084953/EFTA00084953.metadata.json b/marker2/ds9/EFTA00084953/EFTA00084953.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..409ef18923225d470b0704f74677de885d306830 --- /dev/null +++ b/marker2/ds9/EFTA00084953/EFTA00084953.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084953.pdf", + "engine": { + "marker_major": "2", + "marker_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": 955, + "elapsed_seconds": 0.55, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 26 + ], + [ + "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/EFTA00084953" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084954/EFTA00084954.md b/marker2/ds9/EFTA00084954/EFTA00084954.md new file mode 100644 index 0000000000000000000000000000000000000000..de54dec9d3024772f318222cbc920a963cc59738 --- /dev/null +++ b/marker2/ds9/EFTA00084954/EFTA00084954.md @@ -0,0 +1,35 @@ +![](_page_0_Picture_3.jpeg) + +nateefemly 09/06/2019 + +IMMAGEILI, Corrections Officer at Bureau of Prison's (BOP) METROPOLITAN CORRECTIONAL CENTER (MCC), 150 Park Row, New York, New York, , was interviewed by FBI Special Agent (SA) , FBI Task Force Officer (TFO) Inspector General (OIG) SA Office (USAO), Southern District of New York (SDNY), 1 St. Andrews Plaza, New York, New York. TFO advised that there is an on-going criminal investigation and he has an obligation to answer questions truthfully and that it would be a federal crime to lie to a federal agent during the meeting. SA and Office of the at the United States Attorneys provided with an OIG "Warnings and Assurances to Employee Requested to Provide Information on a Voluntary Bases" form, which signed and was witnessed by SAs M . SA retained the original and a copy section of this report. is and attached in the lA + +After being advised of the identity of the interviewing investigators and the nature of the interview, provided the following information: + +shift in the time couldn't Saturday. has worked for BOP for four years. was working an overtime the Special Housing Unit (SHU), 10 South, on a 12am-8am shift at that JEFFREY EPSTEIN was found unresponsive in his cell. recall the exact date but did recall that it was the previous had worked a 12pm-8pm shift the previous day, had a four hour break, and then started the overtime shift of 12a-8a. Unit 10 South is a completely locked down unit where the Corrections Officer is alone in the unit. + +recalled he did the 12am count with and that Officer NOEL helped him do the 3am and 5am counts. and 5am counts, the control center had called about the counts and he advised control that he wanted someone to assist him in doing the counts further stated that for the 3am + +\,/ + +Investigationon 08/16/2019 at New York, New York, United States (In Person) + +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 am not to be distributed outside your agency. + +(u) :nterview of Corrections Officer + +Continuation of ED-302 parancranag .on 08/16/2019 .page 2 of 2 + +because he was by himself. said that there should always be a double staff count and that he always wanted a partner to do the count and wouldn't do a count without a partner. advised that while doing the counts, an officer should see breathing flesh. When and NOEL did the 3am and Sam counts, they counted five inmates. + +Officer THOMAS relieved at some point during the shift to give him a break. Lieutenant came by at some point to check on however, didn't remember the exact time. + +was in 10 South when the call came over, referring to when EPSTEIN was found unresponsive in his cell. then worked another shift in the SHU, 8am-4pm. + +stated that he once fed EPSTEIN because EPSTEIN had not received his meal and that EPSTEIN was grateful. Wit said that EPSTEIN didn't appear to be dangerous and that EPSTEIN never offered him money for anything. stated that he was shocked that this had happened, referring to EPSTEIN's death. said that EPSTEIN was supposed to be watched more closely and that the rounds should have been conducted regardless of whether EPSTEIN had previously been on suicide watch or not. + +said that he wanted a lawyer. Investigators discontinued questioning at that time. + +On his own accord, then stated something to the effect of "I want to be clear, I never brought stuff into the jail or allowed stuff in. 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The info came from a different outlet, so no details as of yet, but will let you know if we get anything further. + +[REDACTED] + +Public Affairs + +United States Department of Justice + +U.S. Attorney’s Office | Southern District of New York + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00084956/EFTA00084956.metadata.json b/marker2/ds9/EFTA00084956/EFTA00084956.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..68bd749a6e873974395f4c6077c7842e98525d56 --- /dev/null +++ b/marker2/ds9/EFTA00084956/EFTA00084956.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084956.pdf", + "engine": { + "marker_major": "2", + "marker_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": 745, + "elapsed_seconds": 3.47, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 32 + ], + [ + "Text", + 21 + ], + [ + "Line", + 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/EFTA00084956" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084957/EFTA00084957.md b/marker2/ds9/EFTA00084957/EFTA00084957.md new file mode 100644 index 0000000000000000000000000000000000000000..61719c07c51df37f4fad8d6bbd59e24e1a68a2d6 --- /dev/null +++ b/marker2/ds9/EFTA00084957/EFTA00084957.md @@ -0,0 +1,91 @@ +From: ' (USANYS)" To: ' Cc: (USANYS)" SANYS)" + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Date: Sat, 04 Jan 2020 15:36:43 +0000 + +Attachments: 010420\_Epstein\_Touhy\_Initial\_Letter\_to\_Kaplan.docx; Redline\_to\_010420\_Epstein\_Touhy\_Initial\_Letter to\_Kaplan.docx + +Thanks, all. The changes sound good to me. Please find attached an updated version incorporating edit and nit. + +I'll send this out on Monday unless folks have any further changes. please let me know if I should hold off until you've checked in with Robbie. + +Thanks, + +From: (USANYS) + +Sent: Saturday, January 4, 2020 8:31 AM + +To: Cc: (USANYS) (USANYS) > (USANYS) + +Subject: Re: Jeffrey Epstein-Related Touhy Requests + +I defer to you two on tone. One nit—the letter switches between DOJ and Department. I think Department is the more formal. + +On Jan 3, 2020, at 8:49 PM, wrote: + +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 M. + +thanks again, + +From: (USANYS) Sent: Friday, January 03, 2020 12:55 To: + +Cc: (USANYS) r•; ca; ) ); (USANYS) •ca (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +All, + +Please find attached an initial letter to Kaplan Hecker re: the know if you have any edits or concerns. Once I have sign-off, or let me know if I should use a request for information related to Epstein. Please let me I'll send to Robbie Kaplan (by mail and at different address). + +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: 14 + +Cc: (USANYS) I' (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) ) ' fl ); (USANYS) •ca (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. + +From: (USANYS) + +Sent: Thursday, January 02, 2020 10:01 + +To: (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 re uests 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—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 tEl. 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. Delfiner, 51 N.Y.S.2d 478, 479 (N.Y. Co. Sup. 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You did an extraordinary job in helping her feel comfortable to make this difficult decision. +Thank you all. + +[Redacted line] + +[Redacted text block] + +**Subject:** RE: update + +This is FANTASTIC news! Great work! Thank you all so much! What a wonderful note on which to end the day! [Redacted line] + +[Redacted text block] + +**Subject:** update + +Hi [Redacted line] + +We wanted to share the good news that we spoke with [Redacted line] lawyer late this afternoon, and he told us that his client is on board with cooperating with our office's investigation and possible prosecution of Ghislaine Maxwell. Our next step will be to meet with [Redacted line] for an interview to cover several topics that were previously off-limits during our meetings with her. We hope to have that meeting [Redacted line], or the week thereafter, depending on her schedule. + +Best, + +[Redacted line] + +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/EFTA00084961/EFTA00084961.metadata.json b/marker2/ds9/EFTA00084961/EFTA00084961.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..23f4c9a71eadb0222f25acda141b859f52462968 --- /dev/null +++ b/marker2/ds9/EFTA00084961/EFTA00084961.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084961.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1060, + "elapsed_seconds": 4.59, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 32 + ], + [ + "Span", + 29 + ], + [ + "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 + } + }, + { + "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/EFTA00084961" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084963/EFTA00084963.md b/marker2/ds9/EFTA00084963/EFTA00084963.md new file mode 100644 index 0000000000000000000000000000000000000000..1f7e2829da183d4e22c9bce1daba3e6cfd18abcf --- /dev/null +++ b/marker2/ds9/EFTA00084963/EFTA00084963.md @@ -0,0 +1,47 @@ +Michael C. Miller +[REDACTED] direct +[REDACTED] fax +[REDACTED] + +1114 Avenue of the Americas +New York, NY 10036 +212 506 3900 main +www.steptoe.com + +August 20, 2019 + +Via Electronic Mail + +[REDACTED] + +United States Attorney's Office, Southern District of New York + +[REDACTED] + +Re: *United States v. Jeffrey Epstein*, 19-CRIM-00490 (S.D.N.Y.) + +Dear [REDACTED] + +We represent Jeffrey Epstein, Reg No. 76318-054, who was previously incarcerated at the Metropolitan Correction Center in New York, New York (the "MCC") while awaiting trial on federal charges in the above-captioned case. We have been authorized by his estate to write pursuant to 28 C.F.R. §§ 16.21-16.26 to request documents and records from the U.S. Department of Justice related to Mr. Epstein. + +Specifically, we are seeking: any (1) protocols relating to the response to/investigation of inmate deaths within the MCC; (2) video recordings of all entrances and exits to the MCC; (3) entry and exit logs for the MCC; (4) video recordings of the hallways of the floor on which Mr. Epstein's cell was located; and (5) logs related to the guards on duty at the MCC (collectively, the "Requested Evidence"). The applicable time period for the requests is from 7:00 am on Friday, August 9, 2019 until 8:00 am on Saturday, August 10, 2019. As required by the regulations, we set forth below a summary of the relevance of the Requested Evidence. + +Mr. Epstein died in federal custody in his cell at the MCC. We are troubled by the circumstances of his death and by reports of irregularities at the facility. According to a statement issued by the Federal Bureau of Prisons: + +On Saturday, August 10, 2019, at approximately 6:3o 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. + +In a separate statement, Attorney General William P. Barr indicated that "Mr. Epstein's death raises serious questions that must be answered." On August 12, Mr. Barr further stated, "We are now learning of serious irregularities at this facility that are deeply concerning and that demand a thorough investigation." + +Moreover, there was initial uncertainty about the cause and manner of Mr. Epstein's death. The New York City Office of Chief Medical Examiner ("OCME") declined to immediately release a determination, citing the need for "further information." Days later, the OCME announced that it had reached a conclusion following a "careful review of all investigative information." + +We intend to conduct our own investigation into the circumstances of Mr. Epstein's death. In order to do so, we ask that the Requested Evidence be made available to counsel. + +Please let us know if you would like to discuss this request. + +Sincerely, + +4€16111(t\_ + +Michael C. Miller Steptoe & Johnson LLP 1114 Avenue of the Americas New York, NY 10036 + +Martin G. Weinberg Martin G. 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Miller irect ax + +1114 Avenue of the Americas New York, NY 10036 212 506 3900 main www.steptoe.com + +August 2O, 2019 + +Via Electronic Mail + +Legal Department Metropolitan Correctional Center + +Re: United States v. Jeffrey Epstein, 19-CRIM-00490 (S.D.N.Y.) + +Dear + +We represent Jeffrey Epstein, Reg No. 76318-054, who was previously incarcerated at the Metropolitan Correction Center in New York, New York (the "MCC") while awaiting trial on federal charges in the above-captioned case. We have been authorized by his estate to write pursuant to 28 C.F.R. §§ 16.21-16.26 to request documents and records from the U.S. Department of Justice related to Mr. Epstein. + +Specifically, we are seeking: any (1) protocols relating to the response to/investigation of inmate deaths within the MCC; (2) video recordings of all entrances and exits to the MCC; (3) entry and exit logs for the MCC; (4) video recordings of the hallways of the floor on which Mr. Epstein's cell was located; and (5) logs related to the guards on duty at the MCC (collectively, the "Requested Evidence"). The applicable time period for the requests is from 7:oo am on Friday, August 9, 2019 until 8:oo am on Saturday, August 10, 2019. As required by the regulations, we set forth below a summary of the relevance of the Requested Evidence. + +Mr. Epstein died in federal custody in his cell at the MCC. We are troubled by the circumstances of his death and by reports of irregularities at the facility. According to a statement issued by the Federal Bureau of Prisons: + +On Saturday, August 10, 2019, at approximately 6:3o 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. + +In a separate statement, Attorney General William P. Barr indicated that "Mr. Epstein's death raises serious questions that must be answered." On August 12, Mr. Barr further stated, "We are now learning of serious irregularities at this facility that are deeply concerning and that demand a thorough investigation." + +Moreover, there was initial uncertainty about the cause and manner of Mr. Epstein's death. The New York City Office of Chief Medical Examiner ("OCME") declined to immediately release a determination, citing the need for "further information." Days later, the OCME announced that it had reached a conclusion following a "careful review of all investigative information." + +We intend to conduct our own investigation into the circumstances of Mr. Epstein's death. In order to do so, we ask that the Requested Evidence be made available to counsel. + +Please let us know if you would like to discuss this request. + +Sincerely, + +64/ 6 1116\_ + +Michael Miller Steptoe & Johnson LLP 1114 Avenue of the Americas New York, NY 10036 + +Martin G. Weinberg Martin G. Weinberg, P.C. 20 Park Plaza, Suite 1000 Boston, MA 02116 \ No newline at end of file diff --git a/marker2/ds9/EFTA00084965/EFTA00084965.metadata.json b/marker2/ds9/EFTA00084965/EFTA00084965.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a8fb30f1165200a6bac89b5af84f9ac9da060899 --- /dev/null +++ b/marker2/ds9/EFTA00084965/EFTA00084965.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084965.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3251, + "elapsed_seconds": 0.78, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Line", + 32 + ], + [ + "Text", + 12 + ], + [ + "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", + 76 + ], + [ + "Line", + 34 + ], + [ + "Text", + 9 + ], + [ + "PageHeader", + 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/EFTA00084965" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084967/EFTA00084967.md b/marker2/ds9/EFTA00084967/EFTA00084967.md new file mode 100644 index 0000000000000000000000000000000000000000..8f1423ab0440469ad914cd5a95a6c0a5b0545554 --- /dev/null +++ b/marker2/ds9/EFTA00084967/EFTA00084967.md @@ -0,0 +1,39 @@ +Michael C. Miller + +oct + +1114 Avenue of the Americas New York. NY 10036 212 506 3900 main www.steptoe.com + +August 20, 2019 + +## Via Electronic Mail + +Federal Bureau of Investigation, New York Field Office + +Re: United States v. Jeffrey Epstein, 19-CRIM-00490 (S.D.N.Y.) + +Dear + +We represent Jeffrey Epstein, Reg No. 76318-054, who was previously incarcerated at the Metropolitan Correction Center in New York, New York (the "MCC") while awaiting trial on federal charges in the above-captioned case. We have been authorized by his estate to write pursuant to 28 C.F.R. §§ 16.21-16.26 to request documents and records from the U.S. Department of Justice related to Mr. Epstein. + +Specifically, we are seeking: any (i) protocols relating to the response to/investigation of inmate deaths within the MCC; (2) video recordings of all entrances and exits to the MCC; (3) entry and exit logs for the MCC; (4) video recordings of the hallways of the floor on which Mr. Epstein's cell was located; and (5) logs related to the guards on duty at the MCC (collectively, the "Requested Evidence"). The applicable time period for the requests is from 7:oo am on Friday, August 9, 2019 until 8:oo am on Saturday, August 10, 2019. As required by the regulations, we set forth below a summary of the relevance of the Requested Evidence. + +Mr. Epstein died in federal custody in his cell at the MCC. We are troubled by the circumstances of his death and by reports of irregularities at the facility. According to a statement issued by the Federal Bureau of Prisons: + +On Saturday, August 10, 2019, at approximately 6:3o 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. + +In a separate statement, Attorney General William P. Barr indicated that "Mr. Epstein's death raises serious questions that must be answered." On August 12, Mr. Barr further stated, "We are now learning of serious irregularities at this facility that are deeply concerning and that demand a thorough investigation." + +Moreover, there was initial uncertainty about the cause and manner of Mr. Epstein's death. The New York City Office of Chief Medical Examiner ("OCME") declined to immediately release a determination, citing the need for "further information." Days later, the OCME announced that it had reached a conclusion following a "careful review of all investigative information." + +We intend to conduct our own investigation into the circumstances of Mr. Epstein's death. In order to do so, we ask that the Requested Evidence be made available to counsel. + +Please let us know if you would like to discuss this request. + +Sincerely, + +64/ 6 1116\_ + +Michael Miller Steptoe & Johnson LLP 1114 Avenue of the Americas New York, NY 10036 + +Martin G. Weinberg Martin G. Weinberg, P.C. 20 Park Plaza, Suite 1000 Boston, MA 02116 \ No newline at end of file diff --git a/marker2/ds9/EFTA00084967/EFTA00084967.metadata.json b/marker2/ds9/EFTA00084967/EFTA00084967.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..82594958c1280868c41f602768fda8c24b792b2c --- /dev/null +++ b/marker2/ds9/EFTA00084967/EFTA00084967.metadata.json @@ -0,0 +1,120 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084967.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3255, + "elapsed_seconds": 0.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Via Electronic Mail", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 67.932, + 232.46999999999997 + ], + [ + 176.30899047851562, + 232.46999999999997 + ], + [ + 176.30899047851562, + 248.36248779296875 + ], + [ + 67.932, + 248.36248779296875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 32 + ], + [ + "Text", + 11 + ], + [ + "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", + 70 + ], + [ + "Line", + 32 + ], + [ + "Text", + 9 + ], + [ + "PageHeader", + 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/EFTA00084967" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084969/EFTA00084969.md b/marker2/ds9/EFTA00084969/EFTA00084969.md new file mode 100644 index 0000000000000000000000000000000000000000..61b7d22ea3b25f52f2328f6dae52ecbec2e5e384 --- /dev/null +++ b/marker2/ds9/EFTA00084969/EFTA00084969.md @@ -0,0 +1,56 @@ +| Case Number: | Reporting Office: | +|---------------------|--------------------------| +| 2019-010614 | New Jersey Area Office | + +## Interview of Federal Bureau of Prisons Senior Officer Specialist + +On September 12, 2019, Assistant United States Attorney U.S. Department of Justice (DOJ) Office of the Inspector General (OIG) Special Agent M and SSgent interviewed Federal Bureau of Prisons (BOP) Senior Officer Specialist (SOS) at the United States Attorney's Office, Southern District of New York, 1 Saint Andrews Plaza, New York, New York 10007. The purpose of this interview was to address the events surrounding the death of Jeffrey Epstein, Register Number 76318-054 and the actions of MCC staff members leading up to and subsequent to the death. was advised that the interview was voluntary and could be terminated at any time. was provided with OIG Form II1-22612 (Warnings and Assurances to Employee Requested to Provide Information on a Voluntary Basis), which he reviewed and signed. + +During his voluntary interview, provided the following substantive information: + +stated he began working as a Correctional Officer with the BOP in approximately 2005 or 2006 and spent his entire career at MCC New York. stated he was promoted to his current rank of SOS in approximately 2009. Prior to working for the BOP, served in the United States Army and worked for the Transportation Security Administration. continues to serve in the United States Army Reserve as a Flight Instructor- Master Trainer and performs military orders frequently. + +According to M, he is currently assigned to Morning Watch Overnight, Unit 2, which he described as a female unit. He also has multiple collateral duties, including the Disturbance Control Team and the Mentorship Program. He also serves as a Lead Control Tactics Instructor. stated he was assigned to the Special Housing Unit (SHU) Day Watch (8am — 4pm) from Monday to Friday. added he opted to transfer to Day Watch that quarter because he was able to perform overtime while on Da Watch and still get weekends off. The schedule also worked well with his military orders. stated the only assignment available with weekends off that quarter was the SHU Day Watch, which he accepted. + +stated he worked in the SHU in the past, but prior to this most recent SHU assignment he worked the overnight shift for approximately 5-6 years and was not assigned to the SHU during that time. When he first began working at MCC New York, stated he was assigned to the SHU, a typical post assignment for new officers, for a few months. After he rotated off that assignment, he stated he only worked in the SHU when he was providing coverage, when they were short-staffed, or if he responded to a use of force incidents. + +| Prepared By: | Preparer Title: | Reviewed By: | Reviewer Title: | +|--------------|--------------------|--------------|----------------------| +| | Special Agent | | Senior Special Agent | +| Signature: | | Signature: | | +| | Digitally li ed by | | | +| | | | Digitally signed by | + +stated officers assigned to the SHU on the weekends were responsible for taking institutional counts at 4pm, 10pm, 12am, 3am, and 5am. He added he did not work the weekend shift so he did not perform these counts. The Day Shift, which he was assigned to, performed 30 minute rounds. explained the counts are supposed to be completed every 30 minutes, but within a 40 minute time period. He described Mondays, Wednesdays, and Fridays as "shower days", where the inmates are escorted to a shower at the end of the tier. He added MCC New York SHU does not have showers in the cells so inmates have to be restrained, escorted to the shower, restrained again upon completion of their shower, and escorted back to their cell. described this process as time-consuming and stated it can affect the ability to perform the 30 minutes counts. He added the checks are being performed because officers have contact with the inmates throughout this process and they conduct counts as scheduled once the showers are completed. He added the Recreation Officers also constantly pull inmates out of their cells to take them to the 12th Floor to for their one hour of recreation time, which also affects the ability to perform traditional counts as expected. + +According to M, the 30 minute counts are conducted as required on Tuesdays and Thursdays because showers are not offered those days. further added he did not believe it would be possible to perform 30 minute rounds as scheduled on Mondays, Wednesdays, and Fric due to all of the inmate movement and the current staffing levels at MCC New York, which described as "abysmal". + +When asked to describe the process for filling out the times of the forms documenting the 30 minute counts, stated you are supposed to fill out the form as you are completing the round so you accurately record the time. He added that on shower days, he fills the form out when he gets the inmate out of the cell to transport him to the shower because he has visual contact with the inmate at that time. stated he also fills out the form when he responds to inmate's cells for complaints or things of that nature. He clarified the times may not exactly reflect 30 minutes, but he fills out the forms as he see the inmates. added he cannot comment on how other staff members perform the counts or fill out the logs. + +stated a comparison of the cameras to the 30 minute logs for his quarterly assignment to the SHU would reveal that the log sheet is posted at the end of the tier on occasion and other times the log is maintained at the desk by the officer's station. stated when the log is maintained at the desk, the officers would write things down and fill out the form to "catch up" after the checks were completed instead of filling it out as the checks were being done. He stated the forms are filled out after the fact because it is hectic and the officers don't have the logs with them while completing the checks. He added that, on occasion, some people would fill out the logs without completing the checks. stated he does not agree with this practice because that is not how things are supposed to be done. added there are times the sheets have not been posted on the tiers and are not filled out accurately and times they are filled out accurately. He stated the camera footage should show both instances. + +According to, he tried not to fill out the log sheets if he didn't actually perform the checks. He stated he would fill out the log sheet when it was maintained on the desk if he moved someone for the shower or performed the rounds. added if he noticed the log sheet had not been filled out for a period of time or he wasn't there during that time, he won't sign it. + +opined leadership at MCC New York is aware of how difficult it is for staff members to perform the 30 minutes rounds due to staffing shorts es and other manpower issues, to include additional equipment required i to do the job properly. stated staff members shared their concerns with Captain but nothing changed. He added he was not present at any of the meetings where the information was presented to Captain + +According to M, during his three month rotation on the SHU assignment, he was on military orders for approximately half of that time cumulatively. alined he performed two week military orders but had several sets of orders during that quarter. was at MCC New York during the period leading up to the death of Epstein, however. + +On August 9, 2019, stated he worked overtime on the midnight shift, which ran from 12am on Thursday to 8am on Friday. He performed this overtime on unit 11-South and worked this shift alone. stated he was relieved late, at ahaimately 8:40am, and didn't arrive to his scheduled shift on the SHU until approximately 8:45am. stated Epstein had already been escorted to the attorney conference room by the time he arrived at the SHU to begin his shift. According to =, Epstein never returned to the SHU during his shift. At approximately 3:30pm, checked to see if Epstein was still in the attorney conference room and received confirmation Epstein was still in the area. Epstein was in the attorney conference room for all counts that took place during shift. stated Epstein did not return to the SHU prior to being relieved at 4:00pm and reiterated he did not see Epstein at all during his shift that Friday. stated he believed Epstein stayed in the attorney conference room until late Friday night. + +When asked about Epstein's cellmate, Efrain Reyes, Register Number 85993-054, stated Reyes was gone when he reported to his shift at the SHU at 8:45am and did not return prior to alt relieved at 4:00pm. reiterated he never saw Reyes that Friday. added SOS Roberto may have told him that Reyes left the SHU. clarified he knew Reyes was not in his cell, but he did not know Reyes was released from custody. He stated he never saw the court list that day to know if Reyes was on it and stated just because an inmate was not in their cell, it does not mean they are actually leaving MCC New York. He stated it is not uncommon for inmates to be gone from their cell all day and then return later that evening. stated the most he knew was Reyes left the unit, but he did not know where Reyes went when he left the unit or that he was not returning. + +According to, when he called to see if Epstein was returning to the SHU for count, no one told him Reyes was not coming back. He clarified that no one told him Reyes was not coming back and that a in needed a new cellmate. reiterated that no one, including Captain 1=1, Lieutenant the Psychology Department, or SOS told him Epstein needed a new cellmate. + +When left his shift at 4pm, Correctional Officer (no further information) was in the SHU + +working but he couldn't recall who else was there but did not recall seeing Officer Tova Noel. added he did not see most of the officers on the next shift because he left as soon as he completed his turnover with believed Noel waarosed to come in for the next shift but he does not know who else was supposed to be working. stated he relayed to that Epstein was still down at the attorney conference room and that there were a few inmate showers that had to be tom, because they were unable to finish them during the 8am to 4pm shift. stated he also told what the inmate count should be. could not recall if he passed any information about Reyes. added his focus was providing information about Epstein because he was "high profile". + +stated he was on military orders in July 2019 and learned about Epstein's initial suicide attempt upon his return to MCC New York after completing his orders. added he did not know Epstein was removed from suicide watch until after his death. He reiterated again that no one informed him Epstein required a new cellmate. He elaborated SOS never told him Reyes was being released and Epstein required a new cellmate. Additionally, never saw a memorandum drafted by SOS dictating he provided the information about Reyes and Epstein to added if someone wrote a memorandum stating they told that Epstein required a cellmate it would be false. + +stated if he was made aware that Epstein required a new cellmate, he would have followed direction and ensured Epstein received one. stated if a fellow officer told him Epstein required a new cellmate, he would have confirmed this information with his leadership and then he would have assigned a new cellmate to Epstein. added it would not have been difficult to find a new cellmate for Epstein. repeated that if he was made aware by lead, that Epstein required a new cellmate he would have made it happen, but no one told him. stated it did not matter who the inmate was, if he is told an inmate needs a cellmate, he ensures the inmate receives a cellmate because when they are told an inmate requires a cellmate, it is for a reason. + +When asked about his interactions with Epstein, stated he didn't really interact with Epstein. He stated he escorted him to the attorney conference room on one occasion but he didn't really talk to him. He stated he always got Epstein what he needed, such as socks, like he did with any other inmate at MCC New York. + +## Attachment(s): + +- I. OIG Form III-226/2- Warnings and Assurances to Employee Requested to Provide Information on a Voluntary Basis. 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This investigation is being conducted pursuant to the Inspector General Act of 1978, as amended. + +This investigation pertains to: + +in re: cash of Jeffrey Eastern and +any shift misconduct + +This is a voluntary interview. Accordingly, you do not have to answer questions. No disciplinary action will be taken against you if you choose not to answer questions. + +Any statement you furnish may be used as evidence in any future criminal proceedings or agency disciplinary proceeding, or both. + +### WAIVER + +I understand the warnings and assurances stated above and I am willing to make a statement and answer questions. No promises or threats have been made to me and no pressure or coercion of any kind has been used against me. + +[Redacted] + Office of the Inspector General + Special Agent + +[Redacted] + Employee's Signature + +[Redacted] + Witness + +September 12, 2019 + Date + +11:41 am + Time + +USAO SDNY, No-York + Place \ No newline at end of file diff --git a/marker2/ds9/EFTA00084973/EFTA00084973.metadata.json b/marker2/ds9/EFTA00084973/EFTA00084973.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c0983ab86032a09a0f6b5cf3abd740da31a475d3 --- /dev/null +++ b/marker2/ds9/EFTA00084973/EFTA00084973.metadata.json @@ -0,0 +1,120 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084973.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1219, + "elapsed_seconds": 5.61, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DEPARTMENT OF JUSTICE Office of the Inspector General", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 87.51599999999999, + 69.66 + ], + [ + 520.8119999999999, + 69.66 + ], + [ + 520.8119999999999, + 115.01999999999998 + ], + [ + 87.51599999999999, + 115.01999999999998 + ] + ] + }, + { + "title": "WARNINGS AND ASSURANCES TO EMPLOYEE REQUESTED TO PROVIDE INFORMATION ON A VOLUNTARY BASIS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 127.90799999999999, + 142.56 + ], + [ + 479.808, + 142.56 + ], + [ + 479.808, + 169.29 + ], + [ + 127.90799999999999, + 169.29 + ] + ] + }, + { + "title": "WAIVER", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 276.012, + 420.39 + ], + [ + 330.48, + 420.39 + ], + [ + 330.48, + 432.54 + ], + [ + 276.012, + 432.54 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 25 + ], + [ + "SectionHeader", + 6 + ], + [ + "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/EFTA00084973" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084974/EFTA00084974.md b/marker2/ds9/EFTA00084974/EFTA00084974.md new file mode 100644 index 0000000000000000000000000000000000000000..d59c49c3af49f0681023198e477af063a0d0a610 --- /dev/null +++ b/marker2/ds9/EFTA00084974/EFTA00084974.md @@ -0,0 +1,144 @@ +# Independent Epstein Victims' Compensation Program PROTOCOL DRAFTS + +December 13, 2019 + +#### I. Purpose and Overview + +The Epstein Victims' Compensation Program (the "Program") is a voluntary, independent Program that has been established to compensate and resolve the claims of victims/survivors of sexual abuse by Jeffrey Epstein ("Epstein"). + +The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims administration experts Kenneth R. Feinberg, Camille S. Biros and Jordana H. Feldman to design the Program. Ms. Feldman will also serve as the Administrator of the Program (the "Administrator"). + +Through the Program, the Estate wishes to acknowledge the wrongs endured by victims/survivors and offer them an opportunity to voluntarily resolve their individual claims for such sexual abuse. + +The Program is governed by the following non-exclusive guiding principles: + +- The Program is purely voluntary. It does not affect any rights a victim may have unless and until the Claimant accepts the offered compensation and executes a Release. A Claimant may reject the offer of compensation and may stop participating in the Program and withdraw the claim at any time prior to execution of the Release. +- The Program is independent and will in no way be administered, controlled or overseen by the Estate. The Administrator is responsible for all decisions relating to the review, processing and evaluation of individual claims submitted to the Program. The Administrator will have final, binding and exclusive authority to determine Claimant eligibility and the valuation of each eligible individual claim. Decisions of the Administrator made pursuant to this Protocol are not subject to review or modification in any way by the Estate or any other party or entity. +- There is no cap or limitation on the aggregate amount of funds available to compensate all eligible Claimants or on the amount of compensation to be made to each individual Claimant. Each individual claim will be evaluated separately by the Administrator. The Administrator will determine, in her sole and exclusive discretion, issues of eligibility and the amount of compensation. + +This document is a draft of the Protocol governing the Program and is subject to input from victims/survivors, their lawyers, other potentially interested parties, and representatives of the Estate. + +- All Claimants will be treated with respect, dignity and fairness without regard to race, color, sexual orientation, national origin, religion, gender or disability. To ensure claims will be adjudicated fairly, the Administrator will manage the process so that all Claimants can equally access the Program's claim process. Individuals with disabilities will be given the opportunity to effectively communicate their claims and to request special process accommodations. + +The Program will be effective within 90 days of approval by the Superior Court of the U.S. Virgin Islands ("Effective Date")2 and is available to all victims/survivors regardless of where they were harmed, when they were harmed, whether the claim is time-barred by the applicable statute of limitations, and whether they have previously filed a lawsuit against or settled with Epstein and/or the Estate. + +The exclusive claims period for filing a claim pursuant to this Protocol shall commence on the to-bedetermined Effective Date and shall conclude nine (9) months after that date ("Filing Deadline"). All individual claims filed with the Program must be postmarked within this period. + +### II. Eligibility Requirements + +## A. Eligibility Criteria + +The persons eligible to participate in this Program are individuals who allege they were sexually abused by Epstein. In addition, the following criteria apply: + +- The claim of sexual abuse must be directed against Epstein. +- An individual whose claim is time-barred by the applicable statute of limitations may participate in the Program provided that other eligibility criteria are met. +- An individual who previously entered into a settlement agreement resolving a claim of sexual abuse against Epstein may participate in the Program provided that other eligibility criteria are met. +- An individual who allegedly assisted Epstein in procuring other victims/survivors may participate in the Program where there is a credible basis to determine that the individual acted under duress as a result of her own sexual abuse by Epstein, provided that other eligibility criteria are met. +- If the Claimant chooses to accept the offered compensation, the Claimant must dismiss with prejudice any existing lawsuits or legal actions or claims filed against the Estate or related entities and/or individuals. The Claimant must provide proof of such dismissal along with or prior to the signed acceptance letter and executed Release in order to receive payment. + +2 The final version of the Protocol will include dates certain identifying the commencement date of the Program and registration and filing deadlines, as explained below. + +#### B. Legal Representatives of Claimants + +An individual may file a claim on a victim's behalf where that individual has been granted legal authority to act in a representative capacity pursuant to appropriate law. The "Legal Representative" of an individual Claimant shall mean: (1) in the case of a Claimant who is currently a minor, a parent or legal guardian authorized by law to serve as the minor's legal representative; (2) in the case of an incompetent or legally incapacitated Claimant, a person who has been duly appointed as the Claimant's legal representative in accordance with applicable law; or (3) an attorney authorized to represent the Claimant for purposes of pursuing a claim through this Program. + +Legal Representatives must provide proper documentation demonstrating representative capacity. Such proof may include a power of attorney, documentation showing the individual's appointment as guardian or guardian ad litem, or a copy of a retainer agreement showing legal representation signed by both the Claimant and the attorney. + +### III. Claims Administration - Submission, Evaluation and Determination + +#### A. Claims Submission Process + +Individuals who have filed a lawsuit, legal action or claim against Epstein and/or the Estate on or before the Effective Date will be sent a Claim Form and other relevant Program information, including Instructions for completion and submission of the Claim Form and a list of Frequently Asked Questions. + +Individuals who have not filed a lawsuit, legal action or claim against Epstein and/or the Estate on or before the Effective Date may register to participate in this Program on the Program's website at www.EpsteinVictimsCompensationProgram.com.3 To register, such individuals must complete a questionnaire setting forth their name, contact information, a summary description of the nature of the claim and other requested information. Upon registration, the Administrator will perform a preliminary review to consider if the individual is eligible to participate in the Program. If the Administrator deems that the individual is eligible to participate in the Program, she will then send that individual a Claim Form and other relevant Program information. + +Note: The fact that an individual is sent a Claim Form and other relevant Program information indicates that the Administrator has determined that such individual is eligible to participate in the Program. It does not indicate that the Administrator has determined that such individual is eligible to receive compensation. That determination is made only after a Claim Form and all required documentation has been submitted and evaluated by the Administrator. + +Registrations will be accepted by the Administrator from the Effective Date through a date that is 45 days prior to the Filing Deadline ("Registration Deadline"). It is important to note that the Registration Deadline is separate from, and precedes, the Filing Deadline. As explained above, all claims must be filed by the Filing Deadline. + +This website is in the process of being developed and is yet operational. + +All Claim Forms must be completed and postmarked no later than the Filing Deadline. Claim Forms should be mailed via overnight courier (a pre-paid courier voucher will be included with each packet) to the Administrator at the following address or uploaded to the Program website at www.EpsteinVictimsCompensationProgram.com: + +Epstein Victims' Compensation Program + +c/o Jordana H. Feldman, Administrator + +[Address - To Be Inserted] + +Claimants are invited to provide documentation identified in the Claim Form, and any other corroborating or supporting information sufficient to substantiate the claim, satisfy eligibility requirements, and allow the Administrator to review, process and evaluate the claim. If the claim is being presented by a Legal Representative, then the Legal Representative will be responsible for submitting the necessary documentation relating to the represented Claimant. + +Additional documentation may be requested at the discretion of the Administrator. Both the Claimant and the Estate will be afforded the opportunity to submit to the Administrator any information deemed relevant to the Administrator's evaluation and determination of the claim before the Administrator's final disposition of the claim. + +If a Claimant submits an incomplete or deficient claim, the Administrator will notify the Claimant, explain the additional information that is needed, and work with the Claimant or the Claimant's Legal Representative (where applicable) to assist in submitting a complete claim. + +## B. Claims Evaluation and Determination + +Claims will be evaluated in the order in which they are received, with the Administrator evaluating each submitted individual claim in a prompt and fair manner. Claims will only be determined once all required documentation has been submitted to the Administrator + +## 1. Factors Considered in Evaluating Claims + +As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the information available, whether the allegations of sexual abuse are credible. The Administrator will consider appropriate factors and corroborative support, including but not limited to: + +- The level of documentation, corroboration or other circumstantial evidence regarding the nature and extent of the abuse, the frequency, location and other details of the abuse, and the age of the victim at the time of the abuse. Non-exhaustive examples of such evidence include (i) medical or psychiatric counseling/therapy records relevant to the abuse, and + - (ii) contemporaneous written notification or other correspondence (e.g., letters, emails) of the abuse by the Claimant to law enforcement authorities, parents, friends or others. +- Whether there exists any information and/or pertinent findings offered by the appropriate Office of the District Attorney or other law enforcement agency. + +- Whether the Administrator finds the claims of the individual to be credible after complete review of all relevant documentation and other evidence provided by the Claimant and the Estate. + +As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the information available, the amount of compensation that should be offered to each eligible Claimant. The Administrator will consider appropriate factors and corroborative support, including but not limited to: + +- The nature, duration and extent of the sexual abuse suffered by the Claimant. +- The age of the Claimant at the time of the sexual abuse. +- The nature and extent of the Claimant's physical or psychological damage resulting from the sexual abuse, and the effect of the sexual abuse on the Claimant. +- The credibility of the claim based upon all of the facts and circumstances, supporting documentation and corroborating evidence. +- Whether the claim is time-barred under the applicable statute of limitations. +- Whether the Claimant previously entered into a settlement agreement with Epstein and received a payment pursuant to such agreement. + +The Administrator will confidentially send the Claimant a compensation determination letter including the following: (1) the Administrator's eligibility decision regarding the claim; (2) the amount of compensation offered; (3) a Release to be signed by the Claimant if the Claimant accepts the offered compensation; and (4) a Payment Option Form. The Administrator's offer shall be valid for 60 days from the date of the compensation determination letter. + +The Administrator's determinations in this Program will not be binding on any potential criminal investigation involving the same or similar allegations or Claimant. + +# 2. Opportunities to be Heard + +The Claimant will be afforded an opportunity to be heard, either before or after the Administrator renders her determination. Upon request by the Claimant, the Administrator will be available to meet in person, by video conference/Skype, or by teleconference to further discuss the claim. These meetings are completely optional and voluntary. Requests to meet with the Administrator should be sent by email and will be scheduled at a mutually convenient time and location. The Administrator may also request a meeting with a Claimant or her Legal Representative at a reasonable mutually convenient time and location, though the Claimant is not obligated to attend any such meeting. + +4 This email address is not yet active. + +#### 3. Release + +By submitting a claim to the Program, a Claimant is seeking to resolve all claims relating to allegations of sexual abuse against Epstein and/or the Estate, related entities and/or individuals. If a Claimant chooses to accept the offer of compensation pursuant to the Program, the Claimant will be required to sign and execute a full Release, in a form satisfactory to the Estate, of all past and future claims relating to such allegations of sexual abuse against the Estate, related entities and/or individuals. A Claimant may reject the offer of compensation and may stop participating in the Program and withdraw the claim at any time prior to the execution of the Release. + +The Release will waive any rights the Claimant and her heirs, descendants, legatees or beneficiaries may have to assert any claims relating to allegations of sexual abuse against the Estate, related entities and/or individuals, to file an individual legal action relating to such allegations, or to participate in any legal action associated with such allegations, except as a witness. However, the Release will not operate to preclude or limit the Claimant's ability to report and discuss allegations of sexual abuse with law enforcement officials or anyone else. + +Before signing a Release, the Claimant must consult with an attorney. If the Claimant is not represented by an attorney, the Program will provide an attorney to provide free legal counseling to the Claimant for the sole purpose of advising the Claimant concerning the language and binding nature of the Release. + +No one affiliated with the Program will provide tax or legal advice to those receiving payments under the Program. Claimants are urged to consult with a tax advisor concerning any questions regarding tax liability for payments pursuant to the Program. + +#### 4. Payments + +Upon the Claimant's acceptance of the Administrator's determination, the Administrator's receipt of the Claimant's executed Release and, where applicable, dismissal with prejudice of any existing lawsuit or legal actions or claims against the Estate or related entities and/or individuals, the Administrator will initiate payment by check or electronic funds transfer to each eligible Claimant as directed by the Claimant. Checks will be sent to Claimants via overnight courier service. + +#### C. Program Integrity + +For the purpose of protecting both the integrity of the Program and financial resources for eligible Claimants, the Administrator will institute all necessary measures to prevent payment of fraudulent claims, including taking steps to verify claims and analyze submissions for inconsistencies, irregularities or duplication. + +Each Claimant who signs the Claim Form at the time of submission certifies that the information provided in the Claim Form is true and accurate to the best of the Claimant's knowledge, and that the Claimant understands that false statements or claims made in connection with such submission may result in fines, imprisonment and/or any other remedy available by law. Claims that appear to be potentially fraudulent or to contain false information will be forwarded to federal, state or local law enforcement agencies and/or the appropriate Office of the District Attorney for possible investigation and prosecution. + +## D. Confidentiality/Privacy + +The Program is confidential. By filing a claim with the Program, the Claimant or her Legal Representative (where applicable) agrees that information submitted by the Claimant pursuant to the Program will be used and/or disclosed by the Administrator and her designees only for the following purposes: + +- I) Processing and evaluating the Claimant's claim; +- 2) Administering the Program and other Program-related work; and +- 3) Reports to law enforcement where appropriate. + +When documents maintained or submitted by the Estate become part of a Claimant's file for purposes of the Program, such materials will be reviewed by the Administrator to assist in processing and evaluating the claim, but will otherwise remain confidential. These files are not available for inspection, review or copying by the Claimant or her representatives during or after the Program, and all pertinent settlement privileges and other privileges apply. + +To protect the privacy of Claimants participating in the Program, all personal information provided by the Claimant during this process will be returned or destroyed within one year after the conclusion of the Program. + +Individual Claimants are not bound by any rules of confidentiality. Claimants may, at their sole and voluntary option, disclose information in their possession regarding their claim, their compensation and their experience with the Program. + +All confidentiality requirements are subject to law, regulation and judicial process. + +The Administrator may, on a periodic basis, publish reports regarding the Program's claims processing or other activities in an effort to provide transparency. Such reports will report on an aggregate level only. 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We've confirmed meetings for Tuesday (9/10) with both [REDACTED] and [REDACTED] in Palm Beach. The [REDACTED] meeting will be a reverse proffer, but it's a meaningful step in the investigation. + +We're trying to schedule additional meetings while we're there, and we'll let you know if there are any developments. + +[REDACTED] + +Assistant United States Attorney +Southern District of New York + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00084981/EFTA00084981.metadata.json b/marker2/ds9/EFTA00084981/EFTA00084981.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..293acad30857edb4ee0d3dd7fc16e1d8bb46c947 --- /dev/null +++ b/marker2/ds9/EFTA00084981/EFTA00084981.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084981.pdf", + "engine": { + "marker_major": "2", + "marker_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": 642, + "elapsed_seconds": 3.12, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Text", + 22 + ], + [ + "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/EFTA00084981" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00084982/EFTA00084982.md b/marker2/ds9/EFTA00084982/EFTA00084982.md new file mode 100644 index 0000000000000000000000000000000000000000..eea8b7c128eea9f859ebe48378a14ada0c7b045f --- /dev/null +++ b/marker2/ds9/EFTA00084982/EFTA00084982.md @@ -0,0 +1,195 @@ +![](_page_0_Picture_0.jpeg) + +November 1, 2021 + +VIA EMAIL + +![](_page_0_Picture_7.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 lOth Avenue Denver, Colorado 80203 + +www.hrnflaw.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. M.D., M.P.H., PH.D. + +Dr. 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. =received a bachelor's degree in psychology and biology from the Cornell University CUrne 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 , has evaluated or supervised over 1,000 evaluations of allega ions o sexual vic aniza ion. 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. ill be qualified as an expert in the areas of psychiatry and behavioral science. Dr. curriculum vitae is attached as Exhibit B. Attached as Exhibit C is a list of material reviewed by Dr. + +His testimony may include, but will not be limited to, the following: + +# a. Opinions about Dr.MDisclosed 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. , Grooming and Seduction, 33 J. Interpersonal Violence, 28, 31 (2018). r. 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 an articular population of alleged victims, patients, or plaintiffs—including those whom Dr. 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. IIREp roposed testimony is silent as to whether she is expected to impute a theory of "grooming- y-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.Mis 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. pinion that "[i]ndividuals with particular vulnerabilities are often targeted by perpetrators o 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 whic rvation of prevalent vulnerabilities is derived—including those clients whom Dr. has treated or evaluated—rarely represent groups in which all allegations of abuse have en 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. o the extent they are based on uncorroborated allegations and are also otherwise relevant nere. 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 + +Dr. ed an independent medical and psychiatric evaluation of in 2009. Dr. 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 Dia + +Dr. es 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. He will testify about the facts and circumstances surrounding the evaluation, disclosures made by Ms. and the fact that Ms. did not identify Ms. Maxwell as a perpetrator of any abuse. + +D. + +Professor s 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 extensive scholarship has had an essential role in establishing the study of prosecutona 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 to provide testimony on best practices to ensure the integrity of any prosecution, ocusmg 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. + +Mr. is CEO of He has over 25 years of experience in computer forensics, engineering and so tware tec no ogy. 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. 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. + +I We anticipate that Mr. I will testify about the user data associated with certain devices seized and searched byte 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. may testify in rebuttal to any testimony offered by the government through Ste hen ey. As trial preparation proceeds, the defense will update the topics for Mr. if any arise. + +F. + +Mr. was a Special Agent with the United States Department of the Treasury, Internal Revenue Servicel in ' • al Investigation ("IRS-CI") for over twenty-five years. During his tenure at IRS-CI, Mr. led the New York Asset Forfeiture Task Force and participated in numerous criminal investigations involving complex fraud, corruption, bribery tax evasion, money laundering, and asset forfeiture. Since retiring from the IRS in 2013, Mr. 101has worked as a financial investigator and consultant for several private investigation companies and government enforcement agencies. He currently runs his own private financial investigation and consulting company called JDL Services, Inc. Mr. olds a bachelor's degree in Business Administration, Accounting and Finance from Pace mversity. His curriculum vitae is attached as Exhibit I. + +It is expected that Mr. p will testify about his re certain financial records provided by the government in iscovery. Specifically, Mr. 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. + +ment Dating Specialist with the firm 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 journal pages by witness . 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 quality.lVIr. as an expert to offer the proposed testimony. Nevertheless, we hereby notice Mr. as a potential expert witness in an abundance of caution. + +November 1, 2021 + +Page 14 + +H. + +Ms. is a Forensic Document Examiner who worked for and received specialized training from the United States Secret Service as a Document Analyst. Ms. 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 to journal pages by witness . 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. 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, + +etrrey S. raguuca + +Enclosures \ No newline at end of file diff --git a/marker2/ds9/EFTA00084982/EFTA00084982.metadata.json b/marker2/ds9/EFTA00084982/EFTA00084982.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..01ecb0fc4906aaf812522f01ad8f79fff7aa1661 --- /dev/null +++ b/marker2/ds9/EFTA00084982/EFTA00084982.metadata.json @@ -0,0 +1,755 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084982.pdf", + "engine": { + "marker_major": "2", + "marker_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": 43217, + "elapsed_seconds": 2.22, + "image_assets": [ + "_page_0_Picture_0.jpeg", + "_page_0_Picture_7.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "I. 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The list looks good to me—I thin e comments, but the contact information looks up to date. Regar ing e've been in touch with them recently—I'm copying our case agents here so t at t hey can connect wit you a out getting updated contact information. + +Once the letter is finalized, however, let's send it out quickly today, and we can send letters to the agents are able to provide you with contact information. s soon as + +Thanks! + +From: Sent: Friday, July 26, 2019 10:00 AM To: Cc: Subject: RE: VNS (usANys) ::. + +Hi attached is the updated victim list. There are 2 victims that are highlighted that we don't have contact info. Another victim highlighted in blue looks like has opted out of notifications. + +Can I send the letters out under these circumstances? + +Thanks, + +Victim-Witness Assistant U.S. Attorney's Office — SONY 1 St. Andrews Plaza New York, NY 10007 Office: + +From: Sent: Friday, July 26, 2019 9:38 AM To: Cc: Subject: RE: VNS >; (USANYS) < + +Just checking on the status of the letters— given the court conference next week, we wanted to make sure these went out. FBI tells us that the info should be updated in VNS, if you're able to check. + +Thanks! + +From: + +Sent: Tuesday, July 23, 2019 4:45 PM + +To: + +Cc: (USANYS) < + +Subject: RE: VNS + +Thanks . Let me contact FBI. I'll get back to you. + +From: + +Sent: Tuesday, July 23, 2019 4:42 PM + +To: + +Cc: (USANYS) < + +Subject: RE: VNS + +Hi M, + +Thanks for making those changes. Looks like you weren't able to get contact information for several of the victims. What is the easiest way to accomplish that—do you want to touch base with our case agents? Or should we take certain steps? Thanks. + +From: + +Sent: Tuesday, July 23, 2019 4:23 PM + +To: + +Cc: (USANYS) < + +Subject: RE: VNS + +attached is the updated victim list. Please look it over and let me know if it's accurate. + +Also attached is the notification that will be sent to these victims. Can it go out? Thank you. + +From: + +Sent: Friday, July 19, 2019 5:25 PM + +To: (USANYS) < + +Cc: `: 1>; + +Subject: RE: VNS + +Apologies—there is one more victim who should be added: also represented by Thanks. + +From: + +Sent: Friday, July 19, 2019 5:21 PM + +To: (USANYS) < + +Thanks! I know everyone has been moving quickly on this, so understandably there are some errors in the system. Is it possible to make the following corrections to the VNS system? In addition, I've listed below several victims who should be added— are you able to coordinate with FBI to get their contact information, or should we ask them to add them to the system? + +**Edits:** + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +[REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +[REDACTED] + +**Victims to add:** + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +--- + +**From:** [REDACTED] > + +**Sent:** Friday, July 19, 2019 5:05 PM + +**To:** [REDACTED] < [REDACTED] >; [REDACTED] (USANYS) < [REDACTED] > + +**Cc:** [REDACTED] < [REDACTED] >; [REDACTED] < [REDACTED] > + +**Subject:** RE: VNS + +Hi [REDACTED], you're welcome! Please see attached. The list was pulled from VNS and I edited it the best I can. Let me know if you want it in a Word version and I'll work on that next week. + +[REDACTED] +Victim-Witness Assistant +U.S. Attorney's Office – SDNY +1 St. Andrews Plaza +New York, NY 10007 +Offic [REDACTED] + +Thanks for putting together the next round of notifications. Would it be possible to email us the list of victims you have indexed (and their attorneys, for notification purposes)? Because of the volume of victims, it would be great if we could double check that everything made it into the system, and also check some of the spellings. + +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/EFTA00084996/EFTA00084996.metadata.json b/marker2/ds9/EFTA00084996/EFTA00084996.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..075f0dc87427404195875153b8f419373637188d --- /dev/null +++ b/marker2/ds9/EFTA00084996/EFTA00084996.metadata.json @@ -0,0 +1,195 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00084996.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3929, + "elapsed_seconds": 6.44, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Edits:", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 31.823999999999998, + 121.5 + ], + [ + 61.2, + 121.5 + ], + [ + 61.2, + 133.65 + ], + [ + 31.823999999999998, + 133.65 + ] + ] + }, + { + "title": "Victims to add:", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 31.823999999999998, + 350.73 + ], + [ + 104.03999999999999, + 350.73 + ], + [ + 104.03999999999999, + 362.88 + ], + [ + 31.823999999999998, + 362.88 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 35 + ], + [ + "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", + 85 + ], + [ + "Line", + 42 + ], + [ + "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": "surya", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Text", + 34 + ], + [ + "Line", + 24 + ], + [ + "SectionHeader", + 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": 3, + "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/EFTA00084996" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085000/EFTA00085000.md b/marker2/ds9/EFTA00085000/EFTA00085000.md new file mode 100644 index 0000000000000000000000000000000000000000..e6b15dab62245ff92a635b0b19cd32c7ceb58a1b --- /dev/null +++ b/marker2/ds9/EFTA00085000/EFTA00085000.md @@ -0,0 +1,47 @@ +ay, ovem er 29, 2021 11:57 AM From Sent: o To: + +From: " To: ' Cc: " r. + +Subject: RE: URGENT--Update Maxwell Victim Notice + +Date: Mon, 29 Nov 2021 17:28:16 +0000 + +Attachments: 344.pdf; 502.pdf + +Inline-Images: image001.jpg + +I think these two orders have the key info. + +From: Sent: Monday, November 29, 2021 12:12 PM To: Cc: + +Subject: URGENT--Update Maxwell Victim Notice + +Importance: High + +See Ed Friedland's request below. Can you come up with a current update that explains whatever victims should know about attending the trial? (And makes clear that the dial-in info for previous proceedings is no longer applicable?) Jeffrey Liao can add it to our Maxwell victim page. + +https:/Avww.justice.gov/usao-sdny/united-states-v-ghislaine-maxwell + +From Sent: on ay, ovem er 29, 2021 12:01 PM To: + +Cc Subject: FW: Maxwell Link + +This info on your web page is outdated and is causing the public to try and access the Maxwell matter by phone. Can you pull down the access number info and update with the latest order which says in-person? + +District Court Executive United States District Court Southern District of New York + +Subject: Maxwell Link + +https://www.justice.goviusao-sdny/united-states-v-ghislaine-maxwell + +![](_page_0_Picture_18.jpeg) + +Office of the District Executive + +United States District Court Southern District of New York + +Email: + +Office: + +PLEASE CONSIDER THE ENVIRONMENT BEFORE PRINTING THIS E-MAIL \ No newline at end of file diff --git a/marker2/ds9/EFTA00085000/EFTA00085000.metadata.json b/marker2/ds9/EFTA00085000/EFTA00085000.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0c5abea366042f4ededc40cc3b708702cc2fefb4 --- /dev/null +++ b/marker2/ds9/EFTA00085000/EFTA00085000.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085000.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1.11, + "image_assets": [ + "_page_0_Picture_18.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 88 + ], + [ + "Line", + 42 + ], + [ + "Text", + 24 + ], + [ + "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/EFTA00085000" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085000/_page_0_Picture_18.jpeg b/marker2/ds9/EFTA00085000/_page_0_Picture_18.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..bbcdcaf8355aa9fc516c602ab32c0cf47c0834d5 --- /dev/null +++ b/marker2/ds9/EFTA00085000/_page_0_Picture_18.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:0ed085f91b33dbff362307750c4bef292d99526a88a37e3897ed9d072ec550cc +size 11544 diff --git a/marker2/ds9/EFTA00085001/EFTA00085001.md b/marker2/ds9/EFTA00085001/EFTA00085001.md new file mode 100644 index 0000000000000000000000000000000000000000..ea702cc3bd75aa27ee6163d43da25a50b577a533 --- /dev/null +++ b/marker2/ds9/EFTA00085001/EFTA00085001.md @@ -0,0 +1,1467 @@ +1 UNITED STATES DISTRICT COURT +2 SOUTHERN DISTRICT OF NEW YORK +3 -----x +4 UNITED STATES OF AMERICA, + +5 v. 20 CR 330 (AJN) + +6 GHISLAINE MAXWELL, + +7 Defendant. Jury Trial + +8 -----x +9 New York, N.Y. +10 November 29, 2021 +11 10:30 a.m. + +12 Before: + +13 HON. ALISON J. NATHAN, + +14 District Judge + +15 APPEARANCES + +16 DAMIAN WILLIAMS + +17 United States Attorney for the +18 Southern District of New York + +19 BY: [REDACTED] +20 [REDACTED] +21 [REDACTED] +22 [REDACTED] +23 Assistant United States Attorneys + +24 HADDON MORGAN AND FOREMAN +25 Attorneys for Defendant + +26 BY: JEFFREY S. PAGLIUCA +27 CHRISTIAN R. EVERDELL +28 LAURA A. MENNINGER + +29 -and- + +30 BOBBI C. STERNHEIM + +31 -and- + +22 RENATO STABILE + +23 Also Present: + +24 [REDACTED] +25 [REDACTED], +Paralegal, U.S. Attorney's Office +Ann Lundberg, +Paralegal, Haddon Morgan and Foreman + +4 + +5 + +6 + +7 + +8 + +9 + +10 11 : That's fine with the government, your Honor. + +12 13 MR. EVERDELL: That's fine with defense, as well, your Honor. + +14 15 16 17 THE COURT: I will note that the first available juror on the first floor on the list is the individual who is one of the two who are not here, the one who we haven't reached, and left a message. + +18 So let me tell you where we are. + +19 20 21 On the fifth floor, it's 117 who's not here. Then on the first floor, it's 169 and 273. So we would move 170 to the fifth floor. + +22 Okay, + +23 : Yes, your Honor. + +24 25 Would your Honor mind repeating those numbers, please, one more time? + +(In open court) + +(Voir dire resumed) + +THE COURT: I have an update. So the one juror on the fifth floor, who's not here, we've not been able to reach and left a message. The two jurors in 110, here, are not here. One we've not been able to reach and left a message and the other forgot and is not on the way. + +So I propose, counsel, that we take the next available juror in on the first floor. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +THE COURT: Of course. Not present are 117, 169, and 273. So, by my count, the next juror from the first floor that we would move to the fifth floor is 170. + +: Thank you, your Honor. + +THE COURT: Ms. Sternheim? + +MS. STERNHEIM: No objection. + +THE COURT: I'll direct my staff to have 170 move to the fifth floor. Once they're settled, we'll get the live feed going and I'll ask the questions. + +Counsel, do you want to have somebody go to the courtroom since we're close to that point? + +: Yes, please, your Honor. + +MS. MENNINGER: Yes, your Honor. + +MS. STERNHEIM: I believe they're already there, but I'm just checking. We're fine. + +THE COURT: Okay. + +: Your Honor, just to clarify, are we sending a representative to both of the overflow rooms or just one overflow room? + +THE COURT: We have 40 in 506, so we can start there. I'm going to ask both rooms if there are any "yes" responses. So it's up to you. + +: Thank you, your Honor. + +THE COURT: We now have 40 jurors on the fifth floor. So I think I'm ready to direct court staff to allow the live + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +feed to the juror rooms on the fifth floor and the first floor. + +We've confirmed that they've got the feed. + +: Apologies, your Honor. If the second pool of jurors is on the first floor -- I went down to the first floor to observe and court security told me I was not permitted to enter the courtroom. If that's the Court's preference -- + +THE COURT: Of course. We'll take care of it. + +: Thank you so much, your Honor. + +THE COURT: You have your government credentials, I suppose? + +: Yes, your Honor. + +THE COURT: You can head back down, . We'll ensure that you're permitted in. I apologize. Good to know we have security, but -- () + +Good morning, everyone. I'm told that the live feed now is working in the courtroom where our jurors are. Thank you so much. + +Ladies and gentlemen of the jury, welcome back to the Southern District of New York and thank you again for your time and service. I'm just going to pause for a moment to make sure that we get confirmation that we have counsel in both rooms and that the audio/video is working. + +We have confirmation, so we can proceed. + +As I said, welcome back to the Southern District of New York. Ladies and gentlemen, we are here for the third and + +4 Members of the jury panel, I'm going to ask two questions for everyone. If your answer to either question is yes, please just raise your hand. + +5 6 7 8 My first question is, since you were here for individual questioning by me, have you read, heard, seen, or researched anything about the case or discussed the case with anybody. + +9 10 11 My second question is, do you feel, for any reason, that you could not be a fair and impartial juror in this case. Now is the final opportunity to say so. + +12 13 14 If your answer to either question is yes, please raise your hand, otherwise please sit quietly until I give you further direction. Thank you so much. + +15 16 17 18 We have one juror who we'll bring up to speak to and I'll ask the audio/video feed to the jury rooms to please be turned off at this time. I'll give you further instruction shortly. Thank you so much for your patience. () + +19 20 Counsel, so we have just one hand, I understand, in both rooms, and that's a juror on the fifth floor, number 87. + +21 22 23 Just trying to get clarification on whether there were any hands in 110. Sounds like we did have some hands in 110, but just the one in 506. + +24 25 Can I ask counsel in the room if that's in 506, the one hand? + +final step of selecting a jury to serve in this case. + +4 (Juror present) + +5 Good morning, juror 87. + +6 JUROR: Good morning. + +7 THE COURT: You had a "yes" response? + +8 JUROR: Yes, that's right. + +9 10 11 : Your Honor, I apologize, but has not returned back to the courtroom. May we please wait for her to return? + +12 THE COURT: Sure. Could you test your volume? + +13 JUROR: Test. Is that better? + +14 THE COURT: That's good. Thank you. + +15 : Thank you, your Honor. She's on her way. + +16 THE COURT: Maybe she got detained. + +17 18 Okay. Juror number 87, you had a "yes" response to one of my questions. Go ahead. + +19 20 21 22 23 24 25 JUROR: Yes. So you had asked if I had discussed this case. Well, the answer is unfortunately yes. Just based on the timeline I provided the people that I work with, as well as the extensive media coverage, people I work with were pretty able to easily piece together what case this was. As such, they wanted to express their opinions and were pretty adamant and compassionate about the case. So I wanted to be fully + +MR. ROHRBACH: Yes, your Honor. + +MS. MENNINGER: Correct. + +THE COURT: So we'll bring in juror 87. + +4 5 6 JUROR: I tried to, to be honest, but some of the people that were speaking to me, I didn't feel comfortable doing that with. So in some cases, I did not. + +7 THE COURT: Counsel, without objection? + +8 : No objection, your Honor. + +9 MR. PAGLIUCA: No, your Honor. Thank you. + +10 11 12 THE COURT: Thank you for your candid response. I will excuse you. Thank you. The jury department will tell you how to check out. Thank you. + +13 (Juror not present) + +14 15 16 17 Counsel, I think then we can move -- there were some hands in 110, but not the next juror, which is 181. So I think we can move juror 181 to the fifth floor and you can exercise your peremptories with 181 as the final juror in the room. + +18 Everybody agree with that? + +19 : Yes, your Honor. + +20 MR. PAGLIUCA: Yes, your Honor. + +21 MS. STERNHEIM: Yes. + +22 23 THE COURT: So I will ask that juror 181 be brought to the fifth floor, please. + +24 25 Just going to get confirmation when 181 is on the fifth floor and then I'll bring you up for alternating + +transparent and disclose that I discussed the case. + +THE COURT: Did you cut them off when they were talking to you or discuss back? + +4 MR. PAGLIUCA: Yes, your Honor. I'm confirming juror 119 is now in the 28th spot? + +5 THE COURT: That's correct. + +6 MR. PAGLIUCA: Thank you. + +7 (At the sidebar) + +8 9 THE COURT: Counsel, if you want to look at the jury wheel while we're waiting. + +10 11 Counsel, I do have confirmation that we now have our 30 jurors on the fifth floor and we can do our peremptories. + +12 Defense first two is? + +13 MR. PAGLIUCA: 63 and 21, your Honor. + +14 15 : Government would strike juror number 93, your Honor. + +16 17 ? THE COURT: To be clear, we're just doing on the first + +18 MS. STERNHEIM: Yes. + +19 THE COURT: Okay. + +20 MR. PAGLIUCA: Juror number 54 and juror number 82. + +21 THE COURT: Okay. + +22 : Juror number 27, your Honor. + +23 THE COURT: Okay. + +24 MR. PAGLIUCA: Juror number 22. + +25 THE COURT: Okay. + +peremptories. + +Mr. Pagliuca. + +4 THE COURT: Okay. + +5 MR. PAGLIUCA: Juror number 30. + +6 : Juror number 108. + +7 MR. PAGLIUCA: Juror number 96. + +8 THE COURT: Okay. + +9 : Juror number 113. + +10 THE COURT: Okay. + +11 MR. PAGLIUCA: Juror number 62. + +12 THE COURT: Last one for the government. + +13 : Juror number 20. + +14 THE COURT: Okay. Last one for defense. + +15 MR. PAGLIUCA: Number 93, your Honor. + +16 : Your Honor, I believe I struck 93 first. + +17 18 MR. PAGLIUCA: I'm sorry. Juror number 13, your Honor. + +19 20 THE COURT: Okay. All right. Everybody good with the regular jury? Okay. + +21 22 Now I'll do alternates, alternating three each on the 29 through 40 beginning with the government. + +23 : Juror number 132, your Honor. + +24 THE COURT: Defense. + +25 MR. PAGLIUCA: Number 129. + +MR. PAGLIUCA: Juror number 8. + +THE COURT: Okay. + +: Juror number 14. + +4 THE COURT: Last one for the government. + +5 6 : Your Honor, the government is going to waive its third strike for alternates. + +7 8 9 THE COURT: So, defense has one more and the highest number not struck will also be struck in light of the government's waive. + +10 MR. PAGLIUCA: Number 147, your Honor. + +11 12 THE COURT: Okay. So 147 is struck. That means 181 is out, as well. Correct? + +13 : I believe that's right, your Honor. + +14 15 16 17 18 THE COURT: I'm going to start the feed again and read those numbers and then will take the selected jurors to the jury room and then I'll ask if the rest can be excused and if you say yes, I'll excuse them. So I need the feed. + +19 (In open court) + +20 21 22 23 24 THE COURT: Okay, we are ready to proceed. Thank you, members of the jury panel, for your patience. I'm going to read the numbers of the selected jurors. Those jurors will please then gather their belongings and my courtroom deputy, , will escort you in a moment to the jury room. + +25 The following numbers are the selected jurors: Number + +THE COURT: + +: 126. + +MR. PAGLIUCA: 162. + +4 5 is going to escort the selected jurors to the jury room. Everyone else please remain quietly in your seats until I give further instruction. + +6 7 So again, the selected jurors are 2, 7, 26, 29, 37, 48, 49, 50, 58, 70, 89, 119, 124, 125, 149, 151, 152, and 170. + +8 9 10 11 12 13 Thank you so much, ladies and gentlemen. I'll ask you to please remain quietly in your seats if your number was not called until I give you further instruction. If your number was called, I'll ask you to gather your belongings and follow instruction of the jury staff and my courtroom deputy, , who will take you to the jury room. + +14 We can stop the feed for the moment. + +15 16 Counsel, the feed is off to the jury rooms. We're bringing the selected jurors down to the jury room. + +17 18 Let me ask counsel if there is any reason why the remaining jurors on the panel cannot be excused at this time. + +19 : No, your Honor. + +20 MR. PAGLIUCA: No, your Honor. + +21 22 23 THE COURT: As soon as I have confirmation that the 18 jurors are in the jury room, I'll go back on the live feed and thank the jurors who are going to be excused. + +24 25 Let me ask, who will do the opening for the government? + +2, number 7, 26, 29, 37, 48, 49, 50, 58, 70, 89, 119, 124, 125, 149, 151, 152, and 170. I'll read those numbers again as + +: I will, your Honor. + +THE COURT: What is your time approximation? + +: I will estimate about 25 minutes, your 4 Honor. + +5 THE COURT: Who will do the opening for the defense? + +6 MS. STERNHEIM: I will, Judge. + +7 THE COURT: And how long? + +8 MS. STERNHEIM: I hope to keep it under an hour. + +9 10 11 12 13 14 15 16 THE COURT: Thank you. What I anticipate, as I said, as soon as we get the jurors in the jury room, I'll go back on and thank and excuse the remaining jurors. We'll get them settled in the jury room, the bathroom and the like, and then bring them out, swear them in, preliminary instructions. We'll see if we can do both or if it makes sense to break for lunch at the time after the government opens. We'll see where we are. + +17 Ms. Sternheim. + +18 19 MS. STERNHEIM: Judge, after the jury is sworn and taken to the jury room, may we have just a quick break? + +20 21 22 THE COURT: The jury is going to the jury room now, then I'll bring them in, swear them, and we'll go straight to openings. So would you like a break now? + +23 MS. STERNHEIM: I would. + +24 25 THE COURT: Let me see if I can excuse our other jurors and then we'll break. + +MS. STERNHEIM: Of course. + +THE COURT: Counsel, will there be any visuals during openings? + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +: No, your Honor. + +MS. STERNHEIM: Just me. + +THE COURT: So for the overflow rooms, we're sorting out cameras. So after I instruct the jury, we'll have the overflow room cameras on the podium box, but we wanted to see if we needed to show any visuals, as well, and it sounds like no. Great. + +Just, it takes some time, given distancing, to move 18 people between the floors. So as soon as I get confirmation that they are in the jury room, as I said, I'll excuse the other jurors. + +(Continued on next page) + + THE COURT: Counsel, we have all the jurors down. There's one juror indicating that they'd like to speak to me about their employer. If you're comfortable, I would have the court reporter and I go into the robing room and speak to them and then report back, if that's okay. + + : No objection, your Honor. + + MS. STERNHEIM: No objection. + + THE COURT: All right. We'll do that. + + (Pages 737 to 738 SEALED) + + (Continued on next page) + +4 THE COURT: You have a concern with your employer? + +5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 JUROR: Yes. So last we spoke, I knew that there would be some issue with me being out for six weeks. So I spoke with HR; and they mentioned that the company policy states that they would cover two weeks of jury duty paid time off. And then after the two weeks, they would use, like, my personal time off, like vacation. Currently now I don't have enough to cover for the four weeks remaining. And if I were out for four weeks, that's unpaid time. So that would be a financial hardship on my end, which just doesn't -- I wouldn't be able to, you know, pay bills and stuff like that. So, you know, that financial hardship I wouldn't be able to take on. And the company's policy just states that they cover the two weeks of paid time. And then after that's done, they would go into my PTO for the remaining time, and I don't have that amount of PTO currently. So then that accounts to four weeks of unpaid time. + +21 22 23 24 THE COURT: And tell me about what that means in terms of hardship. Given where we are at this stage and everybody's going to face some difficulty, tell me what it means to you in terms of hardship. + +25 JUROR: That means like my rent, loans, car payment, + +(In the robing room) + +(Counsel not present) + +(Juror present ) + +you know, just living expenses in New York, it means a lot. + +THE COURT: Tell me who your employer is. + +JUROR: + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +the local brand is That's the corporate umbrella. And then • + +THE COURT: So you get two weeks for jury duty, and then it's into your paid time off. And how much do you have of that remaining? + +JUROR: Yeah. So two weeks for paid time off, but I've used four days so far for coming in for jury duty. So that would be a balance of six by way of the company's policy. And then -- six days by way of the company's policy. And then after that, they would use my accrued paid time off, which I believe through the calculations that they mentioned through the end of the year, I would have about five days. And then once that's completed, they would -- I would be placed on unpaid leave, which that's about three and a half weeks or so. So three and a half weeks, my salary, that's essentially a month, which would put me behind with car payments, my school loans, my rent, etc., especially since it's the holiday season, so -- + +THE COURT: All right. I'm going to send you back to the jury room. I'll let you know. + +(Juror not present) + +4 + +5 + +6 + +7 + +8 + +9 10 11 And I'll tell you, I also have another juror who has indicated that their spouse surprised them with a trip. I'm getting the dates of the trip. That's where we are. + +12 How would you like to proceed, + +13 14 : Your Honor, I believe the juror who expressed financial hardship should be struck for cause. + +15 16 MR. PAGLIUCA: I think I'd like to know what juror number we're talking about here, your Honor. + +17 18 THE COURT: Well, I think that not matters to the analysis. + +19 20 21 MR. PAGLIUCA: I think it does, to the extent that we exercised peremptory challenges already and accepted this jury and excused the remaining jurors. + +22 23 24 25 THE COURT: Well, I haven't excused remaining jurors yet. So I think the question is whether anybody wants to try to do anything with the remaining jurors if this juror needs to be struck for cause. + +(In open court) + +THE COURT: Okay. We have a juror indicating financial hardship. The juror has further conferred with their employer, was told that they get two weeks of paid time for jury duty, four days of which have been used up. After that, they can go to their paid time off. They only have about five days remaining, and unpaid leave after that. And the juror has indicated that that is a substantial financial hardship. + +One option, counsel, we had an unstruck juror. There was a juror on whom nobody exercised a peremptory who has not been excused. We could sub in that person since nobody exercised a peremptory. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +MS. STERNHEIM: Judge, may I offer a suggestion that has been done by colleagues of yours in years past? Depending on who the employer is, if it's a large employer, judges have contacted the employer and inquired whether they would be willing to expand their policy. And it has been successful. + +THE COURT: I can try that. + +: The government would have no objection to that, your Honor. + +THE COURT: Okay. So I'll try that now. + +The other juror has indicated that the spouse surprised them with a trip December 24th through 28th. So we are to be sitting two of those days. I have not spoken to that juror yet, but can, and see if there's any flexibility there. So I'll call -- I'll try calling the employer of the juror who's indicated hardship. + +In the meantime, perhaps think about my suggestion, which is that there is an unstruck juror who, because the government waived a peremptory -- now, I recognize the defense, knowing that the government waived the peremptory, knew that that juror would drop off, if not. But nonetheless, it's an unstruck juror, so we could potentially pick that person up if + +we need to. + +I will see about calling the employer. And then I would also suggest I'll speak to the other juror with the trip with the court reporter and find out if there's any potential flexibility there. + +MS. STERNHEIM: Thank you. + +(Pages 742 to 744 SEALED) + +(Continued on next page) + +4 THE COURT: Juror 58. How are you? + +5 Please have a seat. + +6 7 So I've been told that you have a surprise trip planned. + +8 JUROR: Yes, my wife surprised me with a trip. + +9 10 11 12 THE COURT: And that was the kind of information I was looking for, for any reason you can't serve. Now that we're at this point in the process, I need to ask whether it's possible to move that trip? + +13 14 15 JUROR: It's possible to move? I believe we can. I think we've got insurance on there. I will speak to her again afterwards and see if we can move it. + +16 17 THE COURT: If you can, if she can move it, are you able to serve? + +18 19 JUROR: Yes. If she's able to move it, I will be able to serve. + +20 21 THE COURT: Okay. Can I let you use a phone and you can call her if I give you some privacy? + +22 JUROR: Sure. + +23 24 THE COURT: If you know her number. I don't know anybody's number. + +25 (Pause) + +(In the robing room) + +(Counsel not present) + +(Juror present) + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +JUROR: She said unfortunately it can't be moved, but she will try. But I'm not sure if you guys could wait that long anyway. + +When you asked that question earlier, I just figured, you know, you said, you know, if you saw something or if you know you were still going to be unfair, had I known, I would have said something then. But she said unfortunately, right now she don't think it could be changed. Because she's in school right now. So when we get home, she's going to see if it could be changed. + +THE COURT: Well, okay. + +I'm going to hope that it can be changed. + +JUROR: Okay. + +THE COURT: I'll talk to the lawyers about how they want to proceed, but I'm going to assume for now you're going to stay on the jury. + +JUROR: Okay. + +THE COURT: And hopefully it can be moved or we can accommodate in some way. + +JUROR: Okay. + +THE COURT: But at this stage we need you to stay, unless it's impossible. + +JUROR: Okay. + +THE COURT: Okay? All right. Thank you. + +JUROR: All right. So I'll be back again + +4 + +5 + +6 + +7 + +THE COURT: Well, you're going to go back to the jury room now and then I'll let you know -- + +JUROR: Okay. + +THE COURT: -- what's next. + +JUROR: Okay. + +THE COURT: Okay? + +JUROR: Thank you. + +8 THE COURT: Thank you. But for now, you're staying. + +9 JUROR: All right. Thank you. + +10 (Juror not present) + +11 (Continued on next page) + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +(In open court) + +THE COURT: Okay. Here's my update: We're still gathering the employer information on the juror. They needed to go get their phone and get the contact information. So we're working on that. So I haven't called yet. + +In the meantime, I did speak to the other juror whose spouse surprised them with a trip from the 24th to the 28th. They weren't sure if it was movable, tried calling the spouse, and basically just isn't sure at this point if it's movable. + +My view is we charge ahead with that juror, hope that it's movable. I suppose, worst-case scenario, we could arrange when we sit, but I'm not inclined to not sit that week. But I'm going to hope it's movable. That's my view. You tell me. + +MS. STERNHEIM: I'll speak first. + +That's fine. + +: That's fine with the government, your Honor. + +THE COURT: All right. + +So I'm going to let that juror know to keep pressing to see what options are moving, and that my intention is to keep them on the jury. + +With that, I'll step down in order to try to call the employer. Once I get that information, in the meantime, any thoughts on whether to -- if this doesn't work, to keep the unstruck juror? + +4 THE COURT: Okay. + +5 You still want to think about it, Ms. Sternheim? + +6 7 8 9 MS. STERNHEIM: Judge, our feeling is had we known this was going to happen during the choosing of the jurors, we would have exercised differently. I think the remedy is to give each side a peremptory back. + +10 11 : Your Honor, I don't believe that that would be -- + +12 13 THE COURT: How would that work? And exercise with respect to whom? + +14 MS. STERNHEIM: With regard to the alternates. + +15 THE COURT: You mean re -- + +16 MS. STERNHEIM: Yes. + +17 THE COURT: Restrike on alternates? + +18 19 MS. STERNHEIM: Yes. It's the easiest way of doing it, just one. + +20 21 22 : Your Honor, one alternative might be if we took the next three unstruck jurors and each side had a simultaneous strike. + +23 THE COURT: Or alternating strike. + +24 : Or alternating strike. + +25 MS. STERNHEIM: That is fine. + +: Yes, your Honor. The government's proposal would be to take the unstruck juror, make that juror the sixth alternate, and proceed from there. + +THE COURT: Okay. Why don't you work on that. But let me actually -- I think we might run into where we had some hands. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +: Your Honor, my list would be that that would be we have Juror 181, 189, and 195 as the next three. + +THE COURT: I believe we had hands raised for 189 and 195. So perhaps we could go -- + +MS. STERNHEIM: Judge, would you please repeat those two numbers, the jurors that you believe had issues? + +THE COURT: So this was what -- I didn't follow up on this because it was preliminary, but I got a note that the following jurors in 110 had raised their hand: 189, 195, 198, 235, 239, and 261. + +I will step down while you think about how you want to proceed if we do go down one the other option is to proceed with five alternates. Just not what I'd hoped to do out of the gate. But let me make this call and you think about if we lose somebody, how you want to proceed. I'll hear your requests + +MS. STERNHEIM: Thank you. + +(Recess) + +THE COURT: All right. Here's my update: + +I just spoke to the human resources person at the entity where the juror works. The policy is two weeks paid But I urged consideration of some -- whether there might be an ability to do more on that, and she said she would check. And + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +I said I could give her about ten minutes. So we will wait and see what the word is there. + +I would also like to just bring back the juror who had the trip plan with the court reporter and just let that juror know that I do intend to keep them on the jury and urge efforts to move the trip plans in light of where we are in this process. I'll let you know if anything further develops with that. + +Otherwise, anything? + +: Your Honor, I believe the parties have reached agreement on what to do if one of these jurors cannot proceed. + +THE COURT: Okay. + +: I believe the parties are in agreement that we would bring back the juror who would have been seated had the government not waived, if that makes sense. + +THE COURT: It does. + +: Juror No. 181, I believe it is. I think we have agreed that that juror should be seated as the sixth alternate. + +THE COURT: Okay. Ms. Sternheim? + +MS. STERNHEIM: That is the most efficient thing to do at this point. + +THE COURT: All right. Thank you. I appreciate that. + +I think that's a good backup solution. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +So let me speak to the juror with the trip planned, wait the ten minutes that I've given this human resources person to respond, and then we'll get underway. + +: Thank you, your Honor. + +THE COURT: Thank you. + +MS. STERNHEIM: Judge, will we still be given a break? + +THE COURT: Yes. + +MS. STERNHEIM: Thank you. + +THE COURT: Let me suggest that you take a break now also. + +MS. STERNHEIM: Okay. + +THE COURT: Because I think it will be at least 10 to 15 minutes before I return. + +MS. STERNHEIM: All right. Thank you. + +THE COURT: Thank you. + +(Pages 750 to 751 SEALED) + +(Continued on next page) + +4 THE COURT: Hi, Juror 58. + +5 JUROR: Hi. + +6 7 THE COURT: Just wanted to let you know we are going to keep you on the jury. + +8 JUROR: Okay. + +9 10 THE COURT: Want you to do everything you can to try to move that. + +11 JUROR: Okay. + +12 13 THE COURT: I'm happy to call the airline or the travel agent if that would be helpful or write a letter. + +14 JUROR: Okay. + +15 16 17 18 19 THE COURT: See what you can do. And you can let me know down the road, hopefully, that you're able to move it. But let me know that you're not and we'll take it one step at a time. We might not be able to sit for those days, if it's necessary. + +20 JUROR: Okay. + +21 22 THE COURT: But my hope is that you guys can move it and enjoy the trip when this is done. + +23 24 JUROR: Okay. Yeah, I'll definitely go home and call all the necessary parties. + +25 THE COURT: That would be great. Let me know if a + +(In robing room) + +(Counsel not present) + +(Juror present) + + You can return to the jury room. + + JUROR: Thank you so much. + + (Juror not present) + + (Continued on next page) + +letter or phone call from me would be helpful. + +JUROR: Okay. + +THE COURT: Thank you very much. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +THE COURT: The update is that I don't have the information yet. The employer of this juror, they are working on it, but because it's a deviation from an existing policy, they have to work it up the chain. They understand the urgency, and the person I spoke to anticipated an answer within an hour, but trying to do it as soon as possible. + +I think there are a couple of options. One, we can move to the juror that you agreed as our sixth alternate. The other, I think, on consent, you could agree to seven alternates and we could bring that juror and we proceed, and if it turns out this is a hardship because this company is not able to make the exception, then I will obviously, after conferring with you, dismiss that juror for cause, but we could get underway or we could, not knowing, dismiss the juror and move to the other juror or we could simply wait until we get more information. + +: Your Honor, the government would adopt your Honor's proposal that we seat the seventh alternate and proceed. + +MS. STERNHEIM: We would prefer to wait. + +THE COURT: And wait altogether, I presume, you mean, Ms. Sternheim? + +MS. STERNHEIM: Yes, your Honor. + +THE COURT: I think we'll give it a cutoff, a reasonable cutoff. Of course, I have two courtrooms full of jurors who are waiting and maybe what it makes sense to do is + +for me to Zoom in and let them know that the process is ongoing, we may still need them, and that I appreciate their patience. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Any concerns with that? + +: No concerns with that, your Honor, but given that we may be waiting an hour, would it make sense to move the lunch break a little earlier, break for lunch now and then have more time this afternoon? + +THE COURT: I will check with . I believe the jurors' lunch is anticipated at 1:00, so that may not be possible. + +Can I get the feed to 506 and 110, please. Let me know when we're live. + +Okay, I understand that the feed is working again with the jurors in 506 and 110. + +I want to thank you so much for your patience. The reason I haven't excused you yet is because the process is still ongoing. It remains possible that we would call on some of you to serve jury duty, and that's why I ask you to continue to wait patiently. I will provide additional information as soon as I have it. Thank you very much. + +I'll step down. Thank you. + +(Recess) + +(Continued on next page) + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +THE COURT: Good news. This employer has approved the request. And so what I suggest is I tell the juror with the court reporter just so they know, send them back to the jury room, bring the jury out, swear them in, and then send them back for lunch, and then I'll excuse the remaining jurors. + +Okay? + +: Yes, your Honor. Thank you. + +MS. STERNHEIM: Thank you. + +THE COURT: Thank you. + +(Pages 755 to 756 SEALED) + +(Continued on next page) + +4 THE COURT: Hi, Juror 124. + +5 JUROR: Hello. + +6 7 8 spoke to service. THE COURT: So good news. You have been approved -- I -- for six weeks of paid time for your jury + +9 JUROR: Fantastic. + +10 11 12 13 THE COURT: So I'm delighted that you'll be able to stay on the jury. Thank you very much. I just wanted to let you know I spoke to She was terrific and ran all the traps and got formal approval. So you're set. + +14 15 JUROR: I was going to ask the details, if you spoke . She may have gone through everything. + +16 17 18 19 20 THE COURT: She did. And the reason we were waiting is she had to run it through a number of people, including the CEO and the like, I understand. And they had to get formal approval, since it is a written policy, and you've been approved. + +21 JUROR: That's good news. That's good news. + +22 All right. Thank you. + +23 THE COURT: All right. + +24 We'll send you back and await further instruction. + +25 JUROR: Fantastic. + +(In the robing room) + +(Counsel not present) + +(Juror present) + + (Continued on next page) + +THE COURT: Thank you so much. + +JUROR: Thank you. + +(Juror not present) + +4 + +5 + +6 + +7 + +8 9 10 11 12 Ladies and gentlemen of the jury panel, I want to thank you so much for your patience and your time. We could not have done this process without you. On behalf of myself, on behalf of the parties and on behalf of the Southern District of New York, I thank you for your service. + +13 14 15 16 17 You will be excused by the jury department staff in just a few more minutes. I'll ask you to remain patiently seated until they give you further instruction. But this will be my opportunity to say thank you to you for your service. We couldn't do this process without you. Thank you. + +18 (Pause) + +19 THE COURT: Okay. Thank you for your patience. + +20 21 22 We will bring -- let me just tell you the plan. We will bring in the jury, we will swear in the jury, and then 1 will excuse them for lunch. + +23 Their lunch is here; correct? + +24 25 So, counsel, I propose a 45-minute break for lunch, if that works for everybody. + +(In open court) + +THE COURT: Okay. Message delivered. And the jurcr was pleased, and so we have our 18 jurors. + +What I'll do is while is gathering them to come in, I will thank the other jurors for their service, although they won't actually be let go until we swear the jury in. So I'm ready to talk to 506 and 110. + +: Yes. Thank you, your Honor. + +MS. STERNHEIM: That's fine. + +THE COURT: The staff has done some arranging of jurors in light of seating requirements and the like. We will provide a seating chart so that you know exactly -- both sides know exactly which juror is sitting in what seat. 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Maxwell, new production + +Date: The, 30 Nov 2021 05:03:32 +0000 + +Attachments: 2021.11.29\_Maxwell\_3500\_Cover\_Letter.pdf; 202I.11.29\_U.S.\_v\_Maxwell\_3500\_Index\_(Defense).pdf; 2021.11.29\_U.S.\_v\_Maxwell\_Non-Testifying\_Witness\_Materialindex\_(Defense).pdf; 2021.11.29\_Maxwell\_Discovery\_Letter.pdf; 2021.11.29\_US\_v.\_Maxwell\_Government\_Exhibit\_Index\_(Defense).pdf + +Counsel, + +We have a supplemental production of 3500, discovery, non-testifying witness material, and exhibits prepared to send you via USAfx. Attached please find the accompanying cover letters and indexes. + +Best, + +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/EFTA00085037/EFTA00085037.metadata.json b/marker2/ds9/EFTA00085037/EFTA00085037.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8598ba858dcb190312f09de4295591dcc7c31fb0 --- /dev/null +++ b/marker2/ds9/EFTA00085037/EFTA00085037.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085037.pdf", + "engine": { + "marker_major": "2", + "marker_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": 798, + "elapsed_seconds": 0.59, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00085037" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085038/EFTA00085038.md b/marker2/ds9/EFTA00085038/EFTA00085038.md new file mode 100644 index 0000000000000000000000000000000000000000..1c0a94222ece9b780666922418e73757d61eb1e0 --- /dev/null +++ b/marker2/ds9/EFTA00085038/EFTA00085038.md @@ -0,0 +1,47 @@ +![](_page_0_Picture_0.jpeg) + +United States Attorney Southern District of New York + +The Siltio.1. MoNo Building One Saint Andrew's Plaza New York New York 10007 + +November 29, 2021 + +## BY ELECTRONIC MAIL + +Christian Everdell, Esq. Mark Cohen, Esq. + +![](_page_0_Picture_7.jpeg) + +Laura Menninger, Esq. + +![](_page_0_Picture_9.jpeg) + +ism + +![](_page_0_Picture_11.jpeg) + +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 number SDNY\_GM\_02775781. + +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 02775781 | SDNY GM 02775781 | Letter from DriveSavers | | + +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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GhisThine Maxwell 20 Cr. 330 (MN) Government Exhibit Index 11/29/2021 + +# 0 Series Message Pads + +| CS | Description | Status | Bates Range/Identifier | Produced to Defense | +|---------|----------------------|---------------------------|------------------------|---------------------| +| GX-I | Physical Message Pad | Marked for identification | | 2021.10.11 | +| GX-1-A | Message Pad Cover | Public | SDNY_ GM_ 00165559 | 2021.10.11 | +| GX-I-B | Message Pad Excerpt | Sealed | SDNY GM 00165560 | 2021.10.11 | +| GX-I-C | Message Pad Excerpt | Sealed | SDNY GM 00165562 | 2021.10.11 | +| GX-I-J | Message Pad Excerpt | Sealed | SDNY_GM_00165584 | 2021.10.11 | +| GX-I-K | Message Pad Excerpt | Scaled | SDNY _ GM _ 00165587 | 2021.10.11 | +| GX-I-M | Message Pad Excerpt | Scaled | SDNY GM 00165610 | 2021.10.11 | +| GX-I-O | Message Pad Excerpt | Scaled | SDNY GM 00165622 | 2021.10.11 | +| GX-I-P | Message Pad Excerpt | Scaled | SDNY GM 00165625 | 2021.10.11 | +| GX-2 | Physical Message Pad | 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2021.10.11 | +| GX-3-P | Message Pad Excerpt | Scaled | SDNY GM 00165714 | 2021.10.11 | +| GX-3-Q | Message Pad Excerpt | Scaled | SDNY_GM_00165719 | 2021.10.11 | +| GX-3-R | Message Pad Excerpt | Scaled | SDNY GM 00165729 | 2021.10.11 | +| GX-3-1 | Message Pad Excerpt | Scaled | SDNY GM 00165742 | 2021.10.11 | +| GX-3-T | Message Pad Excerpt | Scaled | SDNY GM 00165743 | 2021.10.11 | +| GX-3-U | Message Pad Excerpt | Scaled | SDNY_GM_00165744 | 2021.10.11 | +| GX-3-V | Message Pad Excerpt | Scaled | SDNY GM 00165745 | 2021.10.11 | +| GX-3-W | Message Pad Excerpt | Scaled | SDNY GM 00165747 | 2021.10.11 | +| GX-3-X | Message Pad Excerpt | Scaled | SDNY GM 00165731 | 2021.10.11 | +| GX-3-Y | Message Pad Excerpt | Scaled | SDNY_GM_00165736 | 2021.10.11 | +| GX-3-Z | Message Pad Excerpt | Scaled | SDNY_GM_00165737 | 2021.10.11 | +| GX-3-AA | Message Pad Excerpt | Scaled | SDNY GM 00165738 | 2021.10.11 | +| GX-3-BB | Message Pad Excerpt | Scaled | SDNY GM 00165739 | 2021.10.11 | +| GX-3-CC | Message Pad Excerpt | Scaled | SDNY_GM_00165740 | 2021.10.11 | +| GX-3-DD | Message Pad Excerpt | Scaled | SDNY_GM_00165741 | 2021.10.11 | +| GX-3-EE | Message Pad Excerpt | Scaled | SDNY GM 00165742 | 2021.10.11 | +| GX-3-FF | Message Pad Excerpt | Scaled | SDNY GM 00165743 | 2021.10.11 | +| GX-3-GG | Message Pad Excerpt | Sealed | SDNY_GM_00165744 | 2021.10.11 | +| GX-3-HI-1 | Message Pad Excerpt | Scaled | SDNY_GM_00165745 | 2021.10.11 | +| GX-3-II | Message Pad Excerpt | Scaled | SDNY GM 00165747 | 2021.10.11 | +| GX-3-JJ | Message Pad Excerpt | Scaled | SDNY GM 00165749 | 2021.10.11 | +| GX-3-KK | Message Pad Excerpt | Scaled | SDNY GM 00165750 | 2021.10.11 | +| GX-4 | Physical Message Pad | Marked for identification | | 2021.10.11 | +| GX-4-A | Message Pad Cover | Public | SDNY GM 00165751 | 2021.10.11 | +| GX-4-B | Message Pad Excerpt | Scaled | SDNY GM 00165752 | 2021.10.11 | +| GX-4-C | Message Pad Excerpt | Scaled | SDNY GM 00165754 | 2021.10.11 | +| GX-4-D | Message Pad Excerpt | Scaled | SDNY_GM_00165759 | 2021.10.11 | +| GX-4-E | Message Pad Excerpt | Scaled | SDNY GM 00165761 | 2021.10.11 | +| GX-4-F | Message Pad Excerpt | Scaled | SDNY GM 00165776 | 2021.10.11 | +| GX-4-G | Message Pad Excerpt | Scaled | SDNY GM 00165790 | 2021.10.11 | +| GX-4-H | Message Pad Excerpt | Scaled | SDNY_GM_00165798 | 2021.10.11 | +| GX-4-I | Message Pad Excerpt | Scaled | SDNY GM 00165811 | 2021.10.11 | +| GX-4-J | Message Pad Excerpt | Scaled | SDNY GM 00165815 | 2021.10.11 | +| GX-4-K | Message Pad Excerpt | Scaled | SDNY GM 00165817 | 2021.10.11 | + +#### Birth Certificates and Licenses + +### 10 Series + +| GX | | Description | Status | Bates Number/Identifier | Produced to Defense | +|----|--------------------------------|-------------|--------|-------------------------|---------------------| +| | Certified Birth Certificate of | | Scaled | SDNY GM 02765030 | 2021.10.11 | +| | Certified Birth Certificate of | | Scaled | SDNY GM 02760681 | 2021.10.11 | + +| _GX-13 | Certified Binh Certificate of | Scaled | SDNY_GM_02753693 | 2021.10.11 | +|---------|-----------------------------------------|--------|-----------------------------------|------------| +| GX-13-R | Redacted Certified Birth Certificate of | Public | SDNY GM 02753693 | 2021.11.28 | +| GX-14 | Certified Birth Certificate of | Scaled | SDNY GM 02765767 | 2021.10.28 | +| GX-15 | Certified Binh Certificate of | Scaled | SDNY_GM 02760679-SDNY GM_02760680 | 2021.10.11 | +| GX-16 | Certified Binh Certificate of | Scaled | iDNY_GM_0276i968 | 2021.10.28 | +| GX-17 | License ofd | Scaled | SDNY_GM_02775780 | 2021.11.28 | + +#### Other Physical Exhibits 1 + +#### 50 Series + +| GX | Description | Status | Bates Numherfldentifier | Produced to Defense | +|---------|---------------------------------------------------|---------------------------|-------------------------------------------|---------------------| +| GX-51 | Florida Massage Table | Public | | 2021.10.11 | +| GX-51-A | Photograph of Underside of Florida Massage Table | Public | SDNY GM 02763005 | 2021.10.11 | +| GX-51-B | Photograph of Sticker on Florida Massage Table | Public | SDNY GM 02763006 | 2021.10.11 | +| GX-51-C | Photograph of Sticker on Florida Massage Table | Public | SDNY GM 02763007 | 2021 10 II | +| GX-52 | Black Contact Book | Marked for identification | | 2021.10.11 | +| GX-52-A | Scanned Page from Black Contact Book | Scaled | SDNY _ GM _ 02763008-SDNY _ GM _ 02763008 | 2021.10.11 | +| GX-52-D | Scanned Page from Black Contact Book | Scaled | SDNY GM 02763011-SONY GM 02763011 | 2021.10.11 | +| GX-52-E | Scanned Page from Black Contact Book | Scaled | SDNY GM 027630B-SONY GM 02763014 | 2021.10.11 | +| GX-52-F | Scanned Page from Black Contact Book | Sealed | SDNY GM 02763015-SDNY GM 02763015 | 2021.10.11 | +| GX-52-G | Scanned Page from Black Contact Book | Sealed | SDNY_GM 02763016-SDNY_GM_02763016 | 2021.10.11 | +| GX-52-H | Scanned Page from Black Contact Book | Sealed | SDNY _ GM _ 02765768 | 2021.10.11 | +| GX-53 | Box of five costumes | Public | | 2021.10.11 | +| GX-54 | Hard Drive NYC024350 | Marked for identification | | 2021.10.11 | +| GX-54-A | Photograph of GX-54 | Public | SDNY GM 02772261 | 2021.11.16 | +| GX-55 | Hard Drive NYC024349 | Marked for identification | | 2021.10.11 | +| GX-55-A | Photograph of GX-55 | Public | SDNY _ GM _ 02772260 | 2021.11.16 | +| GX-55-B | Photograph of bag contained within GX-55 | Public | SDNY GM 02772258 | 2021.11.16 | +| GX-55-C | Photograph of bag contained within GX-55 | Public | SDNY GM 02772259 | 2021.11.16 | +| GX-56 | Hard Drive NYC024383 | Marked for identification | | 2021.10.11 | +| GX-57 | New York Massage Table | Public | | 2021.10.11 | +| GX-57-A | Photograph of Underside of New York Massage Table | Public | SDNY_GM 02763019-SDNY_GM_02763019 | 2021.10.11 | +| GX-57-B | Photograph of Sticker on New York Massage Table | Public | SDNY GM 02763018-SONY GM 02763018 | 2021.10.11 | +| GX-58 | Pair of Boots | Public | | 2021.10.11 | +| GX-59 | Photograph of disk | Public | SDNY GM 02775779 | 2021.11.28 | + +#### Photographs of People + +## 100 Series + +| GX GX-101 | Description Photograph of | Status Public | Bates Numherfldentifier SDNY_ GM _ 001 02766005 | Produced to Defense 2021.10.11 | +|-----------|--------------------------------------|---------------|-------------------------------------------------|--------------------------------| +| GX-102 | Photograph of | Public | SDNY GM | | +| | | | 50527 | 2021.10.11 | +| GX-103 | Photograph of | Public | | | +| | | Scaled | SDNY GM 02760624 | 2021.10.11 | +| GX-104 | Photograph of | | SDNY GM 02753398 | 2021.10.11 | +| GX-105 | Photograph of Females. Including | Sealed | SDNY GM 02753398 | 2021.10.11 | +| GX-106 | Photograph of | Sealed | SDNY _ GM _ 00165992 | 2021.10.11 | +| GX-107 | Photograph of | Sealed | SDNY _ GM00165995 | 2021.10.11 | +| GX-108 | Photograph of | Sealed | SDNY GM 00165999 | 2021.11.11 | +| GX-109 | Photograph of | Sealed | SDNY GM 00166002 | 2021.10.11 | +| GX-110 | Photograph of | | | | +| | | Public | SDNY GM 02753621 | 2021.10.11 | +| GX-111 | Photograph of Clhislaine NI:iv...ell | Public | SONY GM 02753632 | 2021.10.11 | + +| GX-I 12 | Photo ,ra of Jeff E ein | Public | SDNY GM 02753623 | 2021.10.11 | +|---------|---------------------------------|--------|---------------------------|------------| +| GX-113 | Photograph of | Public | Made Available for Review | 2021.10.11 | +| GX-I 14 | Photograph of | Public | SDNY GM 02753629 | 2021.10.11 | +| GX-I 15 | Photograph of Ghislaine Maxwell | Public | SDNY GM 02753644-2753692 | 2021.11.11 | + +#### Photographs and 200 Series Videos from PBPD Search + +| GX | Description | Status | Bates Number/Identifier | Produced to Defense | +|---------|---------------------------------------------------------------------|--------|-------------------------|---------------------| +| GX-201 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY GM 00174459 | 2021.10.11 | +| GX-202 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY_GM_00174460 | 2021.10.11 | +| GX-203 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY GM 00174461 | 2021.10.11 | +| GX-204 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY GM 00174470 | 2021.10.11 | +| GX-205 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY GM 00174471 | 2021.10.11 | +| GX-206 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY_GM_00174472 | 2021.10.11 | +| GX-207 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY GM 00174473 | 2021.10.11 | +| GX-208 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY GM 00174381 | 2021.10.11 | +| GX-209 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY GM 00174474 | 2021.10.11 | +| GX-210 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY_GM_00174476 | 2021.10.11 | +| GX-2I I | Photograph of Exterior at 358 El Brillo Way | Public | SDNY GM 00174477 | 2021.10.11 | +| GX-212 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY GM 00174478 | 2021.10.11 | +| GX-213 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY GM 00174479 | 2021.10.11 | +| GX-214 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY_GM_00174480 | 2021.10.11 | +| GX-2I 5 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY GM 00174481 | 2021.10.11 | +| GX-216 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY GM 00174482 | 2021.10.11 | +| GX-217 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY GM 00174483 | 2021.10.11 | +| GX-218 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY_GM_00174484 | 2021.10.11 | +| GX-219 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY GM 00174490 | 2021.10.11 | +| GX-220 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY GM 00174491 | 2021.10.11 | +| GX-221 | Photograph of Exterior at 358 El Brillo Way | Public | SDNY GM 00174492 | 2021.10.11 | +| GX-222 | Photograph of Exterior at 358 E/ Brillo Way | Public | SDNY_GM_00174493 | 2021.10.11 | +| GX-223 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Scaled | SDNY_GM_00174366 | 2021.10.11 | +| GX-224 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Sealed | SDNY GM 00174367 | 2021.10.11 | +| GX-225 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Scaled | SDNY GM 00174368 | 2021.10.11 | +| GX-226 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY_GM_00174518 | 2021.10.11 | +| GX-227 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY_GM_00174521 | 2021.10.11 | +| GX-228 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY GM 00174524 | 2021.10.11 | +| GX-229 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY GM 00174525 | 2021.10.11 | +| GX-230 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY GM 00174526 | 2021.10.11 | +| GX-231 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY_GM_00174527 | 2021.10.11 | +| GX-232 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY GM 00174528 | 2021.10.11 | +| GX-233 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY GM 00174530 | 2021.10.11 | +| GX-234 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Scaled | SDNY GM 00174532 | 2021.10.11 | +| GX-235 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY_GM_00174533 | 2021.10.11 | +| GX-236 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY GM 00174535 | 2021.10.11 | +| GX-237 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY GM 00174536 | 2021.10.11 | +| GX-238 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY GM 00174545 | 2021.10.11 | +| GX-239 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY_GM_00174687 | 2021.10.11 | +| GX-240 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY GM 00174688 | 2021.10.11 | +| OX-241 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Scaled | SDNY GM 00174698 | 2021.10A I | + +| GX-242 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Scaled | SDNY GM 00174442 | 2021.10.11 | +|--------|-----------------------------------------------------------------------|--------|---------------------------|------------| +| GX-243 | Photograph of First Floor Office & Livin • Room at 358 El Brillo Wa • | Scaled | SDNY GM 00174444 | 2021.10.11 | +| GX-244 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Scaled | SDNY GM 00174445 | 2021.10.11 | +| GX-245 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Scaled | SDNY_GM_00174699 | 2021.10.11 | +| GX-246 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Scaled | SDNY GM 00174446 | 2021.10.11 | +| GX-247 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Scaled | SDNY GM 00174447 | 2021.10.11 | +| GX-248 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Scaled | SDNY_GM_00174700 | 2021.10.11 | +| GX-249 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Scaled | SDNY_GM_00174704 | 2021.10.11 | +| GX-250 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Scaled | SDNY GM 00174448 | 2021.10.11 | +| GX-252 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Scaled | SDNY GM 00174450 | 2021.10.11 | +| GX-253 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Scaled | SDNY GM 00174451 | 2021.10.11 | +| GX-254 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Scaled | SDNY_GM_00174452 | 2021.10.11 | +| GX-255 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Scaled | SDNY_GM_00174707 | 2021.10.11 | +| GX-256 | Photograph of First Flow Office & Living Room at 358 El Brillo Way | Public | SDNY GM 00174726 | 2021.10.11 | +| GX-257 | Photograph of First Flow Office & Living Room at 358 El Brillo Way | Public | SDNY GM 00174727 | 2021.10.11 | +| GX-258 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Scaled | SDNY_GM_00174369 | 2021.10.11 | +| GX-260 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY_GM_00174425 | 2021.10.11 | +| GX-261 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY GM 00174426 | 2021.10.11 | +| GX-262 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY GM 00174427 | 2021.10.11 | +| GX-263 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | Public | SDNY_GM_00174428 | 2021.10.11 | +| GX-264 | Photograph of Kitchen at 358 El Brillo Way | Public | SDNY_GM_00174504 | 2021.10.11 | +| GX-265 | Photograph of Kitchen at 358 El Brillo Way | Public | SDNY GM 00174505 | 2021.10.11 | +| GX-266 | Photograph of Kitchen at 358 El Brillo Way | Public | SDNY GM 00174506 | 2021.10.11 | +| GX-267 | Photograph of Kitchen at 358 El Brillo Way | Public | SDNY GM 00174685 | 2021.10.11 | +| GX-268 | Photograph of Kitchen at 358 El Brillo Way | Public | SDNY_GM_00174686 | 2021.10.11 | +| GX-269 | Photograph of Master Bedroom at 358 El Brillo Way | Public | SDNY GM 00174594 | 2021.10.11 | +| GX-270 | Photograph of Master Bedroom at 358 El Grillo Way | Scaled | SDNY GM 00174432 | 2021.10.11 | +| GX-271 | Photograph of Master Bedroom at 358 El Brillo Way | Public | SDNY GM 00174596 | 2021.10.11 | +| GX-272 | Photograph of Master Bedroom at 358 El Brillo Way | Public | SDNY_GM_00174599 | 2021.10.11 | +| GX-273 | Photograph of Master Bedroom at 358 El Brillo Way | Public | SDNY GM 00174600 | 2021.10.11 | +| GX-276 | Photograph of Master Bedroom at 358 El Brillo Way | Public | SDNY GM 00174601 | 2021.10.11 | +| GX-277 | Photograph of Master Bedroom at 358 El Brillo Way | Public | SDNY GM 00174602 | 2021.10.11 | +| GX-278 | Photograph of Master Bedroom at 358 El Brillo Way | Sealed | SDNY_GM_00174603 | 2021.10.11 | +| GX-279 | Photograph of Master Bedroom at 358 El Brillo Way | Public | SDNY GM 00174604 | 2021.10.11 | +| GX-280 | Photograph of Master Bedroom at 358 El Brillo Way | Public | SDNY GM 00174605 | 2021.10.11 | +| GX-281 | Photograph of Master Bedroom at 358 El Brillo Way | Scaled | SDNY GM 00174433 | 2021.10.11 | +| GX-282 | Photograph of Master Bedroom at 358 El Brillo Way | Scaled | SDNY_GM_00174434 | 2021.10.11 | +| GX-283 | Photograph of Master Bedroom at 358 El Brillo Way | Public | SDNY_GM_00174435 | 2021.10.11 | +| GX-284 | Photograph of Master Bedroom at 358 El Brillo Way | Public | SDNY GM 00174436 | 2021.10.11 | +| GX-285 | Photograph of Master Bedroom at 358 El Brillo Way | Scaled | SDNY GM 00174440 | 2021.10.11 | +| GX-286 | Photograph of Master Bedroom at 358 El Brill() Way | Scaled | SDNY_GM_00174453 | 2021.10.11 | +| GX-287 | Photograph of Master Bedroom at 358 El Brillo Way | Scaled | SDNY_GM_00174454 | 2021.10.11 | +| GX-289 | Photograph of Second Floor at 358 El Brillo Way | Public | SDNY GM 00174557 | 2021.10.11 | +| GX-290 | Photograph of Second Floor at 358 El Brillo Way | Public | SDNY GM 00174558 | 2021.10.11 | +| GX-291 | Photograph of Second Floor at 358 El Brillo Way | Public | SDNY_GM_00174559 | 2021.10.11 | +| GX-292 | Photograph of Second Floor at 358 El Brillo Way | Public | SDNY_GM_00174560 | 2021.10.11 | +| GX-293 | Photograph of Second Floor at 358 El Brillo Way | Public | SDNY GM 00174563 | 2021.10.11 | +| GX-294 | Photograph of Second Floor at 358 El Brillo Way | Public | SDNY GM 00174419 | 2021.10.11 | +| GX-295 | Property Receipts | Public | SDNY GM 02753638-02753643 | 2021.10.11 | +| GX-296 | Video of Walkthrough al 358 El Bruno Way | Sealed | SDNY_GM_00332873 | 2021.10.11 | + +| GX-296-R | Video of Walkthrough at 358 El Brillo Way (warrant reading redacted) | Scaled | | 2021.11.29 | +|-----------|--------------------------------------------------------------------------------|--------|------------------|------------| +| GX-296-RR | Video of Walkihrough at 358 El Brillo Way (warrant reading and photo redacted) | Sealed | | 2021.11.29 | +| GX-297 | 358 El Brillo Way Floorplan | Public | SDNY_GM_00328519 | 2021.11.16 | +| GX-298 | 358 El Brillo Way Floorplan | Public | SDNY GM 00328520 | 2021.11.16 | +| GX-299 | 358 El Brillo Way Floorplan | Public | SDNY GM 00328521 | 2021.11.16 | + +#### ESI Photographs + +## 300 Series + +| CA | Description | Status | Bates Number/Identifier | Produced to Defense | +|----------|-----------------------------------------------------|------------|------------------------------|---------------------| +| GX-301 | Photograph of Jet | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-302 | Photograph of Jet | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-303 | Photograph of Jet Interior | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-304 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | Public | SDNY _ GM _ 02753644-2753692 | 2021.10.11 | +| GX-305 | Photograph of Ghislaine Maxwell | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-306 | I Photograph of Ghislaine Maxwell | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-307 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-308 | Photograph of Island | Public | SDNY_ GM_ 02753644-2753692 | 2021.10.11 | +| GX-309 | Photograph of | Scaled | Made Available for Review | 2021.10.11 | +| GX-310 | Photograph of Jeffrey Epstein and | Public | SDNY GM 02753644-2753692 | 2021.11.11 | +| GX-3 1 1 | Photograph of Plane (N404CE) | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-312 | Photograph of Plane (N908.1E) | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-313 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | Scaled | Made Available for Review | 2021.10.11 | +| GX-314 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-315 | Photograph of Jeffrey Epstein and Plane | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-316 | Photograph of Ghislaine Maxwell, | and Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-317 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-318 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-319 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-320 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | Public | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-321 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | Public | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-322 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-323 | Photograph of Ranch | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-324 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | Public | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-325 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | Public | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-326 | Photo ra h of Island | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-327 | Photograph of | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-328 | Photograph of Zoo Ranch Entry | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-329 | Photograph offeffrey Epstein and | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-330 | Photo:ra ho | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-331 | Photograph of Ghislaine Maxwell.. | and Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-332 | Photograph of | Scaled | Made Available for Review | 2021.10.11 | +| GX-333 | Photograph of Ghislaine Maxwell and leffre E stein | Public | SDNY _ GM _ 02753644-2753692 | 2021.10.11 | +| GX-336 | Photograph of Planes | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-337 | Photograph of Ghislaine Maxwell on Plane | Public | SDNY _ GM _ 02753644-2753692 | 2021.10.11 | +| GX-338 | Photograph of Ghislaine Maxwell | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-339 | Photograph of Ghislaine Maxwell | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-340 | Photograph of Ghislaine Maxwell | Public | SDNY GM 02753644-2753692 | 2021.10.11 | + +| GX-34I | Photograph of Ghislaine Maxwell and Jeffrey Epstein | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +|--------|-----------------------------------------------------|--------|--------------------------|------------| +| GX-342 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | Public | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-343 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-344 | Photograph of Helicopter | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-345 | Photograph of Helicopter | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-346 | Photograph of Island | Public | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-347 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | Public | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-348 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | Public | SDNY GM 02753644-2753692 | 2021.10.11 | + +# ES! Documents and Metadata I + +### 400 Series + +| GX | Description | Status | Bates Number/Identifier | Produced to Defense | +|----------|----------------------------------------------------------------------------|--------|----------------------------------------|---------------------| +| GX-405 | NYC024349 System Information | Public | SDNY CM 02762473 | 2021.11.16 | +| GX-406 | Email Chain between Jeffrey Epstein and | Sealed | SDNY GM 00631742-SDNY GM 00631742 | 2021.10.11 | +| GX-406-R | Redacted Email Chain between Jeffrey Epstein and M | Public | SDNY GM 00631742-SDNY GM 00631742 | 2021.11.28 | +| GX-407 | Email Chain between Jeffrey Epstein and Ghislaine Maxwell | Public | SDNY _ GM _ 00623470-SDNY _ GM00623470 | 2021.10.11 | +| GX-408 | Email from Ghislaine Maxwell to Jeffrey Epstein | Public | SDNY GM 00579091-SDNY GM 00579091 | 2021.10.11 | +| GX-412 | Email Chain | Public | SDNY GM 02741883-SDNY GM 02741884 | 2021.10.11 | +| GX-415 | Email Chain | Public | SDNY GM 02741441-SDNY GM 02741442 | 2021.10.11 | +| GX-4I7 | List and Contact Info of Masseuses | Sealed | SDNY _ GM _ 02735985-SDNY _ GM02735991 | 2021.10.11 | +| GX-417-B | List and Contact Info of Masseuses - Metadata | Public | | 2021.10.11 | +| GX-418 | List and Contact Info of Palm Beach House Workers & Maintenance | Sealed | SDNY GM 02736160-SONY GM 02736166 | 2021.10.11 | +| GX-418-B | List and Contact Info of Palm Beach House Workers & Maintenance - Metadata | Public | | 2021.10.11 | +| GX-418-R | Redacted List and Contact Info of Palm Beach House Workers & Maintenance | Public | SDNY_GM_02736160-SDNY_GM_02736166 | 2021.11.28 | +| GX-419 | NYC024350 System Information | Public | SDNY GM 02762473 | 2021.11.16 | +| GX-420 | List of PB New Shampoo and Massage Products | Public | SDNY GM 02736212-SDNY GM 02736212 | 2021.10.11 | +| GX-420-B | List of PB New Shampoo and Massage Products - Metadata | Public | | 2021.10.11 | +| GX-42I | Massage Therapist Help Wanted Ad | Public | SDNY_GM_02736260-SDNY_GM_02736260 | 2021.10.11 | +| GX-421-B | Massage Therapist Help Wanted Ad - Metadata | Public | | 2021.10.11 | +| GX-422 | Ghislaine Maxwell and Jeffrey Epstein Relationship Essay | Public | SDNY GM 02736272-SDNY GM 02736272 | 2021.10.11 | +| GX-422-B | Ghislaine Maxwell and Jeffrey Epstein Relationship Essay - Metadata | Public | | 2021.10.11 | +| GX-423 | Jeffrey Epstein Amazon Order Confirmation | Public | SDNY_GM_00567862 | 2021.10.11 | +| GX-424 | Email Chain | Public | SDNY_GM_02741334-SDNY_GM_02741336 | 2021.11.16 | + +| 1 | | Financial | | | +|--------|-----------------------------------------------------|-----------|-------------------------------------------|---------------------| +| GX | Description | Status | Bates Number/Identifier | Produced to Defense | +| GX-501 | June 2007 JPMC Statement for Air Ghislaine | Public | SDNY GM 00277986-SDNY GM 00277989 | 2021. I 1.21i | +| GX-502 | June 2007 JPMC Statement for Ghislaine Maxwell | Public | SDNY _ GM _ 00321356-SDNY _ GM _ 00321363 | 2021.11.28 | +| GX-503 | J.P. Morgan Entity Ac aunt Application | Public | SDNY GM 00271135-SONY GM 00271137 | 2021.11.28 | +| GX-504 | September 2002 JPMC Account Activity | Public | SDNY GM 00274703-SDNY GM 00274711 | 2021.11.28 | +| GX-505 | JPMC October 1999 Asset Account Portfolio Records | Public | SDNY GM 00306061-SONY GM 00306067 | 2021.11.28 | +| GX-506 | Air Ghislaine Account Documents | Public | SDNY_GM 00271608-SDNY GM_00271610 | | +| GX-507 | Ghislaine Maxwell J.P. Morgan Account and Signature | Public | GM 000682- | 54 2021.11.28 | +| GX-508 | J.P. Morgan Records | | | | +| | | | SDNY GM 00271584-SONY- | GM- 00271593 | +| GX-509 | J.P. Morgan Record,. | Public | SDNY GM 02775035-SDNY GM 02775037 | 2021.11.28 | + +## 500 Series + +# Exhibits + +# 550 Series + +# Phone Records + +| GX | Description | Status | Bates Number/Identifier | Produced to Defense | +|--------|--------------------------------------------------------------|--------|-----------------------------------|---------------------| +| GX-551 | May 2004 AT&T Wireless Monthly Statement for Jeffrey Epstein | Sealed | SDNY GM 00365036-SDNY GM 00365049 | 2021.10.11 | + +# 600 Series + +# Miscellaneous Documents + +| GX | Description | Status | Bates Number/Identifier | Produced to Defense | +|--------|--------------------------------|--------|-------------------------------------|---------------------| +| GX-601 | Journal Front Cover | Public | SDNY_GM_00165987 | 2021.10.11 | +| GX-602 | Journal Entry | Public | SDNY GM 00165986 | 2021.10.11 | +| GX-603 | January 7. 1996 Journal Entry | Public | SDNY GM 00165984 | 2021.10.11 | +| GX-604 | January 25, 1996 Journal Entry | Public | SDNY_GM_00165982 | 2021.10.11 | +| GX-605 | Journal Back Cover | Public | SDNY_GM_00165988 | 2021.10.11 | +| GX-606 | Household Manual | Public | SDNY GM 00516864-SDNY GM 00516922 | 2021.10.11 | +| GX-607 | Work Hours Document | Public | SDNY GM 00515785 - SDNY GM 00515787 | 2021.10.11 | + +# 660 Series + +# Flight Records + +| GX | Description | Status | Bates Number/Identifier | Produced to Defense | +|--------|-----------------------------------------------------------|---------|-------------------------------------|---------------------| +| 6X-661 | Flight Logbook from January 23, 2006 to September 19.2013 | Sea led | SDNY _ GM 00005650-SDNY GM 00005676 | 2021.10.11 | +| | nicht Loubook from April 25 1991 to January 19. 2006 | Scaled | SDNY GM 00005532-SDNY GM 00005649 | 2021.10.11 | + +# 700 Series + +# Photographs of Places + +| GX | Description | Status | Bates Number/Identifier | Produced to Defense | +|--------|--------------------------------------|--------|-------------------------|---------------------| +| GX-701 | Ghislainc Maxwell New York Townhouse | Public | SDNY GM 02760645 | 2021.10.11 | +| GX-702 | Ghislainc Maxwell London Townhouse | Public | SDNY_GM_02762477 | 2021.10.11 | +| GX-703 | Little Saint James | Public | SDNY GM 02760646 | 2021.10.11 | +| GX-704 | Jeffrey Epstein New York Townhouse | Public | SDNY GM 02760647 | 2021.10.11 | +| GX-705 | Paris Apartment Building | Public | SDNY GM 02760648 | 2021.10.11 | +| GX-706 | New Mexico Ranch | Public | SDNY GM 02760649 | 2021.10.11 | + +## 720 Series + +## Maps + +| GX | Description | Status | Bates NumberIldentifier | Produced to Defense | +|--------|-------------------|--------|-------------------------|---------------------| +| GX-721 | Map of Palm Beach | Public | SDNY GM 02762484 | 2021.10.11 | +| GX-722 | Map of Palm Beach | Public | SDNY_GM_02762485 | 2021.10.11 | + +## 740 Series + +# Records + +| GX | | Description | Status | Bates Number/Identifier | Produced to Defense | +|--------|---------------|-------------|---------|-----------------------------------|---------------------| +| GX-741 | Donor Records | | | | | +| GX-742 | Application | | >..d:.1 | SDNY GM 02753523-SDNY GM 02753524 | 2021.11.28 | + +| | | | SDNY GM 02753433-SDNY GM 02753434, | | +|--------|--------------------------|--------|-----------------------------------------------------|------------| +| GX-743 | Application | Scaled | | | +| | | | SDNY_ GM_ SONNI_GM-_02753435 | | +| GX-744 | Student Roster | Sealed | GM 02775778 —SDNY | 2021.11.28 | +| GX-745 | Photograph of Cabin | Public | SDNY GM 02775027 | 2021.11.20 | +| GX-746 | Photograph ofMand Family | Sealed | SDNY GM 02775028 SDNY_GM_02753480-SDNY GM 02753481, | 2021.11.20 | +| GX-747 | Application | Scaled | | | +| | | | SDNY GM 02775031 SONY— GM— 02753482 | | + +# 760 Series + +| GX | Description | Status | Bates Number/Identifier | Produced to Defense | +|--------|-------------|--------|-----------------------------------|---------------------| +| GX-761 | for | Sealed | SDNY_GM_00005511-SDNY_GM_00005514 | 2021.10.11 | + +# 780 Series + +# School District Records + +| CX | | Description | Status | Bates Number/Identifier | Produced to Defense | +|----------|----------|----------------------------------|----------|------------------------------------|---------------------| +| GX-781 | I | Enrollment Records for 1989-2002 | Public | SDNY GM 02753596 | 2021.10.11 | +| GX-782 | I | Enrollment Records for 2001-2002 | Public | SDNY GM 02753597-SDNY GM 02753598 | 2021.10.11 | +| GX-783 | I | Re!_l!t__ration Records | ‘c.ilc‘l | SDNY GM 02753608-SONY GM 02753610 | 2021.10.11 | +| GX-783-R | Redacted | Registration Records | Public | SDNY_G?4_02753608-SDNY_GM_02753610 | 2021.11.28 | + +#### FedEx Records I + +# 800 Series + +| GX | Description | Status | Bates Number/Identifier | Produced to Defense | +|----------|------------------------------------|--------|-----------------------------------|---------------------| +| GX-80I | December 16, 2002 Invoice | Sealed | SDNY_GM_00525676-SDNY_GM_00525690 | 2021.10.11 | +| GX-801-R | Redacted December 16.2002 Invoice | Public | SDNY GM 00525676-SDNY GM 00525690 | 2021.11.28 | +| GX-802 | December 23.2002 Invoice | Scaled | SDNY GM 0052570D-SDNY GM 00525720 | 2021.10.11 | +| GX-802-R | Redacted December 23, 2002 Invoice | Public | SDNY GM 0052570D-SDNY GM 00525720 | 2021.11.28 | +| GX-803 | October 14. 2002 Invoice | Scaled | SDNY GM 00431553-SONY GM 00431561 | 2021.10.11 | +| GX-803-R | Redacted October 14, 2002 Invoice | Public | SDNYGM00431553-SDNYGM00431561 | 2021.11.28 | + +#### Mar -A-Lego Records + +# 820 Series + +| GX | Description | | Status | Bates Number/Identifier | Produced to Defense | +|----------|------------------------------------------|---------|--------|--------------------------------------|---------------------| +| GX-82I | Human Resources Correspondence Regarding | Records | Public | SDNY GM 00120681 | 2021.11.28 | +| GX-822 | Mar-A-Lago Termination List | | Scaled | SDNY GM_00120686-SDNY_GM_00120702 | 2021.10.11 | +| GX-823 | Mar-A-Lago Personnel Records | | | | | +| | | | | SDNY_GM—00120566, SDNY- GM_00120568- | | +| GX-823-R | Redacted Mar-A-Lago Personnel Records | | | | | +| | | | | SDNGM00120566, SDNY- GM_00120568- | | + +#### New York Search Photos + +# 900 Series + +| GX | Description | Status | Bates Number/Identifier | Product Defense | +|--------|-------------------------------------------|--------|-------------------------|-----------------| +| GX-901 | Photograph of Stairwell and Nude Portrait | Sealed | SDNY - GM - 00166249 | 2021.10.11 | + +| GX-902 | Photograph of Hallway and Nude Portrait | Sealed | SDNY_GM_00166251 | 2021.10.11 | +|----------|---------------------------------------------------------|--------|------------------|------------| +| GX-903 | Photograph of Massage Room | Sealed | SDNY_GM_00166252 | 2021.10.11 | +| GX-903-R | Redacted Photograph of Massage Room | Public | SDNY_GM_00166252 | 2021.11.28 | +| GX-904 | Photograph of Massage Room | Sealed | SDNY_GM_00166253 | 2021.10.11 | +| GX-904-R | Redacted Photograph of Massage Room | Public | SDNY_GM_00166253 | 2021.11.28 | +| GX-905 | Photograph of Bathroom | Sealed | SDNY_GM_00166258 | 2021.10.11 | +| GX-906 | Photograph of Massage Table | Sealed | SDNY_GM_00166260 | 2021.10.11 | +| GX-906-R | Redacted Photograph of Massage Table | Public | SDNY_GM_00166260 | 2021.11.28 | +| GX-907 | Photograph of Nude Portrait | Sealed | SDNY_GM_00166265 | 2021.10.11 | +| GX-908 | Photograph of Stairwell and Nude Portrait | Public | SDNY_GM_00166273 | 2021.10.11 | +| GX-909 | Photograph of Townhouse Exterior | Public | SDNY_GM_00166275 | 2021.10.11 | +| GX-910 | Photograph of Interior and Stairwell | Public | SDNY_GM_00166327 | 2021.10.11 | +| GX-911 | Photograph of Interior | Public | SDNY_GM_00166328 | 2021.10.11 | +| GX-912 | Photograph of Interior | Public | SDNY_GM_00166386 | 2021.10.11 | +| GX-913 | Photograph of Interior | Sealed | SDNY_GM_00166417 | 2021.10.11 | +| GX-914 | Photograph of Black Binders in Closet | Public | SDNY_GM_00166594 | 2021.10.11 | +| GX-915 | Photograph of Stairwell | Public | SDNY_GM_00166719 | 2021.10.11 | +| GX-916 | Photograph of Desk | Public | SDNY_GM_00166731 | 2021.10.11 | +| GX-917 | Photograph of Massage Table | Public | SDNY_GM_00166746 | 2021.10.11 | +| GX-918 | Photograph of Vanity Drawers | Public | SDNY_GM_00166761 | 2021.10.11 | +| GX-919 | Photograph of Costumes | Public | SDNY_GM_00166767 | 2021.10.11 | +| GX-920 | Photograph of Costumes | Public | SDNY_GM_00166768 | 2021.10.11 | +| GX-921 | Photograph of Desk | Public | SDNY_GM_00166771 | 2021.10.11 | +| GX-922 | Photograph of Interior | Public | SDNY_GM_00167663 | 2021.10.11 | +| GX-924 | Photograph of Nude Sculpture | Sealed | SDNY_GM_00166778 | 2021.10.11 | +| GX-925 | Photograph of Black Binders in Closet | Public | SDNY_GM_00166779 | 2021.10.11 | +| GX-926 | Photograph of Drawer Contents | Public | SDNY_GM_00166782 | 2021.10.11 | +| GX-927 | Photograph of Nude Sculpture | Sealed | SDNY_GM_00166784 | 2021.10.11 | +| GX-928 | Photograph of Interior | Public | SDNY_GM_00166907 | 2021.10.11 | +| GX-929 | Photograph of Interior | Public | SDNY_GM_00167081 | 2021.10.11 | +| GX-930 | Photograph of Nude Portrait in Bathroom | Sealed | SDNY_GM_00167094 | 2021.10.11 | +| GX-931 | Photograph of Nude Portrait in Bathroom | Sealed | SDNY_GM_00167095 | 2021.10.11 | +| GX-932 | Photograph of Townhouse Exterior | Public | SDNY_GM_00167102 | 2021.10.11 | +| GX-933 | Photograph of Interior | Public | SDNY_GM_00167111 | 2021.10.11 | +| GX-934 | Photograph of Interior | Public | SDNY_GM_00167211 | 2021.10.11 | +| GX-935 | Photograph of Bookshelves and Cabinet Contents | Sealed | SDNY_GM_00167251 | 2021.10.11 | +| GX-935-R | Redacted Photograph of Bookshelves and Cabinet Contents | Public | SDNY_GM_00167251 | 2021.11.28 | +| GX-936 | Photograph of Interior | Public | SDNY_GM_00166421 | 2021.11.28 | +| GX-937 | Photograph of Massage Room | Public | SDNY_GM_00166748 | 2021.11.28 | + +| 1000 Series | | | | | +|--------------|-------------------------------------------------------------------------|--------|-------------------------|---------------------| +| Stipulations | | | | | +| GX | Description | Status | Bates Number/Identifier | Produced to Defense | +| GX-1004 | Signed stipulation regarding birth certificates | Public | | 2021.11.28 | +| GX-1005 | Signed stipulation regarding deposition transcript of ██████████ | Public | | 2021.11.28 | +| GX-1006 | Signed stipulation regarding deposition transcript of ██████████ | Public | | 2021.11.16 | +| GX-1007 | Signed stipulation regarding deposition transcript of ██████████ | Public | | 2021.11.16 | +| GX-1008 | Signed stipulation regarding deposition transcript of Ghislaine Maxwell | Public | | 2021.11.16 | \ No 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b/marker2/ds9/EFTA00085051/EFTA00085051.md @@ -0,0 +1,52 @@ +From: To: Cc: + +Subject: RE: Discovery questions + +Date: Tue, 18 Aug 2020 08:45:17 +0000 + +Attachments: Pages\_from\_Miami\_Case\_Docs.pdf + +Sorry, got a bounceback for M'too. I'm just attaching the one page I referenced in my email below. Hopefully that will go through. + +From Sent: ues ay, ugust , : AM To: > + +Cc: + +Subject: FW: Discovery questions + +I got a bounceback from your account for the below email because the attachment was too big. Hopefully it went through for Mandy so she can see it. If not, please let me know. + +Thanks, + +From: + +Sent: Tuesday, August 18, 2020 4:33 AM + +To: (NY) (FBI) < > + +Cc: (USANYS) + +Subject: Discovery questions + +Thanks so much for your help with the Maxwell discovery so far. I have some follow-up questions about the most recent batch you provided, and wanted to check in on the longer term tasks we discussed last month. + +Below are some questions regarding the discover dropped off a few days ago with requests for additional items: + +- The last page of the attached appears to be a photograph of a disc. The label on the disc seems to suggest it contains grand jury transcripts. Have you given us those transcripts? +- The message pad scans you provided still have post-it notes on top of several of the message pad pages. I think mentioned that each pad had been scanned twice, but I'm only seeing one copy of each pad—and those copies all of post-its on them. That's true of nearly every "Notebook" pdf you provided in the "Message pad scans" folder. Would you please get us a scans of these without post-its on them? +- It looks like we're still missing SW returns for the 20 mag 6719 warrant and for the NH premises warrant. Would you please get us copies of those returns? + +Following up on our conversation last month, I think we're still waiting on the below items from you guys. Would you please be able to get us these this week? + +- Full FBI sentinel file +- CART paperwork regarding the extraction of data from all devices seized during the investigation +- All 302s regarding the extraction of data from any seized devices and the review of images (both digital and hard copy) seized during the investigation, including from Epstein's properties. +- Scans of the filesMprovided to the FBI and provide us with all of those scanned materials +- Scans of all hard copy documents, including photos, in the possession of the FBI that have not yet been scanned, including anything seized during any searches. Please produce to SDNY all of those scans, except any nude or partially nude images. For nude or partially nude images, please provide us with a log detailing how many such images were scanned, where they were from, and where they are being stored. +- Copies of the contents of all the discs that were seized and searched pursuant to search warrants to a platform for review. Then please produce to SDNY a copy all of those materials, except any nude or partially nude images. For nude or partially nude images, please provide us with a log detailing how many such images were located, where they were from, and where they are being stored. + +Please let me know if you have any questions or if it would be useful to hop on a call. + +Thanks very much, + +![](_page_1_Picture_4.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00085051/EFTA00085051.metadata.json b/marker2/ds9/EFTA00085051/EFTA00085051.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e2d95357a75d320e4b062d1a9de0e145f6216c78 --- /dev/null +++ b/marker2/ds9/EFTA00085051/EFTA00085051.metadata.json @@ -0,0 +1,106 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085051.pdf", + "engine": { + "marker_major": "2", + "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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-0,0 +1,37 @@ +From: "cl To:' CRM)" Cc: ' (London)" <1 + +Subject: RE: Status of conversations: Witness PA + +Date: Tue, 18 Aug 2020 08:49:39 +0000 + +Embedded: 8 \_ 11 \_ 20 \_ notes \_ from\_ call \_ with \_ PA\_counsel.msg; + +Reference\_materials\_further\_to\_our call.msg; RE:\_Sensitive\_Correspondence.msg + +Welcome back—I hope you had a wonderful vacation and a safe trip back to London. + +Attached are the notes from the most recent call with Blackfords and the most recent email correspondence with them. Our next call is scheduled for Wednesday 8/19. + +Thanks, + +Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 + +From RM) + +Sent: Monday, August 17, 2020 9:10 AM + +To: + +Cc (London) + +Subject: Status of conversations: Witness PA + +Hi + +I am back from vacation (and back on the ground in London). Just wanted to check in on the status of any discussions with Blackfords. 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As you suggested in your email to Special Agent [REDACTED], attached please find a subpoena seeking any non-privileged materials regarding that transaction. Please feel free to contact me with any questions or concerns. I can be reached on my cellphone at [REDACTED]. + +Thank you, + +[REDACTED] +Assistant United States Attorney +Southern District of New York +1 St. Andrew's Plaza +New York, NY 10007 +[REDACTED] +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00085056/EFTA00085056.metadata.json b/marker2/ds9/EFTA00085056/EFTA00085056.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b457e88dd878f780a4e3c072f6df7ca6bb59d6c4 --- /dev/null +++ b/marker2/ds9/EFTA00085056/EFTA00085056.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085056.pdf", + "engine": { + "marker_major": "2", + "marker_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": 883, + "elapsed_seconds": 3.67, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 28 + ], + [ + "Text", + 18 + ], + [ + "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/EFTA00085056" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085057/EFTA00085057.md b/marker2/ds9/EFTA00085057/EFTA00085057.md new file mode 100644 index 0000000000000000000000000000000000000000..c3e05ff736056fd99fc79173ae0e62aa1b1a8af4 --- /dev/null +++ b/marker2/ds9/EFTA00085057/EFTA00085057.md @@ -0,0 +1,121 @@ +![](_page_0_Picture_0.jpeg) + +# U.S. Department of Justice + +United States Attorney Southern District of New York + +The Silvio J. Mollo Building One Saint Andra..9 Plaza New York. New York 10007 + +July 8, 2020 + +### VIA EMAIL + +Attorney at Law + +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. + +Very truly yours, + +Audrey Strauss Actin>r United States Attome + +By: + +Assistant United States Attorney + +United States District Court +SOUTHERN DISTRICT OF NEW YORK + +TO: + +[REDACTED] + +Attorney at Law + +[REDACTED] + +GREETINGS: + +WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before the GRAND JURY of the people of the United States for the Southern District of New York, at the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the following date, time and place: + +Appearance Date: July 21, 2020 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 [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 +July 8, 2020 + +![]()Audrey Strauss +Acting 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 + +[REDACTED] + +![]()(Grand Jury Subpoena to + +dated July 8, 2020) + +### Instructions and Definitions: + +- 1. This Subpoena calls for the production of categories of documents, records, correspondence, and other material (includin electronicall stored material), as specified below, in the possession, custody, or control of Attorney at Law. +- 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 "Property" means the property located at +- 4. The "Transaction" means the purchase of the Property by Granite Realty, LLC. +- 5. 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. +- 6. 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: + +- 1. All non-privileged documents relating to the Transaction, including, without limitation: (a) any and all financial records, including records related to any and all transfers of funds; (b) any and all title records; (c) any and all closing documents; (d) any and all records regarding the ownership of the Property; (e) any and all records related to the formation of any limited liability companies or trusts; and (f) any and all records related to or referencing Ghislaine Maxwell. + +N.B.: Personal appearance is not required if the r 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 Yorl 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. + +## Declaration of Custodian of Records + +Pursuant to 28 U.S.C. 0 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 July 8, 2020 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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If so, we have one attached for tomorrow please — and if not, if you could please just let us know who to send to? + +From: + +Sent: Friday, April 17, 2020 12:59 + +To: Cc: + +Subject: RE: NDO renewal + +you! + +Got it, thanks very much - and thank youMI + +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. + +From: < + +Sent: Friday, April 17, 2020 12:34 PM + +To: + +Cc: + +Subject: RE: NDO renewal + +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 always!! + +![](_page_1_Picture_1.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00085061/EFTA00085061.metadata.json b/marker2/ds9/EFTA00085061/EFTA00085061.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cf2ae560bc7e8d9a04363138f7c9fada44ce3902 --- /dev/null +++ b/marker2/ds9/EFTA00085061/EFTA00085061.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085061.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1259, + "elapsed_seconds": 1.29, + "image_assets": [ + "_page_1_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 31 + ], + [ + "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", + 5 + ], + [ + "Line", + 3 + ], + [ + "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/EFTA00085061" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085061/_page_1_Picture_1.jpeg b/marker2/ds9/EFTA00085061/_page_1_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..42e3afe9b8be4206576bf8a99511fb2acfe02141 --- /dev/null +++ b/marker2/ds9/EFTA00085061/_page_1_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:84270e872a2cab4ede69de03f48623c612035afc0f6fe808701f8f785e1da274 +size 1387 diff --git a/marker2/ds9/EFTA00085063/EFTA00085063.md b/marker2/ds9/EFTA00085063/EFTA00085063.md new file mode 100644 index 0000000000000000000000000000000000000000..b31e12ee9f913e4c90066d67a4b9ade7baa49a5a --- /dev/null +++ b/marker2/ds9/EFTA00085063/EFTA00085063.md @@ -0,0 +1,50 @@ +From: "[REDACTED]" +To: [REDACTED] +Cc: [REDACTED] +[REDACTED] + +**Subject:** RE: 302s / interview notes + +**Date:** Fri, 08 May 2020 22:51:32 +0000 + +[REDACTED] + +Thanks very much again for getting us so many 302s recently, we really appreciate it. Collectively, there have been more than 120 interviews in this case, which is incredible. We've now completed a full review and cross-reference of all our materials, so wanted to address a handful of loose ends. In terms of reports, I think currently we're down to only missing three, all of which we have interview notes for but no 302s: + +- [REDACTED] +[REDACTED] +[REDACTED] + +And then there are a larger number of interviews where we have a 302 but not hand-written notes. My guess is that for some of these, and possibly most, there aren't notes because the "interviews" were so short that they just got typed up, but we wanted to check. Also most of them were interviews conducted by other agents (where it was agents other than one or both of you, I've indicated below). But if you could please double check to see if there are interview notes for the following, and in particular the few that are in bold? And let us know if any questions or issues. They are: + +- [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] + +Assistant U.S. Attorney + +Southern District of New York + +212.637.2415 \ No newline at end of file diff --git a/marker2/ds9/EFTA00085063/EFTA00085063.metadata.json b/marker2/ds9/EFTA00085063/EFTA00085063.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1abf2758ceb14f861816a49e4111ab6fd39920b9 --- /dev/null +++ b/marker2/ds9/EFTA00085063/EFTA00085063.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085063.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1612, + "elapsed_seconds": 41.36, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Text", + 18 + ], + [ + "Line", + 16 + ], + [ + "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", + 9 + ], + [ + "Text", + 5 + ], + [ + "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/EFTA00085063" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085065/EFTA00085065.md b/marker2/ds9/EFTA00085065/EFTA00085065.md new file mode 100644 index 0000000000000000000000000000000000000000..3b017aa927ff9f7ac772a4722ac19fd723149f05 --- /dev/null +++ b/marker2/ds9/EFTA00085065/EFTA00085065.md @@ -0,0 +1,97 @@ +**From:** [REDACTED] > +**To:** [REDACTED] +**Cc:** [REDACTED] +[REDACTED] +[REDACTED] + +**Subject:** RE: 302s / interview notes +**Date:** Thu, 14 May 2020 17:47:22 +0000 + +**Attachments:** [REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +--- + +Hi all, + +I've attached the notes you've requested. I've also attached [REDACTED] 302 and notes; that interview was not in the batch we gave you. You'll see below where I've typed "attached" to reflect what notes we have. Interviews where this is not written simply meant there were no notes to attach likely because the interview/contact was brief (I double checked all to be sure). Let me know if there is anything else you come across that we've missed sending. + +Also, could you send over the notes from the last two phone interviews with [REDACTED] and [REDACTED]? Just want to make sure we have them on our end. + +Thanks, +[REDACTED] + +--- + +**From:** [REDACTED] +**Sent:** Friday, May 08, 2020 6:52 PM +**To:** [REDACTED] +**Cc:** [REDACTED] +[REDACTED] +**Subject:** RE: 302s / interview notes + +[REDACTED] +Thanks very much again for getting us so many 302s recently, we really appreciate it. Collectively, there have been more than 120 interviews in this case, which is incredible. We've now completed a full review and cross-reference of all our materials, so wanted to address a handful of loose ends. In terms of reports, I think currently we're down to only missing three, all of which we have interview notes for but no 302s: + +[REDACTED] + +And then there are a larger number of interviews where we have a 302 but not hand-written notes. My guess is that for some of these, and possibly most, there aren't notes because the "interviews" were so short that they just got typed up, but we wanted to check. Also most of them were interviews conducted by other agents (where it was agents other than one or both of you, I've indicated below). But if you could please double check to see if there are interview notes for the following, and in particular the few that are in bold? And let us know if any questions or issues. They are: + +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- +- + +![](_page_1_Picture_35.jpeg) + +Thanks again! + +![](_page_1_Picture_37.jpeg) + +Assistant U.S. Attorney +Southern District of New York + +![](_page_1_Picture_39.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00085065/EFTA00085065.metadata.json b/marker2/ds9/EFTA00085065/EFTA00085065.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..870fc4ffa1c6c001d545a7ac3100e9a4dec0eb94 --- /dev/null +++ b/marker2/ds9/EFTA00085065/EFTA00085065.metadata.json @@ -0,0 +1,100 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085065.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2514, + "elapsed_seconds": 77.65, + "image_assets": [ + "_page_1_Picture_35.jpeg", + "_page_1_Picture_37.jpeg", + "_page_1_Picture_39.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Text", + 31 + ], + [ + "Line", + 24 + ], + [ + "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", + 17 + ], + [ + "Text", + 9 + ], + [ + "Line", + 9 + ], + [ + "Picture", + 3 + ], + [ + "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/EFTA00085065" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085065/_page_1_Picture_35.jpeg b/marker2/ds9/EFTA00085065/_page_1_Picture_35.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..09c09ae05af6c60fae2f5caaec8864f1b771102f --- /dev/null +++ b/marker2/ds9/EFTA00085065/_page_1_Picture_35.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:67ed9641536089a0783739a6f6bce24e0bb7dd84e959bbec61e36e93116f5444 +size 21671 diff --git a/marker2/ds9/EFTA00085065/_page_1_Picture_37.jpeg b/marker2/ds9/EFTA00085065/_page_1_Picture_37.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..3ef1f941004a2203e0ee0558166c5e4f0ed538e2 --- /dev/null +++ b/marker2/ds9/EFTA00085065/_page_1_Picture_37.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:4f55929ff343b5fc0ea53f10a94b3772fcd0a0f81cafde523344bf4269834809 +size 1690 diff --git a/marker2/ds9/EFTA00085065/_page_1_Picture_39.jpeg b/marker2/ds9/EFTA00085065/_page_1_Picture_39.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..18428ea921bb03a3e7e7af4c1bce5d58d5f4440a --- /dev/null +++ b/marker2/ds9/EFTA00085065/_page_1_Picture_39.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:5bb3d29ee7d98aa72556c6ebe5712aaafa94095ae4fa0409f6395de62423651d +size 1381 diff --git a/marker2/ds9/EFTA00085067/EFTA00085067.md b/marker2/ds9/EFTA00085067/EFTA00085067.md new file mode 100644 index 0000000000000000000000000000000000000000..ebc5afe2ac3a8698a4b3bc6aa244697d783663b6 --- /dev/null +++ b/marker2/ds9/EFTA00085067/EFTA00085067.md @@ -0,0 +1,180 @@ +WILLIAM BOOTH +FOUNDER +JOHN GOWANS +GENERAL + +![](_page_0_Picture_21.jpeg) + +# THE SALVATION ARMY + +Founded in 1865 by William and Catherine Booth + +## THE PARKSIDE EVANGELINE RESIDENCE + +18 GRAMERCY PARK SOUTH +NEW YORK, N. Y. 10003-1724 + +LT.-COLONEL JERRY W. GAINES, ADMINISTRATOR + +TELEPHONE: (212) 677-6200 + +FAX: (212) 677-0640 + +JOE NOLAND +TERRITORIAL COMMANDER +MAJOR CARL L. SCHOCH +DIVISIONAL COMMANDER + +November 8, 2002 + +TO WHOM IT MAY CONCERN: + +Gentlemen, + +Ms. [REDACTED] currently resides at [REDACTED] +[REDACTED] She has been a tenant here since March +27, 2001. + +Her accounts are in good standing. + +Sincerely, + +![]()Deborah Rasberry +Administrative Assistant + +# THE C MMOD TION BE RENT CONTRQL AND RENT STABILIZATION LAWS + +### THE SALVATION ARMY THE PARKSIDE EVANGELINE RESIDENCE 18 Gramercy Park South New York, NY 10003 + +## ADM + +The Salvation Army (\*Residence') and and hereby agree to the following financial terms and arrangements for Parent, Guardian or Sponsor providing comtortable, gracious living for \_ \_ ("Resident"). + +### AGREEMENT OF RESIDENCE + +- 1. To furnish room (-room') and two meals per day, and weekly cleaning of bathroom and common areas. + +### AGREEMENT OF RESIDENT OR PARENT. GUARDIAN OR SPONSOB + +- To comply with the lving arrangements and housekeeping, health and safety standards of the Residence, as set form in this Agreement and the attached House Rules, which the Resident acknowledges having fully read and understood. +- 2. To pay the occupancy fee when due. Prices are subject to change without notification. New rates usually take effect September of each year. +- 3. To pay for additional charges as they are due. +- 4. To pay full room and board charges if for any reason the room is retained but not occupied. + +# STANDARD ADMISSION WAIVER AND OMER cf\_RovisinNa + +- The Administration of this Residence has agreed to exercise reasonable care toward the Resident; however, the Residence is in no sense an insurer of the Resident's safety or welfare and assumes no liability as such. +- 2. The Residence will not be responsible for the Resident's personal property, valuables or money. +- 3. The Residence may assign the Resident to a different room, as deemed necessary by the Residence in its solo discretion. condoot. a business from tho 4 busin Ileztder.qo or use the Nn ca psi rtent may rlasidence address or telephone nurnbei on ess cards or in newspapers advertisements . +- 5. The Residence and its agents have the'right to enter Resident's quarters at all times for any reasonable purpose. II the Residence must make repairs because of damage caused by a Resident, the Resident is reimbursing the Residence for the cost of such repairs. responsible for +- 6. Residents have no right or power to incur any obligation or to make any upon commitments that shall be binding in any way the Residence. +- 7. This Agreement may not be assigned or transferred, in whole or in part, either by the Resident or by operation of law, nor may the Resident or Parent, Guardian or Sponsor grant any sublicense under it. + +Parent, Guardian or Sponsor hereby agree to the following financial terms and arrangements for receiving comfortable, gracious living for [redacted] ("Resident"). + +AGREEMENT OF RESIDENCE + +1. To furnish room ("room") and two meals per day, and weekly cleaning of bathroom and common areas. + +AGREEMENT OF RESIDENT OR PARENT, GUARDIAN OR SPONSOR + +- 1. To comply with the living arrangements and housekeeping, health and safety standards of the Residence, as set forth in this Agreement and the attached House Rules, which the Resident acknowledges having fully read and understood. +- 2. To pay the occupancy fee when due. + Prices are subject to change without notification. New rates usually take effect September of each year. +- 3. To pay for additional charges as they are due. +- 4. To pay full room and board charges if for any reason the room is retained but not occupied. + +STANDARD ADMISSION WAIVER AND OTHER PROVISIONS + +- 1. The Administration of this Residence has agreed to exercise reasonable care toward the Resident; however, the Residence is in no sense an insurer of the Resident's safety or welfare and assumes no liability as such. +- 2. The Residence will not be responsible for the Resident's personal property, valuables or money. +- 3. The Residence may assign the Resident to a different room, as deemed necessary by the Residence in its sole discretion. +- 4. No Resident may conduct a business from the Residence or use the Residence address or telephone number on business cards or in newspapers advertisements. +- 5. The Residence and its agents have the right to enter Resident's quarters at all times for any reasonable purpose. If the Residence must make repairs because of damage caused by a Resident, the Resident is responsible for reimbursing the Residence for the cost of such repairs. +- 6. Residents have no right or power to incur any obligation or to make any commitments that shall be binding in any way upon the Residence. +- 7. This Agreement may not be assigned or transferred, in whole or in part, either by the Resident or by operation of law, nor may the Resident or Parent, Guardian or Sponsor grant any sublicense under it. + +No provision of this Agreement can be waived or modified unless in writing signed by a representative of the Residence. The Residence does not waive any provisions set forth in this Agreement and those other documents, including the House Rules, and "Information for Our Residents", hereby incorporated in and made a part of this Agreement (which the Resident acknowledges having fully read and understood), by its failure to enforce them. + +This Agreement is a license and not a lease, and no leasehold or tenancy is intended to be or shall be created by it. + +1. Former Residents' property unclaimed for 30 days shall be deemed to have been contributed to The Salvation Army. + +The term of this license agreement shall begi aroom. Should the Security Deposit not provb assigned after a brief period. valid. the applicant will be considered aTransient uest, and the room rewhen th Resident is assigned to + +- 1. the The equivalent minimum stay of three is three (3) months. II It honor this 90-days Agreementrf (3) months occupancy fee. I pay The Parkside Residence +- 2. If I do not give 'in writing' a 30-days Notice of my of one month intention to vacate. I will pay The Parkside Residence the equivalent occupancy fee. +- 3. I understand eviction. that I need to pay my weekly rent in advance. If I do not do so, I will be subject to late fees and possible + +Changes may be made in the room assignment at the discretion of the Residence. Either party may terminate this agreement auipsocri fe3t0endays' of the written Residence, notice. Otherwise, this Agreement will remain in effect until circumstances make it necessary, at the sole for the Resident to leave under.theIbiev-Blon.s. of the Agreement or otherwise pursuant to law. + +# E + +this The amount Resident or Parent, Guardian or Sponsor aees to pay \$?CC • OCLekly. in full consideration for all included ervices rendered. The Residenc reserves advance, adva the right theht to eincrease Residence wthilil safceceeaptt its sole discretion. The Resident or Parent, Guar an or Sponsor also agrees to y incur that are not the additional charges the Resident may included in the weekly occupancy e. (See above, "Agreeme of Resident or Parent. Guardian or Sponsor"). Such additional charges are hereby deemed to be a nal occupan yds. + +Weekly charges are due on or before each Monday. Weekly accounts not paid by Friday morning are subject to a Late Fee. Parents-Pay accounts are due at the beginning of the month and are subject to Late Fees as of the 15th and every week thereafter until balance is cleared in full. + +There will be a refurbishing charge, payable by the Resident at time of departure, if any damage to the room has been incurred. + +Should the Resident die while in residence, the Residence will issue a 30 days' written notice to terminate (see above. "Term or Occupancy), and the Resident's estate or administrator or the Parent, Guardian or Sponsor hereby agrees to pay all charges through the termination date and to remove the Resident's belongings by that date. The 'termination date" shall be defined for the purpose herein before stated to mean the date 30 days after the Residence issues its written notice to terminate. + +### CERTIFICATION BY RESIDENT + +I certify that: + +- A. I in will and comply made with apart the of terms this Admission and conditions for residence set forth herein and in those other documents incorporated and Occupancy Agreement. +- 2. fee and any additional charges incurred in connection Parent. Guardian with or Sponsor) will pay when duo the weekly occupancy the room and meal charges + +![](_page_3_Picture_12.jpeg) + +DATE —.1) 7 /0 I + +Parent, Guardian or Sponsor + +REPRESENTATIVE ,(Z + +OATE DESCRIPTION ACCOUNT NO. AMOUNT 91365 + +03/11/03 Rent payment ck01080 01-000-000-12030 223.00 + +![](_page_4_Picture_2.jpeg) + +IIIIIIIII C/I March/27/01 + +001141 + +HE SALVAITOIV ARMY 18GRAMERCY PARK SOUTH, NEW YORK, N.V. 10003 + +PARKSIDE EVANGELINE RESIDENCE + +TOTAL metwormmerrnmawnikemmmoommmwma + +ND. 091366 + +223.00 + +Name + +Room No. Rent + +Date //Oa Phone + +Clerk's Initials Misc. + +Cash. Traveler's Total r-Aa3 + +• + +![](_page_6_Picture_2.jpeg) + +WITH THE COMPLIMENTS +OF +**JEFFREY E. EPSTEIN** + +**J. EPSTEIN & Co., Inc.** +THE VILLARD HOUSE +457 MADISON AVENUE, N.Y. 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In attendance at the interview were FBI Special Agent (SA) S Office of the Inspector General (OIG) SA I, Assistant United States Attorney (AUSA) Si, and attorneys, Andy Patel, Jill Shellow, and Donald Yanella. was advised of his rights and also that it is a separate crime to lie to a federal agent. acknowledged what he was advised of and was willing to proceed with the interview. After being advised of the identity of the interviewing investigators and the nature of the interview, INMATE 2 provided the following information: + +has been at MCC in the Special Housing Unit (SHU) L Tier since August 2, 2019. His cell is the first cell on the left and he is able to see all the cells on the right side in L Tier. can also see G and H Tier along with the middle portion of the multi-purpose room in the SHU from his cell. 1::iCA-E usually goes to sleep around 11pm or 12am. If he gets to sleep during the day, he will then go to bed around 3am. that he is always up for breakfast which is around 6:10am. INMATE 2 stated will sometimes wake up when the count is conducted because he can hear the keys. + +On the morning that JEFFREY EPSTEIN was found unresponsive in his cell, said that he saw a Guard, who he described as a black male, on the shorter side heightwise, and had close cut hair, knock on EPSTEIN's cell door. The Guard looked into the cell and then entered the cell. When the Guard opened the door, INMATE 2 could only see EPSTEIN's legs from the knee down but could tell that he was laying down on his back because his feet were pointed upward. INMATE 2 could only see this portion of EPSTEIN because EPSTEIN always slept on the floor to the right side of the cell. + +The Guard bent down to shake EPSTEIN and was saying "Epstein. Epstein.". + +Investigationon 09/03/2019 at New York, New York, United States (In Person) + +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 am not to be distributed outside your agency. + +ComthuationofFD-Mor (U) Interview of INMATE 2 .on 09/03/2019 .Page 2 of 2 + +The Guard then tried to pick up EPSTEIN from behind, with his arms wrapped around EPSTEIN. Both the Guard and EPSTEIN fell back to the floor, with EPSTEIN falling to the side of the Guard. stated that once the two fell, he could then see EPSTEIN. The Guard then started giving EPSTEIN chest compressions and mouth-to-mouth. At this point the Guard said "Fuck!" and asked the female Guard, who was standing near the L Tier gate, if she had pressed the button. The female Guard said "Yeah, a long time ago." + +A Lieutenant then came in and also a male nurse who tried to revive EPSTEIN. However, EPSTEIN was not responsive because, according to INNAli 2 EPSTEIN was already dead. INN said that EPSTEIN looked dead when he fell with the Guard after the Guard tried to pick him up. + +said that personnel were having trouble getting EPSTEIN onto the stretcher because EPSTEIN was basically dead weight. When they did get him on the stretcher, EPSTEIN still had on headphones. stated that EPSTEIN did not have any marks around his neck and he didn't see a rope around EPSTEIN's neck. At this point, \_NY! then took a look at what was happening. woke up his cellmate who INV.AT 2 cellmate made a comment that EPSTEIN didn't hang himself because he didn't have the typical injuries. INMATE 2 at some point, saw a male come out of EPSTEIN's cell with a sheet that had a loop and knot. + +After this, MCC personnel, to include Lieutenant started to cover up the windows to the cells on L Tier. They also brought dividers to block views from his cell and the camera. + +The day before EPSTEIN died, EPSTEIN and his cellmate left at the same time that morning. EPSTEIN was with his lawyers all day, as usual. However, when he was brought back to the SHU that night, the guards took him up to J Tier before they brought him back to his cell. That night, a count was done a little before 12am, but none were conducted after 12am. Wiala ildn't hear anyone say that counts weren't going to be done that night. 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I made some changes to the sections I already sent you. Those are highlighted in yellow. I will send you the verdict sheet later tonight. + +Regarding the "Minor-Victim" terminology, I know the redactions are a pain, but it is still our position that there is no need to anonymize them and we object to calling them both "minors" and "victims." So I can't agree to that. + +Thanks, + +Chris + +From: + +Sent: Tuesday, November 2, 2021 6:35 PM + +To: Christian Everdell + +Subject: RE: Redactions to MILs + +Hi Chris, + +Also, do you have any objection if we edit the places where your redline uses victim names to the "Minor Victim-X" terminology? Our understanding is that we have to file this on ECF, and we just want to avoid having to redact anything. + +Thanks, + +From: Christian Everdell < Sent: Tuesday, November 2, 2021 3:43 PM To: Subject: [EXTERNAL] Re: Redactions to MILs + +Do you have a minute for a quick call about the jury instructions? Should take 5-10 mins. + +Thanks, + +Chris + +Sent from my iPhone + +On Nov 2, 2021, at 12:44 PM, > wrote: + +Counsel, + +We're preparing a new version of the proposed redactions to the MILs that withdraw some of our proposals. Please let us know which if any of your proposed redactions you would like to withdraw, and whether you would like to see our version before we send it to the Court. In particular, please let us know by Thursday at 10 a.m. so we have some time before this is due to the Court. + +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/EFTA00085080/EFTA00085080.metadata.json b/marker2/ds9/EFTA00085080/EFTA00085080.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..eefaa24d1e498128854c84da0a1593a092d5011d --- /dev/null +++ b/marker2/ds9/EFTA00085080/EFTA00085080.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085080.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2217, + "elapsed_seconds": 1.09, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "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", + 45 + ], + [ + "Line", + 23 + ], + [ + "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/EFTA00085080" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085082/EFTA00085082.md b/marker2/ds9/EFTA00085082/EFTA00085082.md new file mode 100644 index 0000000000000000000000000000000000000000..4a65e30914583eaea28e0c79722086f6ecc7c33e --- /dev/null +++ b/marker2/ds9/EFTA00085082/EFTA00085082.md @@ -0,0 +1,40 @@ +## 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: | 11/3/21 | + +20-CR-330 (AJN) + +ORDER + +ALISON J. NATHAN, District Judge: + +The Court is in receipt of the Government's letter dated November 2, 2021. Dkt. No. 403. The Government is hereby ORDERED to confer further with MDC legal counsel and file a letter regarding Defendant's transportation to the courthouse for proceedings in this matter on or before November 8, 2021. The Court hereby authorizes the letter to be filed under seal because such information may implicate security concerns. The Court will also confer with the United States Marshal for the Southern District of New York and with the District Executive regarding transportation of the Defendant for upcoming in court proceedings and trial. + +With respect to legal mail, the Court requires MDC Legal Counsel to consider what additional steps can be taken (including what steps by counsel for the Government or the Defendant) to ensure that within the weeks leading up to trial, Ms. Maxwell promptly receives her legal mail. The Government shall docket a letter with MDC Legal Counsel's proposal on or before November 8, 2021. + +The Court will also transmit this Order to Chief Judge Brodie, who is overseeing the litigation and mediation in Case No. 19-cv-660 (E.D.N.Y.) regarding access to counsel for pretrial detainees being held at the MDC so that the issue can be discussed as to all MDC pre-trial detainees who require prompt access to legal mail in the weeks leading up to their trials. + +SO ORDERED. + +Dated: November 3, 2021 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00085082/EFTA00085082.metadata.json b/marker2/ds9/EFTA00085082/EFTA00085082.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a2fcdf37028109468cc11d29d3e2d29862f4bc7c --- /dev/null +++ b/marker2/ds9/EFTA00085082/EFTA00085082.metadata.json @@ -0,0 +1,120 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085082.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1900, + "elapsed_seconds": 2.02, + "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, + 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", + 61 + ], + [ + "Line", + 31 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 2 + ], + [ + "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", + 11 + ], + [ + "Text", + 7 + ], + [ + "Line", + 6 + ], + [ + "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/EFTA00085082" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085084/EFTA00085084.md b/marker2/ds9/EFTA00085084/EFTA00085084.md new file mode 100644 index 0000000000000000000000000000000000000000..a0ecfac3d70a0c85a47092f76219a8704ec0623c --- /dev/null +++ b/marker2/ds9/EFTA00085084/EFTA00085084.md @@ -0,0 +1,27 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +United States of America, + +—v— + +Ghislaine Maxwell, + +Defendant. + +USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 11/3/21 + +20-CR-330 (AJN) + +ORDER + +ALISON J. NATHAN, District Judge: + +The Court is in receipt of the Defendant's motions for reconsideration. See Dkt. Nos. 407, 408. The Government is hereby ORDERED to respond to Defendant's motion for reconsideration, Dkt. No. 408, on or before November 8, 2021. + +As to the motion for reconsideration regarding the disclosure of juror names, the Court reminds counsel of the following. First, as the Court previously indicated, the lawyers will be provided the names of jurors on November 16, prior to the commencement of the voir dire process. Second, the Court has now resolved the logistical issues regarding the ability to conduct peremptory challenges on November 29 and the Court can now confirm that peremptory strikes will not be exercised until November 29. Finally, as previously indicated, although only 40 qualified jurors are needed for the exercise of peremptory strikes, the Court will seek to qualify approximately 50 to 60 prospective jurors to return on November 29 for the exercise of peremptory strikes. If counsel for either side learns of any additional information that would be a basis for a strike for cause prior to November 29, they shall immediately raise the issue with the Court. + +Bearing in mind this information, the Government is ORDERED to respond to Defendant's motion for reconsideration, Dkt. No. 407, on or before November 4, 2021. SO ORDERED. + +Dated: November 3, 2021 New York, New York AL Ut( + +ALISON J. NATHAN United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00085084/EFTA00085084.metadata.json b/marker2/ds9/EFTA00085084/EFTA00085084.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f0ad62d53629e6b5dd585bc9abfa14da5f4b6e86 --- /dev/null +++ b/marker2/ds9/EFTA00085084/EFTA00085084.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085084.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1698, + "elapsed_seconds": 0.69, + "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", + 67 + ], + [ + "Line", + 32 + ], + [ + "Text", + 11 + ], + [ + "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 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 14 + ], + [ + "Line", + 7 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00085084" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085086/EFTA00085086.md b/marker2/ds9/EFTA00085086/EFTA00085086.md new file mode 100644 index 0000000000000000000000000000000000000000..55562bcf70b71dded26aa2bdb7ddb59e7c3f0306 --- /dev/null +++ b/marker2/ds9/EFTA00085086/EFTA00085086.md @@ -0,0 +1,39 @@ +**United States District Court** +**SOUTHERN DISTRICT OF NEW YORK** + +TO: + +[REDACTED] + +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 [REDACTED] +Appearance Place: 40 Foley Square, Courtroom 906 +to testify and give evidence in the following matter: + +***United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)*** + +and not to depart the Court without leave thereof, or of the United States Attorney, and that you bring with you and produce at the above time and place the following: + +[REDACTED] +• [REDACTED] +• [REDACTED] + +Failure to attend and produce any items hereby demanded will constitute contempt of court and will subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law. + +DATED: New York, New York +July 28, 2021 + +/s + +[REDACTED] + +Assistant United States Attorney +One St. Andrew's Plaza +New York, New York 10007 +Email: [REDACTED] +Telephone: [REDACTED] + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00085086/EFTA00085086.metadata.json b/marker2/ds9/EFTA00085086/EFTA00085086.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e38b73712c85db406b24af2f30fcfa3e56b4dac6 --- /dev/null +++ b/marker2/ds9/EFTA00085086/EFTA00085086.metadata.json @@ -0,0 +1,132 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085086.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1250, + "elapsed_seconds": 5.35, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "United States District Court SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 185.43599999999998, + 91.53 + ], + [ + 429.624, + 91.53 + ], + [ + 429.624, + 127.98000000000002 + ], + [ + 185.43599999999998, + 127.98000000000002 + ] + ] + }, + { + "title": "GREETINGS:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 56.304, + 224.37 + ], + [ + 129.744, + 224.37 + ], + [ + 129.744, + 237.32999999999998 + ], + [ + 56.304, + 237.32999999999998 + ] + ] + }, + { + "title": "United States v. 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Cohen +1 (212) 957-7600 mcohen(cticohengresscr.com + +Christian R. Everdell +1 (212) 957-7600 ceverdell@colungresscr.com + +August 10, 2020 + +## VIA ECF + +The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Dear Judge Nathan: + +**On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter motion seeking the Court's assistance with two critical issues that greatly impact Ms. Maxwell's ability to receive a fair trial on the schedule set by the Court. First, we request that the Court enter an order directing the government to disclose to defense counsel the identities of the three alleged victims referenced in the indictment ("Victims 1-3"), subject to the restrictions of the protective order entered by the Court, so that Ms. Maxwell and defense counsel can meaningfully investigate the alleged conduct, which is now over 25 years old. Second, we request that the Court enter an order directing the Bureau of Prisons ("BOP") to release Ms. Maxwell into the general population and provide Ms. Maxwell with increased access to the discovery materials while she is detained so that she can meaningfully participate in the preparation of her defense.** + +## **1. Disclosure of Victim Identities** + +**The Court should order the government to disclose the identities of Victims 1-3 to defense counsel, subject to the restrictions of the protective order, because Ms. Maxwell cannot prepare for or receive a fair trial without this information. Moreover, the requested disclosure is authorized under the law in this Circuit, and is narrowly-tailored and reasonable under the circumstances of this case.** + +**Here, it is clear from the face of the indictment that the government's case is based on the accounts of Victims 1-3, the three individuals specifically referenced in the indictment. It is therefore critical for the defense to know the names of these individuals as soon as possible, so** + +that we can mount an effective defense investigation and adequately prepare for trial. This is especially true in this case where the alleged misconduct took place on unspecified dates roughly 25 years ago in multiple locations—namely, New York, Florida, New Mexico, and the United Kingdom—and where the central figure, Jeffrey Epstein, is alleged to have engaged in misconduct with dozens, if not hundreds, of alleged victims. The defense should not have to speculate which of these individuals are Victims 1-3 referenced in the indictment. + +It is now almost six weeks since Ms. Maxwell's arrest, and the government is just now beginning to produce Rule 16 discovery, despite confirming to the Court that discovery would begin as soon as the Court entered a protective order. Moreover, the government still has not confirmed to the defense the identities of Victims 1-3. Ms. Maxwell was arrested on July 2, 2020. On July 14, 2020, during her arraignment and bail hearing, the government indicated that it had "begun preparing an initial production" and would be "prepared to produce a first batch of discovery as soon as a protective order [was] entered by the Court."' The Court entered the protective order on July 30, 2020. (Dkt. 36). The following day, July 31, 2020, defense counsel contacted the government and requested disclosure of the identities of Victims 1-3. The government refused to do so, stating that it would only disclose the identities of alleged victims through its production of Rule 16 discovery, or as part of its production of Jencks Act material closer to trial. That same day, per the government's request, the defense provided a hard drive to load the Rule 16 discovery. However, the government did not make its first production until after 2:00 p.m. on Wednesday, August 5, 2020. + +The government's initial production was a subset of non-electronic discovery materials, totaling nearly 13,000 pages, which the defense expeditiously reviewed for high-level content. Upon initial review, the materials contain certain records related to one specific individual. However, nothing in the production specifically identifies this individual as Victim I, 2, or 3. The defense should not be required to speculate whether this individual is one of the three alleged Victims, and if so, which one. Moreover, the initial production does not appear to contain any materials identifying the other two alleged Victims. Although the government has indicated that it will provide additional discovery on a rolling basis, if the initial production is any guide, it seems unlikely that later productions will sufficiently identify the remaining alleged Victims. Furthermore, the defense should not be forced to wait almost two additional weeks until August 21, 2020 (the deadline for the production of initial non-electronic discovery) or potentially months until November 9, 2020 (deadline for the completion of all discovery) before learning information that is vital to the defense. Ms. Maxwell's right to a fair trial depends on the defense's ability to adequately investigate the charges against her, and that investigation will be significantly impaired until we know for certain the names of Victims 1-3. + +July 14, 2020 Tr. at 12:14-17; see also id. at 12:25-13:3 ("Following the entry of [the] protective order . . . the government is prepared to make a substantial production of discovery."). + +District courts have the inherent authority to compel pretrial disclosure of the identities of government witnesses. See United States v. Cannone, 528 F.2d 296, 301 (2d Cir. 1975). Such disclosure is warranted when there is a specific showing that the disclosure is material to the preparation of the defense and reasonable in light of the circumstances surrounding the case. See id. at 302; United States v. Rueb, No. 00 CR. 91 (RWS), 2001 WL 96177, at \*9 (S.D.N.Y. Feb. 5, 2001) (ordering disclosure of government witness list where defendant "ha[d] met his burden to show a particularized need that outweighs the possible dangers of disclosure").2 This principle has been applied in sex crimes cases, where the right of the defendant to prepare a defense can outweigh the privacy interests of alleged victims referenced in the indictment and warrant the disclosure of their identities. See United States v. Warne, No. 09CR19A, 2009 WL 427111, at \*2 (W.D.N.Y. Feb. 20, 2009) (ordering government to disclose identity of sex crime victim where "defendant's ability to adequately prepare a defense against this charge is significantly compromised without being advised of the identity of the alleged victim"); see also id. ("Absent knowing the identity of Victim 1, the defendant is precluded from investigating the facts surrounding the crime charged."). + +The defense's narrowly-tailored request, which only seeks the disclosure of the identity of Victims 1-3, and not the government's entire witness list, is also reasonable in light of the circumstances of this case. And because the protective order prohibits Ms. Maxwell, defense counsel, and others on the defense team from disclosing or disseminating the identity of any alleged victim or potential witness referenced in the discovery materials (Dkt. 36 ¶ 5), the disclosure will have no impact on the privacy interests of Victims 1-3. Nor is there any basis for the government to claim that there is a risk that witnesses will face intimidation or refuse to testify.; To the contrary, many alleged victims have already chosen to speak on the record in criminal proceedings in the Epstein case and in this case; to file civil suits against Mr. Epstein, Ms. Maxwell and others, and to provide deposition testimony and discovery in those suits; and to give interviews to the press and other television and film productions. Moreover, Victims 1-3 are no longer minors, but are now adults in their late 30s or early 40s, which provides additional assurance that they will be willing to appear for trial. Disclosure is therefore warranted here. + +2 In determining whether to order pretrial disclosure of the identity of witnesses, some district courts have considered the following factors: (1) Did the offense alleged in the indictment involve a crime of violence? (2) Have the defendants been arrested or convicted for crimes involving violence? (3) Will the evidence in the case largely consist of testimony relating to documents (which by their nature are not easily altered)? (4) Is there a realistic possibility that supplying the witnesses' names prior to trial will increase the likelihood that the prosecution's witnesses will not appear at trial, or will be unwilling to testify at trial? (5) Does the indictment allege offenses occurring over an extended period of time, making preparation of the defendants' defense complex and difficult? (6) Do the defendants have limited funds with which to investigate and prepare their defense? Rueb, 2001 WL 96177, at \*7-8 (citation omitted). The Second Circuit, however, has not adopted these factors, nor do they constitute an exhaustive list of factors that the Court may consider in determining whether to disclose the identities of alleged victims. + +3 Notably, the government did not argue at the bail hearing that Ms. Maxwell posed a danger to the community. (See 7/14/2020 Tr. at 37:15-21). + +See Warme, 2009 WL 427111, at \*2 (ordering government to disclose identity of sex crime victim where "the government has not demonstrated that disclosing the identity to the defendant would subject the victim to a significant risk, or to increase the likelihood that victim will refuse to appear or testify"). + +With each day that passes without knowing the identities of Victims 1-3, the defense is losing crucial time to conduct a meaningful investigation and prepare its defense so that Ms. Maxwell can receive a fair trial on the schedule set by the Court. For these reasons, we respectfully request the Court to order the government to disclose the identities of Victims 1-3 to defense counsel, consistent with the provisions of the protective order. + +## 2. Ms. Maxwell's Conditions of Confinement and Access to Discovery + +We also seek the Court's assistance to improve Ms. Maxwell's conditions of confinement at the Metropolitan Detention Center ("MDC"), and her access to the discovery in this case, so that she can meaningfully participate in her defense. As discussed below, Ms. Maxwell has been treated less favorably than a typical pretrial detainee, and this has impacted her ability to assist in her defense. + +It has become apparent that the GOP's treatment of Ms. Maxwell is a reaction to the circumstances surrounding the pretrial detention and death of Mr. Epstein. On July 6, 2019, Mr. Epstein was arrested and detained at the Metropolitan Correctional Center ("MCC") on sex trafficking charges, and was subsequently assigned to the MCC's Special Housing Unit ("SHU") due to risk factors for suicide and safety concerns. After an apparent suicide attempt on July 23, 2019, Mr. Epstein was transferred to suicide watch and then psychological observation. On August 10, 2019, Mr. Epstein's body was discovered in his cell. Thereafter, the government indicted the two correctional officers who were assigned to the SHU at the time of Mr. Epstein's death. + +As a result of what occurred with Mr. Epstein, Ms. Maxwell is being treated worse than other similarly situated pretrial detainees, which significantly impacts her ability to prepare a defense and be ready for trial on the schedule set by the Court. Since arriving at the MDC over a month ago, on July 6, 2020, Ms. Maxwell has been held under uniquely onerous conditions. Ms. Maxwell has been confined alone in an area outside of the general population for the entire 36 day period (40 days if we include her confinement in New Hampshire), which is over three weeks longer than the 14-day quarantine period required for all new arrivals to the MDC under current COVID-19 protocols, and there is no indication that this will change. She continues to be surveilled 24 hours a day by security cameras and by multiple prison guards, many of whom do not appear to be regular MDC personnel. These prison guards constantly observe Ms. Maxwell and take notes on her every activity, including her phone conversations with defense counsel. Until recently, Ms. Maxwell was subjected to suicide watch protocols, including being woken up every few hours during the night and being forced to wear special clothing, despite the + +fact that she, unlike Mr. Epstein, has never been suicidal and was never diagnosed as exhibiting risk factors for suicide. Her cell is searched multiple times a day and she has been forced to undergo numerous body scans. In addition, Ms. Maxwell's access to the standard prison resources available to other pretrial detainees in the general population has been extensively curtailed or eliminated altogether. + +This treatment threatens Ms. Maxwell's Sixth Amendment right to participate in her defense. This case will require time-consuming review of voluminous discovery materials. Ms. Maxwell must therefore have adequate time to review the materials, to confidentially take notes on them, and to discuss them with her attorneys. But there currently is no such structure in place. Indeed, although the government agreed that Ms. Maxwell would have access to a hard drive containing the discovery in the MDC, it is our understanding that the hard drive containing the first production has not yet been made available to Ms. Maxwell. + +Defense counsel understands that the BOP has proposed (but not yet implemented) a procedure that would permit Ms. Maxwell to use a computer on her floor to review discovery materials during the three-hour period each day that she is not confined to her cell. But there are two significant flaws in this proposal: + +- The three-hour period is specifically designated to be used by Ms. Maxwell for recreation, exercise, and personal hygiene, including showers. The BOP should not be permitted to force Ms. Maxwell to choose between maintenance of her physical and mental health and participating in her own defense. +- Even if Ms. Maxwell were to forgo personal maintenance altogether, three hours a day is on its face an insufficient amount of time for reviewing documents in a complex case with voluminous document discovery, such as this one. As an illustration, the government's first set of production materials consists of nearly 13,000 pages of documents. Assuming it takes Ms. Maxwell an average of one minute to review each page of those materials, based on the GOP's proposed cap of three hours per day of review, Ms. Maxwell would conceivably finish reviewing this first set of documents at the earliest by mid-November 2020. This is entirely unworkable under the schedule set by the Court. + +Ms. Maxwell does not seek special treatment at the MDC; but she does ask that she not be specially disfavored in her treatment in detention, especially when it comes to preparing her defense to conduct that allegedly took place over 25 years ago. In light of the voluminous discovery that we expect to receive, Ms. Maxwell would normally be spending 40 hours a week or more reviewing the discovery. Ms. Maxwell should be granted a comparable amount of time + +to review the discovery in the MDC so that she can engage in her defense full-time. We therefore request that Ms. Maxwell: + +- Be released to the general population and be granted the privileges given to other pretrial detainees. +- Be given significantly increased access to a computer terminal in order to review the discovery in this case. + +For the reasons set forth above, we respectfully submit that the Court should grant Ms. Maxwell's motion. + +Respectfully submitted, + +/s/ Christian R. Everdell + +Mark S. Cohen + +Christian R. 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They are from someone named in Australia. She knows to call by name. She is talking about crimes committed against her. She claims to be a prisoner. She references Lisa Marie Presley, the British Royal Family, President Trump, and Jeffrey Epstein. We are passing these along to you for review and follow up if appropriate or nothing if not. We will be blocking the number from calling again and otherwise doing nothing further on our end because the caller is from a foreign country and because of international comity, we can't respond. Let me know if you have any questions. + +From: Sent: Sunday, August 9, 2020 7:44 PM To: >; Subject: Voicemails + +The attached are 3 voicemails that received this morning at 9:22, 9:26, and 9:54 respectively. + +They are from someone named in Australia. She knows to call by name. She is talking about crimes committed against her. She claims to be a prisoner. She references Lisa Marie Presley, the British Royal Family, President Trump, and Jeffrey Epstein. + +Let me know what other actions I should take. + +Thank you! + +Special Assistant to the U.S. Attorney United States Attorney's Office, SDNY \ No newline at end of file diff --git a/marker2/ds9/EFTA00085093/EFTA00085093.metadata.json b/marker2/ds9/EFTA00085093/EFTA00085093.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..89134c8a37b1756bcf139f41f18bd472acc3938f --- /dev/null +++ b/marker2/ds9/EFTA00085093/EFTA00085093.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085093.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1591, + "elapsed_seconds": 0.7, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00085093" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085094/EFTA00085094.md b/marker2/ds9/EFTA00085094/EFTA00085094.md new file mode 100644 index 0000000000000000000000000000000000000000..052c289c6fca2f9e96002963f9cab177d0947f39 --- /dev/null +++ b/marker2/ds9/EFTA00085094/EFTA00085094.md @@ -0,0 +1,25 @@ +From: " )" To: ' ]"<1 Subject: Re: bank records Date: Mon, 01 Jun 2020 18:59:21 +0000 + +Thank you! + +Sent from my iPhone + +On Jun 1, 2020, at 2:05 PM, wrote: + +Definitely. I will be able to handle this. + +From: Sent: Monday, June 1, 202011:12 AM To: Subject: bank records + +Hi M, + +For the Epstein case, are you able to assist with getting a copy of some recent bank subpoena returns to our case agent, ? We were hoping to leave a copy for her downstairs at 1 Saint Andrews sometime this week. I'm not sure who might be in the office to handle this, but if you could possibly coordinate that, it would be extremely helpful. + +Thanks! + +The returns are saved here: + +investigation \Subpoena Returns \FirstBank Puerto Rico 2018 SDNY + +Much appreciated— + +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/EFTA00085094/EFTA00085094.metadata.json b/marker2/ds9/EFTA00085094/EFTA00085094.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4971e808269da0294a83a24f373780a086b6e0d7 --- /dev/null +++ b/marker2/ds9/EFTA00085094/EFTA00085094.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085094.pdf", + "engine": { + "marker_major": "2", + "marker_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": 847, + "elapsed_seconds": 0.79, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 27 + ], + [ + "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/EFTA00085094" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085095/EFTA00085095.md b/marker2/ds9/EFTA00085095/EFTA00085095.md new file mode 100644 index 0000000000000000000000000000000000000000..56a6927fa1ad3f4745df7d0ca73304084e657299 --- /dev/null +++ b/marker2/ds9/EFTA00085095/EFTA00085095.md @@ -0,0 +1,29 @@ +To: + +Subject: RE: bank records + +Date: Mon, 01 Jun 2020 18:05:36 +0000 + +Definitely. I will be able to handle this. + +From: + +Sent: Monday, June 1, 202011:12 AM + +To: + +Subject: bank records + +Hi + +For the Epstein case, are you able to assist with getting a copy of some recent bank subpoena returns to our case agent, ? We were hoping to leave a copy for her downstairs at 1 Saint Andrews sometime this week. I'm not sure who might be in the office to handle this, but if you could possibly coordinate that, it would be extremely helpful. + +Thanks! + +The returns are saved here: + +FirstBank Puerto Rico + +Much appreciated— + +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/EFTA00085095/EFTA00085095.metadata.json b/marker2/ds9/EFTA00085095/EFTA00085095.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cc7280213ef98d02db8522c0a201d7912b7cd2ea --- /dev/null +++ b/marker2/ds9/EFTA00085095/EFTA00085095.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085095.pdf", + "engine": { + "marker_major": "2", + "marker_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": 719, + "elapsed_seconds": 0.82, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 44 + ], + [ + "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/EFTA00085095" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085096/EFTA00085096.md b/marker2/ds9/EFTA00085096/EFTA00085096.md new file mode 100644 index 0000000000000000000000000000000000000000..8b1687bff853b9c8bbfd90202373c77d92ef8b19 --- /dev/null +++ b/marker2/ds9/EFTA00085096/EFTA00085096.md @@ -0,0 +1,39 @@ +From: ' ‹I To: ' Subject: Re: bank records Date: Mon, 01 Jun 2020 20:32:24 +0000 + +Perfect, thanks! + +Sent from my iPhone + +On Jun 1, 2020, at 4:25 PM, wrote: + +The files were able to be loaded to USAfx. I am going to share them with and let her know that they are uploaded. + +From: Sent: Monday, June 1, 2020 3:00 PM To: Subject: Re: bank records + +Just these ones, thanks. + +Sent from my iPhone + +On Jun 1, 2020, at 2:08 PM, > wrote: + +Are we planning to leave just these FirstBank Puerto Rico records or are there other bank records that we want to leave? + +From: Sent: Monday, June 1, 202011:12 AM To: Subject: bank records + +Hi M, + +For the Epstein case, are you able to assist with getting a copy of some recent bank subpoena returns to our case agent, ? We were hoping to leave a copy for her downstairs at 1 Saint Andrews sometime this week. I'm not sure who might be in the office to handle this, but if you could possibly coordinate that, it would be extremely helpful. + +Thanks! + +The returns are saved here: + +2018 SDNY investigation \Subpoena Returns \FirstBank Puerto Rico + +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/EFTA00085096/EFTA00085096.metadata.json b/marker2/ds9/EFTA00085096/EFTA00085096.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..081d21d69459a8ad99c8575cb007b9aa94ba6994 --- /dev/null +++ b/marker2/ds9/EFTA00085096/EFTA00085096.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085096.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1182, + "elapsed_seconds": 0.9, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 33 + ], + [ + "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", + 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/EFTA00085096" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085098/EFTA00085098.md b/marker2/ds9/EFTA00085098/EFTA00085098.md new file mode 100644 index 0000000000000000000000000000000000000000..96e92e320687ab0a816e10681f504cb68dfd8410 --- /dev/null +++ b/marker2/ds9/EFTA00085098/EFTA00085098.md @@ -0,0 +1,472 @@ +2019WL 2814839 + +Only the Westlaw citation is currently available. + +United States Court of Appeals, Second Circuit. + +Julie BROWN, Miami Herald Company, Intervenors-Appellants, + +v. + +Ghislaine MAXWELL, Defendant-Appellee, + +v. + +MM. Plaintiff-Appellee. + +. r owitz, Michael Cernovich, dba Cernovich Media, Intervenors-Appellants, + +v. + +Plaintiff-Appellee, + +v. + +Ghislaine Maxwell, Defendant-Appellee: + +The Clerk of Court is directed to amend the captions as set out above. + +No. 18-2868-cv, No. 16-3945-cvn No. 17-1625 (CON), No. 17-1722(CON) + +August Term 2018 + +Argued: March 6, 2019 + +Decided: July 3, 2019 + +# Synopsis + +Background: Alleged sexual abuse victim filed defamation action against alleged abuser. After suit settled, another alleged abuser, journalist and newspaper moved to intervene and to unseal documents. The United States District Court for the Southern District of New York, Robert W. Sweet, J., 2017 WL 1787934, 325 F.Supp.3d 428, granted motions to intervene, but denied requests to unseal. Intervenors appealed. + +Holdings: The Court of Appeals, Jose A. Cabranes, Circuit Judge, held that: + +['l district court was required to review documents individually and produce specific, on-the-record findings, and + +[21 district court abused its discretion in denying motion to unseal filings related to discovery motions. + +Pooler, Circuit Judge, dissented in part and filed opinion. + +West Headnotes (20) + +# I I Records + +ti-Court records + +When reviewing district court's decision to seal filing or maintain such seal, Court of Appeals examines court's factual findings for clear error, its legal determinations de novo, and its ultimate decision to seal or unseal for abuse of discretion. + +Cases that cite this headnote + +### Records + +### o-Court records + +## 121 Records + +## a-Court records + +Documents submitted to court for its consideration in summary judgment motion are—as matter of law—judicial documents to which strong presumption of access attaches, under both common law and First Amendment. U.S. Const. Amend. 1. + +1 Cases that cite this headnote + +# 131 Constitutional Law + +## a-Court documents or records + +In light of strong First Amendment presumption of public access to judicial records, continued sealing of documents may be justified only with specific, on-the-record findings that sealing is necessary to preserve higher values and only if sealing order is narrowly tailored to achieve that aim. U.S. Const. Amend. 1. + +3 Cases that cite this headnote + +# Hi Constitutional Law + +## a-Court documents or records + +Countervailing values that may overcome First Amendment presumption of public access to judicial records include, depending on circumstances, preserving accused's right to fundamental fairness in jury selection process, protection of attorney-client privilege, danger of impairing law enforcement or judicial efficiency, and privacy interest of those who resist disclosure. U.S. Const. Amend. 1. + +Cases that cite this headnote + +# 151 Records + +## a-Court records + +Presumption of public access that attaches to documents filed in connection with summary judgment motions is not diminished by fact that motion is denied. + +1 Cases that cite this headnote + +# 161 Records + +# ots-Court records + +On motion to unseal documents filed in defamation action, district court was required to review documents individually and produce specific, on-the-record findings that sealing was necessary to preserve higher values. + +2 Cases that cite this headnote + +## lin Records + +o—Court records + +Mere filing of paper or document with court is insufficient to render that paper "judicial document" subject to right of public access; instead, item filed must be relevant to performance of judicial function and useful in judicial process in order for it to be designated judicial document. + +1 Cases that cite this headnote + +## PH Records + +o-Court records + +Document is relevant to performance of judicial function, and thus is "judicial document" to which presumption of public access attaches, if it would reasonably have tendency to influence district court's ruling on motion or in exercise of its supervisory powers, without regard to which way court ultimately rules 191 + +1101 + +or whether document ultimately in fact influences court's decision. + +Cases that cite this headnote + +## Records + +o-Court records + +If court determines that documents filed by party are not relevant to performance of judicial function, no presumption of public access attaches. + +Cases that cite this headnote + +# Records + +o-Court records + +Once item is deemed relevant to exercise of judicial power, weight to be given presumption of public access must be governed by role of material at issue in exercise of Article III judicial power and resultant value of such information to those monitoring federal courts. U.S. Const. art. 3, § 1 et seq. + +Cases that cite this headnote + +#### [12] Records + +#### 1131 Records + +# Records + +## s-Court records + +While evidence introduced at trial or in connection with summary judgment enjoys strong presumption of public access, documents that play only negligible role in performance of Article III duties are accorded only low presumption that amounts to little more than prediction of public access absent countervailing reason. U.S. Const. art. 3, § 1 et seq. + +Cases that cite this headnote + +## v-Court records + +Documents that are never filed with court, but simply passed between parties in discovery, lie entirely beyond reach of presumption of public access accorded to judicial documents. + +Cases that cite this headnote + +## 4-Court records + +All documents submitted to court in connection with, and relevant to, judicial decision-making are subject + +#### nil Records + +to at least some presumption of public access. + +Cases that cite this headnote + +## -Court records + +Presumption of public access in filings submitted in connection with discovery disputes or motions in limine is generally somewhat lower than presumption applied to material introduced at trial, or in connection with dispositive motions such as motions for dismissal or summary judgment, and thus, while court must still articulate specific and substantial reasons for sealing such material, reasons usually need not be as compelling as those required to seal summary judgment filings. + +Cases that cite this headnote + +# 1151 Records + +# 4-Court records + +District court abused its discretion in denying motion to unseal filings related to motions to compel testimony, to quash trial subpoenae, and to exclude certain deposition testimony in defamation action on ground that privacy interests outweighed presumption of public access, even if court did not rely on materials in adjudicating motions, where court did not conduct individualized review of sealed materials to determine whether presumption of public access outweighed any countervailing privacy interests. + +Cases that cite this headnote + +# 1161 Courts + +4—Making and custody + +Every court has supervisory power over its own records and files to ensure they are not used to gratify private spite or promote public scandal or serve as reservoirs of libelous statements for press consumption. + +Cases that cite this headnote + +# 1111 Records + +4-Court records + +Because material that is rejected or stricken by district court as redundant, immaterial, impertinent, or scandalous is not relevant to performance of judicial function, it is not considered "judicial document" and enjoys no + +#### Its' Federal Civil Procedure + +#### 1191 Libel and Slander + +presumption of public access. Fed. R. Civ. P. 12(4 + +Cases that cite this headnote + +4-Impertinent or scandalous matter + +Although motions to strike material solely on ground that matter is impertinent and immaterial are disfavored, when material is also scandalous, no such presumption applies. Fed. R. Civ. P. 12(0. + +Cases that cite this headnote + +4—.Judicial Proceedings + +Under New York law, absolute immunity from liability for defamation exists for oral or written statements made in connection with proceeding before court. + +Cases that cite this headnote + +# 1201Libel and Slander + +6—Exceeding privilege or right Libel and Slander + +6-Statements made in judicial and official proceedings + +Under New York law, immaterial and impertinent statements in court filings are—at least nominally—actionable, particularly when they are so needlessly defamatory as to warrant inference of express malice. + +Cases that cite this headnote + +On Appeal from the United States District Court for the Southern District of New York (Robert W. Sweet, Judge). + +## Attorneys and Law Firms + +Sanford L. Bohrer (Christine N. Walz, Madelaine J. Harrington, New York, NY, on the brief), Holland & Knight LLP, Miami, FL, for Intervenors-Appellants Julie Brown and Miami Herald. + +Ty Gee (Adam Mueller, on the brief), Haddon, Morgan and Foreman, P.C., Denver, CO, for Defendant-Appellee Ghislaine Maxwell. + +Paul G. Cassell (Sigrid S. McCawley, Boies Schiller Flexner LLP, Ft. Lauderdale, FL, on the brief), S.J Quinney College of Law, University of Uta • T, for Plaintiff-Appellee + +Andrew G. Celli Jr. (David A. Lebowitz, on the brief), Emery, Celli, Brinckerhoff & Abady LLP, New York, NY, for Intervenor-Appellant Alan M. Dershowitz. + +Marc Randazza (Jay Marshall Wolman, Las Vegas, NV, on the brief), Randazza Legal Group, PLLC, Hartford, CT, for Intervenor-Appellant Michael Cernovich. + +Before: CABRANES, POOLER, and DRONEY, Circuit Judges. + +# Opinion + +Jose A. Cabranes, Circuit Judge: + +\*1 Intervenors-Appellants Alan M. Dershowitz ("Dershowitz"), Michael Cernovich ("Cernovich"), and the Miami Herald Company (with reporter Julie Brown, jointly the "Herald") appeal from certain orders of the United States District Court for the Southern District of New York (Robert W. Sweet, Judge) denying their respective motions to unseal filings in a defamation suit. We conclude that the District Court failed to conduct the requisite particularized review when ordering the sealing of the materials at issue. At the same time, we recognize the potential damage to privacy and reputation that may accompany public disclosure of hard-fought, sensitive litigation. We therefore clarify the legal tools that district courts should use in safeguarding the integrity of their dockets. Accordingly, we VACATE the District Court's orders entered on November 2, 2016, May 3, 2017, and August 27, 2018, ORDER the unsealing of the summary judgment record as described further herein, and REMAND the cause to the District Court for particularized review of the remaining sealed materials. + +## I. BACKGROUND + +## A. Jeffrey Epstein's Conviction and the CVRA Suit + +The origins of this case lie in a decade-old criminal proceeding against financier Jeffrey Epstein ("Epstein"). On June 30, 2008, Epstein pleaded guilty to Florida state charges of soliciting, and procuring a person under the age of eighteen for, prostitution. The charges stemmed from sexual activity with privately hired "masseuses," some of whom were under eighteen, Florida's age of consent. Pursuant to an agreement with state and federal prosecutors, Epstein pleaded to the state charges. He received limited jail-time, registered as a sex offender, and agreed to pay compensation to his victims. In return, prosecutors declined to bring federal charges. + +Shortly after Epstein entered his plea, two of his victims, proceeding as "Jane Doe 1" and "Jane Doe 2," filed suit against the Government in the Southern District of Florida under the Crime Victims' Rights Act ("CVRA"). The victims sought to nullify the plea agreement, alleging that the Government failed to fulfill its legal obligations to inform and consult with them in the process leading up to Epstein's plea deal.' + +On December 30, 2014, two additional unnamed victims—one of whom has now self-identified as Plaintiff-Appellee petitioned to join in t e case. ese petitioners included in their filings not only descriptions of sexual abuse by Epstein, but also new allegations of sexual abuse by several other prominent individuals, "including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders," as well as Dershowitz (a long-time member of the Harvard Law School faculty who had worked on Epstein's legal defense) and Defendant-Appellee Ghislaine Maxwell ("Maxwell").2 + +On February 21, 2019, the Florida District Court ruled that federal prosecutors had violated the CVRA by failing to adequately notify the two victims-plaintiffs of the plea deal. The District Court has not yet determined the appropriate remedy. See Doe 1 v. United States, 359 F. Supp. 3d 1201, 1204-17 (S.D. Fla. 2019). + +2 Doe I v. United States, No. 08-CV-80736-1CAM, 2015 WL 11254692, at "2 (S.D. Fla. Apr. 7, 2015) (internal quotation marks omitted). + +\*2 Dershowitz moved to intervene, seeking to "strike the outrageous and impertinent allegations made against him and to request a show cause order to the attorneys that have made them."3 Exercising its authority to "strike from a pleading an insufficient defense or any redundant, immaterial, impertinent, or scandalous matter ... on its own,"" the Florida District Court (Kenneth A. Marra, Judge) sua sponte struck all allegations against additional parties from the pleadings, including those against Dershowitz, and therefore denied Dershowitz's motion as moots + +3 Id. (internal quotation marks and brackets omitted). 4 Fed. R. Civ. P. 12(0. 5 Doe I, 2015 WL 11254692, at "2-3. + +The stricken allegations, however, quickly found their way into the press, and several m is utlets published articles repeating accusations. In response to the allegations, on January 3, 2015, Maxwell's publiSid a press statement declaring that allegations "against Ghislaine Maxwell are untrue" and that her "claims are obvious lies."6 + +6 SeMIEv. Maxwell, 325 F. Supp. 3d 428, 434 (S.D.N.Y. 2018). + +BM Sues Maxwell On September 21, 2015, filed the underlying action against Maxwell in the Southern District of New York. alleged that Maxwell had defamed her through this and other public statements. Extensive and hard-fought discovery followed. Due to the volume of sealing requests filed during discovery, on August 9, 2016, the District Court entered a Sealing Order that effectively ceded control of the sealing process to the parties themselves. The Sealing Order disposed of the requirement that the parties file individual letter briefs to request sealing and prospectively granted all of the parties' future sealing requests. In total, 167 documents—nearly one-fifth of the docket—were filed under seal. These sealed documents include, inter alia, motions to compel discovery, motions for sanctions and adverse inferences, motions in limine, and similar material. + +On January 6, 2017, Maxwell filed a motion for summary judgment. The parties submitted their memoranda of law and supporting exhibits contesting this motion under seal. On March 22, 2017, the District Court denied the motion in a heavily redacted 76-page opinion. Once again, the entire summary judgment record, including the unredacted version of the District Court opinion denying summary judgment, remained under seal. On May 24, 2017, Maxwell and executed a settlement agreement, and the case was closed the next day. + +C. Motions to Intervene and Unseal Over the course of the litigation before Judge Sweet, three outside parties attempted to unseal some or all of the sealed material. On August 11, 2016, Dershowitz moved to intervene, seeking to unseal three do l. that, he argues, demonstrate that invented the accusations against him. On January 19, 2017, Cernovich, an independent blogger and self-described "popular political journalist,"7 moved to intervene, seeking to unseal the summary judgment record, and Dershowitz joined his motion. On April 6, 2018, after the case had + +settled, the Herald moved to intervene and unseal the entire docket. The District Court granted each of these motions to intervene, but denied the related requests to unseal in orders entered November 2, 2016, May 3, 2017, and August 27, 2018, respectively. + +7 Br. Appellant (Cemovich) 4. + +The Appellants timely appealed from each of the orders denying their respective motions to unseal. Although each Appellant seeks the release of a different set of documents, all argue that the District Court failed to analyze the documents individually or properly apply the presumption of public access to court documents. We therefore ordered that the appeals be heard in tandem and held argument on March 6, 2019. + +\*3 On March 11, 2019, we issued an order to show cause why we "should not unseal the summary judgment motion, including any materials filed in connection with this motion, and the District Court's summary judgment decision."s The parties timely filed their responses. + +8 v. Maxwell, No. 18-2868-cv, Docket No. 138. + +# II. DISCUSSION + +There are two categories of sealed material at issue in these appeals: (1) the summary judgment record, which includes the parties' summary judgment briefs, their statements of undisputed facts, and incorporated exhibits; and (2) court filings made in the course of the discovery process and with respect to motions in limine. In this Opinion, we explain that our law requires the unsealing of the summary judgment materials and individualized review of the remaining sealed materials. + +While the law governing public access to these materials is largely settled, we have not yet adequately addressed the potential harms that often accompany such access. These harms are apparent. Over forty years ago, the Supreme Court observed that, without vigilance, courts' files might "become a vehicle for improper purposes."9 Our legal process is already susceptible to abuse. Unscrupulous litigants can weaponize the discovery process to humiliate and embarrass their adversaries. Shielded by the "litigation privilege,"I0 bad actors can defame opponents in court pleadings or depositions without fear of lawsuit and liability. Unfortunately, the presumption of public access to court documents has the potential to exacerbate these harms to privacy and reputation by ensuring that damaging material irrevocably enters the public record. + +9 Nixon v. Inisner Commc'ns, Inc., 435 U.S. 589, 598, 98 S.Ct. 1306, 55 L.Ed.2d 570 (1978). + +10 See notes 46-47 and accompanying text, post. + +We therefore take the opportunity to describe the tools available to district courts in protecting the integrity of the judicial process, and emphasize the courts' responsibility to exercise these powerful tools. We also caution the public to critically assess allegations contained in judicial pleadings. + +## A. Standard of Review + +111When reviewing a district court's decision to seal a filing or maintain such a seal, "we examine the court's factual findings for clear error, its legal determinations de novo, and its ultimate decision to seal or unseal for abuse of discretion."11 + +I I Bernstein v. Bernstein Dimwits Berger & Grossmann LLP, 814 F.3d 132, 139 (2c1Cir. 2016). + +# B. The Summary Judgment Materials + +121 131 I4IWith respect to the first category of materials, it is well-settled that "documents submitted to a court for its consideration in a summary judgment motion are—as a matter of law—judicial documents to which a strong presumption of access attaches, under both the common law and the First Amendment."12 In light of this strong First Amendment presumption, "continued sealing of the documents may be justified only with specific, on-the-record findings that sealing is necessary to preserve higher values and only if the sealing order is narrowly tailored to achieve that aim."I3 + +12 Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 121 (2d Cir. 2006). We observe that our holding in Lugosch relies on the general principle that parties may "be assumed to have supported their papers with admissible evidence and non-frivolous arguments." Id. at 122. Insofar as a district court has, through striking a + +filing, specifically found that assumption inapplicable, the categorical rule in Lugosch may not apply. See notes 42-43 and accompanying text, post. + +13 Id. at 124. Examples of such countervailing values may include, depending on the circumstances, preserving "the right of an accused to fundamental fairness in the jury selection process," Press-Enter. Co. v. Superior Court of California. Riverside Cry., 464 U.S. 501, 510, 104 S.Ct. 819, 78 L.Ed.2d 629 (1984); the protection of attorney-client privilege, Lugosch, 435 F.3d at 125; "the danger of impairing law enforcement or judicial efficiency," SEC. v. TheStreet.Com, 273 F.3d 222, 232 (2d Cir. 2001); and "the privacy interest of those who resist disclosure," id. + +\*4 151In this case, the District Court erred in several respects.14 First, it failed to give proper weight to the presumption of access that attaches to documents filed in connection with summary judgment motions. The District Court reasoned that the summary judgment materials were "entitled to a lesser presumption of access" because "summary judgment was denied by the Court."Is In assigning a "lesser presumption" to such materials, the District Court relied on a single sentence of dicta from our decision in United States v. Amodeois We have since clarified, however, that this sentence was based on a "quotation from a partial concurrence and partial dissent in the D.C. Circuit ... [and] is thus not the considered decision of either this court or the D.C. Circuit."17 In fact, we have expressly rejected the proposition that "different types of documents might receive different weights of presumption based on the extent to which they were relied upon in resolving [a] motion [for summary judgment]."ig + +14 Our discussion here focuses specifically on the District Court's denial of the Herald's motion to unseal the entire record. Because this decision grants relief to all + +IS 25 F. Supp. 3d at 444. 16 71 F.3d 1044, 1049 (2d Cir. 1995)("Amodeo If') ("One judge [in the District of Columbia Circuit] has pointed out, for example, that where a district court denied the summary judgment motion, essentially postponing a final determination of substantive legal rights, the public interest in access is not as pressing." (internal quotation marks omitted; emphasis in original)). + +Appellants, we need not discuss any separate, additional error in the District Court's denial of the earlier motions to unseal. + +17 Lugosch, 435 F.3d at 121. + +IS Id. at 123. + +161Second, in contravention of our precedent, the District Court failed to review the documents individually and produce "specific, on-the-record findings that sealing is necessary to preserve higher values."i0 Instead, the District Court made generalized statements about the record as a whole.30 This too was legal error. + +19 Id. at 124. + +20 See. e.g., Giuffre, 325 F. Supp. 3d at 445 (summarily concluding that all "[t]he Summary Judgment Judicial Documents openly refer to and discuss these allegations [of sexual assault and sexual trafficking] in comprehensive detail, and that those allegations + +'establish( J a strong privacy interest here')". + +Finally, upon reviewing the summary + +judgment materials in connection with this appeal, we find that there is no countervailing privacy interest sufficient to justify their continued sealing. Remand with respect to these documents is thus unnecessary. Accordingly, and to avoid any further delay,31 we order that the summary judgment documents (with minimal redactions) be unsealed upon issuance of our mandate.22 + +21 Cf. Lugosch, 435 F.3d at 127 (ordering that "the mandate shall issue forthwith" to expedite the unsealing process). + +- 22 Upon issuance of our mandate, a minimally redacted version of the summary judgment record will be made accessible on the Court of Appeals docket. We have implemented minimal redactions to protect personally identifying information such as personal phone numbers, contact lists, birth dates, and social security numbers. We have also redacted the names of alleged minor victims of sexual abuse from deposition testimony and police reports, as well as deposition responses concerning intimate matters where the questions were likely only permitted—and the responses only compelled—because of a strong expectation of continued confidentiality. See Fed. R. + - Civ. P. 5.2. While we appreciate the views expressed in Judge Pooler's separate opinion, the panel majority believes that the efforts invested by three former district judges in reviewing these materials adequately address those concerns. + +## C. The Remaining Sealed Materials + +PiThe law governing disclosure of the remaining sealed material in this case is only slightly more complex. The Supreme Court has recognized a qualified right "to inspect and copy judicial records and documents."23 In defining "judicial records and documents," we have emphasized that "the mere filing of a paper or document with the + +court is insufficient to render that paper a judicial document subject to the right of public access."24 Instead, "the item filed must be relevant to the performance of the judicial function and useful in the judicial process in order for it to be designated a judicial document."28 + +23 Nixon, 435 U.S. at 597-98, 98 S.Ct. 1306. + +24 United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995)("Amodeo 1"). + +25 Id. + +\*5 181 I9IAs our precedent makes clear, a court "perform[s] the judicial function" not only when it rules on motions currently before it, but also when properly exercising its inherent "supervisory powers."26 A document is thus "relevant to the performance of the judicial function" if it would reasonably have the tendency to influence a district court's ruling on a motion or in the exercise of its supervisory powers, without regard to which way the court ultimately rules or whether the document ultimately in fact influences the court's decision.72 Accordingly, if in applying these standards, a court determines that documents filed by a party are not relevant to the performance of a judicial function, no presumption of public access attaches.28 + +26 CI United States v. HSBC Bank USA, N.A., 863 F.3d 125, 135 (2d Cir. 2017) (explaining that, in considering whether the report of a monitor charged with assessing compliance with a deferred prosecution agreement is a judicial document, illy the district court's conception of its supervisory power in this context were correct, the Monitor's Report would quite obviously be relevant to the performance of the judicial function and useful in the judicial process" (internal quotation marks omitted)). Whether a specific judicial decision constitutes a "performance of the judicial function" is a question of law. Accordingly, we review such determinations de novo. Id. at 134. + +27 Amodeo 1, 44 F.3d at 145-46 (concluding that documents were relevant to the performance of a judicial function because they would have "informed" the district court's decision whether to discharge or retain a Receiver); see also FTC. v. Standard Fin. Mgmt. Corp., 830 F.2d 404, 409 (1st Cir. 1987) (citing Federal Rule of Evidence 401's "having any tendency" definition of relevance in determining whether documents were "judicial documents"). + +28 As we explain below, there are several (often preferable) tools beyond sealing that district courts can use to protect their dockets from becoming a vehicle for irrelevant—and potentially defamatory—accusations. See Section D, post. + +1101 1111 11~1Once an item is deemed relevant to the exercise of judicial power, "the weight to be given the presumption of access must be governed by the role of the material at issue in the exercise of Article III judicial power and the resultant value of such information to those monitoring the federal courts."29 Thus, while evidence introduced at trial or in connection with summary judgment enjoys a strong presumption of public access, documents that "play only a negligible role in the performance of Article III duties" are accorded only a low presumption that "amounts to little more than a prediction of public access absent a countervailing reason."30 Documents that are never filed with the court, but simply "passed between the parties in discovery, lie entirely beyond the presumption's reach."3] + +29 Amodeo II, 71 F.3d at 1049. + +30 Id. at 1050. + +31 Id. + +1131The remaining sealed materials at issue here include filings related to, inter alia, motions to compel testimony, to quash trial subpoenae, and to exclude certain deposition testimony. All such motions, at least on their face, call upon the court to exercise its Article III powers. Moreover, erroneous judicial decision-making with respect to such evidentiary and discovery matters can cause substantial harm. Such materials are therefore of value "to those monitoring the federal courts."12 Thus, all documents submitted in connection with, and relevant to, such judicial decision-making are subject to at least some presumption of public access.73 + +32 Id. at 1049. + +33 In previous decisions, we have identified an important exception to this general rule: the presumption of public access does not apply to material that is submitted to the court solely so that the court may decide whether that same material must be disclosed in the discovery process or shielded by a Protective Order. See TheStreaCom, 273 F.3d at 233. + +\*6 1141Although a court's authority to oversee discovery and control the evidence introduced at trial surely constitutes an exercise of judicial power, we note that this authority is ancillary to the court's core role + +in adjudicating a case. Accordingly, the presumption of public access in filings submitted in connection with discovery disputes or motions in limine is generally somewhat lower than the presumption applied to material introduced at trial, or in connection with dispositive motions such as motions for dismissal or summary judgment?' Thus, while a court must still articulate specific and substantial reasons for sealing such material, the reasons usually need not be as compelling as those required to seal summary judgment filings. + +34 Amodeo II, 71 F.3d at 1049-50. + +Here, the precise basis for the District Court's decision to deny the motion to unseal these remaining materials is unclear. In the three paragraphs devoted to the issue, the District Court emphasized the potential for embarrassment "given the highly sensitive nature of the underlying allegations," and concluded that "the documents sealed in the course of discovery were neither relied upon by [the District] Court in the rendering of an adjudication, nor necessary to or helpful in resolving a motion."33 It is therefore unclear whether the District Court held that these materials were not judicial documents (and thus are not subject to a presumption of public access), or found that privacy interests outweighed a limited right of public access. + +35 325 F. Supp. 3d. at 442 (internal quotation marks and brackets omitted). + +1151On either interpretation, however, the District Court's holding was error. Insofar as the District Court held that these materials are not judicial documents because it did not rely on them in adjudicating a motion, this was legal error. As explained above, the proper inquiry is whether the documents are relevant to the performance of the judicial function, not whether they were relied upon.36 Indeed, decision-makers often find that a great deal of relevant material does not ultimately sway their decision. And insofar as the District Court held that privacy interests outweigh the presumption of public access in each of the thousands of pages at issue, that decision—which appears to have been made without particularized review—amounts to an abuse of discretion." + +36 See text accompanying notes 12-18 and 26-28, ante. + +37 See In re City of New York, 607 F.3d 923, 943 n.21 (2d Cir. 2010) (explaining that "abuse of discretion" is a nonpejorative, legal "term of art"). + +In light of the District Court's failure to conduct an individualized review of the sealed materials, it is necessary to do so now. We believe the District Court is best situated to conduct this review. The District Court can directly communicate with the parties, and can therefore more swiftly and thoroughly consider particular objections to unsealing specific materials. Relatedly, the District Court can obtain the parties' assistance in effecting any necessary redactions, and in notifying any outside parties whose privacy interests might be implicated by the unsealing. Accordingly, we remand the cause to the District Court to conduct such a particularized review and unseal all documents for which the presumption of public access outweighs any countervailing privacy interests. + +## EA Protecting the Integrity of Judicial Proceedings + +While we disagree with the District Court's disposition of the motions to unseal, we share its concern that court files might be used to "promote scandal arising out of unproven potentially libelous statements."38 We therefore describe certain methods courts can employ to protect the judicial process from being coopted for such purposes. + +38'25 F. Supp. 3d at 447. + +\*7 1161The Supreme Court has explained that "[e]very court has supervisory power over its own records and files" to ensure they "are not used to gratify private spite or promote public scandal" or "serve as reservoirs of libelous statements for press consumption."39 This supervisory function is not only within a district court's power, but also among its responsibilities. + +39 Nixon. 435 U.S. at 598, 98 S.O. 1306 (internal quotation marks). + +1171 1181In practice, district courts may employ several methods to fulfill this function. They may, for instance, issue protective orders forbidding dissemination of certain material "to protect a party or person from annoyance, embarrassment, oppression, or undue burden" and require that filings containing such material be submitted under seal.49 If parties then seek to file such materials, the court may deny them leave to do so"" District courts may also seek to counteract the effect of defamatory statements by explaining on the record that the statements appear to lack credibility. Moreover, under Federal Rule of Civil Procedure 12(f), the district court may strike such material from the filings on the grounds that it is "redundant, immaterial, impertinent, or scandalous."12 Because such rejected or stricken material is not "relevant to the performance of the judicial function" it would not be considered a "judicial document" and would enjoy no presumption of public access." Finally, in appropriate circumstances, district courts may impose sanctions on attorneys and parties under Federal Rule of Civil Procedure 11(c)." + +40 Fed. R. Civ. P. 26(c); see also TheStreet Com, 273 F.3d at 229-30. + +41 See, e.g., S.D.N.Y. Electronic Case Filing Rules & Instructions, February 1, 2019 Edition, Rule 6.1, http://nysd.uscourts.gov/ecOECF% 20Rules% 20020119% 20Final.pdf. + +42 Fed. R. Civ. P. 12(1). Courts may strike material from the pleadings either "on its own" or "on motion made by a party." Id. Although motions to strike material solely "on the ground that the matter is impertinent and immaterial" are disfavored, when material is also - scandalous," no such presumption applies. CI Lipsky v. Commonwealth United Corp., 551 F.2d 887, 893 (2d Cir. 1976); see also Talbot v. Robert Matthews Distrib. Co., 961 F.2d 654, 664 (7th Cir. 1992) ("Allegations may be stricken as scandalous if the matter bears no possible relation to the controversy or may cause the objecting party prejudice."); Wine Markets Intl, Inc. v. Bass, 177 F.R.D. 128, 133 (E.D.N.Y. 1998) ("Motions to strike are not generally favored, except in relation to scandalous matters."); Alvarado-Morales V. Digital Equip. Corp., 843 F.2d 613, 617-18 (1st Cir. 1988) (categorizing as scandalous "matter which impugned the character of defendants"). + +43 Anuxleo I, 44 F.3d at 145. + +44 In relevant part, Rule II provides: + +By presenting to the court a pleading, written motion, or other paper ... an attorney or unrepresented party certifies that ... it is not being presented for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation .... (Tile court may impose an appropriate sanction on any attomey, law timt, or party that violated the rule or is responsible for the violation .... The sanction may include nonmonetary directives; an order to pay a penalty into court; or, if imposed on motion and warranted for effective deterrence, an order directing payment to the movant of part or all of the reasonable attorney's fees and other expenses directly resulting from the violation. + +Fed. R. Civ. P. II. See also Amodeo II, 71 F.3d at 1049 (describing sanctions available to the court). + +## E. A Cautionary Note + +\*8 We conclude with a note of caution to the public regarding the reliability of court filings such as those unsealed today. + +Materials submitted by parties to a court should be understood for what they are. They do not reflect the court's own findings. Rather, they are prepared by parties seeking to advance their own interests in an adversarial process. Although affidavits and depositions are offered "under penalty of perjury," it is in fact exceedingly rare for anyone to be prosecuted for perjury in a civil proceeding." Similarly, pleadings, complaints, and briefs—while supposedly based on underlying evidentiary material—can be misleading. Such documents sometimes draw dubious inferences from already questionable material or present ambiguous material as definitive. + +45 Sonia Sotomayor & Nicole A. Gordon, Returning Majesty to the Law and Politics: A Modern Approach, 30 Suffolk U. L. Rev. 35, 47 n.52 (1996) ("Perjury cases are not often pursued ...."). + +1191INIMoreover, court filings are, in some respects, particularly susceptible to fraud. For while the threat of defamation actions may deter malicious falsehoods in standard publications, this threat is non-existent with respect to certain court filings. This is so because, under New York law (which governs the underlying defamation claim here), "absolute immunity from liability for defamation exists for oral or written statements made ... in connection with a proceeding before a court."J6 Thus, although the act of filing a document with a court might be thought to lend that document additional credibility, in fact, allegations appearing in such documents might be less credible than those published elsewhere.J9 + +46 Front, Inc. V. Khalil, 24 N.Y.3d 713, 718, 4 N.Y.S.3d 581, 28 N.E.3d 15 (2015); see also Kelly v. Albarino, 485 F.3d 664, 666 (2d Cir. 2007) (adopting the reasoning of the District Court explaining that this privilege is "the broadest of possible privileges"); Restatement (Second) of Torts § 587 (1977) ("A party to a private litigation or a private prosecutor or defendant in a criminal prosecution is absolutely privileged to publish defamatory matter concerning another in communications preliminary to a proposed judicial proceeding, or in the institution of or during the course and as a part of, a judicial proceeding in which he participates, if the matter has some relation to the proceeding."). But see note 47, post. + +47 While common law courts have generally interpreted the litigation privilege broadly, they nevertheless maintain an important (if rarely implemented) limitation on its scope: to qualify for the privilege, a statement must be "material and pertinent to the questions involved." Front, 24 N.Y.3d at 718, 4 N.Y.S.3d 581, 28 N.E.3d IS (quoting Youmans v. Smith, 153 N.Y. 214, 219-20, 47 N.E. 265 (1897)). It follows, then, that immaterial and impertinent statements are (at least nominally) actionable, particularly when they are "so needlessly defamatory as + +to warrant the inference of express malice." Id. (same). It seems to us that when a district court strikes statements from the record pursuant to Fed. R. Civ. P. 12(1) on the ground that the matter is "impertinent" and "immaterial," it makes the very same determination that permits a defamation action under the common law. We think the judicial system would be well served were our common law courts to revitalize this crucial qualification to the litigation privilege. + +\*9 We have long noted that the press plays a vital role in ensuring the public right of access and in enhancing "the quality and safeguards the integrity of the factfinding process."49 When faithfully observing its best traditions, the print and electronic media "contributes to public understanding of the rule of law" and "validates [its] claim of functioning as surrogates for the public."J9 + +48 Westmoreland v. Columbia Broad. Sys., Inc., 752 F.2d 16, 23 (2d Cir. 1984) (quoting Globe Newspaper Co. v. Superior Court for Norfolk Cly., 457 U.S. 596, 606, 102 S.Ct. 2613, 73 L.Ed.2d 248 (1982)). + +49 Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 572-73, 100 S.Q. 2814, 65 L.Ed.2d 973 (1980) (plurality opinion) (internal quotation marks omitted). + +At the same time, the media does the public a profound disservice when it reports on parties' allegations uncritically. We have previously observed that courts cannot possibly "discredit every statement or document turned up in the course of litigation," and we have criticized "the use by the media of the somewhat misleading term `court records' in referring to such items."90 Even ordinarily critical readers may take the reference to "court papers" as some sort of marker of reliability. This would be a mistake. + +50 Amodeo 11, 71 F.3d at 1049. + +51 See note 22, ante. + +We therefore urge the media to exercise restraint in covering potentially defamatory allegations, and we caution the public to read such accounts with discernment. + +# III. CONCLUSION + +To summarize, we hold as follows: + +- (1) Materials submitted in connection with a motion for summary judgment are subject to a strong presumption of public access. +- (2) The summary judgment record at issue will be unsealed upon issuance of our mandate, subject to minimal redactions.g +- (3) Materials submitted in connection with, and relevant to, discovery motions, motions in litnine, and other non-dispositive motions are subject to a lesser—but still substantial—presumption of public access. +- (4) The District Court is directed to review the remaining sealed materials individually and unseal those materials as appropriate. +- (5) District courts should exercise the full range of their substantial powers to ensure their files do not become vehicles for defamation. + +For the foregoing reasons, we VACATE the orders of the District Court entered on November 2, 2016, May 3, 2017, and August 27, 2018, ORDER the unsealing of the summary judgment record as described herein, and REMAND the cause to the District Court for particularized review of the remaining materials. + +In undertaking this task, the District Court may be well-served by ordering the parties to submit to the Court unredacted, electronic copies of the remaining sealed materials, as well as specific, proposed redactions. The District Court may also order the parties to identify and notify additional parties whose privacy interests would likely be implicated by disclosure of these materials. + +In the interests of judicial economy, any future appeal in this matter shall be referred to this panel. + +Pooler, Circuit Judge, dissenting in part: + +I join the Court's opinion in every respect but one: the decision to unseal the summary judgment record ourselves. I agree that all or most of the material must be unsealed. Nevertheless, in my view, the district court is better suited to the task. As the Court's opinion recognizes in connection with the remaining sealed materials, the district court is better positioned to communicate with the parties and any nonparties whose privacy interests might be affected by unsealing. On that score, it is worth clarifying here the breadth of the Court's unsealing order: it unseals nearly 2000 pages of material. The task of identifying and making specific redactions in such a substantial volume is perilous; the consequences of even a seemingly minor error may be grave and are irrevocable. Moreover, although I share the majority's concern about avoiding delay, I would alleviate that concern through other means—perhaps with an order directing the district court to act expeditiously and by making clear what types of limited redactions are and are not appropriate. In sum, I would unseal the district court's summary judgment decision only and leave the remainder of the materials for the district court to review, redact, and unseal on remand. + +# All Citations + +--- F.3d ----, 2019 WL 2814839 \ No newline at end of file diff --git a/marker2/ds9/EFTA00085098/EFTA00085098.metadata.json b/marker2/ds9/EFTA00085098/EFTA00085098.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d457445b0796db98da8b8dd74e7a6034bfaf8c00 --- /dev/null +++ b/marker2/ds9/EFTA00085098/EFTA00085098.metadata.json @@ -0,0 +1,1756 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085098.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 18, + "chars": 44870, + "elapsed_seconds": 3.52, + "image_assets": 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A summary of the key meetings/contacts is below: + +- On July 29th, the team met with Epstein's attorneys, who, in very general terms, discussed the possibility of a resolution and/or the possibility of cooperation. Defense counsel did not make a specific proposal, and they did not indicate in any detail what Epstein's cooperation might consist of, if anything. The team informed defense counsel they were free to re-engage if and when Epstein was prepared to accept responsibility for his conduct. +- On July 31st, the team met with counsel for who was one of Epstein's personal assistants during the period of the charged conduct. lawyers provided an initial attorney proffer, which largely focused on background, as well as her relationship with Epstein which they described as sexually abusive. The attorneys also provided a brief overview of what might say about her role in scheduling massages for Epstein, which was not promising, but the team plans to talk again with counsel for ain Monday, August 5 with a focus on exploring potential cooperation. +- On July 31st, the team met with who was sexually assaulted by Epstein in Florida, New Mexico, and the Virgin Islands in approxir,W04, and when she was 16 and 17 years old. During this time period, Ms. = who was on the verge of homelessness and had nowhere else to go, lived and travelled with Epstein. Ms. reported that Epstein raped her on more than one occasion. Ms. recalled that her travel to Epstein's properties was scheduled by one of Epstein's assistants in New York (whom we believe to be . We have also identified partially nude photographs of Ms. taken when she was approximately 17 from the materials seized from Epstein's New York residence. +- On August 1st, the team met with another New York victim, . Ms. was introduced to Epstein in or about 2004, when she was 16 and working as a model in New York. On multiple occasions, she went to Epstein's Manhattan residence to engage in sexualized massages after which she was paid in cash. During these sessions, Epstein sexually abused her. The abuse escalated over time, and during her last encounter with Epstein, he raped her. Epstein knew her true age, because she told him during their first meeting that she was 16. +- On August 2nd, the team spoke by phone with attorneys in California who contacted our Office and represent two victims, I Both Ms. and Ms. =were recruited to perform "massages" for Epstein in New York in or about 2004, during which they were sexually assaulted, and after which they were paid. 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We wanted to reach out in connection with the Epstein investigation because there are some subpoenas that we served that were returnable to you, but for which we don't have returns. I've listed them below and also attached them for your convenience and reference. + +If you've gotten returns for these, could you please send them to us? And if they're too large to email, our paralegal Will, copied here, can set up a USAFX file-sharing portal for you to just upload them to us. + +And for any that you haven't gotten returns yet, could you please follow up with the subpoena recipient so we make sure we have everything? + +The subpoenas were to: + +- 1) Albany Division of Corporations, dated July 10, 2019 +- 2) USVI (2x), Corporations and Trademarks, dated July 23, 2019 and dated August 7, 2019 +- 3) State of Delaware, Division of Corporations, dated August 9, 2019 + +Please let us know if any questions or issues, and thanks very much. + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00085118/EFTA00085118.metadata.json b/marker2/ds9/EFTA00085118/EFTA00085118.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..eb9aa202b9fe183e70d474023ea2f481a91fec72 --- /dev/null +++ b/marker2/ds9/EFTA00085118/EFTA00085118.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085118.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1809, + "elapsed_seconds": 0.94, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 32 + ], + [ + "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", + 8 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00085118" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085120/EFTA00085120.md b/marker2/ds9/EFTA00085120/EFTA00085120.md new file mode 100644 index 0000000000000000000000000000000000000000..9a2ff9d87dd5fba4f1f6693c00387259a307de0e --- /dev/null +++ b/marker2/ds9/EFTA00085120/EFTA00085120.md @@ -0,0 +1,32 @@ +Declaration of Custodian of Records + +Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare: + +My name is Denise Johannes +(name of declarant) + +I am a United States citizen and I am over eighteen years of age. I am the custodian of records of the business named below, or I am otherwise qualified as a result of my position with the business named below to make this declaration. + +I am in receipt of a Grand Jury Subpoena, dated August 7, 2019, 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 August 13, 2019 +(date) + +![]()Denise Johannes, Director - Corporations & Trademarks +(name and title of declarant) + +Office of the Lieutenant Governor +(name of business) + +5049 Kongens Gade, St. Thomas, VI 00802 +(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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THOMAS, VI 00802** + +**To All To Whom These Presents Shall Come:** + +I, the undersigned, LIEUTENANT GOVERNOR, DO hereby certifies that +**NAUTILUS, INC.** + +**Business Corporation** + +of the Virgin Islands filed in my office on **November 22, 2011** as provided for by law, Articles of Incorporation, duly acknowledged. + +WHEREFORE the persons named in said Articles, and who have signed the same, and their successors, are hereby declared to be from the late aforesaid, a Business Corporation by the name and for the purposes set forth in said Articles, with the right of succession as therein stated. + +![](_page_0_Picture_94.jpeg) + +Witness my hand and the seal of the Government of the Virgin Islands of the United States, at Charlotte Amalie, St. Thomas, this 27th day of December, 2011. + +![]()GREGORY R. FRANCIS +Lieutenant Governor of the Virgin Islands + +### ARTICLES OF INCORPORATION OF NAUTILUS, INC. + +Territory of the U.S. Virgin Islands Creation - Corporation - Domestic 8 Page(s) + +![](_page_1_Picture_2.jpeg) + +We, the undersigned, for the purposes of associating to establish acorporation for the transaction of the business and the promotion and conduct of the objects and purposes hereinafter stated, under the provisions and subject to the requirements of the laws of the Virgin Islands of the United States (hereinafter called the "Virgin Islands'), and particularly the General Corporation Law of the Virgin Islands (Chapter 1, Tide 13, Virgin Islands Code), as the same may be amended from time to time, do make and file these Articles of Incorporation in writing and do certify: + +### ARTICLE I + +The name of the Corporation (hereinafter referred to as the "Corporation") is Nautilus, Inc. + +## ARTICLE U + +The principal office of the Corporation in the Virgin Islands is located at 9100 Havensight, Port of Sale, Suite 15-16, St. Thomas, U.S. Virgin Islands, 00802 and the name of the resident agent of the Corporation is Kellerhals Ferguson LLP, whose mailing address is 9100 Havensight, Port of Sale, Suite 15-16, St. Thomas, US. Virgin Islands 00802, and whose physical address 9100 Havensight, Port of Sale, Suite 15-16, St. Thomas, US. Virgin Islands. + +## ARTICLE III + +Without limiting in any manner the scope and generality of the allowable functions of thlSorporation, it is hereby provided that the Corporation shall have the following purposes, objects and powers: + +- (1) To engage in any lawful business in the United States Virgin Islands. +- (2) To enter into and carry out any contracts for or in relation to the foregoing business with "?itiy person, firm, association, corporation, or government or governmental agency. +- (3) To conduct its business in the United States Virgin Islands and to have offices within the United States Virgin Islands. +- (4) To borrow or raise money to any amount permitted by law by the sale or issuance of obligations of any kind, to guarantee loans, other types of indebtedness and financing obligations, and to secure the foregoing by mortgages or other liens upon any and all of the property of every kind of the Corporation. +- (5) To do all and everything necessary, suitable and proper for the accomplishment of any of the purposes or the attainment of any of the objects or the exercise of any of the powers herein set forth, either alone or in connection with other firms, individuals, associations or corporations in the Virgin Islands and elsewhere in the United States and foreign countries, and to do any other acts or things incidental or appurtenant to or growing out of or connected with the said business, purposes, objects and powers of any part thereof not inconsistent with the laws of the Virgin Islands, and to exercise any and all powers now or hereafter conferred by law on business corporations whether expressly enumerated herein or not. + +The purposes, objects and powers specified in this Article shall not be limited or restricted by reference to the terms of any other subdivision or of any other article of these Articles of Incorporation. + +### ARTICLE IV + +The total number of shares of all classes of stock that the Corporation is authorized to issue is Ten Thousand (10,000) shares of common stock at \$.01 par value; no preferred stock authorized. + +The minimum amount of capital with which the Corporation will commence business is One Thousand Dollars (\$1,000). + +### ARTICLE V + +The names and places of residence of each of the persons forming the Corporation are as follows: + +### NAME ENSIDENCE + +Erika A. Kellerhals Gregory J. Ferguson Brett Geary + +The Corporation is to have perpetual existence. + +### ARTICLE VI + +### ARTICLE VII + +![](_page_2_Picture_8.jpeg) + +For the management of the business and for the conduct of the affairs of the Corporatiorkand in further creation, definition, limitation and regulation of the powers of the Corporation and of its directors and stockholders, it is further provided: + +- (1) The number of directors of the Corporation shall be fixed by, or in the mapper provided in, the by-laws, but in no case shall the number be fewer than three (3). ¶I'he c1iSectors need not be stockholders. +- (2) In furtherance and not in limitation of the powers conferred by the laws of the Virgin Islands, and subject at all times to the provisions thereof, the Board of Directors is expressly authorized and empowered: + - (a) + - (b) To make, adopt and amend the by-laws of the Corporation, subject to the powers of the stockholders to alter, repeal or modify the by-laws adopted by the Board of Directors. To authorize and issue obligations of the Corporation, secured and unsecured, to include therein such provisions as to redeemability, convertibility or otherwise, as the Board of Directors in its sole discretion may determine, and to authorize the mortgaging or pledging of, and to authorize and cause to be executed mortgages and liens upon any property of the Corporation, real or personal, including after acquired property. + - (c) To determine whether any and, if any, what part of the net profits of the Corporation or of its net assets in excess of its capital shall be declared in dividends and paid to the stockholders, and to direct and determine the use and disposition thereof. + +- (d) +- (e) To set apart areserve or reserves, and to abolish such reserve or reserves, or to make such other provisions, if any, as the Board of Directors may deem necessary or advisable for working capital, for additions, improvements and betterments to plant and equipment, for expansion of the business of the Corporation (including the acquisition of real and personal property for this purpose) and for any other purpose of the Corporation. To establish bonus, profit-sharing, pension, thrift and other types of incentive, compensation or retirement plans for the officers and employees (including officers and employees who are also directors) of the Corporation, and to fixthe amount of profits to be distributed or shared or contributed and the amounts of the Corporation's funds or otherwise to be devoted thereto, and to determine the persons to participate in any such plans and the amounts of their respective participations. (0 To issue or grant options for the purchase of shares of stock of the Corporation to officers and employees (including officers and employees who are also directors) of the Corporation and on such terms and conditions as the Board of Directors may from dine to time determine. +- (g) To enter into contracts for the management of the business of the Corporation for terms not exceeding five (5) years. +- (h) To exercise all the powers of the Corporation, except such as are con:Tined by law, or by these Articles of Incorporation or by the by-laws of theccorKtration upon the stockholders. To issue such classes of stock and series within any class of stock with sueh value and voting powers and with such designations, preferences and relative, participating, optional or other special rights, and qualifications, limitations or restrictions thetedf as is stated in the resolution or resolutions providing for the issue of such stock adopted by the Board of Directors and duly filed with the office of the Li. Governor of the Virgin Islands in accordance with Sections 91 and 97, Chapter 13, Virgin Islands Code, as the same may be amended from time to time. + +### ARTICLE VIII + +No stockholder shall sell, convey, assign or otherwise transfer any of his or her shares of stock without first offering the same to the Corporation at the lowest price at which the stockholder is willing to dispose of the same; and the Corporation shall have thirty (30) days within which to accept same; the Corporation shall notify the stockholder of its election in writing. If accepted by the Corporation, the stockholder shall promptly assign the shares of stock to the Corporation, and the Corporation shall promptly pay therefor. If the Corporation rejects the offer, then the stockholder shall offer the stock to the remaining stockholders under the same terms as offered to the Corporation; and the remaining stockholders shall have thirty (30) days within which to collectively or individually accept the same in writing. If the remaining stockholders reject the offer, then the stockholder shall have the right to sell the stock at the same or agreater price than that at which it was offered to the Corporation. If the stockholder shall desire to sell the stock at alesser price than that originally quoted to the Corporation, the stockholder must then repeat the process of offering the stock for sale to the Corporation and the stockholders in turn. Shares of stock in this Corporation shall not be transferred or sold until the sale or transfer has been reported to the Board of Directors and approved by them. + +No stockholder shall pledge as collateral for indebtedness any shares of stock without first obtaining the written consent of a majority of the disinterested members of the Board of Directors of the Corporation. + +### ARTICLE IX + +At all elections of directors, each stockholder shall be entitled to as many votes as shall equal the number of votes that (except for such provision as to cumulative voting) the stockholder would be entitled to cast for the election of directors with respect to his or her shares of stock multiplied by the number of directors to be elected. The stockholder may cast all votes for a single director or distribute them among any two or more of them as he or she may see fit. At least ten (10) days notice shall be given, however the shareholders are entitled to waive notice of the meeting as provided by law. Furthermore, the meeting and vote of stockholders may be dispensed with, if all of the stockholders who would have been entitled to vote upon the action if such meeting were held, shall consent in writing to such corporate action being taken. + +### ARTICLE X + +Subject to the provisions of Section 71, Title 13, Virgin Islands Code, the Corporation may enter into contracts or otherwise transact business with one or more of its directors or officers, or with any firm or association of which one or more of its directors or officers are members or employees, or with any other corporation or association of which one or more of its directors or officers are stockholders, directors, officers, or employees, and no such contract or transaction shall be invalidated or in any way affected by the fact that such director or directors or officer or officers have or may have interests therein that are or might be adverse to the interests of the Corporation even though the vote of the director or directors having such adverse interest is necessary to obligate the Corporation on such contract or transaction, provided that in any such case the fact of such interest shall be disclosed or known to the directors or stockholders acting on or in reference to such contract or transaction. No director or directors or officer or officers having such disclosed or known adverse interest shall be liable to the Corporation or to any stockholder or creditor thereof or to any other person for any loss incurred by it under or by reason of any such contract or transaction, nor shall any such director or directors or officer or officers be accountable for any gains or profits realized thereon. The provisions of this Article shall not be construed to invalidate or in any way affect any contract or transaction that would otherwise be valid under law. + +### ARTICLE XI + +(a) The Corporation shall indemnify any person who was or is a party or is threatened to be made a party to any threatened, pending, or completed action, suit, or proceeding, whether civil, criminal, administrative, or investigative (other than an action by or in the right of the Corporation) by reason of the fact that he or she is or was a director, officer, employee, or agent of the Corporation, or is or was serving at the request of the Corporation as a director, officer, employee, or agent of another corporation, partnership, joint venture, trust, or other enterprise, against expenses (including attorney's fees), judgments, fines, and amounts paid in settlement actually and reasonably incurred by him or her in connection with such action, suit, or proceeding if: + +1. (1) he or she acted + 1. (A) in good faith and + 2. (B) in a manner reasonably believed to be in or not opposed to the best interests of the Corporation; and +2. (2) with respect to any criminal action or proceeding, he or she had no reasonable cause to believe his or her conduct was unlawful. + +The termination of any action, suit, or proceeding by judgment order, settlement, conviction, or upon aplea of nolo contendere or its equivalent, shall not, of itself, create apresumption that the person did not act in good faith and in amanner which he or she reasonably believed to be in or not opposed to the best interests of the Corporation and, with respect to any criminal action or proceeding, had reasonable cause to believe that his conduct was unlawful. + +- (b) The Corporation shall indemnify any person who was or is aparty or is threatened to be made aparty to any threatened, pending, or completed action or suit by or in the right of the officer, employee, or agent of the Corporation, or is or was serving at the request of the venture, trust, or other enterprise against expenses (including attorney's fees) actually and reasonably incurred by him or her in connection with the defense or settlement of such action or suit if he or she acted: + +- (1) in good faith; and +- (2) in amanner he or she reasonably believed to be in or not opposed to the best interests of the Corporation. + +However, no indemnification shall be made in respect of any claim, issue, or matter as to which such person shall have been adjudged to be liable for negligence or misconduct in the performance of his or her duty to the Corporation unless and only to the extent that the court in which such action or suit is brought shall determine upon application that, despite the adjudication of liability but in view of all the circumstances of the Can, such person is fairly and reasonably entitled to indemnity for such expenses which the court shall deem proper. + +- (c) To the extent that adirector, officer, employee, or agent of the Corporation has been successful on the merits or otherwise in defense of any action, suit, or proceeding referred to in •,3bpartigraphs (a) and (b), or in defense of any claim, issue, or matter theriri, he or she shall be laden mified - against expenses (including attorneys' fees) actually and reasonably incurred by him or her in connection therewith. +- (d) Any indemnification under subparagraphs (a) and (b) (unless ordered by a court)'illall be made by the Corporation only as authorized in the specific case upon a determination that ho-or she had met the applicable standard of conduct set forth in subparagraphs (a) and (b). Such determination shall be made: + - (1) by the board of directors by a majority vote of aquorum consisting oflireefOrs who were not parties to such action, suit, or proceeding; or + - (2) if such aquorum is not obtainable, or even if obtainable aquorum of disinterested directors so directs, by independent legal counsel in a written opinion; or + - (3) by the stockholders. +- (e) Expenses incurred in defeating a civil or criminal action, suit, or proceeding may be paid by the Corporation in advance of the final disposition of such action, suit, or proceeding as authorized by the board of directors in the specific case upon receipt of an undertaking by or on behalf of the director, officer, employee, or agent to repay such amounts unless it shall ultimately be determined that he or she is entitled to be indemnified by the Corporation as authorized in this article. (0 The indemnification provided by this Article shall not be deemed exclusive of any other tights to which those seeking indemnification may be entitled under any bylaw, agreement, vote of stockholders or disinterested directors, or otherwise, both as to action in his or her official capacity and as to action in another capacity while holding such office, and shall continue as to aperson who has ceased to be a + +director, officer, employee, or agent and shall inure to the benefit of the heirs, executors, and administrators of such person. + +- (g) The Corporation shall have power to purchase and maintain insurance on behalf of any person who is or was a director, officer, employee, or agent of the Corporation, or is or was serving at the request of the Corporation as a director, officer, employee, or agent of another corporation, partnership, joint venture, trust, or other enterprise against any liability asserted against him or her and incurred by him or her in any such capacity, or arising out of his or her status as such, whether or not the Corporation would have the power to indemnify him or her against such liability under the provisions of this Article. + +### ARTICLE XII + +The Corporation reserves the right to amend, alter or repeal any of the provisions of these Articles of Incorporation and to add or insert other provisions authorized by the laws of the Virgin Islands in the manner and at the time prescribed by said laws, and all rights at any time conferred upon the Board of Directors and the stockholders by these Articles of Incorporation are granted subject to the provisions of this Article. + +[NJ + +[signature page follows) + +IN WITNESS WHEREOF, we have hereunto subscribed our names this 21st day of November, 2011. + +[REDACTED] + +Erika A. Kellerhals, Incorporator + +[REDACTED] + +Gregory J. Ferguson, Incorporator + +[REDACTED] + +Brett Geary, Incorporator + +TERRITORY OF THE UNITED STATES VIRGIN ISLANDS ) +DISTRICT OF ST. THOMAS AND ST. JOHN ) + +The foregoing instrument was acknowledged before me this 21st day of November, 2011, by Erika A. Kellerhals, Gregory J. Ferguson, and Brett Geary. + +[REDACTED] + +GINA MARIE BRYAN +NOTARY PUBLIC NP 069-09 +COMMISSION EXPIRES 09/28/2013 +ST. THOMAS/ST. JOHN. USV! + +2011 +LT CON 22 PPT 4 01 +RECEIVED +GOV. OFFICE +APPORTATIONS-STT + +## Consent of Agent for Service of Process + +0 + +This writing witnesseth that the undersigned *Kellerhals Ferguson LLP* having been designated by *Nautilus, Inc.*, as agent of the said company upon whom service of process may be made in all suits arising against the said company in the Courts of the Virgin Islands, do hereby consent to act as such agent and that service of process may be made upon me in accordance with Title 13 of the Virgin Islands Code. + +IN WITNESS WHEREOF, I have hereunto set my signature this 21st day of November, 2011. + +Kellerhals Ferguson LLP + +![](_page_8_Picture_100.jpeg) + +Erika A Kellerhals, Partner + +CORPC +2011 NOV 22 PM 3 59 + +RECEIVED +LT. GOV. OFFICE + +1708016 +1708019 + +300.- + +cl# 1369 + +Subscribed and sworn to before me this 21st day of October, 2011. + +![](_page_8_Picture_108.jpeg) + +Notary Publicin and for the Territory of the United States Virgin Islands +My commission expires: + + GINA MARIE BRYAN + NOTARY PUBLIC NP 069-09 + COMMISSION EXPIRES 09/28/2013 + ST. THOMAS/ST. JOHN, USVI + + +### CERTIFICATE OF CHANGE OF RESIDENT AGENT FOR NAUTILUS, INC. + +The undersigned, being the President and Secretary of Nautilus, Inc., a United States Virgin Islands corporation (the "Corporation"), pursuant to Chapter 1, Tide 13, Section 54 of the Virgin Islands Code, hereby adopt the following resolutions by written consent in lieu of a meeting: + +WHEREAS, the Corporation was duly formed in the United States Virgin Islands on November 22, 2011; and + +WHEREAS, the physical address of the designated office of the Corporation is 9100 Havensight, Port of Sale, Suite 15-16, St. Thomas, U.S. Virgin Islands 00802. The physical address and mailing address of the designated office of the Corporation are the same; and + +WHEREAS, the name and address of the Corporation's current agent for service of process is Kellerhals Ferguson LLP, 9100 Havensight, Port of Sale, Suite 15-16, St. Thomas, U.S. Virgin Islands 00802; and + +WHEREAS, the Corporation desires to change the resident agent for service of process; and + +WHEREAS, the name and address of the new agent for service of process is Business Basics VI, LI.C, 9100 Havensight, Port of Sale, Suite 15-16, St. Thomas, U.S. Virgin Islands 00802. + +NOW THEREFORE BE IT: + +RESOLVED, that the current agent for service of process of the Corporation, Kellerhals Ferguson LIP, hereby resigns as agent for service of process for the Corporation; and it is further + +RESOLVED, that the Corporation hereby appoints, Business Basics VI, LLC, as the lillv agent for c> ;.•cil service of process for the Corporation; and it is further o + +:./7 en I— . • • ri --t, " ... - n irr i (./) -n a 4 v) --I ,—. c, m —4 Cl) + +RESOLVED, that the physical and mailing address for the new agent for service of piacess,g Business Basics VI, LLC, is 9100 Havensight, Port of Sale, Suite 15-16, St. Thomas, U.S. Virgjrfalandc ;:ti 00802. t\_' + +[rignatmn page follows] + +IN WITNESS WHEREOF, as of this 1st day of June, 2012, the undersigned have executed this Resolution for the purpose of giving their consent thereto and approval thereof. + +*Corporate Seal* + +*Nautilus, Inc.* + +Nautilus, Inc. + +![]()Darren Indyke, Secretary + +TERRITORY OF THE UNITED STATES VIRGIN ISLANDS +DISTRICT OF ST. THOMAS & ST. JOHN + +) +)ss: +) + +On this the 1 day of June, 2012, before me [REDACTED] the undersigned, personally appeared Jeffrey E. Epstein and Darren Indyke who acknowledged themselves to be the President and Secretary of Nautilus, Inc., a Virgin Islands Corporation, and as being authorized so red do, executed the foregoing instrument for the purpose therein contained. + +IN WITNESS WHEREOF, I hereto set my hand and official seal. + +![]()Notary Public + +RECEIVED +GOV. OFFICE +PRESIDENT +OFFICIALS +PAGE 13 PM +JUN 13 2012 + +HARRY I. BELLER +Notary Public, State of New York +No. 01BE485924 +Qualified in Rockland County 14 +Commission Expires Feb. 17, 20 - + +![](_page_11_Picture_16.jpeg) + +THE UNITED STATES VIRGIN ISLANDS + OFFICE OF THE LIEUTENANT GOVERNOR + DIVISION OF CORPORATIONS AND TRADEMARKS + +**RESIDENT AGENT FORM + CONSENT OF AGENT FOR SERVICE OF PROCESS** + +This writing witnesseth that I, the undersigned Business Basics VI, LLC + having been designated by Nautilus, Inc. + as resident agent of said company, upon whom service of process may be made in all suits + arising against said company in the Courts of the United States Virgin Islands, do hereby consent + to act as such agent and that service of process may be made upon me in accordance with + Title 13, Virgin Islands Code. + +IN WITNESS WHEREOF, I have hereunto set my signature this 13th day of +September 2012 + +I DECLARE, UNDER PENALTY OF PERJURY, UNDER THE LAWS OF THE UNITED STATES VIRGIN ISLANDS, THAT ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY + ACCOMPANYING DOCUMENTS, ARE TRUE AND CORRECT, WITH FULL KNOWLEDGE THAT ALL STATEMENTS MADE IN THIS APPLICATION ARE SUBJECT TO INVESTIGATION + AND THAT ANY FALSE OR DISHONEST ANSWER TO ANY QUESTION MAY BE GROUNDS FOR DENIAL OR SURREQUENT REVOCATION OF REGISTRATION. + +SIGNATURE OF RESIDENT, AGENT + +| DAYTIME CONTACT NUMBER | [REDACTED] | +|------------------------|----------------------------------------------------------------| +| MAILING ADDRESS | 9100 Havensight, Port of Sale, Ste 15-16, St. Thomas, VI 00802 | +| PHYSICAL ADDRESS | 9100 Havensight, Port of Sale, Ste 15-16, St. Thomas, VI 00802 | +| EMAIL ADDRESS | [REDACTED] | + +RECEIVED + LT. V. OFF. + 3 PP + SEP 12 2012 + +R 201428 + 25.00 + C 1078 + +**NOTARY ACKNOWLEDGEMENT** + +Subscribed and sworn to before me this 18th day of September, 2012 at +St. Thomas + +Brett A. Geary + Notary Public NP-124-11 + St. Thomas / St. John, USVI + My Commission Expires December 21, 2015 + +My Commission Expires + +![](_page_12_Picture_30.jpeg) + +# 300-00 +C# 1060 +Rec# 3881254 + +THE UNITED STATES VIRGIN ISLANDS +OFFICE OF THE LIEUTENANT GOVERNOR +DIVISION OF CORPORATIONS AND TRADEMARKS + +5049 Kongens Gade +Charlotte Amalie, Virgin Islands 00802 +Phone - 340.776.8515 +Fax - 340.776.4612 + +1105 King Street +Christiansted, Virgin Islands 00820 +Phone - 340.773.6449 +Fax - 340.773.0330 + +**FRANCHISE TAX REPORT - DOMESTIC CORPORATION** + +CORPORATE FILINGS AND REQUISITE TAXES ARE DUE, EACH YEAR, ON OR BEFORE JUNE 30th. +AVOID PENALTIES AND INTEREST BY PAYING ON TIME. + +| TODAY'S DATE | 6/30/2018 | +|-----------------------------------|------------| +| TAX CLOSING DATE | 12/31/2017 | +| EMPLOYER IDENTIFICATION NO. (EIN) | [REDACTED] | + +LT. 60V. CORP - STT +JUN 26 2018 +RECEIVED + +SECTION 1 + +| CORPORATION NAME | Nautilus, Inc. | +|-----------------------|------------------------------------------------------------------| +| PHYSICAL ADDRESS | 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 | +| MAILING ADDRESS | 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 | +| DATE OF INCORPORATION | 11/22/2011 | +| NATURE OF BUSINESS | Holding Property for Personal Use | + +SECTION 2 + +| CAPITAL STOCK AUTHORIZED ON LAST FILED REPORT | 10,000 shares of common stock, \$.01 per value | +|-----------------------------------------------|------------------------------------------------| +| CAPITAL STOCK AUTHORIZED ON THIS DATE | 10,000 shares of common stock, \$.01 per value | + +SECTION 3 - PAID-IN CAPITAL STOCK USED IN CONDUCTING BUSINESS + +| A. AS SHOWN ON LAST FILED REPORT | \$1,000 | +|----------------------------------------------------------------|---------| +| B. ADDITIONAL CAPITAL PAID SINCE LAST REPORT | \$ 0 | +| C. SUM OF 'A' AND 'B' ABOVE | \$1,000 | +| D. PAID-IN CAPITAL WITHDRAWN SINCE LAST REPORT | \$ 0 | +| E. PAID-IN CAPITAL STOCK AT DATE OF THIS REPORT | \$1,000 | +| F. HIGHEST TOTAL PAID-IN CAPITAL STOCK DURING REPORTING PERIOD | \$1,000 | + +SECTION 4 - COMPUTATION OF TAX + +| A. AT RATE OF \$1.50 PER THOUSAND (PLEASE ROUND DOWN TO THE NEAREST THOUSAND)
ON HIGHEST TOTAL PAID-IN CAPITAL STOCK AS REPORTED ON LINE 3F ABOVE | \$300.00 | +|------------------------------------------------------------------------------------------------------------------------------------------------------|----------| +| B. TAX DUE (4A OR \$150.00 (WHICHEVER IS GREATER)) | \$300.00 | + +SECTION 5 - PENALTY AND INTEREST FOR LATE PAYMENT + +| A. PENALTY - 20% OR \$50.00 (WHICHEVER IS GREATER) OF 4B | | +|---------------------------------------------------------------------------------------------------------------------------------------------------|--| +| B. INTEREST - 1% COMPOUNDED ANNUALLY FOR EACH MONTH,
OR PART THEREOF, BY WHICH PAYMENT IS DELAYED BEYOND
THE JUNE 30 TH DEADLINE | | +| C. TOTAL PENALTY AND INTEREST | | + +SECTION 6 - TOTAL DUE (TAXES, PENALTY, INTEREST) + +| SUM OF 4B AND 5C | \$300.00 | +|------------------|----------| +|------------------|----------| + +I DECLARE UNDER PENALTY OF PERJURY, UNDER THE LAWS OF THE UNITED STATES VIRGIN ISLANDS, THAT ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE TRUE AND CORRECT, WITH FULL KNOWLEDGE THAT ALL STATEMENTS MADE IN THIS APPLICATION ARE SUBJECT TO INVESTIGATION AND THAT ANY FALSE OR DISHONEST ANSWER TO ANY QUESTION MAY BE GROUNDS FOR DENIAL OR SUBSEQUENT REVOCATION OF REGISTRATION. + +*Jeffrey E. Epstein* 6/20/2018 +DATE + +![](_page_13_Picture_18.jpeg) + +THE UNITED STATES VIRGIN ISLANDS + +OFFICE OF THE LIEUTENANT GOVERNOR +DIVISION OF CORPORATIONS AND TRADEMARKS + +5049 Kongens Gade +Charlotte Amalie, Virgin Islands 00802 +Phone - 340.776.8515 +Fax - 340.776.4612 + +1105 King Street +Christiansted, Virgin Islands 00820 +Phone - 340.773.6449 +Fax - 340.773.0330 + +**ANNUAL REPORT – DOMESTIC AND FOREIGN CORPORATION** + +CORPORATE FILINGS AND REQUISITE TAXES ARE DUE, EACH YEAR, ON OR BEFORE JUNE 30th. AVOID PENALTIES AND INTEREST BY PAYING ON TIME. + +| TODAY'S DATE | TAX CLOSING DATE | EMPLOYER IDENTIFICATION NO. (EIN) | +|--------------|------------------|-----------------------------------| +| 6/30/2018 | 12/31/2017 | [REDACTED] | + +**SECTION 1** + +CORPORATION NAME Nautilus, Inc. +ADDRESS OF MAIN OFFICE 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 +ADDRESS OF PRINCIPLE USVI OFFICE Business Basics VI, LLC, Royal Palms Professional Building 9053 Estate Thomas, Suite 101, St. Thomas, U.S. Virgin Islands 00802 +DATE OF INCORPORATION 11/22/2011 +COUNTRY/STATE OF INCORPORATION U. S. Virgin Islands +AMOUNT OF AUTHORIZED CAPITAL STOCK AT CLOSE OF FISCAL YEAR 10,000 shares of common stock, \$.01 par value +AMOUNT OF PAID-IN CAPITAL CAPITAL AT CLOSE OF FISCAL YEAR \$1,000 +AMOUNT OF CAPITAL USED IN CONDUCTING BUSINESS WITHIN THE USVI DURING THE FISCAL YEAR \$1,000 + +*LT. GOV. CORP. STA +JUN 26 2018 +RECEIVED* + +**SECTION 2** + +NAMES AND ADDRESSES OF ALL DIRECTORS AND OFFICERS OF THE CORPORATION AT THE CLOSE OF FISCAL YEAR AND EXPIRATION DATES OF TERMS OF OFFICE - + +| NAME/TITLE | ADDRESS | TERM EXPIRATION | +|-----------------------------------------------------|---------------------------------------------------|--------------------------------| +| Jeffrey E Epstein, President/Director | 6100 Red Hook Quarter, B3, St. Thomas, USVI 00802 | Serves until successor elected | +| Richard Kahn, Treasurer/Director | [REDACTED], New York, NY 10021 | Serves until successor elected | +| Darren K. Indyke, Vice President/Secretary/Director | [REDACTED], Livingston, NJ 07039 | Serves until successor elected | +| | | | +| | | | + +I DECLARE, UNDER PENALTY OF PERJURY, UNDER THE LAWS OF THE UNITED STATES VIRGIN ISLANDS, THAT ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE TRUE AND CORRECT, WITH FULL KNOWLEDGE THAT ALL STATEMENTS MADE IN THIS APPLICATION ARE SUBJECT TO INVESTIGATION AND THAT ANY FALSE OR DISHONEST ANSWER TO ANY QUESTION MAY BE GROUNDS FOR DENIAL OR SUBSEQUENT REVOCATION OF REGISTRATION. + +TREASURER + +SIGNATURE + +Richard Kahn + +PRINTED FIRST NAME AND LAST NAME + +6/20/2018 +DATE + +PRESIDENT + +SIGNATURE + +6/20/2018 +DATE + +Jeffrey Epstein + +PRINTED FIRST NAME AND LAST NAME + +- • F THE LAST REPORT DOES NOT COVER THE PERIOD IMMEDIATELY PRECEDING THE REPORT PERIOD COVERED BY THIS REPORT, A SUPPLEMENTARY REPORT ON THE SAME MUST BE FILED, BRIDGING THE GAP BETWEEN THE TWO REPORTS, +- • THIS REPORT IS NOT CONSIDERED COMPLETE UNLESS ACCOMPANIED BY A GENERAL BALANCE SHEET AND PROFIT AND LOSS STATEMENT FOR THE LAST FISCAL YEAR, AS REQUIRED BY THE VIRGIN ISLANDS CODE. FINANCIAL STATEMENTS SHOULD BE SIGNED BY AN INDEPENDENT PUBLIC ACCOUNTANT. +- • FOREIGN SALES CORPORATIONS THAT ARE REGISTERED WITH THE SECURITY AND EXCHANGE COMMISSION MUST FRINSH EVIDENCE OF SUCH REGISTRATION AND COMPLY WITH BALANCE SHEET AND PROFIT AND LOSS STATEMENTS. FCSS THAT ARE NOT REGISTERED WITH THE COMMISSION ARE EXEMPT FROM FILING THE GENERAL BALANCE SHEET AND THE PROFIT AND LOSS STATEMENT. + +![](_page_14_Picture_25.jpeg) + +#15000 +Rec#3641570 +C#1057 + +THE UNITED STATES VIRGIN ISLANDS +OFFICE OF THE LIEUTENANT GOVERNOR +DIVISION OF CORPORATIONS AND TRADEMARKS + +5049 Kongens Gade +Charlotte Amalie, Virgin Islands 00802 +Phone - 340.776.8515 +Fax - 340.776.4612 + +1105 King Street +Christiansled, Virgin Islands 00820 +Phone - 340.773.6449 +Fax - 340.773.0330 + +**FRANCHISE TAX REPORT - DOMESTIC CORPORATION** + +CORPORATE FILINGS AND REQUISITE TAXES ARE DUE, EACH YEAR, ON OR BEFORE JUNE 30th. +AVOID PENALTIES AND INTEREST BY PAYING ON TIME. + +| TODAY'S DATE | 6/30/2017 | +|-----------------------------------|------------| +| TAX CLOSING DATE | 12/31/2016 | +| EMPLOYER IDENTIFICATION NO. (EIN) | [REDACTED] | + +SECTION 1 + +| CORPORATION NAME | Nautilus, Inc. | +|-----------------------|------------------------------------------------------------------| +| PHYSICAL ADDRESS | 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 | +| MAILING ADDRESS | 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 | +| DATE OF INCORPORATION | 11/22/2011 | +| NATURE OF BUSINESS | Holding Property for Personal Use | + +2017 +CORPORATIONS - STI +LIEUTENANT GOVERNOR +DIVISION OF CORPORATIONS AND TRADEMARKS +RECEIVED +OFFICE +SIGNED + +SECTION 2 + +| CAPITAL STOCK AUTHORIZED ON LAST FILED REPORT | 10,000 shares of common stock, \$.01 per value | +|-----------------------------------------------|------------------------------------------------| +| CAPITAL STOCK AUTHORIZED ON THIS DATE | 10,000 shares of common stock, \$.01 per value | + +SECTION 3 - PAID-IN CAPITAL STOCK USED IN CONDUCTING BUSINESS + +| A. AS SHOWN ON LAST FILED REPORT | \$1,000 | +|----------------------------------------------------------------|---------| +| B. ADDITIONAL CAPITAL PAID SINCE LAST REPORT | \$ 0 | +| C. SUM OF 'A' AND 'B' ABOVE | \$1,000 | +| D. PAID-IN CAPITAL WITHDRAWN SINCE LAST REPORT | \$ 0 | +| E. PAID-IN CAPITAL STOCK AT DATE OF THIS REPORT | \$1,000 | +| F. HIGHEST TOTAL PAID-IN CAPITAL STOCK DURING REPORTING PERIOD | \$1,000 | + +SECTION 4 - COMPUTATION OF TAX + +| A. AT RATE OF \$1.50 PER THOUSAND (PLEASE ROUND DOWN TO THE NEAREST THOUSAND) | \$150.00 | +|-------------------------------------------------------------------------------|----------| +| ON HIGHEST TOTAL PAID-IN CAPITAL STOCK AS REPORTED ON LINE 3F ABOVE | \$150.00 | +| B. TAX DUE (4A OR \$150.00 (WHICHEVER IS GREATER)) | \$150.00 | + +SECTION 5 - PENALTY AND INTEREST FOR LATE PAYMENT + +| A. PENALTY - 20% OR \$50.00 (WHICHEVER IS GREATER) OF 4B | | +|----------------------------------------------------------|--| +| B. INTEREST - 1% COMPOUNDED ANNUALLY FOR EACH MONTH. | | +| OR PART THEREOF, BY WHICH PAYMENT IS DELAYED BEYOND | | +| THE JUNE 30 th DEADLINE | | +| C. TOTAL PENALTY AND INTEREST | | + +SECTION 6 - TOTAL DUE (TAXES, PENALTY, INTEREST) + +| SUM OF 4B AND 5C | \$150.00 | +|------------------|----------| +|------------------|----------| + +I DECLARE, UNDER PENALTY OF PERJURY, UNDER THE LAWS OF THE UNITED STATES VIRGIN ISLANDS, THAT ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE THE PROPERTY OF THE UNITED STATES VIRGIN ISLANDS, AND THAT ALL STATEMENTS MADE IN THIS APPLICATION ARE SUBJECT TO INVESTIGATION AND THAT ANY FALSE OR DISMONEST ANSWER TO ANY QUESTION MAY BE REVOCATION OF REGISTRATION. + +THE [REDACTED] +SIGNATURE +Richard Kahn +PRINTED FIRST NAME AND LAST NAME + +PRESIDENT +SIGNATURE +Jeffrey E. Epstein +PRINTED FIRST NAME AND LAST NAME + +![](_page_15_Picture_18.jpeg) + +THE UNITED STATES VIRGIN ISLANDS + +OFFICE OF THE LIEUTENANT GOVERNOR +DIVISION OF CORPORATIONS AND TRADEMARKS + +5049 Kongens Grade +Charlotte Amblee, Virgin Islands 00802 +Phone - 340.776.8515 +Fax - 340.776.4612 + +1105 King Street +Christiansled, Virgin Islands 00820 +Phone - 340.773.6449 +Fax - 340.773.0330 + +**ANNUAL REPORT - DOMESTIC AND FOREIGN CORPORATION** + +CORPORATE FILINGS AND REQUISITE TAXES ARE DUE, EACH YEAR, ON OR BEFORE JUNE 30th. AVOID PENALTIES AND INTEREST BY PAYING ON TIME. + +| TODAY'S DATE | TAX CLOSING DATE | EMPLOYER IDENTIFICATION NO. (EIN) | +|--------------|------------------|-----------------------------------| +| 6/30/2017 | 12/31/2016 | [REDACTED] | + +**SECTION 1** + +| CORPORATION NAME | Nautilus, Inc. | +|--------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------| +| ADDRESS OF MAIN OFFICE | 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 | +| ADDRESS OF PRINCIPLE USVI OFFICE | Business Basics VI, LLC Royal Palms Professional Building 9053 Estate Thomas, Suite 101, St. Thomas, U.S. Virgin Islands 00802 | +| DATE OF INCORPORATION | 11/22/2011 | +| COUNTRY/STATE OF INCORPORATION | U. S. Virgin Islands | +| AMOUNT OF AUTHORIZED CAPITAL STOCK AT CLOSE OF FISCAL YEAR | 10,000 shares of common stock, \$.01 par value | +| AMOUNT OF PAID-IN CAPITAL CAPITAL AT CLOSE OF FISCAL YEAR | \$1,000 | +| AMOUNT OF CAPITAL USED IN CONDUCTING BUSINESS WITHIN THE USVI DURING THE FISCAL YEAR | \$1,000 | + + RECEIVED + L. GOV. OFFICE + DIRECTOR + CORPORATIONS-STI + JUN 26 AM 11 34 + + +**SECTION 2** + +NAMES AND ADDRESSES OF ALL DIRECTORS AND OFFICERS OF THE CORPORATION AT THE CLOSE OF FISCAL YEAR AND EXPIRATION DATES OF TERMS OF OFFICE - + +| NAME/TITLE | ADDRESS | TERM EXPIRATION | +|-----------------------------------------------------|---------------------------------------------------|--------------------------------| +| Jeffrey E Epstein, President/Director | 6100 Red Hook Quarter, B3, St. Thomas, USVI 00802 | Serves until successor elected | +| Richard Kahn, Treasurer/Director | [REDACTED], New York, NY 10021 | Serves until successor elected | +| Darren K. Indyke, Vice President/Secretary/Director | [REDACTED], Livingston, NJ 07039 | Serves until successor elected | +| | | | +| | | | + +I DECLARE, UNDER PENALTY OF PERJURY, UNDER THE LAWS OF THE UNITED STATES VIRGIN ISLANDS, THAT ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE TRUE AND CORRECT AND THAT THESE STATEMENTS MADE IN THIS APPLICATION ARE SUBJECT TO INVESTIGATION AND THAT ANY FALSE OR DISCOMPLETE ANSWER TO ANY QUESTION MAY BE REGISTRATION. + +TREASURER +[REDACTED] +SIGNATURE +Richard Kahn +DATE + +PRESIDENT +[Signature] +SIGNATURE +Jeffrey Epstein +DATE + +- • IF THE LAST REPORT DOES NOT COVER THE PERIOD IMMEDIATELY PRECEDING THE REPORT PERIOD COVERED BY THIS REPORT, A SUPPLEMENTARY REPORT ON THE SAME MUST BE FILED, BRIDGING THE GAP BETWEEN THE TWO REPORTS. +- • THIS REPORT IS NOT CONSIDERED COMPLETE UNLESS ACCOMPANIED BY A GENERAL BALANCE SHEET AND PROFIT AND LOSS STATEMENT FOR THE LAST FISCAL YEAR, AS REQUIRED BY THE VIRGIN ISLANDS CODE, FINANCIAL STATEMENTS SHOULD BE SIGNED BY AN INDEPENDENT PUBLIC ACCOUNTANT. +- • FOREIGN SALES CORPORATIONS THAT ARE REGISTERED WITH THE SECURITY AND EXCHANGE COMMISSION MUST FRISH EVIDENCE OF SUCH REGISTRATION AND COMPLY WITH BALANCE SHEET AND PROFIT AND LOSS STATEMENTS. FCSS THAT ARE NOT REGISTERED WITH THE COMMISSION ARE EXEMPT FROM FILING THE GENERAL BALANCE SHEET AND THE PROFIT AND LOSS STATEMENT. + +![](_page_16_Picture_25.jpeg) + +THE UNITED STATES VIRGIN ISLANDS +**OFFICE OF THE LIEUTENANT GOVERNOR** +**DIVISION OF CORPORATIONS AND TRADEMARKS** + +5049 Kongens Gade + Charlotte Amalie, Virgin Islands 00802 + Phone - 340.776.8515 + Fax - 340.776.4612 + +1105 King Street + Christiansted, Virgin Islands 00820 + Phone - 340.773.6449 + Fax - 340.773.0330 + +**FRANCHISE TAX REPORT - DOMESTIC CORPORATION** + +CORPORATE FILINGS AND REQUISITE TAXES ARE DUE, EACH YEAR, ON OR BEFORE JUNE 30th. + AVOID PENALTIES AND INTEREST BY PAYING ON TIME. + +| TODAY'S DATE | 6/30/2016 | +|-----------------------------------|------------| +| TAX CLOSING DATE | 12/31/2015 | +| EMPLOYER IDENTIFICATION NO. (EIN) | [REDACTED] | + +**SECTION 1** + +| CORPORATION NAME | Nautilus, Inc. | +|-----------------------|------------------------------------------------------------------| +| PHYSICAL ADDRESS | 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 | +| MAILING ADDRESS | 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 | +| DATE OF INCORPORATION | 11/22/2011 | +| NATURE OF BUSINESS | Holding Property for Personal Use | + +**SECTION 2** + +CAPITAL STOCK AUTHORIZED ON LAST FILED REPORT + CAPITAL STOCK AUTHORIZED ON THIS DATE + +10,000 shares of common stock, \$0.01 per value + 10,000 shares of common stock, \$0.01 per value + +**SECTION 3 - PAID-IN CAPITAL STOCK USED IN CONDUCTING BUSINESS** + +- A. AS SHOWN ON LAST FILED REPORT +- B. ADDITIONAL CAPITAL PAID SINCE LAST REPORT +- C. SUM OF 'A' AND 'B' ABOVE +- D. PAID-IN CAPITAL WITHDRAWN SINCE LAST REPORT +- E. PAID-IN CAPITAL STOCK AT DATE OF THIS REPORT +- F. HIGHEST TOTAL PAID-IN CAPITAL STOCK DURING REPORTING PERIOD + +| \$1,000 | EXCEIVED | +|---------|----------| +| \$ 0 | OFFICE | +| \$1,000 | | +| \$ 0 | | +| \$1,000 | | +| \$1,000 | | + +**SECTION 4 - COMPUTATION OF TAX** + +- A. AT RATE OF \$1.50 PER THOUSAND (PLEASE ROUND DOWN TO THE NEAREST THOUSAND) + ON HIGHEST TOTAL PAID-IN CAPITAL STOCK AS REPORTED ON LINE 3F ABOVE +- B. TAX DUE (4A OR \$150.00 (WHICHEVER IS GREATER)) + +| \$150.00 | +|----------| +| \$150.00 | + +**SECTION 5 - PENALTY AND INTEREST FOR LATE PAYMENT** + +- A. PENALTY - 20% OR \$50.00 (WHICHEVER IS GREATER) OF 4B +- B. INTEREST - 1% COMPOUNDED ANNUALLY FOR EACH MONTH, OR PART THEREOF, BY WHICH PAYMENT IS DELAYED BEYOND THE JUNE 30th DEADLINE +- C. TOTAL PENALTY AND INTEREST + +**SECTION 6 - TOTAL DUE (TAXES, PENALTY, INTEREST)** + +SUM OF 4B AND 5C + +\$150.00 + +I DECLAR UNDER PENALTY OF PERJURY, UNDER THE LAWS OF THE UNITED STATES VIRGIN ISLANDS, THAT ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE TRUE AND CORRECT THAT ALL STATEMENTS MADE IN THIS APPLICATION ARE SUBJECT TO INVESTIGATION AND THAT ANY FALSE OR DISHONEST ANSWER TO ANY QUESTION MAY BE REVOCATION OF REGISTRATION. + +TRAINER + SIGNATURE + +6/10/2016 + DATE + +PRESIDENT + SIGNATURE + +6/10/16 + DATE + +#150.00- CL#153 - 330/780 + +![](_page_17_Picture_22.jpeg) + +THE UNITED STATES VIRGIN ISLANDS + +OFFICE OF THE LIEUTENANT GOVERNOR +DIVISION OF CORPORATIONS AND TRADEMARKS + +5049 Kongens Gade +Charlotte Amalie, Virgin Islands 00802 +Phone - 340.776.8515 +Fax - 340.776.4612 + +1105 King Street +Christiansted, Virgin Islands 00820 +Phone - 340.773.6449 +Fax - 340.773.0330 + +**ANNUAL REPORT – DOMESTIC AND FOREIGN CORPORATION** + +CORPORATE FILINGS AND REQUISITE TAXES ARE DUE, EACH YEAR, ON OR BEFORE JUNE 30TH. AVOID PENALTIES AND INTEREST BY PAYING ON TIME. + +| TODAY'S DATE | TAX CLOSING DATE | EMPLOYER IDENTIFICATION NO. (EIN) | +|--------------|------------------|-----------------------------------| +| 6/30/2016 | 12/31/2015 | [REDACTED] | + +**SECTION 1** + +CORPORATION NAME Nautilus, Inc. + ADDRESS OF MAIN OFFICE 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 + ADDRESS OF PRINCIPLE USVI OFFICE Business Basics VI, LLC Royal Palms Professional Building 9053 Estate Thomas, Suite 101, St. Thomas, U.S. Virgin Islands 00802 + DATE OF INCORPORATION 11/22/2011 + COUNTRY/STATE OF INCORPORATION U. S. Virgin Islands + AMOUNT OF AUTHORIZED CAPITAL STOCK AT CLOSE OF FISCAL YEAR 10,000 shares of common stock, \$.01 per value + AMOUNT OF PAID-IN CAPITAL CAPITAL AT CLOSE OF FISCAL YEAR \$1,000 + AMOUNT OF CAPITAL USED IN CONDUCTING BUSINESS WITHIN THE USVI DURING THE FISCAL YEAR \$1,000 + +**SECTION 2** + +NAMES AND ADDRESSES OF ALL DIRECTORS AND OFFICERS OF THE CORPORATION AT THE CLOSE OF FISCAL YEAR AND EXPIRATION DATES OF TERMS OF OFFICE - + +| NAME/TITLE | ADDRESS | TERM EXPIRATION | +|-----------------------------------------------------|---------------------------------------------------|----------------------------------------------------| +| Jeffrey E Epstein, President/Director | 6100 Red Hook Quarter, B3, St. Thomas, USVI 00802 | Serves until successor elected | +| Richard Kahn, Treasurer/Director | [REDACTED], New York, NY 10021 | Serves until successor elected | +| Darren K. Indyke, Vice President/Secretary/Director | [REDACTED], Livingston, NJ 07039 | Serves until successor elected | +| | | SERVATIONS - 6/30/2016 PM 8 AM PROCEEDED ON OFFICE | + +I DECLARE, UNDER PENALTY OF PERJURY, UNDER THE LAWS OF THE UNITED STATES VIRGIN ISLANDS, THAT ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE TRUE AND CORRECT AND THAT STATEMENTS MADE IN THIS APPLICATION ARE SUBJECT TO INVESTIGATION AND THAT ANY FALSE OR DISHONEST ANSWER TO ANY QUESTION MAY BE GRANTED BY THE COURT OF REGISTRATION. + +TRUE [REDACTED] DATE 6/10/2016 + SIGNATURE Richard Kahn + PRINTED FIRST NAME AND LAST NAME + +PRESIDENT [Signature] DATE 6/10/16 + SIGNATURE Jeffrey Epstein + PRINTED FIRST NAME AND LAST NAME + +- IF THE LAST REPORT DOES NOT COVER THE PERIOD IMMEDIATELY PRECEDING THE REPORT PERIOD COVERED BY THIS REPORT, A SUPPLEMENTARY REPORT ON THE SAME MUST BE FILED, BRIDGING THE GAP BETWEEN THE TWO REPORTS. +- THIS REPORT IS NOT CONSIDERED COMPLETE UNLESS ACCOMPANIED BY A GENERAL BALANCE SHEET AND PROFIT AND LOSS STATEMENT FOR THE LAST FISCAL YEAR. AS REQUIRED BY THE VIRGIN ISLANDS CODE. FINANCIAL STATEMENTS SHOULD BE SIGNED BY AN INDEPENDENT PUBLIC ACCOUNTANT. +- FOREIGN SALES CORPORATIONS THAT ARE REGISTERED WITH THE SECURITY AND EXCHANGE COMMISSION MUST FINISH EVIDENCE OF SUCH REGISTRATION AND COMPLY WITH BALANCE SHEET AND PROFIT AND LOSS STATEMENTS. FCSS THAT ARE NOT REGISTERED WITH THE COMMISSION ARE EXEMPT FROM FILING THE GENERAL BALANCE SHEET AND THE PROFIT AND LOSS STATEMENT. + +![](_page_18_Picture_65.jpeg) + +THE UNITED STATES VIRGIN ISLANDS + +OFFICE OF THE LIEUTENANT GOVERNOR +DIVISION OF CORPORATIONS AND TRADEMARKS + +5049 Kongens Gade +Charlotte Amalie, Virgin Islands 00802 +Phone - 340.776.8515 +Fax - 340.776.4612 + +1105 King Street +Christiansted, Virgin Islands 00820 +Phone - 340.773.6449 +Fax - 340.773.0330 + +**FRANCHISE TAX REPORT - DOMESTIC CORPORATION** + +CORPORATE FILINGS AND REQUISITE TAXES ARE DUE, EACH YEAR, ON OR BEFORE JUNE 30th. +AVOID PENALTIES AND INTEREST BY PAYING ON TIME. + +| TODAY'S DATE | 6/30/2015 | +|-----------------------------------|------------| +| TAX CLOSING DATE | 12/31/2014 | +| EMPLOYER IDENTIFICATION NO. (EIN) | [REDACTED] | + +2968781 +\$150 +CHK 1025 + +SECTION 1 + +&K268USOPSOSOBS3TOLOHOOS12.00VS10H3E6.0 +C60F +MISCELLANEOUS PAYMENT RECPT#: 2968781 +Gov't of the U.S. Virgin Islan +2314 Hronprindsens Gade +Charlotte Amalie VI 00802 + +Tus, Inc. + +Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 + +Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 + +/2011 + +Property for Personal Use + +DATE: 06/30/15 TIME: 09:51 +CLERK: aventur1 DEPT: LTGOVSTT +CUSTOMER#: 0 + +10,000 shares of common stock, \$.01 per value +10,000 shares of common stock, \$.01 per value + +COMMENT: /2015 + +CHG: 210151 CORPORATE FRANC 150.00 + +AMOUNT PAID: 150.00 + +PAID BY: NAUTILUS, INC +PAYMENT METH: CHECK +1023 + +REFERENCE: + +ANT TENDERED: 150.00 +ANT APPLIED: 150.00 +CHANGE: .00 + +| BUSINESS | \$1,000 | +|-----------------------|---------| +| PORT | \$ 0 | +| REPORT | \$1,000 | +| EPORT | \$1,000 | +| RING REPORTING PERIOD | \$1,000 | + +| POUND DOWN TO THE NEAREST THOUSAND() | | +|--------------------------------------|----------| +| AS REPORTED ON LINE 3F ABOVE | \$150.00 | +| EATER()) | \$150.00 | + +REATER) OF 4B +R EACH MONTH, +PLAYED BEYOND + +C. TOTAL PENALTY AND INTEREST + +SECTION 6 - TOTAL DUE (TAXES, PENALTY, INTEREST) +SUM OF 4B AND 5C + +\$150.00 + +I DECLARE, UNDER PENALTY OF PERJURY, UNDER THE LAWS OF THE UNITED STATES VIRGIN ISLANDS, THAT ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE TRUE AND CORRECT, WITH FULL KNOWLEDGE THAT ALL STATEMENTS MADE IN THIS APPLICATION ARE SUBJECT TO INVESTIGATION AND THAT ANY FALSE OR DISHONEST ANSWER TO ANY QUESTION MAY BE REVOCATION OF REGISTRATION. + +TRI [REDACTED] +SIGNATURE +Richard Kahn + +6/17/2015 +DATE + +PRESIDENT +SIGNATURE +Jeffrey E. Epstein + +![](_page_19_Picture_198.jpeg) + +THE UNITED STATES VIRGIN ISLANDS + OFFICE OF THE LIEUTENANT GOVERNOR + DIVISION OF CORPORATIONS AND TRADEMARKS + +5049 Kongens Grade + Charlotte Amolle, Virgin Islands 00802 + Phone - 340.776.8515 + Fax - 340.776.4612 + +1105 King Street + Christiansted, Virgin Islands 00820 + Phone - 340.773.6449 + Fax - 340.773.0330 + +## ANNUAL REPORT - DOMESTIC AND FOREIGN CORPORATION + +CORPORATE FILINGS AND REQUISITE TAXES ARE DUE, EACH YEAR, ON OR BEFORE JUNE 30TH. AVOID PENALTIES AND INTEREST BY PAYING ON TIME. + +| TODAY'S DATE | TAX CLOSING DATE | EMPLOYER IDENTIFICATION NO. (EIN) | +|--------------|------------------|-----------------------------------| +| 6/30/2015 | 12/31/2014 | [REDACTED] | + +**SECTION 1** + +CORPORATION NAME Nautilus, Inc. + ADDRESS OF MAIN OFFICE 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 + ADDRESS OF PRINCIPLE USVI OFFICE Business Basics VI, LLC, 9100 Port of Sale Mall, Suite 15, St. Thomas, U.S. Virgin Islands 00802 + DATE OF INCORPORATION 11/22/2011 + COUNTRY/STATE OF INCORPORATION U. S. Virgin Islands + AMOUNT OF AUTHORIZED CAPITAL STOCK AT CLOSE OF FISCAL YEAR 10,000 shares of common stock, \$.01 per value + AMOUNT OF PAID-IN CAPITAL CAPITAL AT CLOSE OF FISCAL YEAR \$1,000 + AMOUNT OF CAPITAL USED IN CONDUCTING BUSINESS WITHIN THE USVI DURING THE FISCAL YEAR \$1,000 + + 2015 JUN 29 AM 3 + CORPORATIONS-ST + RECEIVED + LT. GOV. OFFICE + + +**SECTION 2** + +NAMES AND ADDRESSES OF ALL DIRECTORS AND OFFICERS OF THE CORPORATION AT THE CLOSE OF FISCAL YEAR AND EXPIRATION DATES OF TERMS OF OFFICE - + +| NAME/TITLE | ADDRESS | TERM EXPIRATION | +|-----------------------------------------------------|---------------------------------------------------|--------------------------------| +| Jeffrey E Epstein, President/Director | 6100 Red Hook Quarter, B3, St. Thomas, USVI 00802 | Serves until successor elected | +| Richard Kahn, Treasurer/Director | [REDACTED], New York, NY 10021 | Serves until successor elected | +| Darren K. Indyka, Vice President/Secretary/Director | [REDACTED], Livingston, NJ 07039 | Serves until successor elected | +| | | | +| | | | +| | | | + +I DECLARE, UNDER PENALTY OF PERJURY, UNDER THE LAWS OF THE UNITED STATES VIRGIN ISLANDS, THAT ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE TRUE AND CORRECT, WITH FULL KNOWLEDGE THAT ALL STATEMENTS MADE IN THIS APPLICATION ARE SUBJECT TO INVESTIGATION AND THAT ANY FALSE OR DISHONEST ANSWER TO ANY QUESTION MAY BE GROUNDS FOUNDING OR SUBSEQUENT REFOCATION OF REGISTRATION. + +TREASURER [REDACTED] + [REDACTED] + SIGNATURE: Richard Kahn + PRINTED FIRST NAME AND LAST NAME + +PRESIDENT [Signature] + SIGNATURE: Jeffrey Epstein + PRINTED FIRST NAME AND LAST NAME + +- IF THE LAST REPORT DOES NOT COVER THE PERIOD IMMEDIATELY PRECEDING THE REPORT PERIOD COVERED BY THIS REPORT, A SUPPLEMENTARY REPORT ON THE SAME MUST BE FILED, BRIDGING THE GAP BETWEEN THE TWO REPORTS. +- THIS REPORT IS NOT CONSIDERED COMPLETE UNLESS ACCOMPANIED BY A GENERAL BALANCE SHEET AND PROFIT AND LOSS STATEMENT FOR THE LAST FISCAL YEAR, AS REQUIRED BY THE VIRGIN ISLANDS CODE. FINANCIAL STATEMENTS SHOULD BE SIGNED BY AN INDEPENDENT PUBLIC ACCOUNTANT. +- FOREIGN SALES CORPORATIONS THAT ARE REGISTERED WITH THE SECURITY AND EXCHANGE COMMISSION MUST FRINSH EVIDENCE OF SUCH REGISTRATION AND COMPLY WITH BALANCE SHEET AND PROFIT AND LOSS STATEMENTS. FCSS THAT ARE NOT REGISTERED WITH THE COMMISSION ARE EXEMPT FROM FILING THE GENERAL BALANCE SHEET AND THE PROFIT AND LOSS STATEMENT. + +![](_page_20_Picture_31.jpeg) + +THE UNITED STATES VIRGIN ISLANDS +**OFFICE OF THE LIEUTENANT GOVERNOR** +**DIVISION OF CORPORATIONS AND TRADEMARKS** + +5049 Kongens Gade + Charlotte Amalie, Virgin Islands 00802 + Phone - 340.776.8515 + Fax - 340.776.4612 + +1105 King Street + Christiansted, Virgin Islands 00820 + Phone - 340.773.6449 + Fax - 340.773.0330 + +**FRANCHISE TAX REPORT - DOMESTIC CORPORATION** + +CORPORATE FILINGS AND REQUISITE TAXES ARE DUE, EACH YEAR, ON OR BEFORE JUNE 30th. + AVOID PENALTIES AND INTEREST BY PAYING ON TIME. + +| TODAY'S DATE | 6/30/2014 | +|-----------------------------------|------------| +| TAX CLOSING DATE | 12/31/2013 | +| EMPLOYER IDENTIFICATION NO. (EIN) | [REDACTED] | + +**SECTION 1** + +| CORPORATION NAME | Nautilus, Inc. | +|-----------------------|------------------------------------------------------------------| +| PHYSICAL ADDRESS | 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 | +| MAILING ADDRESS | 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 | +| DATE OF INCORPORATION | 11/22/2011 | +| NATURE OF BUSINESS | Holding Property for Personal Use | + +**SECTION 2** + +| CAPITAL STOCK AUTHORIZED ON LAST FILED REPORT | 10,000 shares \$.01 per value | +|-----------------------------------------------|-------------------------------| +| CAPITAL STOCK AUTHORIZED ON THIS DATE | 10,000 shares \$.01 per value | + +**SECTION 3 - PAID-IN CAPITAL STOCK USED IN CONDUCTING BUSINESS** + +| A. AS SHOWN ON LAST FILED REPORT | \$1,000 | +|----------------------------------------------------------------|---------| +| B. ADDITIONAL CAPITAL PAID SINCE LAST REPORT | \$ 0 | +| C. SUM OF 'A' AND 'B' ABOVE | \$1,000 | +| D. PAID-IN CAPITAL WITHDRAWN SINCE LAST REPORT | \$ 0 | +| E. PAID-IN CAPITAL STOCK AT DATE OF THIS REPORT | \$1,000 | +| F. HIGHEST TOTAL PAID-IN CAPITAL STOCK DURING REPORTING PERIOD | \$1,000 | + +**SECTION 4 - COMPUTATION OF TAX** + +| A. AT RATE OF \$1.50 PER THOUSAND (PLEASE ROUND DOWN TO THE NEAREST THOUSAND) | \$150.00 | +|-------------------------------------------------------------------------------|----------| +| ON HIGHEST TOTAL PAID-IN CAPITAL STOCK AS REPORTED ON LINE 3F ABOVE | \$150.00 | +| B. TAX DUE (4A OR \$150.00 (WHICHEVER IS GREATER)) | | + +**SECTION 5 - PENALTY AND INTEREST FOR LATE PAYMENT** + +| A. PENALTY - 20% OR \$50.00 (WHICHEVER IS GREATER) OF 4B | | +|---------------------------------------------------------------------------------------------------------------------------------------------|--| +| B. INTEREST - 1% COMPOUNDED ANNUALLY FOR EACH MONTH, OR PART THEREOF, BY WHICH PAYMENT IS DELAYED BEYOND THE JUNE 30 TH DEADLINE | | +| C. TOTAL PENALTY AND INTEREST | | + +RECEIVED + JUN 30 PM 12 30 + T. GOV. OFFICE + CHARLOTTE + JOHNS-STI + 26261/60 + +**SECTION 6 - TOTAL DUE (TAXES, PENALTY, INTEREST)** + +| SUM OF 4B AND 5C | \$150.00 | +|------------------|----------| +|------------------|----------| + +I DECLAR ARE THEREFORE MAY BE REGISTRATION. UNITED STATES VIRGIN ISLANDS, THAT ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, MADE IN THIS APPLICATION ARE SUBJECT TO INVESTIGATION AND THAT ANY FALSE OR DISCHONSET ANSWER TO ANY QUESTION REGISTRATION. + +TREE + SIGNATURE + Richard Kahn + PRINTED FIRST NAME AND LAST NAME + +6/30/2014 + DATE + +PRESIDENT + SIGNATURE + Jeffrey E. Epstein + PRINTED FIRST NAME AND LAST NAME + +6/30/14 + DATE + +![](_page_21_Picture_18.jpeg) + +THE UNITED STATES VIRGIN ISLANDS + +OFFICE OF THE LIEUTENANT GOVERNOR +DIVISION OF CORPORATIONS AND TRADEMARKS + +5049 Kongens Gade +Charlotte Amalie, Virgin Islands 00802 +Phone - 340.776.8515 +Fax - 340.776.4612 + +1105 King Street +Christiansled, Virgin Islands 00802 +Phone - 340.773.6449 +Fax - 340.773.0330 + +**ANNUAL REPORT - DOMESTIC AND FOREIGN CORPORATION** + +CORPORATE FILINGS AND REQUISITE TAXES ARE DUE, EACH YEAR, ON OR BEFORE JUNE 30TH. AVOID PENALTIES AND INTEREST BY PAYING ON TIME. + +| TODAY'S DATE | TAX CLOSING DATE | EMPLOYER IDENTIFICATION NO. (EIN) | +|--------------|------------------|-----------------------------------| +| 6/30/2014 | 12/31/2013 | [REDACTED] | + +**SECTION 1** + +CORPORATION NAME Nautilus, Inc. + ADDRESS OF MAIN OFFICE 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 + ADDRESS OF PRINCIPLE USVI OFFICE Business Basics VI, LLC, 9100 Port of Sale Mail Suite 15, St. Thomas U.S., Virgin Islands 00802 + DATE OF INCORPORATION 11/22/2011 + COUNTRY/STATE OF INCORPORATION U.S. Virgin Islands + AMOUNT OF AUTHORIZED CAPITAL STOCK AT CLOSE OF FISCAL YEAR 10,000 shares \$.01 per value + AMOUNT OF PAID-IN CAPITAL CAPITAL AT CLOSE OF FISCAL YEAR 1,000 + AMOUNT OF CAPITAL USED IN CONDUCTING BUSINESS WITHIN THE USVI DURING THE FISCAL YEAR 1,000 + +**SECTION 2** + +NAMES AND ADDRESSES OF ALL DIRECTORS AND OFFICERS OF THE CORPORATION AT THE CLOSE OF FISCAL YEAR AND EXPIRATION DATES OF TERMS OF OFFICE - + +| NAME/TITLE | ADDRESS | TERM EXPIRATION | +|----------------------------------------------------|--------------------------------------------------|--------------------------------| +| Jeffrey E Epstein President/Director | 6100 Red Hook Quarter, B3 St. Thomas, USVI 00802 | Serves until successor elected | +| Richard Kahn Treasurer/Director | [REDACTED] New York, NY 10021 | Serves until successor elected | +| Darren K. Indyke Vice President/Secretary/Director | [REDACTED], Livingston, NJ 07039 | Serves until successor elected | +| | | | +| | | | + +I DECLARE, UNDER PENALTY OF PERJURY, UNDER THE LAWS OF THE UNITED STATES VIRGIN ISLANDS, THAT ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE TRUE AND CORRECT, WITH FULL KNOWLEDGE THAT ALL STATEMENTS MADE IN THIS APPLICATION ARE SUBJECT TO INVESTIGATION AND THAT ANY FALSE OR DISHONEST ANSWER TO ANY QUESTION MAY BE GROUNDS FOR DETERMINATION. + +TREASURER + +SIGNATURE + +Richard Kahn +PRINTED FIRST NAME AND LAST NAME + +6/30/2014 + +PRESIDENT + +SIGNATURE + +Jeffrey Epstein +PRINTED FIRST NAME AND LAST NAME + +6/30/14 + +- • IF THE LAST REPORT DOES NOT COVER THE PERIOD IMMEDIATELY PRECEDING THE REPORT PERIOD COVERED BY THIS REPORT, A SUPPLEMENTARY REPORT ON THE SAME MUST BE FILED, BRIDGING THE GAP BETWEEN THE TWO REPORTS. +- • THIS REPORT IS NOT CONSIDERED COMPLETE UNLESS ACCOMPANIED BY A GENERAL BALANCE SHEET AND PROFIT AND LOSS STATEMENT FOR THE LAST FISCAL YEAR, AS REQUIRED BY THE VIRGIN ISLANDS CODE. FINANCIAL STATEMENTS SHOULD BE SIGNED BY AN INDEPENDENT PUBLIC ACCOUNTANT. +- • FOREIGN SALES CORPORATIONS THAT ARE REGISTERED WITH THE SECURITY AND EXCHANGE COMMISSION MUST FINISH EVIDENCE OF SUCH REGISTRATION AND COMPLY WITH BALANCE SHEET AND PROFIT AND LOSS STATEMENTS. FCSS THAT ARE NOT REGISTERED WITH THE COMMISSION ARE EXEMPT FROM FILING THE GENERAL BALANCE SHEET AND THE PROFIT AND LOSS STATEMENT. + +![](_page_22_Picture_144.jpeg) + +THE UNITED STATES VIRGIN ISLANDS +**OFFICE OF THE LIEUTENANT GOVERNOR + DIVISION OF CORPORATIONS AND TRADEMARKS** + +5049 Kongens Gade + Charlotte Amalie, Virgin Islands 00802 + Phone - 340.776.8515 + Fax - 340.776.4612 + +1105 King Street + Christiansted, Virgin Islands 00820 + Phone - 340.773.6449 + Fax - 340.773.0330 + +**FRANCHISE TAX REPORT - DOMESTIC CORPORATION** + +CORPORATE FILINGS AND REQUISITE TAXES ARE DUE, EACH YEAR, ON OR BEFORE JUNE 30th, + AVOID PENALTIES AND INTEREST BY PAYING ON TIME. + +| TODAY'S DATE | 6/30/2013 | +|-----------------------------------|------------| +| TAX CLOSING DATE | 12/31/2012 | +| EMPLOYER IDENTIFICATION NO. (EIN) | [Redacted] | + +**SECTION 1** + +| CORPORATION NAME | Nautilus, Inc. | +|-----------------------|------------------------------------------------------------------| +| PHYSICAL ADDRESS | 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 | +| MAILING ADDRESS | 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 | +| DATE OF INCORPORATION | 11/22/2011 | +| NATURE OF BUSINESS | Holding Property for Personal Use | + +**SECTION 2** + +CAPITAL STOCK AUTHORIZED ON LAST FILED REPORT + CAPITAL STOCK AUTHORIZED + +10,000 shares \$.01 per value + 10,000 shares \$.01 per value + +**S1** + &K268UsOPsOSsOBs3TOLOHO0s12.0OVs10H3E6.0 + C60F + MISCELLANEOUS PAYMENT RECPT#: 2286112 + Gov't of the U.S. Virgin Islands + 2314 Kronprindsens Gade + Charlotte Amalie VI 00802 + +| RECEIVED | RECEIVED | +|----------------------------------|-----------------------------| +| JUN 27 | JUN 27 | +| S-ST | S-ST | +| REPORTING PERIOD | REPORTING PERIOD | +| D DOWN TO THE NEAREST THOUSAND() | REPORTED ON LINE 3F ABOVE() | +| RT | RT | +| CHECKED | CHECKED | + +**SEC** + DATE: 06/28/13 TIME: 15:10 + CLERK: mventur1 DEPT: LTGOVSTT + CUSTOMER#: 0 + +RECEIVED + RECEIVED + RECEIVED + RECEIVED + +R # 2286112 + \$ 150.00 + C # 1010 + +**SEC** + COMMENT: 2013 + CHG: 210851 CORPORATE FRANC 150.00 + AMOUNT PAID: 150.00 + +**SECTI** + PAID BY: NAUTILUS, INC + PAYMENT METH: CHECK + PAYMENT METH: 1010 + REFERENCE: + +**TREE** + ANT TENDERED: 150.00 + ANT APPLIED: 150.00 + CHANGE: .00 + +TRIGIN ISLANDS, THAT ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, HIS APPLICATION ARE SUBJECT TO INVESTIGATION AND THAT ANY FALSE OR DISHONEST ANSWER TO ANY QUESTION + +![]()![](_page_23_Picture_18.jpeg) + +THE UNITED STATES VIRGIN ISLANDS + +OFFICE OF THE LIEUTENANT GOVERNOR +DIVISION OF CORPORATIONS AND TRADEMARKS + +5049 Kongens Gade +Charlotte Amalie, Virgin Islands 00802 +Phone - 340.776.8515 +Fax - 340.776.4612 + +1105 King Street +Christiansted, Virgin Islands 00820 +Phone - 340.773.6449 +Fax - 340.773.0330 + +**ANNUAL REPORT - DOMESTIC AND FOREIGN CORPORATION** + +CORPORATE FILINGS AND REQUISITE TAXES ARE DUE, EACH YEAR, ON OR BEFORE JUNE 30TH. AVOID PENALTIES AND INTEREST BY PAYING ON TIME. + +| TODAY'S DATE | TAX CLOSING DATE | EMPLOYER IDENTIFICATION NO. (EIN) | +|--------------|------------------|-----------------------------------| +| 6/30/2013 | 12/31/2012 | [REDACTED] | + +**SECTION 1** + +CORPORATION NAME Nautilus, Inc. + ADDRESS OF MAIN OFFICE 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands 00802 + ADDRESS OF PRINCIPLE USVI OFFICE Business Basica VI, LLC, 9100 Port of Sale Mall Suite 15, St. Thomas U.S., Virgin Islands 00802 + DATE OF INCORPORATION 11/22/2011 + COUNTRY/STATE OF INCORPORATION U. S. Virgin Islands + AMOUNT OF AUTHORIZED CAPITAL STOCK AT CLOSE OF FISCAL YEAR 10,000 shares \$.01 par value + AMOUNT OF PAID-IN CAPITAL CAPITAL AT CLOSE OF FISCAL YEAR 1,000 + AMOUNT OF CAPITAL USED IN CONDUCTING BUSINESS WITHIN THE USVI DURING THE FISCAL YEAR 1,000 + + 2013 + JUN 27 PM 3 + LT. GOV. OFFICE + RECEIVED + CORPORATIONS - S + + +**SECTION 2** + +NAMES AND ADDRESSES OF ALL DIRECTORS AND OFFICERS OF THE CORPORATION AT THE CLOSE OF FISCAL YEAR AND EXPIRATION DATES OF TERMS OF OFFICE - + +| NAME/TITLE | ADDRESS | TERM EXPIRATION | +|----------------------------------------------------|--------------------------------------------------|--------------------------------| +| Jeffrey E Epstein President/Director | 6100 Red Hook Quarter, B3 St. Thomas, USVI 00802 | Serves until successor elected | +| Richard Kahn Treasurer/Director | [REDACTED] New York, NY 10021 | Serves until successor elected | +| Darren K. Indyke Vice President/Secretary/Director | [REDACTED], Livingston, NJ 07039 | Serves until successor elected | +| | | | +| | | | + +I DECLARE, UNDER PENALTY OF PERJURY, UNDER THE LAWS OF THE UNITED STATES VIRGIN ISLANDS, THAT ALL STATEMENTS CONTAINED IN THIS APPLICATION, AND ANY ACCOMPANYING DOCUMENTS, ARE TRUE AND CORRECT, WITH FULL KNOWLEDGE THAT ALL STATEMENTS MADE IN THIS APPLICATION ARE SUBJECT TO INVESTIGATION AND THAT ANY FALSE OR DISHONEST ANSWER TO ANY QUESTION MAY BE GROUNDED FOR DENIAL OR SUBMISSION EDITION OF REGISTRATION. + +TREASURY [REDACTED] + SIGNATURE Richard Kahn DATE \_\_\_\_\_ + PRINTED FIRST NAME AND LAST NAME + +PRESIDENT [Signature] + SIGNATURE Jeffrey Epstein DATE \_\_\_\_\_ + PRINTED FIRST NAME AND LAST NAME + +- IF THE LAST REPORT DOES NOT COVER THE PERIOD IMMEDIATELY PRECEDING THE REPORT PERIOD COVERED BY THIS REPORT, A SUPPLEMENTARY REPORT ON THE SAME MUST BE FILED, BRIDGING THE GAP BETWEEN THE TWO REPORTS. +- THIS REPORT IS NOT CONSIDERED COMPLETE UNLESS ACCOMPANIED BY A GENERAL BALANCE SHEET AND PROFIT AND LOSS STATEMENT FOR THE LAST FISCAL YEAR, AS REQUIRED BY THE VIRGIN ISLANDS CODE. FINANCIAL STATEMENTS SHOULD BE SIGNED BY AN INDEPENDENT PUBLIC ACCOUNTANT. +- FOREIGN SALES CORPORATIONS THAT ARE REGISTERED WITH THE SECURITY AND EXCHANGE COMMISSION MUST FINISH EVIDENCE OF SUCH REGISTRATION AND COMPLY WITH BALANCE SHEET AND PROFIT AND LOSS STATEMENTS. FCSS THAT ARE NOT REGISTERED WITH THE COMMISSION ARE EXEMPT FROM FILING THE GENERAL BALANCE SHEET AND THE PROFIT AND LOSS STATEMENT. + +OFFICE OF +THE LIEUTENANT GOVERNOR + +![](_page_24_Picture_36.jpeg) + +## REPORT + +DIVISION OF CORPORATION AND TRADEMARKS + +TEL. (340) 776-8515 • FAX. (340) 776-4612 + +### OF CORPORATION FRANCHISE TAX DUE PURSUANT TO TITLE 13, SECTION 531, VIRGIN ISLANDS CODE + +#### DOMESTIC CORPORATION (THIS REPORT IS DUE ON OR BEFORE JUNE 30TH OF EACH YEAR) + +EMPLOYER L.D. No. [REDACTED] + +Date of Report: June 30, 2012 + +Date of Last Report: First report + +This Report is for the Period Ended June 30th, 2012 + +**1) NAME OF CORPORATION:** Nautilus, Inc. + +- a. Address: 6100 Red Hook Quarter, B3 St. Thomas USVI 00802 +- b. Date of Incorporation: November 22, 2011 +- c. Kind of Business: Holding Property for Personal Use + +**2) AMOUNT OF CAPITAL STOCK AUTHORIZED:** + +- a. When last report filed ..... +- b. On date of this report ..... + +10000 shares common stock \$.01 per +10000 shares common stock \$.01 per..... + +**3) AMOUNT OF PAID-IN CAPITAL STOCK USED IN CONDUCTING BUSINESS:** + +- a. As shown on last report filed ..... \$..... +- b. Additional capital paid in since last report ..... \$..... +- c. Sum of (a) and (b) ..... \$..... +- d. Paid-in Capital withdrawn since last report..... \$..... +- e. Paid-in Capital Stock at date of this report ..... \$..... +- f. **HIGHEST TOTAL PAID-IN CAPITAL STOCK DURING REPORTING PERIOD** ..... \$..... + +**4) COMPUTATION OF TAX:** + +- a. At rate of \$1.50 per M (fractions of a thousand disregarded) on highest total paid-in capital stock as reported on Line 3(t) above \$.150..... +- b. TAX DUE: (Above figure, or \$150 whichever is greater) \$..... + +**5) PENALTY AND INTEREST FOR LATE PAYMENT:** + +- a. 20% or \$50.00 whichever is greater penalty for failure to pay by June 30th \$..... +- b. 1 % interest compounded annually for each month or part thereof by which payment is delayed beyond June 30th \$..... +- c. Total Penalty And Interest: \$..... + +**6) TOTAL DUE AND FORWARDED HEREWITH (Sum of (4) (b) and (5) (c)** + +(Attach checks payable to The Government of the Virgin Islands and mail documents to the Office of the Lieutenant Governor, Division of Corporation and Trademarks, 5049 Kongens Gade, St. Thomas, VI 00802-6487.) + +2012 +JUL 17 ETC +CORPORATIONS - GOVERNOR +RECEIVED +L.T. GOV. OF THE VIRGIN ISLANDS +39 + +[REDACTED] +Treasurer + +![]() + +# ANNUAL REPORT + +## ON DOMESTIC OR FOREIGN CORPORATIONS + +(DUE ON OR BEFORE JUNE 30 OF EACH YEAR) + +PURSUANT TO SECTIONS 371 AND 373, CHAPTER 1, TITLE 13, OF THE VIRGIN ISLANDS CODE, REQUIRING THE FILING OF ANNUAL REPORTS BY DOMESTIC AND FOREIGN CORPORATIONS, THE FOLLOWING STATEMENT IS FILED WITH THE OFFICE OF THE LIEUTENANT GOVERNOR. + +NAME OF CORPORATION: Nautilus, Inc. + +ADDRESS OF MAIN OFFICE: 6100 Red Hook Quarter, B3 St. Thomas, VI 00802 + +PRINCIPAL OFFICE IN THE VIRGIN ISLANDS: 6100 Red Hook Quarter, B3 St. Thomas, VI 00802 + +RESIDENT OR AUTHORIZED AGENT IN THE VI: Kellerhals Ferguson LLP 9100 Havensight Port of Sale Ste. 15-16 St. Thomas, USVI 00802 + +COUNTRY OR STATE IN WHICH INCORPORATED: United States Virgin Islands + +FISCAL YEAR COVERED BY LAST REPORT FILED: First Report + +FISCAL YEAR COVERED BY THIS REPORT: December 31, 2011 + +AMOUNT OF AUTHORIZED CAPITAL STOCK AT CLOSE OF FISCAL YEAR 10,000 shares common stock \$.01 per value + +AMOUNT OF PAID-IN CAPITAL AT CLOSE OF FISCAL YEAR 1,000 + +AMOUNT OF CAPITAL USED IN CONDUCTING BUSINESS WITHIN THE VIRGIN ISLANDS DURING THE FISCAL YEAR: 1,000 + +NAME AND ADDRESSES OF DIRECTORS AND OFFICERS OF THE COMPANY AT THE CLOSE OF FISCAL YEAR AND EXPIRATION DATES OF TERMS OF OFFICE + +Jeffrey Epstein -President/Director Serves until successor elected + +6100 Red Hook Quarter B3 St. Thomas USVI 00802 + +Richard Kahn -Treasurer/Director Serves until successor elected + +[REDACTED] New York, NY 10021 + +Darren Indyke -Vice President and Secretary/Director Serves until successor elected + +[REDACTED] Livingston, NJ 07039 + +DATED June 30, 2012 + +VERIFIED [REDACTED] + +RECEIVED +LT. GOV. OFFICE +CORPORATIONS +2012 +JUL 17 PM +JUL 17 PM + +[REDACTED] + +(TREASURER OR ASST. TREASURER) + +1. 1. If last report filed does not cover the period immediately preceding this period covered by this report, a supplementary report on the same form must be filed, bridging the gap, if any, between the two reports. +2. 2. THIS REPORT IS NOT COMPLETE NOR ACCEPTABLE UNLESS ACCOMPANIED BY GENERAL BALANCE SHEET AND PROFIT AND LOSS STATEMENT FOR THE LAST FISCAL YEAR AS REQUIRED BY THE VIRGIN ISLANDS CODE. FINANCIAL STATEMENTS SHOULD BE SIGNED BY AN INDEPENDENT PUBLIC ACCOUNTANT. + +| CASH | | \$ 14,387 | +|---------------------------------------------------|---------------------|------------------| +| | TOTAL ASSETS | \$ 14,387 | +| | | | +| ADVANCES | | 12,543 | +| | | | +| STOCKHOLDER'S EQUITY | | | +| | | | +| Paid in capital stock | | \$ 1,000 | +| Additional paid in capital | | 2,000 | +| Accumulated deficit | | (901) | +| | | 2,099 | +| | | | +| TOTAL LIABILITIES AND STOCKHOLDER'S EQUITY | | \$ 14,642 | + +**STATEMENT OF INCOME AND RETAINED EARNINGS** + For the year ended December 31, 2017 + +| Income | | \$ - | +|-----------------------------------------------|-----------------------|-----------------| +| | Total revenues | - | +| | | | +| General and administrative expenses | | 150 | +| | | | +| Total expenses | | 150 | +| | | | +| NET LOSS | | (150) | +| | | | +| Accumulated deficit, beginning of year | | (751) | +| | | | +| Accumulated deficit, end of year | | \$ (901) | + +## Nautilus, Inc EN # R GALA As of December 31, 2016 + +CASH + +TOTAL ASSETS + +\$ 40,347 + +40,347 + +ADVANCES 38,098 4=, •-• .0.3 70 :Z. e, m • on'001c rn Additional paid in capital 2,000 at ki.110 2mo .9 Z,. + +STOCKHOLDER'S EQUITY 74 + +Paid in capital stock 73 Accumulated deficit + +TOTAL LIABILITIES AND STOCKHOLDER'S EQUITY + +### STATEMENT OF INCOME AND RETAINED EARNINGS For the year ended December 31, 2016 + +Income + +Total revenues + +General and administrative expenses 150 + +Total expenses 150 + +NET LOSS (150) + +Accumulated deficit, beginning of year (601) + +### Na EIN # BALANCE SHEET As of December 31, 2015 + +CASH \$ 40,347 TOTAL ASSETS 40,347 + +ADVANCES 38,098 + +### STOCKHOLDER'S EQUITY + +Paid in capital stock 1,000 Additional paid in capital 2,000 Accumulated deficit (751) 2,249 + +TOTAL LIABILITIES AND STOCKHOLDER'S EQUITY \$ 40,341 + +# STATEMENT OF INCOME AND RETAINED EARNINGS :70 For the year ended December 31, 2015 cn + +co co + +Income Total revenues C-a? + +General and administrative expenses 150 Total expenses 150 NET LOSS (150) + +Accumulated deficit, beginning of year (601) + +### Nautilus Inc EIN # BALANCE As of December 31, 2014 + +CASH \$ 72,920 TOTAL ASSETS 72,920 + +ADVANCES 70,521 + +# STOCKHOLDER'S EQUITY + +C) vi Accumulated deficit 1 ) (601) 2,399 C 1" + +Paid in capital stock 1,000 Additional paid in capital CLL: ;400 + +TOTAL LIABILITIES AND STOCKHOLDER'S EQUITY \$ \_ 72,92C1; + +### STATEMENT OF INCOME AND RETAINED EARNINGS For the year ended December 31, 2014 + +Income Total revenues + +General and administrative expenses 160 + +Total expenses 160 + +NET LOSS (160) + +Accumulated deficit, beginning of year (441) + +| CASH | \$ 11,383 | +|-----------------------------------------------------------------------------------|------------------| +| TOTAL ASSETS | \$ 11,383 | +| ADVANCES | 10,925 | +| STOCKHOLDER'S EQUITY | | +| Paid in capital stock | \$ 1,000 | +| Accumulated deficit | (441) | +| | 559 | +| TOTAL LIABILITIES AND STOCKHOLDER'S EQUITY | \$ 11,483 | +| STATEMENT OF INCOME AND RETAINED EARNINGS
For the year ended December 31, 2013 | | +| Income | \$ - | +| Total revenues | - | +| General and administrative expenses | 441 | +| Total expenses | 441 | +| NET LOSS | (441) | +| RETAINED EARNINGS, beginning of year | - | +| Accumulated deficit, end of year | (441) | + +| PROPERTY | \$ 1,000 | +|--------------------------------------------|-----------------| +| TOTAL ASSETS | \$ 1,000 | +| STOCKHOLDER'S EQUITY | | +| Paid in capital stock | \$ 1,000 | +| | 1,000 | +| TOTAL LIABILITIES AND STOCKHOLDER'S EQUITY | \$ 1,000 | + +STATEMENT OF INCOME AND RETAINED EARNINGS + For the year ended December 31, 2012 + +NO ACTIVITY for the Year Ended December 31, 2012 + + RECEIVED + LT. GOV. OFFICE + 2013 JUN 27 PM 3 18 + CORPORATIONS-STT + + +PROPERTY + +\$ 1,000 + +TOTAL ASSETS + +\$ 1,000 + +STOCKHOLDER'S EQUITY + +Paid in capital stock + +\$ 1,000 + +TOTAL LIABILITIES AND STOCKHOLDER'S EQUITY + +| | \$ | 1,000 | +|--|----|------------------| +| | | 1,000 | +| | \$ | 1,000 | + +CORPORATIONS-STT + +STATEMENT OF INCOME AND RETAINED EARNINGS +For the year ended December 31, 2011 + +NO ACTIVITY + + RECEIVED + I.T. GOV. 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BOX 898 +DOVER, DELAWARE 19903 + +STATE OF DELAWARE +DEPARTMENT OF STATE +DIVISION OF CORPORATIONS +401 FEDERAL STREET, SUITE 4 +DOVER, DELAWARE 19901 + +GENERAL INFORMATION +www.CORP.DELAWARE.GOV +(302) 739-3073 + +Federal Bureau of Investigation +26 Federal Plaza, Squad C-40 +New York, NY 10278 + +Attention: [REDACTED] + +Please find enclosed certified documents on file with the State of Delaware, +Division of Corporations for **L.S.J. LLC** file number 2884117. If I can be +of further assistance please contact me at [REDACTED]. + +Sincerely, + +![]()June Bilbrough + +# Delaware + +Page 1 + +The First State + +I, JEFFREY W. BULLOCK, SECRETARY OF STATE OF THE STATE OF DELAWARE, DO HEREBY CERTIFY THE ATTACHED ARE TRUE AND CORRECT COPIES OF ALL DOCUMENTS ON FILE OF "L.S.J., LLC" AS RECEIVED AND FILED IN THIS OFFICE. + +THE FOLLOWING DOCUMENTS HAVE BEEN CERTIFIED: + +CERTIFICATE OF FORMATION, FILED THE SEVENTEENTH DAY OF APRIL, A.D. 1998, AT 12 O'CLOCK P.M. + +AND I DO HEREBY FURTHER CERTIFY THAT THE AFORESAID CERTIFICATES ARE THE ONLY CERTIFICATES ON RECORD OF THE AFORESAID LIMITED LIABILITY COMPANY, "L.S.J., LLC". + +![](_page_2_Picture_76.jpeg) + +![]()2884117 8100H +SR# 20196710724 + +Authentication: 203473702 +Date: 08-26-19 + +# Delaware + +The First State + +Page 1 + +I, JEFFREY W. BULLOCK, SECRETARY OF STATE OF THE STATE OF +DELAWARE, DO HEREBY CERTIFY "L.S.J., LLC" IS DULY FORMED UNDER THE +LAWS OF THE STATE OF DELAWARE AND IS IN GOOD STANDING AND HAS A +LEGAL EXISTENCE SO FAR AS THE RECORDS OF THIS OFFICE SHOW, AS OF +THE TWENTY-SIXTH DAY OF AUGUST, A.D. 2019. + +AND I DO HEREBY FURTHER CERTIFY THAT THE ANNUAL TAXES HAVE BEEN +PAID TO DATE. + +![](_page_4_Picture_65.jpeg) + +2884117 8300 + +![]()Authentication: 203473698 + +#### CERTIFICATE OF FORMATION + +OF + +LLC + +The undersigned, desiring to form alimited liability company under Title 6, Sections 18-101 et seq. of the Delaware Code, hereby certifies as follows: + +- 1. The name of the limited liability company shall be L.S.J., LLC. +- 2. The address of the limited liability company's registered office in the state of Delaware is Corporation Trust Center, 1209 Orange Street, in the City of Wilmington, County of New Castle 19801. The name of its registered agent at such address is The Corporation Trust Company. +- 3. The undersigned is an authorized person for purposes of the execution and delivery of this Certificate of Formation. + +IN WITNESS WHEREOF, the undersigned has executed this Certificate of Formation of L.S.J., LLC this 17th day of April, 1998. + +Russell R. Roster, authorized person + +#### Declaration of Custodian of Records + +Pursuant to 28 U.S.C. § 1746,1 the undersigned, hereby declare: + +My name is urtp ' Zi'si bfoukah (name of declarant) + +records of Iam aUnited States citizen and I am over eighteen years of age. I am the custodian of the business the named business named below, or I am otherwise qualified as a result of my position with below to make this declaration. + +United States I am in Attome receipt Subpoena, dated August 9, 2019, and signed by Assistant Pursuant requesting specified records of the business named below. records provided to Rules herewith 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify that the and in response to the Subpoena: + +- (I) by, or were made at or near the time of the occurrence of the matters set forth in the records, from information transmitted by, aperson 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 aregular practice. + +1declare under penalty of perjury that the foregoing is true and correct. + +Executed on blaze I 11 (date) + +Paattotzellt ture of declarant) + +-a trte brogs, Franch•.-)e Ta", Rennin. (name and title of declarant) + +~iuisio n of C Oryorat.t; on) (name of business) + +Llo, GeperaRSF, 6fe 4 130O r Cit. iqqat (business address) + +#### Definitions of terms used above: + +As defined in Fed. R. Evid. 803(6), "record" includes amemorandum, compilation, report, record, or data in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business" as used in Fed. R. 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+1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:dc682484f95007abf1d72b535986392df03cea2a219e7858567f2d22e258a2be +size 29325 diff --git a/marker2/ds9/EFTA00085154/_page_4_Picture_65.jpeg b/marker2/ds9/EFTA00085154/_page_4_Picture_65.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..f72d987e59362c989798e494c77131dacbb58e44 --- /dev/null +++ b/marker2/ds9/EFTA00085154/_page_4_Picture_65.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:1519d28ebd36dc26fdd68997b945742d83838851cbc4633075509a8b75eb2398 +size 31826 diff --git a/marker2/ds9/EFTA00085164/EFTA00085164.md b/marker2/ds9/EFTA00085164/EFTA00085164.md new file mode 100644 index 0000000000000000000000000000000000000000..7009edff5bbccb00b097e299e248ea0d240d51d4 --- /dev/null +++ b/marker2/ds9/EFTA00085164/EFTA00085164.md @@ -0,0 +1,53 @@ +From: To: Cc: "EnCRM)" (CRM)" " aIMIE> (CRM)" + +Subject: Re: Press Queries re: Prince Andrew / MLAT + +Date: Mon, 08 Jun 2020 04:38:52 +0000 + +Thanks very much, . Appreciate you bringing this to my attention. I will pass on to the rest of the SDNY team. + +Best, + +On Jun 7, 2020, at 7:56 PM, (CRM) wrote: + +- wanted SDNY to be aware of the below article, if you have not already seen. DOJ OPA is receiving numerous calls. Best, + +Sent from my iPhone + +Begin forwarded message: + +From: ' (CRM)" `z > Date: June 7 2020 at 6:40:05 PM EDT To: ' (OPA)" Cc: CRM CRM)" OJ London Attache)... + +Subject: Re: Press Queries re: Prince Andrew / MLAT + +Yes. We have made a MLAT request, which is of course highly sensitive, and confidential. Agree with statement. Thanks, + +Sent from my iPhone + +On Jun 7, 2020, at 6:21 PM OPA) wrote: + +British media is reporting DoJ made a MLAT request to speak to Prince Andrew. I am now receiving numerous press inquiries asking If true/what does that entail. For my own knowledge, please advise if this article is accurate: https://www.thesun.co.uk/news/11805488/prince-andrew-quizzed-over-jeffrey-e steinlinks/ and if concur with the following response: As a matter of policy, the U.S. Department of Justice does not publicly comment on communications with foreign governments on investigative matters, including confirming or denying the very existence of such communications. + +Thank you, + +U.S. Department of Justice (DOJ) + +Begin forwarded message: + +From: Kadhim Shubber Date: June 7 2020 at 5:02:20 PM EDT To: 'SOPA)" Subject: Query re: Prince Andrew / MLAT + +Hi M, + +Hope you're doing well. Sony to bother you at the weekend. + +There's a report just out that DOJ issued a MLAT request to the UK last month regarding Prince Andrew to force him to answer questions in the Epstein investigation: https://www.thesun.co.uk/news/11805488/prince-andrew-quizzed-over-jeffrey-epstein-links/ + +Is that something you could guide me on as to its accuracy? And do you have any comment/statement at all? + +Any help would be much appreciated. + +Kadhim + +Kadhim Shubber I Financial Times I (cell) I @kadhim + +This email was sent by a company owned by Financial Times Group Limited (FT Group") registered office at Bracken House, One Friday Street, London, EC4M 9BT Registered in England and Wales with company number 879531. This email may contain confidential information. If you are not the intended recipient, please notify the sender immediately, delete all copies and do not distribute it further. It could also contain personal views which are not necessarily those of the FT Group. 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You can call my de + +Brendan F. Quigley ibiol + +Partner + +From: + +Sent: Thursday, May 6, 2021 4:01 PM + +To: Quigley, Brendan •c + +Cc: + +Subject: RE: SDNY investigation + +[EXTERNAL EMAIL] + +Thanks very much. If 4:30 works, I can call you then. Which number is best to reach you? + +From: Quigley, Brenda' + +Sent: Thursdav—May\_6 2021 3:32 PM + +To + +Cc + +Subject: RE: SDNY investigation (Rodgers) + +Sure. I am around the rest of the afternoon today. Tomorrow is a bit rougher, but I could talk first thing (like 9) or late afternoon. + +Brendan F. Quigley [bio] + +Partner + +Baker Botts L.L.P. + +From: + +Sent: Thursday, May 6, 2021 12:48 PM + +Su jec : : roves iga ion + +Thanks, + +[REDACTED] + +From: [REDACTED] +Sent: Friday, June 5, 2020 3:35 PM +To: [REDACTED] +Cc: [REDACTED] +Subject: Re: SOIVT investigation ([REDACTED]) + +[REDACTED] + +Appreciate the courtesy. Please do not pass on our contact info. That said, feel free to contact us if anything comes up in your investigation. + +Thank you. Hope you guys are all hanging in okay. + +**Brendan F. Quigley** +[REDACTED] + +On Jun 5, 2020, at 3:19 PM, [REDACTED] wrote: + +**[EXTERNAL EMAIL]** + +Brendan, + +An attorney for an individual who has an active civil case in connection with Epstein has reached out to us to ask if we know the current counsel for Mr. [REDACTED]. I assume that the attorney is seeking to serve a request or subpoena for documents and/or testimony, though we haven't asked specifically. + +I don't think we ordinarily engage on that type of question, but given that we have been in touch with you in connection with our interview of Mr. [REDACTED], if you'd like we can pass along your contact info, so that the attorney goes to you rather than attempting to contact or serve Mr. Rogers directly. And if not, of course no problem, and we'll just let him know that we're not able to comment one way or the other on the status of any counsel. Whatever you prefer. + +Thanks, and hope you're well these days. + +[REDACTED] + +From Sen • • To: Cc: Subject: RE: SDNY investigation (MIin) + +ThankM + +From Sent: Friday, February 7, 2020 6:13 PM To: Cc: Subjec : : inves igation + +[EXTERNAL EMAIL] + +Brendan, + +As promised, attached please find a copy of the proffer agreement signed today. + +thanks, + +![](_page_2_Picture_7.jpeg) + +## 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/EFTA00085166/EFTA00085166.metadata.json b/marker2/ds9/EFTA00085166/EFTA00085166.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9a132fe0bbbe2e811564b2d38b228220d6226fb3 --- /dev/null +++ b/marker2/ds9/EFTA00085166/EFTA00085166.metadata.json @@ -0,0 +1,175 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085166.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2834, + "elapsed_seconds": 6.41, + "image_assets": [ + "_page_2_Picture_7.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "[EXTERNAL EMAIL]", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 34.272, + 502.20000000000005 + ], + [ + 114.44400000000002, + 502.20000000000005 + ], + [ + 114.44400000000002, + 513.54 + ], + [ + 34.272, + 513.54 + ] + ] + }, + { + "title": "Confidentiality Notice:", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 34.272, + 421.20000000000005 + ], + [ + 166.0425567626953, + 421.20000000000005 + ], + [ + 166.0425567626953, + 434.3340759277344 + ], + [ + 34.272, + 434.3340759277344 + ] + ] + } + ], + "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": "surya", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Text", + 31 + ], + [ + "Line", + 23 + ], + [ + "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 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Line", + 21 + ], + [ + "Text", + 8 + ], + [ + "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/EFTA00085166" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085166/_page_2_Picture_7.jpeg b/marker2/ds9/EFTA00085166/_page_2_Picture_7.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..295961f15f4917d3981c6b50dd9bdfb3a56495bd --- /dev/null +++ b/marker2/ds9/EFTA00085166/_page_2_Picture_7.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:4912624153d86d167c40c0fe62e49eb04f06f40d0977b40f7d0be919d467cf72 +size 4810 diff --git a/marker2/ds9/EFTA00085169/EFTA00085169.md b/marker2/ds9/EFTA00085169/EFTA00085169.md new file mode 100644 index 0000000000000000000000000000000000000000..87b4fe44b2e87e588a377775568e75c25fb13003 --- /dev/null +++ b/marker2/ds9/EFTA00085169/EFTA00085169.md @@ -0,0 +1,13 @@ +"Laura Menninger" , Jeff Pagliuc , " SANYS " + +Subject: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Date: Thu, 06 May 2021 23:15:43 +0000 + +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 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00085169/EFTA00085169.metadata.json b/marker2/ds9/EFTA00085169/EFTA00085169.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1dc1d168f5194f8cc268d1d3fca8f85bfc30881b --- /dev/null +++ b/marker2/ds9/EFTA00085169/EFTA00085169.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085169.pdf", + "engine": { + "marker_major": "2", + "marker_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": 0.43, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 30 + ], + [ + "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/EFTA00085169" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085170/EFTA00085170.md b/marker2/ds9/EFTA00085170/EFTA00085170.md new file mode 100644 index 0000000000000000000000000000000000000000..84007f0059e36cee906d2e3de043e662c727a2c7 --- /dev/null +++ b/marker2/ds9/EFTA00085170/EFTA00085170.md @@ -0,0 +1,29 @@ +To: "Jestin, Katya' + +Subject: RE: Epstein question + +Date: Fri, 07 May 2021 23:02:09 +0000 + +Hi Katya, + +an you give me a call when you have a chance? I'm free this evening if you want to call my cell at + +Original Message + +From: Jestin, Katya + +Sent: Thursda Ma 6 2021 6:22 PM + +u ject: pstem question + +Hi there - I know you are busy. I was just following up on the question I asked about. + +Katya + +Katya Jestin Co-Managing Partner + +Jenner & Block LLP + +ronouns: e er KJestin@jenner.com + +CONFIDENTIALITY WARNING: This email may contain privileged or confidential information and is for the sole use of the intended recipient(s). Any unauthorized use or disclosure of this communication is prohibited. If you believe that you have received this email in error, please notify the sender immediately and delete it from your system. \ No newline at end of file diff --git a/marker2/ds9/EFTA00085170/EFTA00085170.metadata.json b/marker2/ds9/EFTA00085170/EFTA00085170.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..535950be83a4b5b58f870efaf7fa60a5704be585 --- /dev/null +++ b/marker2/ds9/EFTA00085170/EFTA00085170.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085170.pdf", + "engine": { + "marker_major": "2", + "marker_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": 0.77, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Line", + 22 + ], + [ + "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/EFTA00085170" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085171/EFTA00085171.md b/marker2/ds9/EFTA00085171/EFTA00085171.md new file mode 100644 index 0000000000000000000000000000000000000000..03e4fa7d3cd7645cccee57825228f431095d0246 --- /dev/null +++ b/marker2/ds9/EFTA00085171/EFTA00085171.md @@ -0,0 +1,39 @@ +To: 'Nathan NYSD Chambers' + +Cc: ' + +SANYS)'" + +, 'BOBBI C STERNHEIM' , + +"'Jeff Pagliuca"' , 'Laura Menninger' + +Subject: U.S. v. Ghislaine Maxwell, S2 20 Cr. 330 (ATN) -- Supplemental Pretrial Motions, Memorandum and Exhibits (to be Filed Under Seal) + +Date: Sat, 08 May 2021 01:54:25 +0000 + +Attachments: 2021.05.07\_Filing\_Lzip + +Inline-Images: image005.jpg; image006.jpg + +Dear Judge Nathan — + +As set forth in the attached cover letter and pursuant to Rule 2(B) of the Court's individual rules, attached for the Court and government are copies of Ms. Maxwell's omnibus memorandum in support of her supplemental pretrial motions related to the S2 superseding indictment and accompanying exhibits. The cover letter is being filed on the public docket. + +Due to the volume of materials, we will be sending them in two zip files in successive emails. Attached is the first zip file. + +Regards, + +Christian R Everdell + +## COHEN & GRESSER LLP + +800 Third Avenue New York, NY 10022 +1 212 957 7268 ceverdellacohengresser.com , view bio www.cohengresser.com + +New York I Paris I Washington DC I London + +![](_page_0_Picture_19.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 a! 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Ghislaine Maxwell, S2 20 Cr. 330 (AJN) -- Supplemental Pretrial Motions, Memorandum and Exhibits (to be Filed Under Seal) + +**Date:** Sat, 08 May 2021 01:54:34 +0000 + +**Attachments:** 2021.05.07\_Filing\_2.zip + +**Inline-Images:** image002.jpg; image004.jpg + +--- + +Dear Judge Nathan – + +Attached is the second zip file. + +Regards, + +Christian R Everdell + +**COHEN & GRESSER LLP** + +800 Third Avenue +New York, NY 10022 + +[REDACTED] | [view bio](#) + +[www.cohengresser.com](http://www.cohengresser.com) + +New York | Paris | Washington DC | London + +![](_page_0_Picture_124.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. Thank you. + +**PRIVACY:** A complete copy of our privacy policy can be viewed at: \ No newline at end of file diff --git a/marker2/ds9/EFTA00085172/EFTA00085172.metadata.json b/marker2/ds9/EFTA00085172/EFTA00085172.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..82eee6981e8f91deda4d18ea6914c78d3afc3f70 --- /dev/null +++ b/marker2/ds9/EFTA00085172/EFTA00085172.metadata.json @@ -0,0 +1,64 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085172.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1377, + "elapsed_seconds": 6.21, + "image_assets": [ + "_page_0_Picture_124.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Text", + 42 + ], + [ + "Line", + 26 + ], + [ + "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/EFTA00085172" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085172/_page_0_Picture_124.jpeg b/marker2/ds9/EFTA00085172/_page_0_Picture_124.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..25db5bf104749e79cd6ef0b7beea0b491d90da5e --- /dev/null +++ b/marker2/ds9/EFTA00085172/_page_0_Picture_124.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:96b93dcaeaa374707e0d803e66bb1be7d70a0dcdc8dafe8db4ceef65f746d9ab +size 1379 diff --git a/marker2/ds9/EFTA00085173/EFTA00085173.md b/marker2/ds9/EFTA00085173/EFTA00085173.md new file mode 100644 index 0000000000000000000000000000000000000000..850d4e4de73905260905ffdd2d09f4bea437e174 --- /dev/null +++ b/marker2/ds9/EFTA00085173/EFTA00085173.md @@ -0,0 +1,33 @@ +## Exhibit G + +## FEDERAL BUREAU OF INVESTIGATION + +NraturillOom 05/29/2008 + +On Ma 2.9 2008, Special Agents (SAs) f the Federal Bureai w ". (FBI) at her residence at + +was advised of the identity of the interviewing a ents and before 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. s attorney as listed on the business card is DIARMUID WHITE, (White and White Law Firm), New York, NY 10075, telephone numbe + +Agents explained they were not there to arrest and stated she was not a target of any FBI investigation but 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 understood the consequences 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 Johnson later that same day and stated she wanted to know why agents wanted to talk to her matter. SA EPSTEIN. S. e in turn could consult her attorney in this plied that this was regarding JEFFREY hen asked "well you are familiar with JEFFREY EPSTEIN right?". then answered "OK...", and then asked about travel arrangements to Florida for grand jury. + +was was included with the questions. In town and her uncle but she would do lir that her husband then referred to the printed material that sub oena regarding her travel and answered added that her 10 year old sister was was also supposed to visit and stay with her eat-to make arrangements for them. She added (last name not provided) would probably be + +Investigation on 05/29/20 toria, NY + +Fttc tt 31E-1MM-108062 A Datedicteed + +by + +Thts document contains neither recommendations nor conclusions of the FBI a and its contents arc nos to be distributed outside your agency. It Is the Property of the FBI and is loaned to ;our agency Si it- A-('A- 01002\_1(7s + +CONFIDENTIAL SDNY\_GM\_02743174 + +31E-MM-108062 + +Continuation of FD-302 of [REDACTED], On 05/30/2008, Page 2 + +traveling with her. 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+ +IT APPEARING that the State Attorney's Office has charged Epstein by indictment with 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 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, 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(0, with minor females, in violation of Title IS, 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(0, 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 + +- 1. Epstein shall plead guilty (not nob 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,DONB) charging one (1) count of solicitation of prostitution, in violation of Fl. Star § 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 of Florida 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 tern 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 Attorney's Office from agreeing to recommend any additional charge(s) or any additional term(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 sent aced. 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 be paid 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 ore 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 terms, nor any resulting waivers or settlements by Epstein arc to be consorted 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 inmate, 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 and agrees to comply with them. + +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY + +Dated: \_\_\_\_\_ + +By: \_\_\_\_\_ + +[REDACTED] + +ASSISTANT U.S. ATTORNEY + +Dated: 9/24/07 + +![]()Dated: \_\_\_\_\_ + +\_\_\_\_\_ +GERALD LEFCOURT, ESQ. +COUNSEL TO JEFFREY EPSTEIN + +Dated: \_\_\_\_\_ + +\_\_\_\_\_ +LILLY ANN SANCHEZ, ESQ. +ATTORNEY FOR 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 understands the conditions of this Non-Prosecution Agreement and agrees to comply with them. + +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY + +Dated: \_\_\_\_\_ + +By: \_\_\_\_\_ + +ASSISTANT U.S. ATTORNEY + +Dated: \_\_\_\_\_ + +\_\_\_\_\_ +JEFFREY EPSTEIN + +Dated: 9/24/07 + +![]()Dated: \_\_\_\_\_ + +\_\_\_\_\_ +LILLY ANN SANCHEZ, ESQ. +ATTORNEY FOR JEFFREY EPSTEIN + +By signing this agreement, Epstein assats and codifies 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 thorn. + +> It ALEXANDER ACOSTA UNITED STATES ATTORNEY + +Dated: By + +ASSISTANT U.S. ATTORNEY + +Dated: + +JEFFREY EPSTEIN + +Dated: + +Dated: qAOS I— • + +GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN + +ESQ. ATTORNEY FOR JEFFREY EPSTEIN + +IN 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: + +1. 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-party prior to the final designation of the attorney representative. +2. 7B. The parties 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. +3. 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 in s 2255 to bear the costs of the attorney representative, shall cease. + +By signing this Addenda Epstein awes and catifies that the above has been read and explained to him. Epstein herabx states that he understands the clarifications to the Non-Prosecution Agreement and agrees to comply with them. + +> R. ALEXANDER ACOSTA UNITED STATES ATTORNEY + +Dated: /0/3 O /07 + +Dated: /4 7/ 4 - + +Dated: + +Dated: + +By: + +ASSISTANT U.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 + +Dated: 10/30/07 + +By: [REDACTED] + +ASSISTANT U.S. ATTORNEY + +Dated: \_\_\_\_\_ + +\_\_\_\_\_ +JEFFREY EPSTEIN + +Dated: 10/29/07 + +Gerald Lefcourt +GERALD LEFCOURT ESQ. +COUNSEL TO JEFFREY EPSTEIN + +Dated: \_\_\_\_\_ + +\_\_\_\_\_ +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 + +[REDACTED] + +Dated: 10/30/07 + +ASSISTANT U.S. ATTORNEY + +Dated: \_\_\_\_\_ + +\_\_\_\_\_ +JEFFREY EPSTEIN + +Dated: \_\_\_\_\_ + +\_\_\_\_\_ +GERALD LEFCOURT, ESQ. +COUNSEL TO JEFFREY EPSTEIN + +![]()\_\_\_\_\_ +LILLY ANN SANCHEZ, ESQ. +ATTORNEY FOR JEFFREY EPSTEIN + +Dated: 10-29-07 + +Dec-07-07 04:55pm From-Fowler-White Burnett + +3057886201 + +T-966 P.003/004 F-976 + +Affirmation + +I, Jeffrey B. 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Sigrid McCawley <[REDACTED]>, "[REDACTED]" <[REDACTED]> +**Cc:** "[REDACTED]" <[REDACTED]>, "[REDACTED]" <[REDACTED]> +<[REDACTED]> +**Subject:** RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +**Date:** Mon, 10 May 2021 14:15:55 +0000 + +--- + +Thanks very much, Sigrid. Maxwell's counsel filed a letter on the docket on April 22, 2021 requesting a continuance of the trial to November 8, 2021. (Dkt. No. 246). + +Best, + +[REDACTED] + +--- + +**From:** Sigrid McCawley <[REDACTED]> +**Sent:** Saturday, May 8, 2021 7:35 AM +**To:** [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Hello [REDACTED] -that looks correct. What was Maxwell's proposal on a date? + +Best +Sigrid + +Sigrid McCawley +Partner + +BOIES SCHILLER FLEXNER LLP + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +[www.bsfllp.com](http://www.bsfllp.com) + +On May 7, 2021 at 6:47:17 PM EDT, [REDACTED] (USANYS) <[REDACTED]> wrote: + +Sigrid, + +We are preparing our letter to the Court about the trial date, which is due on Monday. Based on our conversation, we believe the following is accurate but please let us know if you would like to discuss: [REDACTED] is available to testify at a trial if it is scheduled to begin November 29, 2021. [REDACTED] would likely be unavailable for trial between October 1, 2021 and Thanksgiving. + +Thanks, + +[REDACTED] + +--- + +**From:** Sigrid McCawley <[REDACTED]> +**Sent:** Wednesday, May 5, 2021 6:22 PM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]> + +That works — I will dial in at 6:45. + +Sigrid McCawley + +Partner + +BOIES SCHILLER FLEXNER LLP + +www.bsfllp.com + +From: + +Sent: Wednesday, May 5, 2021 5:57 PM + +To: Sigrid McCawley. (USANYS) < + +Cc: + +Subject: RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +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, 20214:31 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 + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Wednesday, May 5, 2021 4:27 PM +**To:** Sigrid McCawley <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; +[REDACTED] <[REDACTED]> +**Subject:** RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +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] +[REDACTED] + +[www.bsfllp.com](http://www.bsfllp.com) + +**From:** [REDACTED] (USANYS) [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 contaned in this electronic message is confidential inforna0on intended only for the use of the named recipients) 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 d this electronic message is not the named recipient. or the empbyee 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 r, stnctty prohibited and no privilege is waived. If you have received this communication in error. please immediately notify the sender by replying to the electronic message and then deleting this electronic message from your computer. (v.1 082018318S9 + +The information con takied in this electronic message is confidential information intended only for the use of the named recipieM(s) and may contain information that. among other protections. is the subject of attorney-client privilege. attorney work product or exempt from disclosure under appbcable law. If the reader ad this electronic message is not the named recipient. or the employee o 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 082018318S9 + +The information cordatied 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 ad this electronic message is not the named recipient. or the employee o 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 082018318S9 + +The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contaii 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. (v.1 08201831BSF] \ No newline at end of file diff --git a/marker2/ds9/EFTA00085192/EFTA00085192.metadata.json b/marker2/ds9/EFTA00085192/EFTA00085192.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..96b432b3104b97fb57dec28111034d5c80640345 --- /dev/null +++ b/marker2/ds9/EFTA00085192/EFTA00085192.metadata.json @@ -0,0 +1,144 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085192.pdf", + "engine": { + "marker_major": "2", + "marker_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": 7679, + "elapsed_seconds": 8.54, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Text", + 41 + ], + [ + "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": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Text", + 37 + ], + [ + "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": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 66 + ], + [ + "Text", + 40 + ], + [ + "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": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 27 + ], + [ + "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/EFTA00085192" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085196/EFTA00085196.md b/marker2/ds9/EFTA00085196/EFTA00085196.md new file mode 100644 index 0000000000000000000000000000000000000000..d5400c5b7fbcaec452b28a71fe2d466c6aac2e42 --- /dev/null +++ b/marker2/ds9/EFTA00085196/EFTA00085196.md @@ -0,0 +1,215 @@ +From: "McNeil. John (CRM)" + +To: a' USANIalr ' II + +Cc: "Cole, Taylor (CRM)" Caylor.Cole®usdoj.gov> + +Subject: Maxwell 182-73090 + +Date: Tue, 03 Aug 2021 14:56:43 +0000 + +Attachments: MLAT\_ to\_ UK \_ 73090 mcn.docx + +Inline-Images: image001.png; image002.png + +Lara - + +Here is a draft back with comments and questions. Let me know what you think. Starting at COB tomorrow, I am out for a week. If you want this to go over to the UK before I depart, please turn around before COB today. + +Thx, + +John + +John T. McNeil + +U.S. Department of Justice Attache - London + +![](_page_0_Picture_13.jpeg) + +United States Embassy + +33 Nine Elms Lane + +London SW11 7US + +Desk: 020 7891 3710 + +Mobile: 0788 581 2862 + +Desk (from U.S.): 301-985-8641 Ex. 23710 + +Mobile (fron U.S.): +44 788-581-2862 + +From: (USANYS) + +Sent: Monday, August 2, 2021 6:35 PM + +To: McNeil, John (CRM) clohn.McNeil2@usdoj.gov>; + +Cc: Cole, Taylor (CRM) + +Subject: RE: British Airways + +John, + +Thanks very much for looking into this for us. We really appreciate it. Attached please find our MLAT request. Please let us know if you have any comments/questions or would like to discuss. + +Best, + +Lara + +Sent: Monday, August 2, 2021 12:07 PM + +To: (USANYS) + +Cc: Cole, Taylor (CRM) + +Subject: RE: British Airways + +Just asked the CBP Attaché. PNR records (which is ticketing information from the airline) is destroyed by CBP after 5 years. However, fight manifest information (which does not include all ticketing information) is kept for a very long period by CBP. Checking on the UK equivalent. + +## John T. McNeil + +U.S. Department of Justice Attaché - London + +![](_page_1_Picture_8.jpeg) + +United States Embassy + +33 Nine Elms Lane + +London SW11 7US + +Desk: 020 7891 3710 + +Mobile: 0788 581 2862 + +Desk (from U.S.): 301-985-8641 Ex. 23710 + +Mobile (fron U.S.): +44 788-581-2862 + +From: (USANYS) + +Sent: Monday, August 2, 2021 4:33 PM + +To: McNeil, John (CRM) ; 1.c >; + +Cc: Cole, Taylor (CRM) + +Subject: RE: British Airways + +Thanks, John. We have been working with CBP locally, but we are also interested in CBP/travel records from the UK side. Our understanding was that it only went 5 years back, but would appreciate any more information/suggestions you have. + +From: McNeil, John (CRM) + +Sent: Monday, August 2, 2021 11:23 AM + +To: (USANYS) )4S + +Cc: Cole, Taylor (CRM) + +Subject: RE: British Airways + +Neither. You should work with CBP locally to get the records from their national database. FBI may also have access to this. + +John + +![](_page_2_Picture_0.jpeg) + +United States Embassy 33 Nine Elms Lane London SW11 7US Desk: 020 7891 3710 Mobile: 0788 581 2862 Desk (from U.S.): 301-985-8641 Ex. 23710 Mobile (fron U.S.): +44 788-581-2862 + +From: (USANYS) + +Sent: Monday, August 2, 2021 3:20 PM + +To: McNeil, John (CRM) ; + +Cc: Cole, Taylor (CRM) + +Subject: RE: British Airways + +Thanks, John. Are those records that the CBP attaché can pull for us now or records we should request through the M LAT? + +Thanks, Lara + +From: McNeil, John (CRM) clohn.McNeil2@usdoj,goy> + +Sent: Monday, August 2, 2021 8:40 AM + +To: (USANYS) + +1.S + +Cc: Cole, Taylor (CRM) + +Subject: FW: British Airways + +I followed up with our CBP Attaché regarding old BA records. She thinks that CBP may have records from those dates if BA does not. (See below) + +John + +John T. McNeil + +U.S. Department of Justice Attache - London + +![](_page_2_Picture_20.jpeg) + +United States Embassy 33 Nine Elms Lane London SW11 7US Desk: 020 7891 3710 Mobile: 0788 581 2862 Desk (from U.S.): 301-985-8641 Ex. 23710 Mobile (fron U.S.): +44 788-581-2862 + +In addition to earlier response, below please find data fields for APIS. Not all information may be present in a record from that time, as there have been expansions of mandatory data collected over the years (i.e. address) but most of it would be. This includes private aircraft arrivals, after 2009 (prior to 2009 FBO could submit manual manifest). See: hftps://www.dhs.gov/sites/default/files/publications privacy-pia-cbp001i-february2021.pdf + +Full name (last, first, and, if available, middle); + +- Date of birth; +- Gender (F = female; M = male); +- Country of Citizenship; +- Country of residence; +- Status on board the conveyance; +- Travel document type (e.g., P = passport; A = alien registration card); +- Passport number, if a passport is required; +- Passport country of issuance, if a passport is required; +- Passport expiration date, if a passport is required for travel; +- Alien registration number (A-Number), where applicable; +- Address while in the United States (number and street, city, state, and zip code), except that this information is not required for U.S. citizens, lawful permanent residents (LPR), or persons who are in transit to a location outside the United States; +- Passenger Name Record (PNR) locator, if available; +- International Air Transport Association (IATA) code of foreign port/place where transportation to the United States began (foreign port code); +- IATA code of port/place of first arrival (arrival port code); +- IATA code of final foreign port/place of destination for in-transit passengers (foreign port code); +- Vessel name; +- Vessel country of registry/flag; +- Conveyance code and number (e.g., Airline carrier code, bus or rail carrier code/International Maritime Organization number, flight, bus, or train number); +- Date of arrival; +- Country/point of origin; and +- Final Destination. + +Jennifer Schroeder-Fawcett + +Attaché + +US Customs and Border Protection + +London, United Kingdom + +AOR: UK, Iceland, Ireland + +Desk: +44 (0)20 7891 3508 (forwards to UK mobile) + +US Mobile/After Hours: +1-202-710-5042 + +Email: Jennifer.L.Schroeder-Fawcett@cbp.dhs.gov + +Class: Schroeder-Fawcettiletate.sgov.gov + ++5 hours from EST + +©Follow CBP Office of International Affairs on INN t ter : + +CBPlnternational Affairs + +CBPAfrica + +CBPAsiaPacific + +CBPEurope + +CBPLatinAmerica \ No newline at end of file diff --git a/marker2/ds9/EFTA00085196/EFTA00085196.metadata.json b/marker2/ds9/EFTA00085196/EFTA00085196.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f365e8b0e537c3c81eb9cb902916ca6d6b017134 --- /dev/null +++ b/marker2/ds9/EFTA00085196/EFTA00085196.metadata.json @@ -0,0 +1,246 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085196.pdf", + "engine": { + "marker_major": "2", + "marker_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": 6043, + "elapsed_seconds": 1.71, + "image_assets": [ + "_page_0_Picture_13.jpeg", + "_page_1_Picture_8.jpeg", + "_page_2_Picture_0.jpeg", + "_page_2_Picture_20.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "John T. 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sha256:f28483373b57824678e76234f0f211475a11bcd9453c6bdb12c5a9557c047965 +size 1758 diff --git a/marker2/ds9/EFTA00085201/EFTA00085201.md b/marker2/ds9/EFTA00085201/EFTA00085201.md new file mode 100644 index 0000000000000000000000000000000000000000..8d0f3625b92b5e1c02275ebb94eced0adb228a02 --- /dev/null +++ b/marker2/ds9/EFTA00085201/EFTA00085201.md @@ -0,0 +1,231 @@ +![](_page_0_Picture_0.jpeg) + +VAA:WHG:JEC:JTM DOS No. CRM-182-73090 + +Office of nternational Affairs Washington, D.C. 20530 + +# U.S. Department of Justice Criminal Division + +FROM: The Central Authority of the United States + +TO: The Central Authority of the United Kingdom + +SUBJECT: Request for Assistance in the Matter of the Prosecution of Ghislaine Maxwell + +DATE: August —a, 2021 + +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 on 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") 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 2004. The U.S. authorities seek the following evidence from the UK:-British-Airamys-travel-reeerikr school recordsLr and-a birth certificate and border entry and exit records. + +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. + +### **PRIOR CONTACT WITH UK AUTHORITIES** + +U.S.-authorities have been in communication with officers from the [name of UK law enforcement agency] including [officer name, title, and email address]: + +### **TIME CONSTRAINTS** + +Please treat this request as urgent and execute this request it on an expedited basis. Trial in the prosecution of *United States v. Ghislaine Maxwell* is scheduled to begin on November 29, 2021, with production of evidence required in advance of trial. Accordingly, the U.S. authorities seek to acquire material as requested herein as soon as possible, and no later than October 15, 2021. + +### **CONFIDENTIALITY** + +Please treat this request as confidential. 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 the existence of this request could seriously jeopardize the investigation or compromise the trial of Maxwell, by prompting others to destroy or tamper with evidence; change patterns of behavior; causing others to intimidate potential witnesses, or alert others who could do the same. Accordingly, pursuant to articles 4(3)(j) and 7 of the Treaty, please keep this request confidential and please ensure that neither its contents nor its subject matter are shared with any persons (including the subjects of the investigation), or with any government officials whose knowledge is not necessary for purposes of executing this request. + +### 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-beettwas 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. 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. + +On or about March 29, 2021, a grand jury in the Southern District of New York returned a Superseding Indictment charging Maxwell with violations of U.S. criminal laws. The Superseding Indictment alleges that from at least in or about 1994, up to and including at least in or about 2004, 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. The Superseding Indictment also alleges that Maxwell participated in a sex trafficking conspiracy between approximately 2001 and 2004 and that Maxwell participated in the + +sex trafficking of a minor, and aided and abetted the same. Finally, the Superseding 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 Superseding Indictment describes Maxwell's conduct as to four particular minor victims. Among other things, Maxwell groomed and befriended one of the minor victims, in London, England between approximately 1994 and 1995, including during a period of time in which Maxwell knew that De Georgiou was under the age of IS. Maxwell introduced De Georgiou to Epstein in London and encouraged o massage Epstein, knowing that Epstein would engage in sex acts with De Georgiou during those massages. Epstein and Maxwell invited United States and Europe. travel with them to various places, including in the + +It is anticipated that will testify at trial. U.S. authorities seek evidence front several sources to corroborate this testimony. First. U.S. authorities seek records oll.=IM attendance at Collingham College in London between 1994 and 1995 and the University of Oxford in Oxford during XXX. Second. U.S. authorities seek a cony of birth certificate to establish her age at the time of the charged conduct. Third. U.S. authorities recuest records held by the UK government (including nassnon. border, and other records) reflecting any travel outside of the UK. and any entries into the UK. during 1994 and 1995. as well as documentation related to the destinations to which she travelled, and identifying information about any persons travelling with her. U.S. authorities note that is cooperating with prosecutors in this case and has consented to the production of any responsive records. + +### 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 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 + +( I) (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 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, + +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. + +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. + +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 (eX2), 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 the 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.1 + +### 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. + +### PERSONS AND ENTITIES INVOLVED + +Name: Ghislaine Maxwell Date of Birth: 25 December 1961 Place of Birth: Maison-Laffitte, France Citizenship: U.S., UK, France + +Name: Jeffrey Epstein Date of Birth: 20 January 1953 Place of Birth: New York, United States + +3 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. + +Citizenship: U.S. + +Name: [REDACTED] +Date of Birth: 04 March 1977 +Place of Birth: United Kingdom +Citizenship: UK + +**ASSISTANCE NEEDED** + +**Business Records** + +*British Airways* + +*Please provide all account information and travel records from British Airways for the following individuals:* + +- • — *Ghislaine Maxwell* +- • — *Jeffrey Epstein* +- • — [REDACTED] + +*Records are requested for the period 1993-to-1999 and should include, but not be limited to, the following:* + +- • — *Please provide any and all records, including but not limited to passenger, travel, payment, membership or loyalty records, or any other records, for each of the above-listed individuals;* + +*Collingham College* + +Please provide records demonstrating the enrollment and attendance of [REDACTED], including but not limited to registration paperwork and student files, reflecting the dates of enrollment at Collingham College (23, Collingham Gardens, London SW5) on or about DATES, for [REDACTED]. + +*University of Oxford* + +Please provide records demonstrating the attendance of [REDACTED] at University of Oxford on or about DATES, including but not limited to application, registration + +**Commented [A1]:** Do you know which college? that would assist. +Author + +paperwork, and student files, reflecting the dates of application and enrollment at University of Oxford for [REDACTED]. + +**Commented [A2]:** This is too broad because it might include medical records and counselling records, which will sink this request. +Author + +### Official Records + +#### Birth Certificate + +Please provide a certified copy of a birth certificate of [REDACTED]. + +#### Travel/Border Records + +Please provide all records held by the UK government (including passport, border, and other records) reflecting any travel outside of the UK, and any entries into the UK, during 1994 and 1995. With regard to such travel, U.S. authorities also request documents reflecting the destinations to which she travelled and identifying information about any persons travelling with her. + +complete UK-official records, including but not limited to of and/or from Her Majesty's Passport Office, as set forth below, for the period between 1993 and 1999: + +- • Documentation of any birth certificate, or other record or statement of birth, of [REDACTED] +- • Documentation of any passports used by [REDACTED] to enter and/or exit the UK (and where De Georgiou traveled); (not sure if this is something that Passport Office can provide?) + +### PROCEDURES TO BE FOLLOWED + +#### Business Records + +Under United States law, foreign business records are usually admitted into evidence in a proceeding in the United States after the party offering them proves, through the testimony at trial of a qualified witness, that: + +1. 1. the records produced are true and accurate copies of original records in the custody of the business; + +- 2. the business made or kept the originals in the ordinary course of business and as a regular business practice; and +- 3. the originals were made, at or near the time of the occurrence of the transactions they record, by a person who either had knowledge of those transactions or received the information from a person with such knowledge. + +The testimony of a qualified witness may be unnecessary at trial in the United States where that witness makes or provides a written declaration in a foreign jurisdiction (Le., the United Kingdom) that (I) contains essentially the same information noted in items 1-3 above and (2) subjects the witness to criminal penalties under the laws of the foreign jurisdiction if the declaration is false. Article 8(5) of the Treaty provides for such a declaration. + +In accordance with Article 8 of the Treaty, please have the appropriate authorities in the United Kingdom do the following: + +- 1. require each business official producing records to complete, and sign the attached Certificate of Authenticity of Business Records; and +- 2. attach the completed certificate to the corresponding records produced by the business official and transmit the records with certificate, through or as directed by the Central Authority for the United Kingdom, to the Office of International Affairs, U.S. Department of Justice. + +In accordance with Article 10(2) of the Treaty, please invite each business official producing records to appear, if it should become necessary, at a date to be determined in December 2021, at the United States District Court for the Southern District of New York, 40 Foley Square, Courtroom 906, at the expense of the United States government, to testify at trial. + +Please notify entities submitting responsive records that if they fail to complete the necessary certificate, U.S. authorities will need to seek a compelled interview and compelled trial testimony under the terms of the Treaty. Completing the necessary certificate will likely avoid the need for such an interview or testimony. + +### Official Records + +Under United States law, foreign official records are usually admitted into evidence in a proceeding in the United States only after the party offering them proves, through a qualified witness who either gives testimony at trial or provides a certification, that + +- 1. the records are true and accurate copies of records maintained by a foreign government office or agency; +- 2. the foreign government office or agency is authorized by foreign law to maintain them; and +- 3. the foreign official providing the records is doing so in his or her official capacity. + +Because a certification containing the information noted above is sufficient, please: + +in accordance with Article 9(3) of the Treaty, have the appropriate custodian of official records complete the attached Attestation of Authenticity of Foreign Public Documents; and + +attach the completed certificate to the corresponding records produced by the official and transmit the records with certificate, through or as directed by the Central Authority for the United Kingdom, to the Office of International Affairs, U.S. Department of Justice. + +### CONCLUSION + +We thank you for your assistance with this matter of the prosecution of Ghislaine Maxwell and ask that you keep us apprised of all developments. + +Date Jason E. Carter Associate Director Office of International Affairs Criminal Division U.S. Department of Justice + +### CERTIFICATE OF AUTHENTICITY OF BUSINESS RECORDS + +(Name), attest on penalty of criminal punishment for false statement or false attestation that I am employed by (Name of Business from which documents are produced) and that my official title is (Official Title). I further state that each of the records attached hereto is the original or a duplicate of the original of records in the custody of (Name of Business from which documents are produced). I further state that: + +- A) such records were made at or near the time of the occurrence of the matters set forth, by (or from information transmitted by) a person with knowledge of those matters; +- B) such records were kept in the course of a regularly conducted business activity; +- C) the business activity made the records as a regular practice; and +- D) if any of such records is not the original, such record is a duplicate of the original. + +(Signature) + +(Date) + +Sworn to r affirmed before me, (Name), a (notary public, judicial officer, etc.), this day of , 20 + +# ATTESTATION OF AUTHENTICITY OF FOREIGN PUBLIC DOCUMENTS + +(Name), attest on penalty of criminal punishment for + +false statement or attestation that my position with the Government of + +(Country) is (Official + +Title) and that in that position I am authorized by the law of + +(Country) to attest that the documents attached and described below are true and accurate copies + +of original official records which are recorded or filed in + +(Name of Office or Agency) which is a government office or agency of the Government of + +(Country). + +Description of Documents: + +(Signature) + +(Title) + +(Date) \ No newline at end of file diff --git a/marker2/ds9/EFTA00085201/EFTA00085201.metadata.json b/marker2/ds9/EFTA00085201/EFTA00085201.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c47d9fb975a0945534c860d3d0fa6811a4c8d330 --- /dev/null +++ b/marker2/ds9/EFTA00085201/EFTA00085201.metadata.json @@ -0,0 +1,1031 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085201.pdf", + "engine": { + "marker_major": "2", + "marker_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": 20149, + "elapsed_seconds": 8.07, + "image_assets": [ + "_page_0_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice \nCriminal Division", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 260.1, + 157.95 + ], + [ + 371.07391357421875, + 157.95 + ], + [ + 371.07391357421875, + 190.982421875 + ], + [ + 260.1, + 190.982421875 + ] + ] + }, + { + "title": "PRIOR CONTACT WITH UK AUTHORITIES", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 135.864, + 189.54000000000002 + ], + [ + 327.42, + 189.54000000000002 + ], + [ + 327.42, + 202.5 + ], + [ + 135.864, + 202.5 + ] + ] + }, + { + "title": "TIME CONSTRAINTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 182.988, + 252.71999999999997 + ], + [ + 280.296, + 252.71999999999997 + ], + [ + 280.296, + 264.87 + ], + [ + 182.988, + 264.87 + ] + ] + }, + { + "title": "CONFIDENTIALITY", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 185.43599999999998, + 379.08000000000004 + ], + [ + 277.236, + 379.08000000000004 + ], + [ + 277.236, + 391.23 + ], + [ + 185.43599999999998, + 391.23 + ] + ] + }, + { + "title": "THE FACTS", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 203.796, + 148.23 + ], + [ + 261.378173828125, + 148.23 + ], + [ + 261.378173828125, + 159.57000000000002 + ], + [ + 203.796, + 159.57000000000002 + ] + ] + }, + { + "title": "THE OFFENSES", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 195.228, + 620.46 + ], + [ + 269.8420715332031, + 620.46 + ], + [ + 269.8420715332031, + 632.7324066162109 + ], + [ + 195.228, + 632.7324066162109 + ] + ] + }, + { + "title": "Title 18, United States Code, Section 371 Conspiracy", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 52.019999999999996, + 210.60000000000002 + ], + [ + 293.6698913574219, + 210.60000000000002 + ], + [ + 293.6698913574219, + 222.482421875 + ], + [ + 52.019999999999996, + 222.482421875 + ] + ] + }, + { + "title": "Title 18. 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--- /dev/null +++ b/marker2/ds9/EFTA00085213/EFTA00085213.md @@ -0,0 +1,33 @@ +![](_page_0_Picture_1.jpeg) + +United States Attorney Southern District of New York + +86 Chambers Street New York, New York 10007 + +April 28, 2021 + +## Submitted Ex Pane and Under Seal 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 ("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. I write respectfully to update the Court on the status of United States v. Noel, I 9-cr-830 (AT), and to explain the basis for the Government's request, submitted contemporaneously by public letter motion, to extend the deadlines for the parties to submit a proposed schedule for the production of remaining documents and for the Government to produce remaining documents. + +Today, this Office preliminarily approved and submitted to Pretrial Services for its review deferred prosecution agreements covering both of the defendants in Noel. Before the agreements can be finalized, Pretrial Services must accept the defendants for supervision pursuant to the proposed agreements and conduct a Pretrial Services investigation in advance of doing so. Pretrial Services has indicated that this process will be completed within forty-five days, although this Office is seeking to expedite Pretrial Services's review. Following Pretrial Services's review, the defendants must review and accept the final agreements. In the event Pretrial Services is able to expedite its review, the Government estimates that approximately one month remains before any final deferred prosecution agreements could be submitted to Judge Torres and publicly disclosed, including to the Times. + +The Government understands that its proposed schedule is not as expeditious as the Court initially ordered, but believes there is an increasing likelihood that Noel will resolve shortly. The Government's present request is intended to conserve the resources of the Government and the Court with respect to the Government's reliance on Exemption 7(A) on the basis of the Noel prosecution. The Government has made and will continue to make best efforts to process records in connection with its reliance on other exemptions and Exemption 7(A) on the basis of United States v. Tartaglione, I 6-cr-832 (KMK). The Government also intends to precisely mark out its reliance on Exemption 7(A) on the basis of the Noel prosecution in its upcoming production of documents withheld in full or in part under Exemption 7(A) on the basis of Tartaglione. + +Because of the sensitive and confidential nature of this Office's efforts to resolve Noel, the Government respectfully requests that this letter be filed ex parte and under seal and that it remain under seal until Noel is resolved. + +I thank the Court for its consideration of this submission. + +Respectfully submitted, + +AUDREY STRAUSS United States Attorney + +By: Steven J. Kochevar + +Steven J. 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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. I write respectfully to seek a two-day extension, from April 30, 2021, to May 4, 2021, to complete the Government's initial production of records for the Court's in camera review, a one-month extension, from April 30, 2021, to May 31, 2021, of the parties' time to submit a schedule to the Court concerning remaining records, and a one-month extension, from May 14, 2021, to June 14, 2021, of the deadline for the Government to produce remaining documents for in camera review. This is the Government's first request for an extension of the April 30, 2021, and May 14, 2021, deadlines. The Times consents to these requests. + +The Government has made—and continues to make—substantial efforts to comply with the April 30, 2021, in camera production deadline, but needs two additional business days to finalize the production. The production involves review by multiple prosecution teams and the BOP, as well as a process of combining the results of the various reviews into a single document reflecting redactions on all applicable grounds. While the review processes have been occurring in parallel and some are complete, the government needs some additional to combine, review and finalize the production before submitting it to the Court. The government anticipates it can complete any remaining review and finalize the production by May 4, 2021. + +The reasons for the Government's request to extend by one month the deadlines to submit a schedule for the production of any remaining documents and to submit such documents is set out in the Government's ex parte and under seal submission filed contemporaneously herewith. + +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/EFTA00085215/EFTA00085215.metadata.json b/marker2/ds9/EFTA00085215/EFTA00085215.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7c7f65147af3d35869bb71c595cd0ed82fdcf703 --- /dev/null +++ b/marker2/ds9/EFTA00085215/EFTA00085215.metadata.json @@ -0,0 +1,149 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085215.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2585, + "elapsed_seconds": 1.04, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 319.464, + 32.400000000000006 + ], + [ + 463.8363037109375, + 32.400000000000006 + ], + [ + 463.8363037109375, + 46.17 + ], + [ + 319.464, + 46.17 + ] + ] + }, + { + "title": "By ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 160.9202880859375 + ], + [ + 116.34480285644531, + 160.9202880859375 + ], + [ + 116.34480285644531, + 174.68701171875 + ], + [ + 68.544, + 174.68701171875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 38 + ], + [ + "Text", + 10 + ], + [ + "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", + 25 + ], + [ + "Line", + 13 + ], + [ + "Text", + 10 + ], + [ + "PageHeader", + 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/EFTA00085215" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085215/_page_0_Picture_1.jpeg b/marker2/ds9/EFTA00085215/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..8f85a7cfebc4f752b5cc9ca3be4e4863bb63aa2c --- /dev/null +++ b/marker2/ds9/EFTA00085215/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:89df919597348348208f8173ce5447f55f43956d54881f2e5a480d35eb70a4ad +size 3729 diff --git a/marker2/ds9/EFTA00085217/EFTA00085217.md b/marker2/ds9/EFTA00085217/EFTA00085217.md new file mode 100644 index 0000000000000000000000000000000000000000..d0646b50561045b9628454898acd4a88d58b7c1c --- /dev/null +++ b/marker2/ds9/EFTA00085217/EFTA00085217.md @@ -0,0 +1,29 @@ +![](_page_0_Picture_1.jpeg) + +United States Attorney Southern District of New York + +86 Chambers Street New York, New York 10007 + +April 28, 2021 + +## 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") seeking the release of certain records related to Jeffrey Epstein. I write respectfully pursuant to Rule 4.B.2 of the Court's Individual Rules and Practices in Civil Cases to seek leave to file under seal and ex parte a letter to the Court, which will be filed contemporaneously with this public letter on ECF and electronically related to it. As set out in greater detail in the letter, the basis for the sealing request is that the letter contains sensitive and confidential information that cannot be described publicly in greater detail without compromising confidentiality. + +The Government has conferred with the Times about the filing of the sealed, ex parte letter. + +I thank the Court for its consideration of this submission. + +Respectfully submitted, + +AUDREY STRAUSS + +United States Attorney + +By: Steven J. Kochevar Steven J. 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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. I write respectfully to update the Court on the status of United States v. Noel, I 9-cr-830 (AT), and to explain the basis for the Government's request, submitted contemporaneously by public letter motion, to extend the deadlines for the parties to submit a proposed schedule for the production of remaining documents and for the Government to produce remaining documents. + +Today, this Office preliminarily approved and submitted to Pretrial Services for its review deferred prosecution agreements covering both of the defendants in Noel. Before the agreements can be finalized, Pretrial Services must accept the defendants for supervision pursuant to the proposed agreements and conduct a Pretrial Services investigation in advance of doing so. Pretrial Services has indicated that this process will be completed within forty-five days, although this Office is seeking to expedite Pretrial Services's review. Following Pretrial Services's review, the defendants must review and accept the final agreements. In the event Pretrial Services is able to expedite its review, the Government estimates that approximately one month remains before any final deferred prosecution agreements could be submitted to Judge Torres and publicly disclosed, including to the Times. + +The Government understands that its proposed schedule is not as expeditious as the Court initially ordered, but believes there is an increasing likelihood that Noel will resolve shortly. The Government's present request is intended to conserve the resources of the Government and the Court with respect to the Government's reliance on Exemption 7(A) on the basis of the Noel prosecution. The Government has made and will continue to make best efforts to process records in connection with its reliance on other exemptions and Exemption 7(A) on the basis of United States v. Tartaglione, I 6-cr-832 (KMK). The Government also intends to precisely mark out its reliance on Exemption 7(A) on the basis of the Noel prosecution in its upcoming production of documents withheld in full or in part under Exemption 7(A) on the basis of Tartaglione. + +Because of the sensitive and confidential nature of this Office's efforts to resolve Noel, the Government respectfully requests that this letter be filed ex parte and under seal and that it remain under seal until Noel is resolved. + +I thank the Court for its consideration of this submission. + +tf 11 .mitt + +![](_page_1_Picture_5.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00085218/EFTA00085218.metadata.json b/marker2/ds9/EFTA00085218/EFTA00085218.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e499fc523748cc155e678b70c96e6509df4aa7cf --- /dev/null +++ b/marker2/ds9/EFTA00085218/EFTA00085218.metadata.json @@ -0,0 +1,154 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085218.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3125, + "elapsed_seconds": 0.75, + "image_assets": [ + "_page_0_Picture_1.jpeg", + "_page_1_Picture_5.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 319.464, + 31.589999999999996 + ], + [ + 463.70361328125, + 31.589999999999996 + ], + [ + 463.70361328125, + 46.353515625 + ], + [ + 319.464, + 46.353515625 + ] + ] + }, + { + "title": "Submitted Ex Pane and Under Seal By ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 159.57000000000002 + ], + [ + 301.5447082519531, + 159.57000000000002 + ], + [ + 301.5447082519531, + 174.603515625 + ], + [ + 68.544, + 174.603515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 42 + ], + [ + "Text", + 9 + ], + [ + "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", + 19 + ], + [ + "Line", + 9 + ], + [ + "Text", + 4 + ], + [ + "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/EFTA00085218" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085218/_page_0_Picture_1.jpeg b/marker2/ds9/EFTA00085218/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..3b9d3b17511817fa0b9fc14884f3200ff4572a42 --- /dev/null +++ b/marker2/ds9/EFTA00085218/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:7d05c1d5785aa107fb881dd7b779782fed0a20aa251e4b43a26aa4c1a7444e5a +size 3640 diff --git a/marker2/ds9/EFTA00085218/_page_1_Picture_5.jpeg b/marker2/ds9/EFTA00085218/_page_1_Picture_5.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..1b041864baffb02d6583a628f0b218990182af86 --- /dev/null +++ b/marker2/ds9/EFTA00085218/_page_1_Picture_5.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:dfae6344dddf9d7fcfbf5d7e47370f0f772b415ff66c65e48456bc93af334460 +size 6360 diff --git a/marker2/ds9/EFTA00085220/EFTA00085220.md b/marker2/ds9/EFTA00085220/EFTA00085220.md new file mode 100644 index 0000000000000000000000000000000000000000..e25e2d76d63473b37df8b3ca247428edf2960b41 --- /dev/null +++ b/marker2/ds9/EFTA00085220/EFTA00085220.md @@ -0,0 +1,57 @@ +**From:** [REDACTED] +**To:** [REDACTED] +<[REDACTED]>, "[REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED] +[REDACTED]" <[REDACTED]> + +**Cc:** "[REDACTED] (USANYS) [Contractor]" <[REDACTED]> + +**Subject:** RE: 042921 -- SDNY -- US v Maxwell -- Maxwell letter -- request from Reuters + +**Date:** Fri, 30 Apr 2021 12:47:20 +0000 + +Thanks, [REDACTED] + +--- + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Thursday, April 29, 2021 9:50 PM +**To:** [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] +[REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] (USANYS) [Contractor] <[REDACTED]> +**Subject:** FW: 042921 -- SDNY -- US v Maxwell -- Maxwell letter -- request from Reuters + +For your awareness, we declined on the inquiry below. + +--- + +**From:** [REDACTED] +**Sent:** Thursday, April 29, 2021 6:07 PM +**To:** [REDACTED] +**Cc:** [REDACTED] +**Subject:** Re: 042921 -- SDNY -- US v Maxwell -- Maxwell letter -- request from Reuters + +Decline from SDNY. Thanks, Jon + +Sent from my iPhone + +On Apr 29, 2021, at 4:58 PM, Stempel, Jonathan E. (Reuters) [REDACTED] > wrote: + +To Whom It May Concern: + +I am a reporter with Reuters in New York, and hope all there are well and safe. + +I was assigned to write up the attached letter, including its discussion of the apparent bruise around Ghislaine Maxwell's left eye, and would welcome any comment concerning the letter, the timing and origin of the bruise, and what is being done about it. + +I have copied the US attorney's office in Manhattan here. I recognize that communications on behalf of the government regarding Maxwell's confinement conditions are coming from multiple sources. [REDACTED] a lawyer for MDC filed one such communication today. + +Thomson Reuters + +Phone: Mobile + +![](_page_1_Picture_3.jpeg) + +This e-mail is for the sole use of the intended recipient and contains information that may be privileged and/or confidential. If you are not an intended recipient, please notify the sender by return e-mail and delete this e-mail and any attachments. Certain required legal entity disclosures can be accessed on our website: + +https://www.thomsonreuters.com/en/resources/disclosures.html + +<042921 -- SDNY -- US v Maxwell -- Maxwell letter.pdf> \ No newline at end of file diff --git a/marker2/ds9/EFTA00085220/EFTA00085220.metadata.json b/marker2/ds9/EFTA00085220/EFTA00085220.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f7dfb47c96fa130896ca0d1007a5092be6a9d114 --- /dev/null +++ b/marker2/ds9/EFTA00085220/EFTA00085220.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085220.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2248, + "elapsed_seconds": 7.15, + "image_assets": [ + "_page_1_Picture_3.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Text", + 43 + ], + [ + "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", + 21 + ], + [ + "Line", + 11 + ], + [ + "Text", + 6 + ], + [ + "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/EFTA00085220" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085220/_page_1_Picture_3.jpeg b/marker2/ds9/EFTA00085220/_page_1_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..cbc1d4a2df514937afa3a62d627b01d1d40e6e91 --- /dev/null +++ b/marker2/ds9/EFTA00085220/_page_1_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:60a6508bac47c168a4fa47b9b23c46ac35a3bb0e3cb598f5b325cf3fd30ef768 +size 2379 diff --git a/marker2/ds9/EFTA00085222/EFTA00085222.md b/marker2/ds9/EFTA00085222/EFTA00085222.md new file mode 100644 index 0000000000000000000000000000000000000000..9143a4c11eab74448c4696e4ce6b1bb67eeea2ba --- /dev/null +++ b/marker2/ds9/EFTA00085222/EFTA00085222.md @@ -0,0 +1,114 @@ +From: To: [Contractor (USANYS) [Contractor]" (USANYS) (USANYS) [Contractor]" Cc: a)" ; (USANYS) [Contractor] Subject: RE: Follow Up >\*, + +Thanks! Would you mind dating them for tomorrow, please? I want to just confirm with the team and the chiefs that we are good with the plan to produce these before I send them out. + +From: (USANYS) (Contractor] Sent: Sunday, May 2, 20218:59 PM To: >; (USANYS) [Contractor] <1 Cc: ; >\*, + +Updated cover letter and zipped production attached (both dated for today). + +From: Sent: Sunday, May 2, 20218:44 PM To: (USANYS) [Contractor] < Cc: Subject: RE: Follow Up >; (USANYS) (Contractor) (USANYS) [Contractor] (USANYS) + +And the cover letter looks great, thanks very much. Just two small changes: + +- Would you please make sure the font is all the same size? It looks like one of the bates numbers may be smaller than the rest of the letter. +- Would you please add name to the signature block? + +With those changes, this is good to produce. If this is small enough to email, would you mind putting the production into a zip file for me to email to defense counsel, please? + +Sent: Sunday, May 2, 2021 8:42 PM + +To: (USANYS) [Contractor] < (USANYS) [Contractor) + +Cc: < >; (USANYS) < ::. + +(USANYS) [Contractor] < + +Subject: RE: Follow Up + +Thanks so much! Yes, please include this production on the drive. Thanks again. + +From: (USANYS) [Contractor] + +Sent: Sunday, May 2, 2021 8:30 PM + +To: (USANYS) [Contractor] >; + +Cc: S.; (USANYS) < + +(USANYS) [Contractor] + +Subject: RE: Follow Up + +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, 2021 6:15 PM + +To: (USANYS) [Contractor] < (USANYS) [Contractor) + +Cc: < >; (USANYS) + +(USANYS) [Contractor] < + +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: (usANys)< > >; + +Cc: Sigrid McCawley + +As a follow up to our call this morning -- the attached pictures were produced as part of [REDACTED] civil case. + +As to [REDACTED] photos –BSF only has electronic copies. The originals are with [REDACTED] in Texas. + +As to the one photo of [REDACTED] – BSF only has electronic copies – the original would be with [REDACTED] in Arkansas. + +You will see that the [REDACTED] pictures have both the [REDACTED] bates number and the [REDACTED] bates number. As reference in the redacted 302 (clipped below) the originals of these photos were taken into custody by the FBI so [REDACTED] 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, SA [REDACTED] and [REDACTED] traveled to [REDACTED] residence where she provided 20 photographs and her ITM massage school certification. FD-597 Receipts for Property were executed for the items and a copy was provided to [REDACTED]. It is noted that 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. + +b6 +b7C + +Sigrid McCawley +Partner + +BOIES SCHILLER FLEXNER LLP + +[REDACTED] +[REDACTED] +[REDACTED] + +[www.bsfllp.com](http://www.bsfllp.com) + +--- + +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. [v.1 08201831BSF] \ No newline at end of file diff --git a/marker2/ds9/EFTA00085222/EFTA00085222.metadata.json b/marker2/ds9/EFTA00085222/EFTA00085222.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4061208e1ad2cf24f6362ed2f04e4bd9181ad56f --- /dev/null +++ b/marker2/ds9/EFTA00085222/EFTA00085222.metadata.json @@ -0,0 +1,122 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085222.pdf", + "engine": { + "marker_major": "2", + "marker_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": 4964, + "elapsed_seconds": 8.59, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 100 + ], + [ + "Line", + 46 + ], + [ + "Text", + 13 + ], + [ + "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", + 104 + ], + [ + "Line", + 50 + ], + [ + "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": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Line", + 28 + ], + [ + "Text", + 24 + ], + [ + "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/EFTA00085222" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085225/EFTA00085225.md b/marker2/ds9/EFTA00085225/EFTA00085225.md new file mode 100644 index 0000000000000000000000000000000000000000..831788facde733054c5c19fb676d1ccc4de23f8a --- /dev/null +++ b/marker2/ds9/EFTA00085225/EFTA00085225.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/EFTA00085225/EFTA00085225.metadata.json b/marker2/ds9/EFTA00085225/EFTA00085225.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2353140563e15ef2e0301ed2a24a15ec898cb38b --- /dev/null +++ b/marker2/ds9/EFTA00085225/EFTA00085225.metadata.json @@ -0,0 +1,1810 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085225.pdf", + "engine": { + "marker_major": "2", + "marker_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": 67256, + "elapsed_seconds": 12.3, + "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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McCawley + +![](_page_0_Picture_3.jpeg) + +March 22, 2021 + +## VIA EMAIL (FILED UNDER SEAL) + +The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, New York 10007 + +> Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Rule 17 Subpoena to Boies Schiller Flexner LLP + +Dear Judge Nathan: + +I write on behalf of Boies Schiller Flexner LLP ("BSF") with respect to Defendant Ghislaine Maxwell's motion for an order authorizing a subpoena on BSF pursuant to Rule 17(c)(3) of the Federal Rules of Criminal Procedure (the "Subpoena") and the Court's March 12, 2021, Sealed and Ex Pane Order requiring BSF to file a letter indicating (1) whether service on BSF can be deemed adequate notice on victims whose personal or confidential information the Subpoena is aimed at obtaining and (2) whether the victims object to or seek modification of the Subpoena. + +First, BSF does not object to service on BSF constituting adequate notice on any victims it represents. The Order and Subpoena, however, do not indicate which victims are to be provided with notice. The Order states that the Defendant identified five individuals who require notice, but the Subpoena appears to seek personal and confidential information about all of the Epstein victims that BSF represents, which is more than five individuals. Thus, in an abundance of caution, BSF will notify each of the Epstein victims it represents, unless otherwise directed by the court. Second, BSF, both on its own behalf and behalf of the women that it represents, objects to the Subpoena in its entirety for the following reasons. + +## BACKGROUND + +The Government in this case has charged the Defendant with enticing (and conspiracy to entice) minors to travel to engage in illegal sex acts and transportation of (and conspiracy to transport) minors with intent to engage in criminal sexual activity from 1994 to 1997. The facts underlying those charges involve three minor victims: Minor Victim-1, Minor Victim-2, and Minor Victim-3. The Government has also charged the Defendant with two counts of jury for lying under oath during a civil deposition in a defamation action brought by when asked if she was aware of Jeffrey Epstein's sex trafficking scheme and whe er s e a ever iven Minor Victim-2 a massage. BSF represents Minor Victim-2 i and but does not represent and has never represented Minor Victim-1 or Minor Victim- . + +Defendant has made clear since the time of her arrest that she seeks to impugn the credibility of her accusers by constructing a false narrative that BSF's cooperation with the + +March 22, 2021 + +Page 2 of 7 + +Government prior to the arrest was somehow improper and that her accusers, several of whom BSF represents, are lying in order to obtain settlements. See Letter from L. Mennin er to Hon. Debra C. Freeman at 2-3, + +ECF No. 108 (accusing of "working during the pendency of this lawsuit with the Southern District of New York's U.S. Attorney's Office to try to circumvent Ms. Maxwell's Fifth Amendment rights in advance of the June 29, 2020 indictment"); id. at 3 ("The fact that seeks, money from the Estate and from Ms. Maxwell, in the millions of dollars, at t re same time she is a government witness in an upcoming criminal trial on the same topic is reason enough to suspect that her newly asserted memories of abuse—without corroboration—are not based on the truth or a desire for `justice' so much as her desire for cash." emphases in original)); Maxwell's Motion to Stay Pending Appeal at 4, 8-10, + +ECF No. 10-1 (explaining the Defendant's "concerns that and [BSF] were acting as either express or de facto agents of the government" and falsely accusing BSF of leaking a confidential deposition transcript to the Government). The Subpoena, which seeks, for example, communications between BSF and the Government and BSF's submissions on behalf of its clients to an independent claims program administered by Jeffrey Epstein's Estate, is a transparent attempt to further this false narrative and to fish for potential impeachment material. But a fishing expedition for potential impeachment material goes well beyond the scope of a permissible Rule 17(c) subpoena. The Defendant's motion to authorize service of the Subpoena on BSF should be denied.' + +## THE REQUIREMENTS OF RULE 17(C) + +Rule 17(c) of the Federal Rules of Criminal Procedure Rule governs nonparty subpoenas in criminal proceedings. Rule 17(c) "was not intended to provide a means of discovery for criminal cases." United States v. Nixon, 418 U.S. 683, 698 (1974); see also, e.g., United States v. Barnes, 560 F. App'x 36, 39 (2d Cir. 2014) ("Rule 17 subpoenas are properly used to obtain admissible evidence, not as a substitute for discovery."); United States v. Cherry, 876 F. Supp. 547, 553 (S.D.N.Y. 1995) (explaining that although the civil rules permit subpoenas "to seek production of documents or other materials which, although not themselves admissible, could lead to admissible evidence," criminal "Rule 17(c) cannot be used to obtain leads as to the existence of additional documentary evidence or to seek information relating to the defendant's case" (internal quotation marks omitted)). Accordingly, a party seeking a Rule 17(c) subpoena must demonstrate: + +- (1) that the documents are evidentiary and relevant; (2) that they are not otherwise procurable reasonably in advance of trial by exercise of due diligence; (3) that the + +A motion to quash the Subpoena is not yet ripe because, without having the benefit of the Defendant's sealed briefing on her motion and any other orders pertaining to it, it appears that the Court has not granted Defendant's motion for an order authorizing service of the Subpoena on BSF. The Court, however, should exercise its discretion and deny the Defendant's motion. See United States v. Weissman, No. 01 Cr. 529 (BSJ), 2002 WL 1467845, at \*1 (S.D.N.Y. July 8, 2002) ("Rule 17(c) expressly commits the decision whether to require pre-trial production of documents to the sound discretion of the court."). Should the Court wish to hear further from BSF prior to deciding the Motion, BSF is prepared to appear before the Court and/or move to intervene and to quash the Subpoena. + +March 22, 2021 + +Page 3 of 7 + +party cannot properly prepare for trial without such production and inspection in advance of trial and that the failure to obtain such inspection may tend unreasonably to delay the trial; and (4) that the application is made in good faith and is not intended as a general "fishing expedition." + +Nixon, 418 U.S. at 699-700. In other words, the proponent of a Rule 17(c) subpoena "must clear three hurdles: (1) relevancy; (2) admissibility; (3) specificity." Id. at 700. Finally, "Rule 17(c) subpoenas may not issue prior to trial to obtain materials usable only to impeach." United States v. Pena, No. 15 Cr. 551 (AJN), 2016 WL 8735699, at \*2 (S.D.N.Y. Feb. 12, 2016) (Nathan, J.) (granting motion to quash Rule 17(c) subpoena for all records relating to cooperating witnesses); see also Nixon, 418 U.S. at 701 ("Generally, the need for evidence to impeach witnesses is insufficient to require its production in advance of trial."); Cherry, 876 F. Supp. at 553 ("[D]ocuments are not evidentiary for Rule 17(c) purposes if their use is limited to impeachment."). + +## THE SUBPOENA FAILS TO MEET THE REQUIREMENTS OF RULE 17(C) + +The Defendant cannot demonstrate that the Subpoena meets Rule 17(c)'s requirements for four, independent reasons. First, the Subpoena is overbroad and non-specific, and a clear fishing expedition to "see what may turn up." See United States v. ilvenatti,No. (81) 19 CR. 373 (PGG), 2020 WL 86768, at \*4 (S.D.N.Y. Jan. 6, 2020) (denying motion for issuance of Rule 17(c) subpoena). "Subpoenas seeking `any and all' materials, without mention of `specific admissible evidence,' justify the inference that the defense is engaging in the type of `fishing expedition' prohibited by Nixon." United States v. Mendinueta-Ibarro, 956 F. Supp. 2d 511, 512-513 (S.D.N.Y. 2013) (internal quotation marks omitted) (granting motion to quash Rule 17(c) subpoena). + +Here, the Subpoena plainly fails Nixon's specificity requirement. Requests 1 through 5 all seek "communications" between "You" and a designated individual or entity, including the U.S. Attorney and BSF's co-counsel, about a certain subject. The Subpoena defines "communications" as "all forms of correspondence, including regular mail, email, text message, memorandum, or other written communication of information of any kind," and defines "You" as "any owner, shareholder, partner or employee of Boies, Schiller, Flexner, LLP, including but not limited to David Boies, Sigrid McCawley, Peter Skinner and any former owner, shareholder, partner or employee, or independent contractor of the firm." Such broad Requests are plainly overbroad and non-specific, and do not meet the strict requirements of Rule 17(c). See, e.g., Mendinueta-lbarro, 956 F. Supp. 2d at 512-513 (quashing subpoena that requested "'any and all writings and records' related to the [police department's] contact with a particular confidential witness"); Pena, 2016 WL 8735699, at \*3 (Nathan, J.) (holding that defendant's subpoena "for `any and all' records associated with the Government's cooperating witnesses for an indefinite length of time takes an impermissible shotgun approach to Rule 17(c)"); United States v. Barnes, No. 04 Cr. 186 (SCR), 2008 WL 9359654, at \*4 (S.D.N.Y. Apr. 2, 2008) (quashing motion that "blindly seeks 'all' documents and records that fall into several categories for an approximate 23-month period rather than identifiable pieces of evidence" because "[s]uch a blanket request implicates all of the problems associated with a classic 'fishing expedition"); United States v. Chen De Yian, No. 94 CR. 719 (DLC), 1995 WL 614563, at \*2 (S.D.N.Y. Oct. 19, 1995) (denying motion for Rule 17(c) subpoena seeking "all records . . . pertaining to any and all investigations" into charged murders, + +March 22, 2021 + +Page 4 of 7 + +because "the subpoena was not crafted to call for admissible evidence. Rather, it called for the production of the entire investigative file and is accurately described as a fishing expedition."). + +Similarly, Request 12 asks for "EVCP Material," which is defined as "any submission to the Epstein Victim's Compensation Program made by You, including any claims on behalf of persons who have accused Jeffrey Epstein or Ghislaine Maxwell of any misconduct, any releases signed by You or Your Clients, and any compensation received by You or Your Clients." This Request does not satisfy the Nixon standard—the Defendant is not a party or otherwise privy to what information BSF has submitted to the confidential Epstein Victim's Compensation Program or on behalf of which clients BSF has submitted such information. The Defendant cannot merely request every piece of confidential information that BSF submitted to the Program in the hopes that something relevant and admissible turns up. This Request thus cannot pass muster under Rule 17(c). + +Second, although BSF does not know what arguments the Defendant made in her ex parte motion, the documents and items requested in the Subpoena bear no apparent relevance to the Defendant's guilt or innocence of the charges in this matter. And to the extent they would be relevant solely for impeachment purposes, or relevant but inadmissible, the Defendant cannot obtain them in advance of trial pursuant to Rule 17(c). Nixon, 418 U.S. 683, 699-700, 701. + +Request 1 seeks communications between BSF and the U.S. Attorney about the Defendant from 2015 through the present, and Requests 3 through 5 seek communications between BSF and BSF's co-counsel from 2015 through the present regarding any meetings with the U.S. Attorney's office about the Defendant. But such communications are not relevant to the Government's allegations that the Defendant enticed minors to travel, and transported minors, to engage in sex acts between 1994 to 1997, nearly 20 years prior to any such communications. Nor do such communications bear any apparent relevance to whether the Defendant perjured herself in a civil deposition. If such communications are relevant, they are only relevant to the Defendant's false narrative that BSF somehow colluded with the Government—an allegation that could serve no other purpose than impeachment of the Government's potential witnesses. Request 8-seeking any grand jury subpoena issued to BSF for documents related to litigation concerning the Defendant—is similarly aimed at developing some ill-informed narrative of collusion between BSF and the Government, as the Defendant has on numerous occasions accused BSF of improperly providing the Government with confidential documents governed by a protective order in a separate civil matter. See, e.g., ECF No. 134 (Defendant's motion to suppress evidence obtained by subpoena to what appears to be BSF).2 Even if these documents were relevant to anything other + +2Requests 3 through 5 also seek protected work product. Those Requests seek communications between BSF and its co-counsel in several matters relating to Jeffrey Epstein and Ghislaine Maxwell. Such communications were prepared in anticipation of litigation or for trial. Where a criminal defendant seeks to subpoena work product, the defendant can only overcome the privilege by demonstrating a "substantial need" for the requested items and that he "cannot, without undue hardship, obtain their substantial equivalent by other means." United States v. Weisberg, No. 08-CR-347 NGG RML, 2011 WL 1327689, at \*5 (E.D.N.Y. Apr. 5, 2011). Given the marginal potential evidentiary value of the communications, the Defendant will be unable to demonstrate a substantial need for protected communications between BSF and its co-counsel. + +March 22, 2021 + +Page 5 of 7 + +than impeachment, many of them are procurable from the Government and are thus improper subjects of a Rule 17(c) subpoena, as explained below. + +Requests 2 through 5 also seek communications from 2015 through the present between BSF, its co-counsel, and the U.S. Attorney about Jean Luc Brunel, who is presently incarcerated in France on charges of sex crimes and is one of Jeffrey Epstein and the Defendant's co-conspirators. But Brunel does not appear to be relevant to any of the Government's charges in the indictment in this case, and, again, communications from 2015 are not relevant to conduct that occurred between 1994 and 1997. The Defendant thus seeks these communications, too, so that she can fish for impeachment materials. + +Requests 6 and 7 seek contingency fee agreements or engagement letters between BSF and Such documents are irrelevant. The fact that the are represented, and the terms of their representation, is not relevant to whether the Defendant committed the crimes of which she is accused. Even the impeachment value of such documents is speculative. is not one of the minor victims described in the indictment, and thus may not be called to testify in this case. And in seeking to determine whether BSF has motive of BSF to drum up contingency IIRonvincing women to falsely accuse the Defendant contingency fee arrangements with the the Defendant appears to seek to establish some f criminal conduct. But BSF's motive for representing the would not be relevant to the otives for testifying for the prosecution (if they testify). + +Request 9 seeks the original, complete copy of journal from when she was a teenager for inspection and copying. But all potentially relevant pages were produced from this journal to the Defendant in civil discovery in another matter, as demonstrated by the Defendant's ability to attach those pages as Exhibit A to the Subpoena. The remainder of the journal has nothing to do with the Defendant or Jeffrey Epstein. And the Defendant cannot inspect it for the purpose of fishing for something that could be potentially relevant—it is her burden to identify relevant and admissible evidence under Nixon. The Defendant also clearly seeks to use the journal for impeachment purposes, as she highlighted in a prior filing in a recently dismissed civil action filed a ainst the Defendant. See Letter from L. Mennin er to Hon. Debra C. Freeman at 2, + +ECF No. 108 ("[P]laintiff produced certain pages from a diary dated in early 1996 which detailed, only, that Jeffrey Epstein had held her hand in a movie theater in late 1995 which made her feel uncomfortable. This same diary contained exactly zero references to Ghislaine Maxwell, contrary to the assertions in her Complaint ...." (emphasis in original)). + +Request 12 for "EVCP Material" is not relevant to the Defendant's defense. BSF submitted claims and supporting evidence to the Epstein Victim's Compensation Program on behalf of several Epstein survivors who have not made separate claims against Maxwell. The Defendant must demonstrate the relevance of all the evidence she seeks by means of a Rule 17(c) subpoena, not merely that she could turn up something that is relevant and admissible. See Pena, 2016 WL 8735699, at \*2 (Nathan, J.) ("Pena has failed to make the requisite showing regarding the admissibility of `any and all' other records regarding the cooperators that might exist at the MDC, MCC, or DOC."); United States v. Aguilar, No. CR 07-00030 SBA, 2008 WL 3182029, at \*6 (N.D. Cal. Aug. 4, 2008) ("Thus, while the Aguilars have sought some relevant evidence here, + +March 22, 2021 + +Page 6 of 7 + +they have not demonstrated the relevance of all of the evidence they seek."). The Defendant simply cannot demonstrate that all of the information submitted on behalf of all of BSF's clients would be relevant and admissible in this matter.' + +Further, the Defendant has made it clear that she seeks to use the "EVCP Material" for impeachment purposes. She has requested not only BSF's submissions to the Program, but also any releases signed by BSF's clients and any compensation received b BSF's clients. The Defendant alread attempted to obtain information about compensation by the Program in recently dismissed civil action against the Defendant. In the Defendant's submissions in that matter, she explicitly stated that she sought the information in order to impeach if she were to testify at her criminal trial: + +By contrast, there is substantial evidence that land [BSF] filed this case with a serious ulterior motive to fabricate a story against Ms. Maxwell some 24 years after the fact. The motives include, but are not limited to, increasing the cash consideration that she might receive from the Epstein Victims Compensation Program ("EVCP"). . . . Just as i has a public right to make her false allegations in a lawsuit and in the news, so Ms. Maxwell should have the right to make public the simple fact that plaintiff did not have a desire for "justice," she had a desire for money... + +Second, as previously explained, ,as publicly self-identified as one of the accusers mentioned in the indictment in the criminal case, 20-cr-330 (MN). She will no doubt be one of the prosecution's key witnesses. The inability to obtain an unredacted copy of the release, including the consideration r creates legal prejudice to Ms. Maxwell's ability to confront luring her criminal trial on general issues of bias and motive for fabrication, as is her right under the Confrontation Clause of the United States Constitution. + +Letter from L. Menninger to Hon. Lorna G. Schofield at 2-3, ECF No. 114; see also Letter from L. Menninger to Hon. Debra C. Freeman at 3 ECF No. 108 ("Certainly, the amount of money that as been offered by the [EVCP] in exchange for her un-tested story will be an issue in the upcoming criminal trial when plaintiff takes the stand, for the first time, and faces cross-examination. . . . The motive for fabrication could not be clearer.").4 Thus, the "EVCP + +3Further, a Rule 17 subpoena may not be used to seek the prior statements of an anticipated trial witness. Rule 17 expressly prohibits a party from serving a subpoena for this purpose. See Fed. R. Crim. P. 17(h) ("No party may subpoena a statement of a witness or of a prospective witness under this rule."). The claims submitted as part of the "EVCP Material" include statements made by potential witnesses. + +4Again, however, even the impeachment value of EVCP compensation determination is dubious. may have received compensation after submitting a claim to the Program, but that oes not s ow a potential motive for testifying for the prosecution in this separate criminal action. + +March 22, 2021 + +Page 7 of 7 + +Material," which is clearly sought for impeachment purposes, is not a proper subject of a Rule 17(c) subpoena. + +Third, certain of the documents that the Defendant seeks to obtain from BSF are "otherwise procurable" from the Government. Nixon, 418 U.S. at 699 (documents requested pursuant to Rule 17(c) must not be "otherwise procurable" from another source). Requests 1 and 2 both seek communications between BSF and the U.S. Attorney, which the Defendant can procure from the Government. Similarly, Request 8 seeks a Grand Jury Subpoena that was served on BSF by the Government itself, and that the Defendant can therefore procure from the Government. Thus, a Rule 17(c) subpoena to BSF for those documents is improper. See, e.g., United States v. Bergstein, No. 16 Cr. 746 (PKC), 2017 WL 6887596, at \*5 (S.D.N.Y. Dec. 28, 2017) ("When `many' of the subpoenaed materials are obtainable through the discovery process, a subpoena contravenes Nixon's requirement that subpoenaed materials must not be otherwise procurable in advance of trial by the exercise of due diligence."); United States v. Boyle, No. 08 Cr. 523 (CM), 2009 WL 484436, at \*3 (S.D.N.Y. Feb. 24, 2009) (quashing a 17(c) subpoena where it was "likely that many of the documents that defendant seeks in his subpoena are obtainable from another source—the United States Attorney's Office—with little or no diligence required"). + +Finally, Requests 10 and 11 seek items that can be produced at trial if they are shown to be relevant and admissible. Request 10 seeks a pair of cowboy boots that the Defendant and Jeffrey Epstein purchased fo for ins ection and copying. Request 11 seeks the original copies of various photograph when she was a teenager, on Leslie Wexner's pro rt of n various of Jeffrey Epstein and the Defendant's properties, and of Prince Andrew, and the Defendant in the Defendant's London townhome. Although the relevance of these items is minimal—the photographs, for example, do not appear to depict any conduct or event described in the indictment—the Defendant cannot show that she "cannot properly prepare for trial without such production and inspection in advance of trial and that the failure to obtain such inspection may tend unreasonably to delay the trial," which is an independent requirement under Nixon. 418 U.S. at 699. There is simply no reason why, if the ! ultimately testify and if these items prove to be relevant and admissible, these items cannot be produced for inspection at trial. + +For all of the foregoing reasons, the Defendant's motion to authorize service of the Subpoena on BSF should be denied + +Respectfully submitted, + +/s/ Sigrid S. McCawlev + +Sigrid S. 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NATHAN, District Judge: + +Last summer, the Court scheduled trial in this matter to commence on July 12, 2021. On March 29, 2021, three and a half months before trial, the Government filed an S2 Superseding Indictment. As a result of the late filing of the S2, counsel for Defendant Ghislaine Maxwell request a continuance of the trial date until either fall 2021 or January 2022. t The Government opposes any continuance, but requests that if one is granted it be until March of 2022. Having carefully considered the parties' respective positions, the Court GRANTS Maxwell's request for a short continuance until the fall of 2021 to allow the defense to prepare for the additional charges brought in the S2 indictment. The Court rejects Maxwell's alternative request to continue the trial date until January of 2022 and the Government's alternative proposal that the Court adjourn trial until March of 2022. + +The Court bases its decision on a number of factors. First, the filing of the S2 indictment has added a significant burden to the defense's preparation for trial. The new indictment alleges + +IThe alternative request by Maxwell resulted from a conflict among lawyers involved in both this case and a criminal matter before Judge Furman, which is discussed in defense counsel's letter. Dkt. No. 246 at 4. The Court has been informed that Judge Furman has adjourned the trial date with respect to two defendants. The Court presumes that this eliminates the September through December conflict for one of Maxwell's defense counsel. It presumably does not eliminate the conflict for one of the AUSAs involved in both cases. Dkt. No. 235 at 10 n.5. + +that the conspiracies charged in Counts I and 3 extended to 2004 (the S I charged through 1997), identifying a fourth alleged victim, Minor Victim-4. It also adds two new charges: Count 5 of the S2 Indictment charges Maxwell with participating in a sex trafficking conspiracy between 2001 and 2004, and Count 6 charges Maxwell with participating in the sex trafficking of a minor or aiding and abetting the same. Dkt. No. 187. These additions will require the defense to (1) review a substantial amount of discovery that is now potentially relevant as a result of the S2 Indictment; (2) re-review discovery that it had previously considered in light of the changes to the case against her; (3) conduct new investigations based on the new charges, including potential interviews of new witnesses; and (4) re-evaluate her trial preparation and strategy. Second, although jury trials have resumed in the district and conditions in MDC and around the country are improving, the defendant's and defense counsel's preparation efforts to date have been and to some extent continue to be hampered by the effects of the COVID-19 pandemic. As the Government indicated in explaining the delay in filing the new charges, travel constraints and other safety concerns resulting from the pandemic have slowed trial preparation and complicated the logistics of conducting investigations. See Dkt. No. 199 at 2. Third, defense counsel must balance preparing for trial with considering and preparing any supplemental pre-trial motions in response to the new charges contained in the S2 Indictment. Although the perjury counts were recently severed, the Court cannot conclude that this sufficiently offsets the additional burdens placed on the defense as a result of the new charges and expanded timeframe resulting from the S2 indictment. + +The Court is very mindful of the countervailing considerations that require that any adjournment be no longer than necessary. For one, the Defendant, whose counsel strenuously request the adjournment, is detained pre-trial. Moreover, with many lawyers on both sides of + +this case, any adjournment runs the risk of precluding some attorneys from being able to participate and/or requiring them to seek adjustments to schedules in other matters. And, importantly, any victims and the public more broadly have a strong interest in trial proceeding without undue delay. It is the Court's obligation to ensure that the case proceed to that trial as expeditiously as possible, taking into account the interests of justice and all relevant circumstances. *See* 18 U.S.C. §3161(h)(7)(A); 18 U.S.C. § 3771(a)(7). + +Having balanced all of the factors outlined above, the Court concludes that the interests of justice justify granting a short continuance. The Court deems an adjournment until fall 2021 to be reasonable. Such an adjournment would plainly give the defense team sufficient time to prepare for trial in light of the additional charges contained in the S2 indictment while also ensuring that the trial proceeds without undue delay. No additional delay is necessary or in the interests of justice. + +The parties are hereby ORDERED to meet and confer and by May 10, 2021, they shall jointly propose a trial start date for the Court to request of the Clerk's Office (as is required by COVID protocols). The Court urges counsel to agree to the earliest possible date this fall and to seek adjustments to other schedules in order to facilitate an early fall trial start date. The parties shall also discuss and propose any adjustments necessary to the pre-trial schedule in place. Dkt. No. 250. The Government may move in the letter for any requested exclusion of time under the Speedy Trial Act. + +SO ORDERED. + +Dated: May 3, 2021 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00085266/EFTA00085266.metadata.json b/marker2/ds9/EFTA00085266/EFTA00085266.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b4b7580d63b815de80666d27e75cbed4cb1f89c3 --- /dev/null +++ b/marker2/ds9/EFTA00085266/EFTA00085266.metadata.json @@ -0,0 +1,166 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085266.pdf", + "engine": { + "marker_major": "2", + "marker_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": 5845, + "elapsed_seconds": 6.73, + "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 + ], + [ + 281.41961669921875, + 72.08999999999999 + ], + [ + 281.41961669921875, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 33 + ], + [ + "Text", + 9 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Form", + 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", + 49 + ], + [ + "Line", + 25 + ], + [ + "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 + } + }, + { + "page_id": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 26 + ], + [ + "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/EFTA00085266" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085269/EFTA00085269.md b/marker2/ds9/EFTA00085269/EFTA00085269.md new file mode 100644 index 0000000000000000000000000000000000000000..ed3b818a9be219ff294aae4af71721c6474512f7 --- /dev/null +++ b/marker2/ds9/EFTA00085269/EFTA00085269.md @@ -0,0 +1,54 @@ +**From:** "[REDACTED] (USANYS)" <[REDACTED]> +**To:** Sigrid McCawley <[REDACTED]> +**Cc:** "[REDACTED]" <[REDACTED]>, "[REDACTED]" <[REDACTED]> +**Subject:** RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +**Date:** Tue, 04 May 2021 14:00:59 +0000 + +--- + +Understood – thanks very much for letting us know, Sigrid. + +--- + +**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) + +Sigrid, + +Please see the attached order regarding the trial date in this case. We will update you when we have more information. + +## Assistant United States Attorney United States Attorney's Office + +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 recip:ent. or the employee or agent responsible to deliver it to the named recipient. you are hereby notified that any dissemination. distribution. copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error. please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. (v.1 08201831BSF) \ No newline at end of file diff --git a/marker2/ds9/EFTA00085269/EFTA00085269.metadata.json b/marker2/ds9/EFTA00085269/EFTA00085269.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1c6464d8d55b32186120da0cdc0a4144670763b5 --- /dev/null +++ b/marker2/ds9/EFTA00085269/EFTA00085269.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085269.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2803, + "elapsed_seconds": 7.32, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Assistant United States Attorney \nUnited States Attorney's Office", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.823999999999998, + 40.403076171875 + ], + [ + 180.1593780517578, + 40.403076171875 + ], + [ + 180.1593780517578, + 67.23 + ], + [ + 31.823999999999998, + 67.23 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Text", + 42 + ], + [ + "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", + 15 + ], + [ + "Line", + 8 + ], + [ + "Text", + 6 + ], + [ + "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/EFTA00085269" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085271/EFTA00085271.md b/marker2/ds9/EFTA00085271/EFTA00085271.md new file mode 100644 index 0000000000000000000000000000000000000000..7ae8fb9c413e8c9c29aff1f3d5506b7a7c172e94 --- /dev/null +++ b/marker2/ds9/EFTA00085271/EFTA00085271.md @@ -0,0 +1,69 @@ +**To:** "[REDACTED] (USANYS)" <[REDACTED]> + +**Cc:** "[REDACTED] (USANYS)" <[REDACTED]> + +**Subject:** RE: Weekly Updates + +**Date:** Fri, 07 Jun 2019 21:55:11 +0000 + +**Importance:** Normal + +--- + +Another update: related to the discussion we had, we are approaching 3 NY Epstein victims on Tuesday. + +--- + +**From:** [REDACTED] (USANYS) + +**Sent:** Friday, June 07, 2019 11:16 AM + +**To:** [REDACTED] (USANYS) <[REDACTED]> + +**Cc:** [REDACTED] (USANYS) <[REDACTED]> + +**Subject:** RE: Weekly Updates + +Relatively quiet week: + +[REDACTED] + +--- + +**From:** [REDACTED] (USANYS) <[REDACTED]> + +**Sent:** Friday, June 07, 2019 8:52 AM + +**To:** + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +**Subject:** Weekly Updates + +I just realized I forgot to send this reminder this morning! Please get me your reports today. Thanks! + +Laura + +Laura Grossfield Birger +Chief, Criminal Division +United States Attorney's Office, SDNY +(212) 637-1117 +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00085271/EFTA00085271.metadata.json b/marker2/ds9/EFTA00085271/EFTA00085271.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8adcdca5b6a831e21224c5da8b495f4538ecd4c1 --- /dev/null +++ b/marker2/ds9/EFTA00085271/EFTA00085271.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085271.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1006, + "elapsed_seconds": 5.8, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 65 + ], + [ + "Span", + 45 + ], + [ + "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/EFTA00085271" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085272/EFTA00085272.md b/marker2/ds9/EFTA00085272/EFTA00085272.md new file mode 100644 index 0000000000000000000000000000000000000000..19250997763ed76afd7bb69c3b1b498fb569df3f --- /dev/null +++ b/marker2/ds9/EFTA00085272/EFTA00085272.md @@ -0,0 +1,35 @@ +From: " To: al iJSANYI.a .callEr Cc: (USANYS)" ctl It + +To: (USANYS) < >; (USANYS) < + +Cc: (USANYS) [Contractor] (USANYS) + +Subject: RE: Epstein's Caribbean Island + +Date: Mon, 22 Jul 2019 20:18:06 +0000 + +If that's true, it's not in coordination with us or with our knowledge or input. (I just this afternoon emailed the agents about talking to employees at the airport and potentially working up PC for a search.) + +From: (USANYS) < + +Sent: Monday, July 22, 2019 16:16 + +To: ) ; + +Cc: (USANYS) < + +Subject: FW: Epstein's Caribbean Island + +From: (USANYS) < MI> + +Sent: Monday, July 22, 2019 4:14 PM + +Subject: Epstein's Caribbean Island + +Just FYI — A reporter is being told there's some sort of police action taking place at his home down there. + +Public Affairs United States Department of Justice + +U.S. Attorney's Office Southern District of New York + +I Mobile: \ No newline at end of file diff --git a/marker2/ds9/EFTA00085272/EFTA00085272.metadata.json b/marker2/ds9/EFTA00085272/EFTA00085272.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..18fcb975dcba83405bb2ec8a2b16c5c8d29d2cd5 --- /dev/null +++ b/marker2/ds9/EFTA00085272/EFTA00085272.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085272.pdf", + "engine": { + "marker_major": "2", + "marker_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": 857, + "elapsed_seconds": 0.86, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "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/EFTA00085272" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085273/EFTA00085273.md b/marker2/ds9/EFTA00085273/EFTA00085273.md new file mode 100644 index 0000000000000000000000000000000000000000..f672ee7a61a3afb2d5c6ad83ccf1d3b9b8174872 --- /dev/null +++ b/marker2/ds9/EFTA00085273/EFTA00085273.md @@ -0,0 +1,54 @@ +To: ' (USANYS)" + +Subject: RE: Epstein interview updates + +Date: Mon, 22 Jul 2019 21:17:37 +0000 + +Thanks. + +Which Victims on the list below appear on the victim list provided to Epstein by the SDFL? + +From: (USANYS) < + +Sent: Monday, July 22, 2019 5:10 PM + +To: Berman, Geoffrey (USANYS) (USANYS) + +(USANYS) ; (USANYS) + +Cc: (USANYS) + +Subject: Epstein interview updates + +All — we wanted to give you a rundown of (i) all the interviews we have done in the last two weeks; and (ii) where we stand with some of the employees / potential co-conspirators. Descriptions are below: + +Employees/Associates + +- (Employee-1 in Indictment): We gave a reverse proffer to Groff last week and she is weighing whether to come in. +- (Employee-2 in Indictment): We will receive an attorney proffer from attorneys next week. +- (Employee-3 in indictment): We interviewed her in Florida and learned the following: met Epstein around 2004, while in her early 20s, through the modelling community. Around December 2004, Epstein offered a job working as an assistant, which she accepted and maintained until early 2006. Her responsibilities included running errands and scheduling massages and other appointments. According to M, Epstein expected to have two massages every day: one in the morning and one in the afternoon. and were responsible for coordinating the Palm Beach massages, and was responsible for coordinating the New York massages. At some point, Epstein and began having sexual encounters, but MI was very distressed when discussing these incidents and was not prepared to describe them in detail during our first meeting. The team believes these encounters may have been coercive and/or nonconsensual. At least some of these encounters involved I= herself providing Epstein with his massages when they were in the Virgin Islands. As a result, was aware that his massages were sexual. described how Epstein had two groups of girls who provided massages in his homes: one group was of professional masseuses who gave actual massages to Epstein's friends, and the second group consisted of young girls who were not professional masseuses and who only gave massages to Epstein. recalled certain details that signaled that girls in this second group were minors. For example, she was asked to help find SAT prep courses for one girl, and she recalled girls mentioning school and their parents. However, at her first proffer, she stopped short of acknowledging that she knew they were minors. +- Ghislaine Maxwell (friend / former girlfriend alleged to be involved in recruiting): The team met with her attorneys last week and she is assessing whether to proffer with us. +- (sexual partner / involved in massages / may be an abuse victim): Has retained counsel and they have asked for a week or so to speak with her before evaluating how to proceed. + +- (former Palm Beach house manager from 90's through 2002): recalled that things changed dramatically during his last two years at the residence. Epstein became increasingly demanding, and staff were told not to speak to Epstein or his guests, to avoid eye contact, and to leave the room when he entered. recalled that, towards the end of his tenure, three young girls came by the house: and a third girl. He believed that was under 18 and was giving Epstein "massages," although he did not know what this entailed. During this period, was responsible for scheduling Epstein's frequent appointments with professional masseuses. During the last several weeks of his employment, was hired as Epstein's personal assistant, and began taking over answering Epstein's phones. At the very end of his tenure, told Epstein that he should slow down, that "these girls" would get him in trouble. Epstein remarked that it was fine, and that "these girls only care about money." When left Epstein's employment, Epstein told him: "I hope you keep your mouth shut." +- : Retained Debevoise, which is going to give us an attorney proffer. + +## New York Victims + +- : Victimized beginning in 2001, when she was approximately 14 years old. Recruited by an unidentified woman her outside her school on the Upper East Side. Provided nude massages to Epstein over approximately a year, each time for \$300 in cash. In fall 2002, while Ms. was massaging Epstein, he asked her to get on top of him, which she did, and was the individual interviewed by NBC News. +- : Gave Epstein massages at the Manhattan mansion on two occasions, during which Epstein . She recalled that Epstein told her: "you look so young." She brought a 19 year old friend to Epstein's house to give a massage, and recalls Epstein telling her not to bring her again, because she was too old. + +## Florida Victims + +- Victimized once in 2002 at the Florida estate. During the massage, Epstein She recruited one other minor girl to give Epstein a massage. +- Gave Epstein at least two massages in the early 2000's at the age of 16 or 17. During the first, Epstein The second involved more extensive abuse, which she was not yet prepared to describe during the first interview. +- ave Epstein massages twice in the early 2000s at the Florida estate, during which he . Has reservations about testifiying. Recruited by a friend at the age of 13 or 14 in the early 2000s, while living in a trailer park in Palm Beach. Over a period of approximately three years, gave numerous massages to Epstein at the Palm Beach residence. Epstein Estimates that she may have brought as many as one hundred underage girls to Epstein's house for massages. During the Florida investigation, she was represented by an attorney paid by Epstein. +- : Florida victim who met with the team to discuss the status of the case. Indicated that she wished to cooperate with the investigation, but she was not prepared to discuss her experiences with Epstein that day. +- First met Epstein through her older sister in 2007 (while Epstein was being investigated) at the age of + - 17. Epstein specifically asked her age and told her, in substance, that they could not interact until she turned 18. After her 18th birthday, Epstein began having give him massages, during which he — A short time later, Epstein took Ms. and her sister on a trip to his private + +island in the Virgin Islands. During that trip, Epstein by Between 2007 and 2009, Epstein had intercourse with her on multiple occasions; the first few were nonconsensual. When Epstein was serving his jail sentence in Palm Beach, visited him at his office on at least one occasions and engaged in sexual conduct with him. In or around 2013, Epstein paid \$10,000 to marry a girl whom Epstein wanted to be able to stay in the U.S. The two were married for about four years, then divorced in 2017. + +- In the early 2000s, when Ms. was 17 years old and working as a model, she was invited to Epstein's house I a 19 year old model who was Epstein's girlfriend at the time. Epstein gave and cash to go shopping, and they purchased underwear together at the mall. They returned to Epstein's house, and Epstein asked to try on the underwear for him; felt as though she could not say no, and complied. That same weekend, invited to come to Epstein's house to receive a massage from a masseuse. She was told Epstein would not be there, and so she agreed. Shortly after undressed for the massage, the masseuse left the room, and Epstein entered. He insisted that ), so that he could show her what he had learned from a chiropractor about "adjustments." Epstein but did not touch her chest. After this experience, she refused to return to the house. + +Mon Unit United States Attorney's Office for the Southern District of New York t. (212) 637-2247 \ No newline at end of file diff --git a/marker2/ds9/EFTA00085273/EFTA00085273.metadata.json b/marker2/ds9/EFTA00085273/EFTA00085273.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d16528288a786bcb865aa1c523641ff55745bfff --- /dev/null +++ b/marker2/ds9/EFTA00085273/EFTA00085273.metadata.json @@ -0,0 +1,185 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085273.pdf", + "engine": { + "marker_major": "2", + "marker_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": 7626, + "elapsed_seconds": 0.92, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "New York Victims", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 218.70000000000002 + ], + [ + 115.8532943725586, + 218.70000000000002 + ], + [ + 115.8532943725586, + 232.214111328125 + ], + [ + 30.6, + 232.214111328125 + ] + ] + }, + { + "title": "Florida Victims", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 398.52 + ], + [ + 104.64269256591797, + 398.52 + ], + [ + 104.64269256591797, + 412.2140808105469 + ], + [ + 30.6, + 412.2140808105469 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 84 + ], + [ + "Line", + 40 + ], + [ + "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", + 87 + ], + [ + "Line", + 42 + ], + [ + "ListItem", + 10 + ], + [ + "ListGroup", + 3 + ], + [ + "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", + 43 + ], + [ + "Line", + 22 + ], + [ + "Text", + 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/EFTA00085273" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085276/EFTA00085276.md b/marker2/ds9/EFTA00085276/EFTA00085276.md new file mode 100644 index 0000000000000000000000000000000000000000..7d307da9182d3db6648ca3d37345bc07116fc468 --- /dev/null +++ b/marker2/ds9/EFTA00085276/EFTA00085276.md @@ -0,0 +1,25 @@ +From: (USANYS)" , ' (USANYS)" Subject: Re: Epstein / MCC Date: Wed, 24 Jul 2019 01:09:33 +0000 + +Let's do 930. I'll get a line. Will have on the call since she spoke to MCC. + +Sent from my iPhone + +On Jul 23, 2019, at 9:06 PM, (USANYS) -:: > wrote: + +Can we set up a dial in tonight? If not, can someone call my cell? Thanks. = + +On Jul 23, 2019, at 8:58 PM, (USANYS) MINIMIW wrote: + +Apparently per protocol he is now on suicide watch. + +Sent from my iPhone + +On Jul 23, 2019, at 8:53 PM, (USANYS) > wrote: + +— asked me to update you on what we learned from MCC just now: + +- Epstein was found on the floor of his cell last not unresponsive, although apparently breathing. There were red stretch marks along his neck. +- He claims to not have a recollection of what happened. He said that within the last few days Tartaglione (his bunkmate) has threatened him. +- Tartaglione claims that he had his headphones on, was not paying attention to Epstein, and does not know what happened. + +The MCC is investigating and will keep us posted. I discussed with whether we/FBI want to be more active in any such investigation — not clear what the right answer is. 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Please let us know what you find out. + +Sent from my iPhone + +On Jul 24, 2019, at 10:43 PM, wrote: + +FYI, just received the below. The noose is a new detail I had not heard. I've reached out to to ask if he has any new information or reports. + +Begin forwarded message: + +From: ' + +Date: Jul 24, 2019 at 9:35:05 PM EDT + +To:" + +Subject: Jeffrey EPSTEIN + +All, + +Please be advised that we received he following report from the Bureau of Prisons MCC New York at 2115 hours on this date: + +Associate Warden (AW) at MCC New York advised that Jeffrey EPSTEIN was found in his cell this morning at 0127 hours in a fetal position with a noose around his neck. EPSTEIN was escorted to medical and was assessed. EPSTEIN was initially placed on suicide watch and subsequently downgraded to suicide observation, where he currently remains. Additionally, AW advised that EPSTEIN's cell mate reported threated to kill him. No further information was provided. + +The above incident is currently under investigation with the BOP. + +Supervisory Deputy United States Marshal Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00085277/EFTA00085277.metadata.json b/marker2/ds9/EFTA00085277/EFTA00085277.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c7421dedee8ffe0b1ba905f5102b2d51b3f78336 --- /dev/null +++ b/marker2/ds9/EFTA00085277/EFTA00085277.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085277.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1302, + "elapsed_seconds": 0.89, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Line", + 28 + ], + [ + "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/EFTA00085277" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085278/EFTA00085278.md b/marker2/ds9/EFTA00085278/EFTA00085278.md new file mode 100644 index 0000000000000000000000000000000000000000..9e1cfc113cbd2fe6d27ac590916ee0e28ba9665c --- /dev/null +++ b/marker2/ds9/EFTA00085278/EFTA00085278.md @@ -0,0 +1,39 @@ +From: ' + +To: ' 1). + +Cc + +Subject: Re: Jeffrey EPSTEIN + +Date: Thu, 25 Jul 2019 12:03:42 +0000 + +Just spoke with It sounds like the SHU Lieutenant who wrote the first report about the incident only mentioned redness on Epstein's neck without mentioning any sort of object around the neck. Two other officers who responded to the cell aa ntly wrote supplemental reports saying that Epstein had something around his neck when they saw him. didn't have the reports in front of him when we spoke, so he couldn't be more specific. I've asked him to provide us with the reports as soon as possible. + +On Jul 24, 2019, at 10:45 PM, > wrote: + +Yes, if true, would be somewhat shocking that didn't report (and more shocking that they took him off suicide watch). Please let us know what you find out. + +Sent from my iPhone + +On Jul 24, 2019, at 10:43 PM, > wrote: + +FYI, just received the below. The noose is a new detail I had not heard. I've reached out to to ask if he has any new information or reports. + +Begin forwarded message: + +From: " + +Date: Jul 24, 2019 at 9:35:05 PM EDT + +To: + +Subject: Jeffrey EPSTEIN + +All, + +Please be advised that we received he following report from the Bureau of Prisons MCC New York at 2115 hours on this date: + +Associate Warden (AW) at MCC New York advised that Jeffrey EPSTEIN was found in his cell this morning at 0127 hours in a fetal position with a noose around his neck. EPSTEIN was escorted to medical and was assessed. EPSTEIN was initially placed on suicide watch and subsequently downgraded to suicide observation, where he currently remains. Additionally, AW advised that EPSTEIN's cell mate reported threated to kill him. No further information was provided. + +Supervisory Deputy United States Marshal Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00085278/EFTA00085278.metadata.json b/marker2/ds9/EFTA00085278/EFTA00085278.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e6f184f5f463868f0abafcea272188fad8c4b490 --- /dev/null +++ b/marker2/ds9/EFTA00085278/EFTA00085278.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085278.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1756, + "elapsed_seconds": 0.98, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "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 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 5 + ], + [ + "Text", + 3 + ], + [ + "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/EFTA00085278" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085280/EFTA00085280.md b/marker2/ds9/EFTA00085280/EFTA00085280.md new file mode 100644 index 0000000000000000000000000000000000000000..2463d0feabfcb0701f9e792dfc18cc40602ec98b --- /dev/null +++ b/marker2/ds9/EFTA00085280/EFTA00085280.md @@ -0,0 +1,47 @@ +**To:** " [REDACTED] > + +**Cc:** " [REDACTED] >, " [REDACTED] >, " [REDACTED] > + +**Subject:** Re: Jeffrey EPSTEIN + +**Date:** Thu, 25 Jul 2019 12:31:07 +0000 + +--- + +I don't know. I'll reach back out to [REDACTED] to find out. + +On Jul 25, 2019, at 8:28 AM, [REDACTED] > wrote: + +Ok. Where is Epstein now? Is he still under at least suicide observation? + +Sent from my iPhone + +On Jul 25, 2019, at 8:03 AM, [REDACTED] > wrote: + +Just spoke with [REDACTED]. It sounds like the SHU Lieutenant who wrote the first report about the incident only mentioned redness on Epstein's neck without mentioning any sort of object around the neck. Two other officers who responded to the cell apparently wrote supplemental reports saying that Epstein had something around his neck when they saw him. [REDACTED] didn't have the reports in front of him when we spoke, so he couldn't be more specific. I've asked him to provide us with the reports as soon as possible. + +On Jul 24, 2019, at 10:45 PM, [REDACTED] > wrote: + +Yes, if true, would be somewhat shocking that [REDACTED] didn't report (and more shocking that they took him off suicide watch). Please let us know what you find out. + +Sent from my iPhone + +On Jul 24, 2019, at 10:43 PM, [REDACTED] > wrote: + +FYI, just received the below. The noose is a new detail I had not heard. I've reached out to [REDACTED] to ask if he has any new information or reports. + +Begin forwarded message: + +**From:** " [REDACTED] > + +**Date:** July 24, 2019 at 9:35:05 PM EDT + +**To:** " [REDACTED] >, " [REDACTED] >, " [REDACTED] > + +**Subject:** Jeffrey EPSTEIN + +Associate Warden (AW) at MCC New York advised that Jeffrey EPSTEIN was found in his cell this morning at 0127 hours in a fetal position with a noose around his neck. EPSTEIN was escorted to medical and was assessed. EPSTEIN was initially placed on suicide watch and subsequently downgraded to suicide observation, where he currently remains. Additionally, AW advised that EPSTEIN's cell mate reported threated to kill him. No further information was provided. + +The above incident is currently under investigation with the BOP. + +Supervisory Deputy United States Marshal Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00085280/EFTA00085280.metadata.json b/marker2/ds9/EFTA00085280/EFTA00085280.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2a1e101323750f56be163c4ad64b67095bc4be1a --- /dev/null +++ b/marker2/ds9/EFTA00085280/EFTA00085280.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085280.pdf", + "engine": { + "marker_major": "2", + "marker_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": 48.41, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Text", + 45 + ], + [ + "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", + 21 + ], + [ + "Line", + 11 + ], + [ + "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/EFTA00085280" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085282/EFTA00085282.md b/marker2/ds9/EFTA00085282/EFTA00085282.md new file mode 100644 index 0000000000000000000000000000000000000000..2175add2f3416507bc0690392015a6049f1fad58 --- /dev/null +++ b/marker2/ds9/EFTA00085282/EFTA00085282.md @@ -0,0 +1,81 @@ +To: ' + +Cc: " , " + +Subject: RE: Jeffrey EPSTEIN + +Date: Thu, 25 Jul 2019 13:16:56 +0000 + +He did not. I'll give him a call and feel him out about bringing in be fine. has worked with before, so it should + +From: + +Sent: Thursday, July 25, 2019 9:11 AM + +To: + +Cc: fl '; + +Subject: Re: Jeffrey EPSTEIN + +Did give you any timeline for getting back to us with the file? I am, in concept, fine with using — I agree that will be more efficient and likely result in us getting better info, but if has given us some assurance is going to get back to us quickly I don't wanna piss him off by effectively going behind his back. + +Sent from my iPhone + +On Jul 25, 2019, at 9:00 AM, > wrote: + +I've asked to gather whatever he can and provide it to us, but that might take a while. + +If we want to go directly to the MCC investigators, it might be good to ask one of our USAO investigators, like in to facilitate that. has great relationships with the MCC investigators and can usually get reports and files much more quickly than the lawyers can. Want me to ask to help? He can then provide whatever files/reports he receives to a neutral AUSA with no involvement in either case for an initial review before sending on to the Epstein and Tartaglione teams to make sure there are no statements that arguably touch on otherwise privileged information. + +From: + +Sent: Thursday, July 25, 2019 8:51 AM + +To: + +Cc: + +Subject: Re: Jeffrey EPSTEIN + +What is status of getting whatever file / reports they have? Does not sound like we are getting reliable third hand information. + +Sent from my iPhone + +On Jul 25, 2019, at 8:31 AM, > wrote: + +On Jul 25, 2019, at 8:03 AM, wrote: + +Just spoke with It sounds like the SHU Lieutenant who wrote the first report about the incident only mentioned redness on Epstein's neck without mentioning any sort of object around the neck. Two other officers who responded to the cell apparently wrote supplemental reports saying that Epstein had something around his neck when they saw him. didn't have the reports in front of him when we spoke, so he couldn't be more specific. I've asked him to provide us with the reports as soon as possible. + +On Jul 24, 2019, at 10:45 PM, wrote: + +Yes, if true, would be somewhat shocking that didn't report (and more shocking that they took him off suicide watch). Please let us know what you find out. + +Sent from my iPhone + +On Jul 24, 2019, at 10:43 PM, > wrote: + +FYI, just received the below. The noose is a new detail I had not heard. I've reached out to to ask if he has any new information or reports. + +Begin forwarded message: + +From: ' + +Date: July 24, 2019 at 9:35:05 PM EDT + +To: + +" )• + +Subject: Jeffrey EPSTEIN + +All, + +Please be advised that we received he following report from the Bureau of Prisons MCC New York at 2115 hours on this date: + +Associate Warden (AW) at MCC New York advised that Jeffrey EPSTEIN was found in his cell this morning at 0127 hours in a fetal position with a noose around his neck. EPSTEIN was escorted to medical and was assessed. EPSTEIN was initially placed on suicide watch and subsequently downgraded to suicide observation, where he currently remains. Additionally, AW advised that EPSTEIN's cell mate reported threated to kill him. No further information was provided. + +The above incident is currently under investigation with the BOP. + +Supervisory Deputy United States Marshal Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00085282/EFTA00085282.metadata.json b/marker2/ds9/EFTA00085282/EFTA00085282.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..46de44478bca471380d5225580d1ee8a1535a981 --- /dev/null +++ b/marker2/ds9/EFTA00085282/EFTA00085282.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085282.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3379, + "elapsed_seconds": 1.38, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Line", + 37 + ], + [ + "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", + 67 + ], + [ + "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/EFTA00085282" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085284/EFTA00085284.md b/marker2/ds9/EFTA00085284/EFTA00085284.md new file mode 100644 index 0000000000000000000000000000000000000000..7506bc3a44224d9abbd61069aad63a7855d83eca --- /dev/null +++ b/marker2/ds9/EFTA00085284/EFTA00085284.md @@ -0,0 +1,66 @@ +## MARTIN G. WEINBERG, P.C. ATTORNEY AT LAW + +EMAIL ADDRESSES: + +NI CY + +July 26, 2019 + +Electronic Mail + +Assistant United States Attorneys U.S. Attorney's Office for the Southern District of New York + +> Re: United States v. Jeffrey Epstein, No. I9-cr-00490 Defendant's First Request for Discovery + +Dear + +We represent Jeffrey Epstein in the above-referenced matter. We write to request the preservation and production of several important categories of documents. + +The following request and future requests' encompass not only documents and information in your office's possession, custody, or control, but also documents that the government has the legal right or practical ability to obtain. Such information includes, but is not limited to, information in the possession, custody, and control of any agency of the United States involved in any way in regulating or investigating the activities alleged in the Indictment or related transactions, including but not limited to the Department of Justice (including but not limited to the Child Exploitation and Obscenity Section, other offices of "Main Justice," the Federal Bureau of Investigation and all United States Attorney's Offices), the Securities and Exchange Commission, and the Department of Homeland Security. In addition, such information includes infonnation in the possession, custody, and control of any local, state, or + +I All of these requests are/will be continuing in nature, requiring supplementation in accordance with, truer aria. Rule 16(c) of the Federal Rules of Criminal Procedure. + +foreign law enforcement entities involved in any way in regulating or investigating the activities alleged in the Indictment or related transactions.2 + +Whether or not you to intend to comply with this (or future) requests for discovery, we respectfully request that you: (1) preserve all documents3, communications4 and/or tangible objects related to, concerning, or otherwise referring to Mr. Epstein (“Responsive Material”); (2) inform any and all entities described above, who you believe to have Responsive Material to preserve it; and (3) inform defense counsel whether these entities intend to comply with this request. In response to your email of today’s date, we would specifically (and without waiving the other requests contained herein) ask you communicate our preservation request to AUSAs [REDACTED] and [REDACTED] of the Northern District of Georgia, to CEOS and anyone else at Main Justice that you have knowledge of as being involved in communications regarding the NPA and the decision by the Southern District of New York to indict, and to any prosecutor at either the Southern or Middle Districts of Florida (or anyone other than AUSA [REDACTED] and [REDACTED] at the Northern District of Georgia), with whom you have had any communication regarding Mr. Epstein, the NPA, the receipt of evidence, or the decision by the Southern District of New York to seek an indictment of Mr. Epstein. Our request that you preserve documents is spelled out in this broader letter but certainly encompasses the Offices identified above. We additionally request that the FBI agents working with any of these offices, or with the Southern District of New York receive the same preservation request. The types of communications for which we seek preservation (and ultimately production) are set forth below. + +While Mr. Epstein intends to provide a more complete request for discovery in the coming days, Mr. Epstein requests that the government expeditiously produce the following categories of documents each of which are highly relevant to Mr. Epstein’s forthcoming motion to dismiss the Indictment as barred by the 2007 non-prosecution agreement between the Department of Justice and Mr. Epstein (the “NPA”). Each is subject to disclosure pursuant to the government’s obligations under, *inter alia, Brady v. Maryland*, 373 U.S. 83 (1963) and the Federal Rules of Criminal Procedure. + +Mr. Epstein seeks all documents, communications, and/or tangible objects relating to, concerning, or referring to: + +1. 1. Any investigatory files provided to the United States Attorney’s Office for the Southern District of New York (or FBI agents working therewith) by the United States Attorney’s + +--- + +2 Such entities include, but are not limited to, the New York Police Department, Manhattan District Attorney’s Office, State Attorney’s Office for the 15th Judicial District in and for Palm Beach County, the Palm Beach County Sheriff’s Office, and New Mexico Attorney General’s Office, which recently confirmed that it would be sharing evidence with “New York prosecutors.” *See Patrick Hayes & Chris Ramirez, Balderas Believes Previous Investigations Failed Epstein’s Alleged NM Victims.* (July 16, 2019), . + +3 The term “documents” should be construed broadly to include do any documents or electronically stored information—including writings, drawings, graphs, charts, photographs, sound recordings, video recordings, images, and other data or data compilations. + +4 The term “communications” means the transmittal of information (in the form of facts, ideas, inquiries or otherwise). + +Offices for the Southern District of Florida, the Middle District of Florida, and/or the Northern District of Georgia (or FBI agents working therewith); + +- 2. Any investigatory files that were received or accessed by the United States Attorney's Office for the Southern District of New York (or FBI agents working therewith) that were sent or disclosed by or originated with the United States Attorney's Offices for the Southern District of Florida, the Middle District of Florida, and/or the Northern District of Georgia (or FBI agents working therewith); +- 3. Communications regarding Mr. Epstein between and among "Main Justice" (including the Child Exploitation and Obscenity Section) and the United States Attorney's Offices for the Southern District of Florida, Middle District of Florida, Northern District of Georgia, and the Southern District of New York; +- 4. Any decision to initiate (or not initiate) criminal proceedings against Mr. Epstein; +- 5. The NPA, including but not limited to communications within the Department of Justice, with counsel for Mr. Epstein, with representatives of the United States Attorney's offices for the Southern and Middle District of Florida or the Northern District of Georgia and/or counsel for the alleged victims; +- 6. Communications with alleged victims (or their counsel), including but not limited to consultations conducted in relation to the government's response to the court's summary judgment order and proposed remedies in Jane Doe v. United Stales, No. 08-cv-80736 (S.D. Fl.); +- 7. Information provided by alleged victims (or their counsel) related to Mr. Epstein prior to the return of the above-captioned Indictment; + +Please advise us whether the government will comply with the above requests so that Mr. Epstein can determine whether it will be necessary to seek judicial intervention. We are available to discuss any of the foregoing requests with you when convenient. We reserve the right to request further discovery and additional particulars as the case progresses. + +Finally you have asked why we believe that these materials are necessary. In short, we intend to file a future Motion to Dismiss based on the September 24, 2007 NPA, contending that properly construed it constitutes aglobal resolution of Mr. Epstein's then-existing offense conduct. Further, we believe that aproduction of the requested documents would reflect communications between the various identified United States Attorney's Offices that would be inconsistent with the duty to not circumvent or transfer acase from the immunizing district to another district even if the NPA is ultimately determined to be venue specific. We also will contend that the documented efforts of the Southern District of Florida, see Jane Doe vUnited States Dkt 205-2, 08 cv 80736 and more recent interactions between the Northern District of Georgia which stands in the shoes of the Southern District of Florida with victims and their attorneys was inconsistent with the immunity-commitments that were incorporated into the NPA. + +We will be addressing all related topics in our future Motion to Dismiss and Motion for Production of Documents relevant to the Motion to Dismiss. + +Very truly yours, + +Reid Weingarten + +Michael Miller + +Ste toe & Johnson LLP + +Martin G. Weinberg + +Martin G. Weinber , P.C. \ No newline at end of file diff --git a/marker2/ds9/EFTA00085284/EFTA00085284.metadata.json b/marker2/ds9/EFTA00085284/EFTA00085284.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..617a40811cab05452eb33113f0feba0423c57868 --- /dev/null +++ b/marker2/ds9/EFTA00085284/EFTA00085284.metadata.json @@ -0,0 +1,184 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085284.pdf", + "engine": { + "marker_major": "2", + "marker_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": 8666, + "elapsed_seconds": 12.49, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "MARTIN G. 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[REDACTED] + +[REDACTED] + +--- + +**From:** [REDACTED] (USANYS) < [REDACTED] > + +**Sent:** Saturday, July 27, 2019 9:16 AM + +**To:** [REDACTED] (USANYS) < [REDACTED] >; [REDACTED] (USANYS) < [REDACTED] >; [REDACTED] (USANYS) < [REDACTED] > + +**Cc:** [REDACTED] (USANYS) < [REDACTED] > + +**Subject:** this coming week + +[REDACTED] + +- • [REDACTED] +- [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +- • + +## Wednesday, July 31 + +- Pretrial conference in Epstein —11 a.m. (PC) +- • + +## Friday, August 2 + +## Other + +- Epstein team is meeting on Monday afternoon with the defense attorneys, who apparently have some sort of proposal to present. (PC) +- • + +Chief, Criminal Division United States Attorney's Office, SDNY \ No newline at end of file diff --git a/marker2/ds9/EFTA00085288/EFTA00085288.metadata.json b/marker2/ds9/EFTA00085288/EFTA00085288.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..be2d566c42466f0d976dfad357a6a8f2b177f0d7 --- /dev/null +++ b/marker2/ds9/EFTA00085288/EFTA00085288.metadata.json @@ -0,0 +1,170 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085288.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1081, + "elapsed_seconds": 4.56, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Wednesday, July 31", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 35.496, + 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rescheduled plea acceptance proceeding now scheduled for this Wednesday, July 31, at 9:00 a.m. + +Also, we have had a meet and confer in the Epstein case scheduled for that time on Wednesday, so it is possible a colleague of mine will cover the proceeding — I just wanted to let the Court know. + +thanks very much, + +[REDACTED] + +[REDACTED] + +Assistant U.S. Attorney +Southern District of New York + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00085290/EFTA00085290.metadata.json b/marker2/ds9/EFTA00085290/EFTA00085290.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1e2ad8bc94f135ff11846cf9f5e2463cb37a114b --- /dev/null +++ b/marker2/ds9/EFTA00085290/EFTA00085290.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085290.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": 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b/marker2/ds9/EFTA00085290/_page_0_Picture_33.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:1175224cbecde4f194be2a9bd7b2d4f0dbf87bed94ee99af0ad7a3c3dc8c593e +size 14203 diff --git a/marker2/ds9/EFTA00085291/EFTA00085291.md b/marker2/ds9/EFTA00085291/EFTA00085291.md new file mode 100644 index 0000000000000000000000000000000000000000..2932c4c1abd043ed19cee4031ed5d1ade966e2fb --- /dev/null +++ b/marker2/ds9/EFTA00085291/EFTA00085291.md @@ -0,0 +1,30823 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION + +IN RE: OPERATION LEAP YEAR + +APPEARANCE: + +TESTIMONY + +OF + +/ + +Grand Jury #07-103 (WPB) West Palm Beach, Florida Tuesday, February 6, 2007 + +ASSISTANT U. S. ATTORNEY FOREPERSON + +COURT REPORTER + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 testimony. + +10 Thereupon, + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +a witness of lawful + +PROCEEDINGS + +- - - + +The sworn testimony of was taken + +before the Federal Grand Jury, west Palm Beach Division, + +701 clematis street, west Palm Beach, Palm Beach County, + +State of Florida, on the 6th day of February, 2007. + +, Registered merit Reporter and Notary + +Public was authorized to and did report the sworn + +age, having been first duly sworn by + +the foreperson, testified on her oath as follows: + +BY MS. VILLAFANA: + +Q + +spell your name for the record. + +, please state and + +A It is and I work for + +the FBI in Palm Beach County + +Q can you spell your last name, please. + +A I'm sorry, it is + +Q And I know we have some people in the back + +having trouble hearing you. You said that you work for + +the FBI. can you tell the Grand Jury what particular + +group you are employed with? + +A I am with the + +in + +1 Palm Beach County, I work primarily crimes against + +2 children, but have been an agent for the last + +3 approximately 10 years. + +4 Q Have you received specialized training in the + +5 area of crimes against children? + +6 A Yes, I have. + +7 Q As part of your employment with the FBI have + +8 you been involved in an investigation of Jeffrey + +9 Epstein? + +10 A Yes, I have. + +11 Q And can you tell us who Jeffrey Epstein is? + +12 A Jeffrey Epstein is an investment advisor who + +13 has a part-time residence in the town of Palm Beach, he + +14 has got multiple residences across the country to + +15 include a ranch in New Mexico, an island in the virgin + +16 Isles, and multiple aircrafts, two airplanes and a + +17 helicopter to be exact, and -- + +18 Q And where is his primary residence? + +19 A His primary residence, he has an office in New + +20 York, but his primary residence I believe is the island. + +21 Q In the virgin Islands? + +22 A Yes. + +23 Q He also has a home in New York, correct? + +24 A Yes. + +25 Q How is it that you started investigating + +1 Mr. Epstein? + +2 A The Palm Beach Police Department in March of + +3 2005 initiated an investigation on Mr. Epstein involving + +4 multiple underage females that had visited Mr. Epstein's + +5 residence and had performed sexual massages or massages + +6 for Mr. Epstein of a sexual nature. + +7 Mr. Epstein paid the underage females anywhere + +8 from 200 to \$400, that investigation was around an 8 to + +9 10-month investigation, and at that point we became + +10 involved in about July of 2006. + +11 Q And once the case was presented to you by the + +12 Palm Beach Police Department did the FBI open its own + +13 investigation? + +14 A Yes, yes, we initiated our investigation in + +15 July of 2006, we took a look at focusing in on the + +16 underage minors and in our investigation we interviewed + +17 many of the girls that were underage and we did an + +18 independent investigation issuing Grand Jury subpoenas + +19 as well as administrative subpoenas getting different + +20 documents of financial records, telephone analysis, + +21 flight manifests, looking to see if Mr. Epstein engaged + +22 in sexual activity with these females. + +23 Q All right. And just so the Grand Jury is + +24 clear, were some of the girls who went to Mr. Epstein's + +25 house 18 or older? + +1 A Yes. + +2 Q And then there were some that were under the + +3 age of 18, correct? + +4 A Yes. + +5 Q And as part of the federal investigation did + +6 you have to investigate what we call the interstate + +7 nexus aspect of the case? + +8 A Yes. + +9 Q And can you explain to the Grand Jury what + +10 that is? + +11 A we looked at -- Mr. Epstein, as I mentioned + +12 earlier, has two aircrafts, and we focused in on the + +13 year 2004, 2005, he took approximately 60 trips to his + +14 residence in Palm Beach, the majority of that time + +15 focusing in on his assistant's cell phone, which his + +16 assistant's name is , we took a look at her + +17 cell phone records and the majority of the times that + +18 Mr. Epstein would fly into Palm Beach Mrs. -- Ms. + +19 would contact many of our underage victims either prior + +20 to coming into Palm Beach, the day of, the day before, + +21 even the day after, and certainly throughout the time + +22 that Mr. Epstein was at his residence in Palm Beach. + +23 Q And from the interviews of the girls that have + +24 been conducted, what was the subject of those telephone + +25 calls? + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 Q And I will just -- I will spell + +15 + +16 and the last name is spelled + +17 + +18 name? + +19 + +20 + +21 Q + +22 + +23 investigating her activity? + +24 A we are looking at that. + +25 + +A Can you restate the question? + +Q Sure. From the interviews of the girls that + +have been conducted, what was the subject matter of the + +telephone calls from ? + +A would schedule the underage girls + +to come and work, perform the massages for Mr. Epstein, + +so she was responsible, she as well as another + +assistant, , they were his personal + +assistants who would set up appointments for Mr. Epstein + +for the girls to come and perform their sexual massages. + +Q All right. is also considered a + +target of this investigation? + +A Yes, she is. + +for the Grand Jury. The first name is + +and does Ms. have a new last + +A Yes, she does, she is married and her name is + +Is ms. at least a subject of + +this investigation, in other words, you are + +Q In addition to those two assistants, from the + +1 interviews of the girls, is there anyone else who is + +2 associated with Mr. Epstein who is thought to be + +3 involved in this activity? + +4 A has been referred to as his + +5 companion, girl friend, personal assistant, she through + +6 the testimony of the girls has engaged in sexual + +7 activity with at least three of the underage minors. + +8 Q And is so ms. + +9 is also at least a subject of the + +10 investigation, correct? + +11 A Yes, she is. + +12 Q Now, as part of this investigation you + +13 mentioned that subpoenas were issued on behalf of either + +14 the old Grand Jury or this Grand Jury. + +15 can you run through what subpoenas have been + +16 issued and what documents have been received in response + +17 to that? + +18 A Sure. we issued a Grand Jury subpoena to + +19 colonial Bank and we received financial records on + +20 credit card accounts and individuals. + +21 we subpoenaed washington mutual and they did a + +22 search and were unable to locate records at this time. + +23 we issued a Grand Jury subpoena for Capital One and + +24 served that and that is still unresolved at this time as + +25 far as them providing documents to us. + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +We have subpoenaed Chase Credit Card and we + +have received documents from Chase. we have subpoenaed + +two businesses that Mr. Epstein has at least partial + +ownership or associated to, Hyperion Air, Inc. and JEGE, + +Inc., they were issued subpoenas and they have provided + +documentation to us. + +we have subpoenaed Mr. , who is a + +pilot of Mr. Epstein's, and we have received + +documentation from We have subpoenaed DTG + +10 + +11 + +Operations, who is doing business as Dollar Rent-A-Car, + +and we have received car rental agreements and financial + +12 records from that business. + +13 we have subpoenaed Royal Palm Beach High + +14 School and have received documentation regarding the + +15 students' records. We have subpoenaed three or four of + +16 the victims, being the first, and we have + +17 received a bathing suit from + +18 we issued a Grand Jury subpoena to + +19 , we actually have issued three subpoenas, + +20 and we are still working on resolving her Grand Jury + +21 material as well as testimony. + +22 We have issued a subpoena, we + +23 have issued -- she also is one of our underage victims. + +24 we've issued Reimer Employment Agency a Grand Jury + +25 subpoena and we have received documentation, that is an + +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 + +employment agency located on the island of Palm Beach. + +we have subpoenaed the Palm Beach Police + +Department for their evidence in this case and we have + +received that. By the way, that is the only thing that + +I did not bring with me today, I brought everything + +else, but it is rather a lot of evidence, so we will + +probably be bringing that to you another time. + +we have issued the Clerk of Courts of the + +State of Florida for Grand Jury transcripts in the state + +matter and we have received those. we have issued the + +Good Samaritan Hospital for billing records and we have + +received those. + +We have issued a Grand Jury subpoena to the + +Dalton School located in New York and at this time they + +do not have the records we have requested or could not + +locate those. + +we have issued a Grand Jury subpoena to Extra + +Touch Flowers located here in west Palm Beach and we + +have received documentation from them. we issued a + +Grand Jury subpoena to , another pilot for + +Mr. Epstein, we have spoken with him. + +we have issued a Grand Jury subpoena to + +another one of Mr. Epstein's pilots, and we + +have received documentation as well as spoken to him. + +we have issued a Grand Jury subpoena to + +1 + +2 + +3 + +4 have issued a Grand Jury subpoena to + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +IS A Yes. + +16 + +17 + +18 any + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +who is the property manager currently for + +Mr. Epstein at his Palm Beach residence, and we have + +received documentation as well as spoken to him, and we + +and have received some documentation and are still + +awaiting a response. + +Q Now, you mentioned that you didn't bring with + +you the evidence that you received from the Palm Beach + +Police Department, but did you bring with you all of the + +other evidence that was received in response to the + +subpoenas? + +A I have. + +Q And is that evidence in the two boxes that are + +here in the front? + +Q we will bring all of this back to you when we + +present the indictment, but would anyone like to look at + +of the documentation today? + +A GRAND JUROR: what does the documentation + +constitute, basically, the subpoenas? + +THE WITNESS: It is primarily business + +records, flight manifests, stuff that came from him + +traveling to and from Palm Beach, credit card + +records, the businesses as far as the rental + +agreement which involves some of the underage girls + +1 with the rental cars, and flower shop, you know. + +2 A GRAND JUROR: Will we have an opportunity + +3 later to go through these if we need to? + +4 Yes, we will bring them when + +5 we present the indictment. Yes, ma'am. + +6 A GRAND JUROR: If I should hold this for + +7 later let me know, she mentioned the hospital + +8 records were subpoenaed, could more information + +9 about why they were subpoenaed be provided at this + +10 + +11 + +12 + +13 + +BY + +time? + +answer that. + +the girls that was an underage -- that + +Q You can + +A One of + +14 was underage at the time that is involved with + +15 Mr. Epstein has had a baby and we were interested and + +16 wondering if possibly he was the father of that baby, + +17 which at this time we do not believe he was. + +18 A GRAND JUROR: Thank you. + +19 A question? + +20 A GRAND JUROR: Did the flight manifest show + +21 passengers on the plane? + +22 THE WITNESS: Yes, they do. + +23 A GRAND JUROR: Were any of the passengers the + +24 underage girls that were a target of the + +25 investigation? + +1 THE WITNESS: At this time we have not + +2 associated any of these underage girls as being the + +3 passengers. The flight manifests, sometimes the + +4 pilot if they did not know who the passenger was + +5 would put one passenger or one female, one male, + +6 these were private planes and they, you know, may + +7 not have felt like they can go up and ask, but we + +8 don't have any evidence at this time to believe + +9 that they were any of our victims. + +10 Any follow-up? Any other + +11 questions from the Grand Jury? Yes, ma'am. + +12 A GRAND JUROR: The records that you + +13 subpoenaed from the high school, what were they + +14 used for or why were they instrumental in the + +15 investigation? + +16 THE WITNESS: Those are the girls' school + +17 records and we are just looking at the girls' + +18 records. + +19 A GRAND JUROR: Absenteeism? + +20 THE WITNESS: Just looking at some of their + +21 grades and performances and how they did in school. + +22 Ladies and gentlemen, before + +23 we continue, the witness has mentioned a few names + +24 of the minors and that is confidential information, + +25 obviously everything that you hear within these + +1 walls is confidential. + +2 BY + +3 Q Now, ' after -- in + +4 addition to issuing the subpoenas, you mentioned that + +5 one of the subpoenas was to the Palm Beach Police + +6 Department. Did you review any of the evidence that + +7 they collected? + +8 A Yes. + +9 Q And can you, for example, did the Palm Beach + +10 Police Department interview any girls? + +11 A Yes, they did, they interviewed several of the + +12 girls, most of the girls, they took taped statements + +13 from the girls either in the form of a tape-recorder or + +14 through video. + +15 Q And you have reviewed some of those + +16 interviews, correct? + +17 A Yes, we have. + +18 Q And has the FBI performed any interviews? + +19 A Yes, we have, we have performed interviews of + +20 past and current employees of mr. Epstein as well as + +21 focusing in on the girls, the girls that were underage + +22 at the time of the sexual activity, we wanted to + +23 determine with these girls, again, the sexual activity + +24 that took place with Mr. Epstein as well as how old they + +25 were at the time, if they traveled with Mr. Epstein, any + +1 gifts that they may have gotten, so we did reach out to + +2 several of the underage minors and gathered more + +3 information from them. + +4 Q And through the FBI's investigation has the + +5 FBI identified additional victims that perhaps the state + +6 police officers did not know about? + +7 A Yes, we are still trying to identify, get + +8 first names of girls and going back and looking through + +9 school yearbooks and attempting to try to locate friends + +10 of friends, so we are still in the process, when you + +11 interview one of the girls and you ask if any of their + +12 friends went, they sometimes will give you other names, + +13 so we are in the process of still uncovering victims and + +14 reaching out and interviewing additional girls that we + +15 believe possibly were underage at the time of this + +16 sexual activity. + +17 Q If I could ask you to step outside. + +18 (The witness was excused from the Grand Jury + +19 room.) + +20 (Questions posed by the Grand Jury.) + +21 (The witness was recalled to testify before + +22 the Grand Jury.) + +23 BY + +24 Q one of the Grand + +25 Jurors asked whether there was any evidence of force or + +1 coercion. + +2 A when talking to the girls they were told that + +3 they may have to -- they were going there to perform a + +4 massage, possibly model lingerie, they went there + +S sometimes on multiple occasions and they may start off + +6 wearing their clothing and then he would instruct them + +7 to remove their clothing, the girls either performed + +8 these massages in the nude or keeping their underwear + +9 on. + +10 As they went back again and again on some of + +11 the occasions the girls would take off more and more of + +12 their clothing, so when they first started they may be + +13 fully clothed and then when they came back he would + +14 instruct them to remove more of their clothing, so as + +15 far as coercion, they were paid \$200 to \$400 to perform + +16 these massages. + +17 They are not trained in performing massages, + +18 they don't -- they are not masseuses, but yet if you ask + +19 if they were coerced, they were paid quite a bit of + +20 money for 30 to 45 minutes work. + +21 Some of the girls, being that they were minors + +22 going to his residence, got in over their heads and did + +23 not always return or come back, some of our victims did + +24 not come back after, you know, they did go down to their + +25 thong underwear and Mr. Epstein did perform sexual acts + +1 either by -- and 1 didn't get into that, but either by + +2 stroking their vagina on the outside of their panties or + +3 sometimes inside their panties as well as fondling them, + +4 and the girls, many of our victims did not realize that + +5 that was what was going to happen. + +6 Q And was there one instance where Mr. Epstein + +7 actually engaged in vaginal intercourse with a girl + +8 against her will? + +9 A Yes, he did, one of our victims who had been + +10 going there over a lengthy period of time had told + +11 mr. Epstein on several occasions that he was not to do + +12 that and he did turn her around, threw her on the + +13 massage table and penetrated her. + +14 Q A Grand Juror asked how old Mr. Epstein is. + +15 A He was 45 at the time that we are looking at + +16 him at that time period. + +17 Q A Grand Juror asked if you know the proportion + +18 of girls who were underage versus 18 or older. + +19 A The majority of the girls that we are looking + +20 at are victims, well, all of our victims that we are + +21 looking at were under the age of 18. + +22 As far as all of the girls that have been + +23 interviewed, the majority definitely were under 18. To + +24 give you a number, 1 would have to go and count, but I + +25 would say in the state investigation there were over 25 + +1 girls identified and more than a majority would have + +2 been under the age of 18. + +3 Q A Grand Juror asked whether we have obtained + +4 Mr. Epstein's DNA and whether there was any DNA testing + +5 of the baby that you spoke of earlier. + +6 A No, we have not. + +7 Q A Grand Juror asked how Mr. Epstein would make + +8 contact with the girls, was this done via computer or in + +9 some other method? + +10 A I am sorry, , his personal + +11 assistant, would contact, or on some occasions + +12 would also contact the girls via their cell + +13 phone and we have message pads from the residents that + +14 also indicate the girls calling the home in response to + +15 some of those phone calls, so they would call, + +16 would call, the majority of the calls were made + +17 by to the girls arranging for these, you + +18 know, can you come at this time, can you come at that + +19 time. + +20 Q And is the cellular telephone a facility of + +21 interstate commerce? + +22 A Yes, it is. + +23 Q And then one of the Grand Jurors asked whether + +24 the assistants knew that the girls were underage or + +25 committed sex acts. + +1 + +2 + +3 + +4 + +5 + +Did anybody, have you interviewed anybody who + +affirmatively told you that they told their + +age or what was going on behind closed doors? + +A No, no, not at this time, not at this time. + +Q And what leads you to believe that she, for + +6 example, knew or should have known what was + +7 going on? + +8 A There are so many girls that + +9 contacted to give mr. Epstein massages that have no + +10 training in massages, and that was aware + +11 that girls were bringing other girls, you know, their + +12 friends to do these massages. + +13 was also making appointments for + +14 legitimate massages for Mr. Epstein from legitimate + +15 masseuses that would come and give him massages, so the + +16 number of girls, their appearances at the time would + +17 lead us to believe that had knowledge that + +18 these girls were underage. + +19 Q All right. Thank you very much. Those were + +20 all the questions from the Grand Jury. + +21 A GRAND JUROR: Actually, I have two more, + +22 but. + +23 okay. + +24 A GRAND JUROR: what was the actual age range + +25 of these girls? + +1 THE WITNESS: 14 to I mean. + +2 A GRAND JUROR: The other one was, how did Ms. + +3 actually originally get these girls, how + +4 were they brought in, I mean how were they, you + +5 know, because you said she called them when he was + +6 arriving, but how did these girls come into this in + +7 the first place? + +8 A GRAND JUROR: Could she speak louder? + +9 , we + +10 just had a request that you speak louder. + +11 A GRAND JUROR: 14 and what? + +12 THE WITNESS: Our victims were 14 to 17, but + +13 we have girls that are 18, we have girls that are + +14 20, we have girls that are in their early 20s, and + +15 your question was? + +16 A GRAND JUROR: How did she originally get + +17 them in in the first place? + +18 THE WITNESS: We are focusing in on 2004, + +19 2005, we have some evidence to show that this + +20 activity was taking place even earlier than that, + +21 certainly to include 2003 if you look at the + +22 message pads, but focusing in on 2004, 2005, the + +23 chain started with one of our minors and from that + +24 minor who goes to the house, Mr. Epstein tells + +25 her -- sees that she is maybe not comfortable with + +1 doing the massage the way he would like it and + +2 tells her that she could bring other girls to do + +3 the massages and she in fact if she brought another + +4 girl she would be paid \$200 for just bringing + +5 another girl, so there starts the chain, and + +6 Mr. Epstein would ask the girls or would ask + +7 the girls for their phone numbers so each time, you + +8 know, if one of the girls brought a girl and he + +9 liked her he would ask for her phone number, ask + +10 her to leave the phone number, or + +11 would get the phone number and then that girl would + +12 maybe bring, because if you brought somebody you + +13 didn't have to do the massage, but you also got + +14 paid for bringing a new person, so not only if you + +15 did the massage would you get anywhere from 200 to + +16 400, but if you brought a new female you would + +17 receive 200 or \$400. + +18 A GRAND JUROR: Do you know how she solicited + +19 that original minor? + +20 THE WITNESS: I don't. well, I know that + +21 minor was approached by two individuals and we have + +22 interviewed one of those individuals who we can + +23 connect back to Mr. Epstein four years, possibly, + +24 prior to this, and stated that his job was actually + +25 to drive some of the girls to the residence and + +1 that's pretty much where we start off. + +2 + +3 + +Would the Grand Jury like + +to maintain the records + +4 that we received in response to the subpoenas? + +5 A GRAND JUROR: Maintain versus what? + +6 A GRAND JUROR: What is our choice? + +7 I don't know that there is. I + +8 guess I could maintain them, but I don't believe we + +9 have secure storage in here. + +10 would you like 5 to + +11 maintain custody? + +12 A GRAND JUROR: Yes. + +13 : You should have something to + +14 swear her in as a custodian. + +15 (The witness was sworn in as the custodian of + +16 records.) + +17 : Thank you, ladies and + +18 gentlemen, I am the last person for today, so you + +19 guys are free to go and we will see you probably in + +20 a couple of weeks, we will be seeing a lot of you. + +21 (The witness was excused from the Grand Jury + +22 room.) + +23 (The testimony of the witness concluded + +24 before the Grand Jury.) + +25 + +1 CERTIFICATE OF REPORTER + +4 I certify pages 2 through 21 are a true + +5 transcript of my shorthand notes of the testimony of + +6 )efore the Federal Grand Jury, + +7 west Palm Beach, Florida on the 6th day of February, + +8 2007. + +11 Notary Public + +12 Commission . + +13 Expires May 8, 2008 + +UNITED STATES DISTRICT COURT + +SOUTHERN DISTRICT OF FLORIDA + +IN RE: OPERATION LEAP YEAR + +APPEARANCES: + +ESQUIRE + +Federal Grand Jury, 07-103 + +West Palm Reach, Florida + +February 27, 2007 + +Assistant United States Attorney + +Foreperson + +TESTIMONY + +ORIGINAL + +The sworn testimony of + +was taken before the Federal Grand Jury, West Palm + +Beach Division, West Palm Beach, Palm Beach County, + +State of Florida, on the 27th day of February, 2007. + +Court Reporter, was authorized to + +and did report the sworn testimony. + +(The witness + +having been duly + +was examined + +entered the grand jury + +room.) + +foreperson, + +as follows: + +sworn by the grand jury + +and testified on her oath + +EXAMINATION + +BY + +Q Good morning, . Could + +you restate and spell your name for the record. + +A It's + +Q Can you remind the grand jury who you are + +employed by? + +A The FBi. + +Q I know that you testified here a few weeks ago. + +Was there anything from that testimony that you wanted to + +correct? + +A I did. I was asked by one of you Mr. Epstein's + +age, and I confused him with another individual in another + +one of my cases. His birthdate is January 20, 1953. We + +are looking at the time period of 2004 and 2005. So + +Mr. Epstein would have been about 51 or 52-years-old, and + +I believe I told you he was 45. So at the time we're + +looking during this investigation, he is 51 or 52. + +Q , how did this case first come + +1 A In March of 2005, our youngest + +identified victim -- called the Palm Beach + +police department and reported that she believed that her + +had been molested by a male that resided in + +the town of Palm Beach. + +So today we are going to talk about + +A Yes. + +Q And we are using her initial to protect her + +identity, correct? + +A Yes. + +Q Can you tell the grand jury date of + +birth? + +A birthday is + +Q And you mentioned that the call came in tto:n + +in March of 2005, correct? + +A Yes. + +Q So how old was at that time? + +A She was 14. + +Q Where does live? + +A lives in the Loxahatchee-Royal Palm Beach + +area here in Palm Beach County. + +At the time, in 2005, what school was she + +attending? + +A + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +A She was a ninth-grader there. + +Q You mentioned that her + +called the + +Palm Beach police department. What did the police + +department do in response to that call? + +A They wanted to interview . I believe it was + +the next day they went out to where Maas attending + +school at that time, which I think was They + +interviewed Mat d wanted to get her side + +of what took place. + +Q Because we'll be referring to this throughout, + +what was the name of the detective who conducted that + +first interview? + +A Detective + +Q So in March of 2005, detective talked with + +Was ever interviewed at any other times? + +A Yes. She was interviewed -- they talked to her + +again. She placed some controlled calls for them later + +that month, we will talk about that later. As well as + +she was interviewed about a year later in July of 2006. + +Not interviewed, but she testified before the grand jury + +for the State of Florida. So she was interviewed by + +detective Pagan in March of 2005, and then about a year or + +three or four months later, in July of 2006, she testified + +before a grand jury with the State of Florida. + +you have a chance to interview + +A Yes, I did. + +Q And when was that? + +A Last night. + +Q Back in March of 2005, you mentioned that + +detective met with on or more than one + +occasion? + +A Yes. + +Q If you could give us sort of an overview of what + +reported during these interviews, and then if there + +are specific discrepancies or differences, we will return + +to those later. + +A All right. On February 5, 2005, it was a + +Saturday, and was at house, She + +was there with her boyfriend, And because these + +are minors, we'll refer to them without using their last + +names, so I'll use those initials. + +They were at residence, and is + +boyfriend, which is also cousin. So they + +were all at house, and was on the phone with + +an individual that refers to as the assistant. + +described the assistant as a tall blonde. + +So throughout I'll refer to her as the blonde lady, if + +that's okay. was unable to recall her name. So + +3 + +4 + +5 + +7 + +8 + +9 + +10 + +11 + +Epstein. + +and overhear on the phone + +describing + +the phone. So when + +(describing to the lady on + +gets off the phone, and + +both want to know why was being described to + +this lady on the phone. Zach becomes upset when + +asks if she would like to go to Palm Beach and give + +man a massage that she knows. agrees, and this + +upsets'''. and an argument ensues wherell'Illand + +go into the bathroom and they argue outside the presence + +of + +12 + +13 + +14 + +15 + +Q Let me stop you there. Was supposed to be + +paid for giving this massage? + +A Yes. told that she would be paid + +\$200 or S300, I believe. + +16 0 You mentioned that is boyfriend, and + +17 Zach is also cousin, correct? + +18 A Yes. + +19 Q What was idea about why they were + +20 arguing? + +21 A She has told us that she believed that must + +22 have known what was doing for this man and the work + +23 that did for Mr. Epstein, and that is why was + +24 so upset. + +1 massage that was going to take place? + +2 + +3 + +4 + +5 A decides to go. + +6 Q Because she wanted to make the \$200 or \$300? + +7 A Yes. + +So tell us then what happened after that + +9 meeting? + +10 A The next day, February 6 -- they discussed that + +11evening about going the next day. We do have on + +12 phone records two calls that were placed. One was placed + +13 to Kellin's cell phone, and the other was placed to + +14 Jeffrey Epstein's residence the night of February 5. + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +A Yes. + +Q So and + +decide to do? + +have this argument. What does + +The next day is contacted a couple of times + +before arrives. Each time prior to being + +contacted by a call is placed by to + +Kellin's cell phone. Kellin, I should tell you, is + +Jeffrey's assistant. + +So on Sunday a call was placed to Kellin, + +and then shortly after that a call was made to That + +same series occurs again, but this time places a + +call to Mr. Epstein's residence, and then is called + +again. + +2 + +3 + +4 + +another girl + +arrive at + +Mr. Epstein's + +in + +house. + +the car, + +residence, + +is driving + +So the two of them + +continue over to + +and . Do you + +and they + +with + +5 know how they were sitting? + +A You know, I'm not sure how they were sitting, + +7 but I know that it was a pickup truck that drove, + +8 and was the driver. I'm not sure exactly the + +9 + +10 + +placement of the other two girls, but they were in the + +truck. + +11Q And ■ **was able to describe how they travelled** + +12 to the island of Palm Beach? + +13 A Yes. She gave directions -- you know, the best + +14 that she could on how she was able to come to + +15 Mr. Epstein's residence. + +16 + +17 + +Once they arrived at the residence, what + +happened? + +18 A I should have mentioned that either the night + +19 before or the day of, there were some things that + +20 tells One, she tells that she is to tell, if + +21 asked, that she is 18-years-of-age, that she attends high + +22 school, that she's in the 12th grade, and I believe it was + +23 + +24 + +Wellington High School that she was to say that she went + +to. + +2 + +3 + +4 + +5 + +6 + +7 + +once she arrived at the residence + +tells her that she + +may possibly be asked to take her clothes off. She also + +tells her that she can stay in her bra, but she may be + +asked to take her clothes off. And told us last + +night that that's when she knew for the first time that + +she might have to possibly remove her clothes. + +At this point they proceed to enter the + +a + +9 + +10 + +11 + +residence. + +approached and + +said they were + +He allowed them + +=describes him as a security person. He + +asked what they were doing there, and + +there to see Mr. Epstein, or see Jeffrey. + +entry into the kitchen area by the pool, + +12 and describes that area. So now and + +13 are all sitting in the kitchen. A short time goes + +14 + +15 + +by and Mr. Epstein, as well as the assistant, enter the + +kitchen. + +16 Q And I know that you mentioned that did not + +17 + +18 + +know the name of the lady who was there in the kitchen, + +correct? + +19 A Right. + +20 Q She just described her as a blonde, tall lady? + +21 A Yes. + +22 + +23 + +Q + +that day? + +Was also interviewed about what happened + +24 A She was interviewed by the Palm Beach police + +Q Did identify the person who was on the + +phone with her as + +A Yes, she did. + +4 Q So even though ■ **doesn't know her name,** + +**s knew Hanle?** + +**6 A Yes.** + +7 Q So you mentioned that the three girls are in the + +kitchen, along with Jeffrey and the person calls the + +blonde lady? + +A Yes. + +11 Q What happened then? + +A follows the blonde lady upstairs to + +Mr. Epstein's bedroom. The blonde lady proceeds to take + +out a massage table and set it up, prepare it. She also + +15 takes out some lotions to be used during the massage. + +told me last night that the blonde lady asked her to + +remove her clothing, and then left the room and said that + +Mr. Epstein would be in shortly. + +19 Q what happened after she left the room? + +A Shortly after that, Mr. Epstein does come into + +the room and shakes s hand. told us last night + +that Mr. Epstein told her to remove her clothing. He + +leaves the room and comes back in just a towel, and he + +tells her again to -- she is at that point -- when he + +1 when he comes back in, he tells her that she needs to take + +her pants off. So she took her pants off. So now she's + +in her bra and underwear. + +4 Q At some point did Sage tell any of the people + +s who interviewed her what was running through her mind? + +6 A She stated at one point that she was upstairs + +with him, with the man, and that Maas downstairs. I + +guess she says, "What coul do? She's downstairs, + +I'm upstairs.' So she did what she was asked to do. + +10 Q So now you mention that Mr. Epstein is here + +wearing just a towel, and has removed both her shirt + +and her pants, is that correct? + +A Yes. + +.4 Q Tell us what happens then? + +A Mr. Epstein gets on the massage table lying on + +his stomach and instructs how to do the massage. He + +tells her to put some lotion on her hand and instructs her + +on how to actually perform the massage. At one point + +during the massage he tells ■ **that she would be more** + +comfortable to get on top of him, so gets on top of + +him and straddles Mr. Epstein's back. + +The way describes it is Mr. Epstein is + +laying on the table, he has a towel covering his bottom, + +and she is straddling him with her bottom touching the + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +of sitting -- it sounds like sitting on his rear end, but + +with part of her skin touching him -- the front of him, + +but he had a towel across his bottom. + +Q What happens as she is providing the massage to + +his back? + +A The massage goes on. She said the entire + +massage lasted anywhere from 30 to 45 minutes. At one + +point Mr. Epstein excuses himself for a few minutes, one + +or two minutes briefly. states that she can hear + +Mr. Epstein moaning or groaning, and states that she + +believes he was, in her words, 'wacking off' or + +masturbating. She didn't say masturbating, she said + +'wacking off.' I am going to use that she believes he was + +masturbating. + +Then he returns. At this point he gets back on + +the table lying on his back and asks her to start + +massaging his chest. So she begins to massage his chest. + +Q Does he keep the towel on? + +A No, at this point the towel is removed. When he + +comes back and he gets back on the table, the towel is + +removed and she is massaging his chest. + +Q What does he do as she is massaging his chest? + +A He moves his hand up and down his penis. So he + +continued to masturbate on the table. He asked at + +extra \$100. He tells her that it would not involve doing + +a massage. agrees. He asked her if he could use a + +vibrator on her, and she does agree. describes it as + +a purple vibrator that was used and she + +said this goes on for about ten minutes. + +At some point during that massage the vibrator + +is not used anymore and takes place. + +describes him + +Q What did she say happened when Mr. Epstein + +digitally penetrated her? + +A The vibrator is used. At some point he does + +her. And these are her words. She + +looks at him kind of funny, and he sarcastically -- which + +is her word -- he sarcastically says, "What's the matter?" + +And she at that point just kind of looks away, and he + +continues on with the In the last + +three to four minutes of that, he begins to masturbate + +again. + +At the conclusion of the sexual activity, + +Mr. Epstein wipes his penis off with a towel. was + +asked if he ejaculated. She did not see him ejaculate, + +but saw him wipe his penis off with a towel. + +Q Was able to provide a physical description + +of Mr. Epstein? + +Q Including of his penis? + +A Yes. + +was she also able to provide a description of + +her surroundings in that massage area? + +A Yes. + +Was that description accurate? + +A Yes. According to other testimony we have + +gotten from other victims, yes. + +Q And a search was performed on Mr. Epstein's + +house? + +A Yes. The Palm Beach police department did + +perform a search, and several of the items that were + +described were found in the house. + +Q After Mr. Epstein wiped himself off, what + +happened? + +A He told that she was getting the extra + +hundred dollars because he was allowed to use the vibrator + +on her and The massage had been + +concluded, the sexual activity had been concluded. He + +gets up and leaves for a brief moment of time and comes + +back with \$300 and pays the \$300. I believe he told + +that she could see herself out. + +Q Before we leave that room, when was either + +being directed to the room or was inside that room where + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +that she noted seeing? + +A She noted seeing several naked pictures of girls + +in the room, a mural or pictures of naked girls either + +exposing their breasts or completely naked. + +Q While the massage was going on, did Mr. Epstein + +talk ton + +A Yes, he did. + +Q And did he talk about sexual conquests with + +girls? + +A Yes, he did. + +Q Once Mr. Epstein has provided with the + +\$300, what did she do? + +A She went back downstairs and she, and + +leave the residence. In the car they ask how + +much money she has made, and she tells them \$300. + +wants to see the money. She shows the money to and + +asks what did she do. At that point tells her + +that he fingered her, as well as used a vibrator. + +• When they left the house, where did they go? + +A When they left the house, they were on their way + +to a mall to go shopping with the money that they had + +received from Mr. Epstein. had told the night + +before that she needed some shoes and wanted to go to the + +mall, and she was going to Mr. Epstein's to pick up some + +Mr. Epstein's house that day, and that they were going to + +go shopping after she got her money, and that could + +make some money. + +Q During that ride, did realize that + +received money from Mr. Epstein? + +A Yes. At some point knows that + +received \$200, but is unsure that ever gave a + +massage. So at that particular time did not know why + +she had gotten the \$200, because she didn't think that + +had had time to give a massage. + +Q In interview, did she explain what she + +got the \$200 for? + +A told the Palm Beach police department in + +her interview that she received her \$200 for bringing + +to the house. + +Q You mentioned that there were these three + +different time periods that was interviewed: Shortly + +after the events, at the time of the state grand jury + +proceedings, and when you met with her, correct? + +A Yes. + +Q And there were some discrepancies between the + +different interviews. Can you explain some of those to + +the grand jury. + +A Before we go and get to that, I want to make + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +car by that we learned from + +interview with + +the Palm Beach police department. So I don't know if I + +said that, but I want to make sure you know that we first + +learned that had beery listening to the + +interview that was conducted between the Palm Beach police + +department and , not from . When I talk later, I + +just want to make sure you realize that that had not + +initially come out in interview, but through the + +interview with + +So going back. I'm sorry, discrepancies? + +Q Yes. + +A I met with ■ **last night to discuss some of** + +**the discrepancies when looking at what she had talked to** + +**detective about in March of 2005 and what she had** + +**testified to in the grand jury in July of 2006. Reading** + +**the testimony and listening to the tapes, or reading the** + +**transcript, there were a few discrepancies.** + +**One of the first ones we talked about was what** + +**had told her about going to Mr. Epstein's house.** + +**She tells detective that she was told about the** + +**massage, told about getting \$200, but that she was not** + +**told that she would have to take her clothes off. She** + +**didn't know she would have to perform the massage naked.** + +**When I asked her last night that question, she** + +1 Mr. Epstein's residence, that did tell her that she + +may be asked to take off her clothes. She also did state + +that told her she could stay in her bra. + +So I wanted you to know that there was a + +discrepancy in what she originally had told detective + +Pagan and what she told me last night. That would be one. + +The second discrepancy I wanted to touch on with + +her was going upstairs and taking off her clothing. When + +she is in that room, she states to detective that + +asked her to remove her clothing, and she took off + +her shirt. Then Mr. Epstein came in the room, shook her + +hand and told her to take off her clothes. He leaves, he + +comes back in a towel. He tells her again. ells + +detective in a stern voice, ^Mr. Epstein told me to + +take off my pants.• Because she hadn't taken off her + +pants from the first time that she met him. + +In her testimony with the grand jury with the + +state, she tells the grand jury that it was who + +asked her to remove her clothing. So last night we went + +over with her who told her to remove what. She had a very + +hard time recalling exactly. She knew she had gotten down + +to her bra and underwear. And then at some point, when + +we're going through the sexual activity, she actually + +tells me that her underwear was off when he was using the + +Later in the interview, we tell her about what + +we have in her testimony to the grand jury and her + +statements made to detective And she really is + +having a difficult time trying to remember who told her to + +take off her clothes and her pants. As we are walking + +through. the sexual activity, she does recall and states + +that it was Mr. Epstein who told her to take off her + +8 pants. + +I guess I'll go to the third discrepancy. Is + +there anything I left off with that? + +11 Q Well, does she report that when the assistant + +leads -- or the blonde lady leads her upstairs, that the + +blonde lady also said, "Get undressed," but that + +didn't get fully undressed? + +A That's what she said in her statement to the + +detective, when she gives her first statement. She tells + +us again last night that that's what she recalled. + +18 Q That the lady said first, "Get undressed," but + +she doesn't get fully undressed. And when Jeffrey comes + +back, he said, "Take your pants off."? + +A Yes. And again, like I said, when we started + +interviewing her and asking her about this, she did have a + +hard time. But when we were walking through the sexual + +activity, that's when she recalls who told her to take off + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +And I'll tell you, when we talked about the + +sexual activity, and it comes out that she wasn't wearing + +her underwear when he was her and + +using the vibrator, she does not recall how they came off. + +She cannot remember removing her underwear. She doesn't + +remember if Mr. Epstein removed her underwear. She knows + +her underwear was off, but she cannot tell you exactly at + +what point her underwear was removed. + +Q Let's talk about the third discrepancy. + +A The third is the sexual activity, when she was + +originally interviewed by detective Pagan about the + +vibrator or being + +Pagan comes + +tell her at + +When detective + +and sees her again a few weeks later, she does + +that time that a vibrator was used on her. + +She also says that to the grand jury, she talks about the + +purple vibrator being used on her. + +Last night she told us about the purple vibrator + +being used on her. When we asked her about him + +her, and that had told the police + +department that she had bee- told us last + +night that she by Mr. Epstein, but that she + +thought only her and knew about this and that she + +did not want her father to know that he her. + +She didn't want anybody to know, but she especially didn't + +she did not know that + +it was only her and + +had told anybody, she thought + +that knew. She was embarrassed + +and didn't want anybody to know that. + +Q Did she become visually upset? + +A Yes, she began crying when we asked her about + +6 being When she realized that we + +knew about that, she became very upset and concerned about + +her father. She mentioned that her father has read a lot + +of the reports in the State of Florida, and has followed + +the state's case. She was concerned about even telling + +us, afraid that he would be able to read in our reports + +about this. + +We explained to her that the FBI's reporting is + +a little bit different than the way the state -- those are + +public records, and ours is part of our case file. + +16 Q In addition to the fact that she had these + +concerns about her father and she was embarrassed, in your + +experience of interviewing victims of sexual abuse, is it + +typical for them to not disclose all of the sexual + +activity? + +A Yes, it's very typical. And young girls, they + +don't want to talk about it. This is just another case of + +her not wanting to tell exactly what took place. + +24 Q After that first visit to Mr. Epstein's house, + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +Pagan ask to make what are called controlled calls? + +A Yes. + +Q Can you explain to the grand jury what a + +controlled call is? + +A A controlled call is where we actually have a + +listening device, where we have an individual place a call + +to somebody and we are able to record the other person's + +voice and the conversation that takes place between the + +person that we're having make the call and the person that + +they are calling. + +Q Who did detective Pagan ask to call? + +A was asked to call on the phone. + +Q And did she do so? + +A Yes, she did. + +Q Can you tell the grand jury when the calls were? + +A I believe the first call was made towards the + +end of March, I believe it was March 30. + +at the + +concerned that father had found out somehow + +called + +where works. was + +and + +that they knew about it. And she refers to him as + +Jeffrey, but Mr. Epstein. + +told her that they did not know about + +Mr. Epstein. Later in the conversation tells her + +that Mr. Epstein would like her to come back and work for + +they agreed that there would be a call between + +tomorrow, that will call tomorrow. + +Q Were there calls also made on March 31 + +A There were two calls made on March 31. + +and + +of 2006? + +The + +first one she doesn't connect to . The second call + +that was made a short time later, answers the phone. + +Again, there is a discussion about coming to work for + +Mr. Epstein. tells -- one of the comments that + +is made is, "The more you do, the more you make." is + +asking her how much can I make. + +Again, detective Pagan is there, and is + +asking how much can I make. is telling + +that she'll have to ask Mr. Epstein that, that she is + +going to see Mr. Epstein tomorrow and that she'll.talk to + +Mr. Epstein. There is conversation about and her + +possibly coming to Mr. Epstein's house. There + +is some discussion about her coming to work for + +Mr. Epstein. + +Q Just so it's clear, because there were a lot of + +shes, is telling that is going to see + +Epstein the following day? + +22 A Yes. + +And that is going to set up a schedule + +with Mr. Epstein for and to work for him? + +2 + +3 + +4 + +Q On April 1, the following day, did make + +calls to + +A From the Palm Beach police department, they were + +able to take voice mail messages left by on + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +phone stating that could come and work on Saturday + +around 11:00. + +Q I think you mentioned this -last time, but in + +case you didn't, did the Palm Beach police department do + +trash pulls at Mr. Epstein's house? + +A Yes, they did. + +Q Was there anything of value related to this + +12 series of calls that were recovered? + +13 A Yes. There was a trash pull done in the + +14 + +15 + +beginning of April, and + +paper that on it had + +in the trash there was a piece of + +name, name, and I + +16 believe it was 10:30 listed on the piece of paper. + +17 Q It said with on Saturday at 10:30? + +18 A Yes, it did. + +19 Q In addition to the actual recordings of those + +20 phone calls and voice mail messages, do you also have + +21 + +22 + +telephone records from + +cell phone that match + +both cell phone and + +up? + +23 A Yes. + +24 Q Just to go back to something that you mentioned. + +1 at Mr. + +Epstein's house? + +2 A Mr. Epstein. + +3 Q You mentioned a girl named + +4 A Yes. + +5 Q Was also interviewed? + +6 A Yes, she was. + +7 Q Was she asked about going with to take + +8 + +9 + +10 + +girls to Mr. Epstein's house? + +A Yes. + +Q Was she asked who the youngest-looking girl was"' + +11 A Yes. + +12 Q What did she say? + +13 A She discussed looking young in her + +14 interview with the Palm Beach police department. + +15 Those are all of my questions + +16 for you now. If you could please step outside, I'll + +17 see if the grand jurors have any. + +18 (Witness excused, and then returned.) + +19 BY MS. VILLAFANA: + +20 Q we have just a few questions. + +21 One relates to the conversation between Mr. Epstein and + +22 about his exploits with other girls. Did Mr. Epstein + +23 say anything about the age of those girls? + +24 A He said that -- in particular on one case he + +with, and her parents were in the front seat. He told + +that they were having sex in the back seat -- were + +doing sexual things in the back seat while he was carrying + +on a conversation with the parents in the front seat. I + +guess they were on their way home from a business party. + +This was one of the stories that he had talked about. + +Q But at no time did he provide any specific ages + +about any of those girls? + +A No. + +Q What was age at the time she took + +to Mr. Epstein's house? + +A She was 18. + +Q Did Mr. Epstein ask anything about her age? + +A He did. He asked her how old she was, she said + +she was 18. He asked her what grade she was in, she said + +she was in the 12th grade. He asked her where she went to + +school, and she said she went to + +Q I know we will be doing a lot more discussion + +about later. But could you tell us briefly how + +■ **was recruited to go to Mr. Epstein's house?** + +A was at the beach, and two individuals + +approached her about making money and giving a massage to + +Mr. Epstein. + +Q How old was when she first went to + +1 + +2 and starting at age 17. + +3 + +4 + +5 + +6 BY + +7 + +8 evidence to suggest that Mr. Epstein knew that was + +9 under the age of 18? + +10 + +11 multiple girls that went to Mr. Epstein's house -- the way + +12 that having seen last night, and now she's 16 -- this + +13 was two years ago -- that age and behavior -- and + +14 again, is that more circumstantial evidence? As far as + +15 concrete evidence, no. But just by her appearance and her + +16 mannerisms and how I observed her last night at age 16. + +17 + +18 during her statement, correct? + +19 + +20 + +21 + +22 + +23 + +24 + +A Through phone records, we have contact between + +Thank you. + +: Those are all the questions. + +(Witness excused, and then returned.) + +Q The question was, was there any particular + +A I would say through the interviews of the + +Q And that's consistent with what Serena said + +A Yes, it is. + +Any other questions? + +JUROR: Did she look 18? + +THE WITNESS: Does look 18? Not in my + +opinion, sir. + +All right. Any other questions? + +(Witness excused.) + +CERTIFICATE OF REPORTER + +I CERTIFY pages 1 to 28 is atrue transcript of + +my shorthand notes of the testimony of + +before the Federal Grand Jury, West Palm + +Beach, Florida, on the 27th day of February, 2007. + +Dated at West Palm Beach, Florida this 18th day + +of March, 2007. + +Court Reporter + +UNITED STATES DISTRICT COURT + +SOUTHERN DISTRICT OF FLORIDA + +ORIGINAL + +RE: OPERATION LEAP YEAR + +TESTIMONY + +OF + +SPECIAL AGENT + +Federal Grand Jury 07-103 Federal Building U.S. Courthouse West Palm Beach, Florida Tuesday, March 20, 2007 + +APPEARANCES: + +ssistant united States Attorney + +Foreperson + +The sworn testimony of SPECIAL AGENT II + +was taken before the Federal + +Grand Jury, West Palm Beach Division, Federal + +Building, U.S. Courthouse, Palm Beach County, + +State of Florida, on Tuesday, March 20, 2007. + +Certified Court + +Reporter and Notary Public, State of Florida, + +Official Reporting Service, LLC, 524 South Andrews + +Avenue, Suite 302N, Fort Lauderdale, Florida, + +33301, was authorized to and did report the sworn + +testimony. + +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 + +BY + +(Witness enters the Grand Jury Room.) + +THE FOREPERSON: You do solemnly swear + +that the testimony you give will be the + +truth, the whole truth, and nothing but the + +truth, so help you God? + +THE WITNESS: I do. + +THE FOREPERSON: Thank you. Please be + +seated. + +Q + +please + +EXAMINATION + +could you + +state and spell your name for the record? + +A + +Q + +It's It's + +Now Special Agent , last week + +or the + +girls, + +A + +last time that we met, we discussed + +correct? + +Yes. + +two + +Q Who visited Mr. Epstein's home? + +A Yes. + +Q And those were and + +A Yes. + +Q + +girls? + +A + +Did you obtain photographs of those + +Yes, I did. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q And do you know approximately when those + +photographs were taken? + +A They were taken during the same time + +period that we are investigating, '04 and '05. + +There may have been a few in '03, but it was + +within a year's time of six months within the + +activity that we are investigating. + +Q All right. Let me show you what has + +been marked as Grand Jury Exhibits 1 and 2, and + +can you tell us what Exhibit 1 is? + +A Exhibit 1 is and it's a + +photograph of her with her date of birth listed. + +Q And what is Exhibit 2? + +A A photograph of with her date + +of birth as well + +BY + +those to the + +Q Now the + +had described how + +to Mr. Epstein's + +A Yes. + +Q Did + +Epstein house? + +A Yes, she did. + +on it. + +And I will just pass + +grand jury. + +last time that we were + +had brought + +here, you + +home? + +bring other girls to the + +1 Q And is one of those girls + +2 A Yes. + +3 Q And what is the date of birth of + +4 ? + +5 A She was born + +6 Q And where did go to high + +7 school? + +8 A + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +A + +Q + +school? + +A + +Q + +And is that the same school that + +went to? + +Yes. + +And was ever a student at that + +Yes, she was. + +Tell us a little bit about -- well, + +first of all, did the Palm Beach Police Department + +have a chance to interview + +A Yes, they did. + +Q And what about yourself? + +A And I did as well. + +Q Okay. Tell us, if you will, how + +started going to Mr. Epstein's house? + +A was the one who brought to + +Mr. Epstein's house. told that she + +may have to remove her clothing and that she could + +1 + +2 + +3 + +4 + +S + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +makes \$200 if she performed a massage for Mr. + +Epstein. + +She also was told by that he may + +try to touch you, but if you are uncomfortable, + +just tell him no, and she also said that if + +Epstein asked her age, she was to say she was 18. + +Q Now that information that you just + +relayed, who provided that information? + +A + +Q And what did + +A I'm sorry. provided in the + +interview to me that information. + +Q Did also admit that she brought + +to Mr. Epstein's home? + +A Yes. + +Q When did this first occur? + +A This occurred in -- we believe the first + +time period was when was 16. + +Q And is there any telephone records that + +show communications between and + +and and + +A Yes. + +Q And when are those phone records? + +Those phone records show up in March of + +'04 when would be 16. + +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 + +Q Let me show what has been marked as + +Grand Jury Exhibit Number 3, and what is Exhibit + +3? + +A This is a hoto raph of with + +her date of birth, + +Q Now you mentioned that in March of 2004 + +and April of 2004, there are these records of + +phone calls and did say how old she was + +when she first went to Mr. Epstein's house? + +A I'm sorry. Did + +was? + +say how old she + +Q Did she tell you or the police officers + +how old she was? + +A Yes. I'm sorry. I thought your + +question was did she tell Mr. Epstein. + +She told me that she was 16 when she + +went to Mr. Epstein's house. + +Q Okay. That is consistent with those + +phones calls? + +A Yes, it is. + +Q Okay. Now during her first visit with + +Mr. Epstein, what happened? + +A She went to Mr. Epstein's house. + +took her there. told her she didn't have + +her driver's license at that time, which she told + +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 + +her she got her driver's license when she was 17. + +So drove her to Mr. Epstein's + +house. She provided Mr. Epstein with a few + +massages. She remained clothed both times that + +she gave him a massage. At this time, she kept + +her clothes on. + +I think one time she was wearing shorts + +and a T-shirt, maybe the second time she was + +wearing jeans and a T-shirt. That he constantly + +grabbed and pulled at her during the massage + +trying to draw her closer to him, but at that + +time, you know, there was no sexual activity other + +than the grabbing and pulling. + +There was no sexual activity that took + +place on those first couple of massages, and she + +remained clothed at that time. + +Q Now after those first few massages, was + +there a break in time before returns to + +the Epstein house? + +A told us that she and had + +had some kind of a fight or a disagreement, a + +breakup in their relationship, so there was a time + +period where she did not go back to Mr. Epstein's + +house. + +Q And when -- did there then come a time + +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 + +when she returned to the Epstein house? + +A Yes. We have phone activity between + +of '04. + +and beginning in December + +Q And + +of '04? + +how old was in December + +A She had turned 17 at that time. In + +fact, through the course of the phone records + +beginning in December of '04 to October of 2005, + +we have over 150 phone calls between + +and , Mr. Epstein's assistant. + +Q What did tell you about the + +activity that occurred when she started returning + +in late '04? + +A When she started giving Mr. Epstein + +massages after that break, the massages became + +much more sexual in nature. Mr. Epstein continued + +to push and there were many times when + +would perform massages completely nude. + +Several times, she would stay in her + +underwear with no bra on, but stated to me that + +many occasions she performed the massages to Mr. + +Epstein in the nude. + +Q In addition to being unclothed, was + +there other sexual activity? + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +A Yes, there was. during my + +interview with she became very upset when + +discussing the sexual activity that took place at + +that time. + +She stated that Mr. Epstein had + +digitally penetrated her. It began first by + +rubbing her on the outside of and then + +on more than one occasion actuallyl + +with + +He would request her o pinch his + +nipples. He rubbed her breasts as well. She + +stated that there was a vibrator that was used on + +as well, but + +that she described the vibrator as being a white + +vibrator with a gray head, and several of the + +other victims have said the same thing, described + +it similar to that. + +Q And jus I forget, when you + +testified about , did also report + +having a vibrator used on her? + +A Yes. + +And, again, so the record is clear, when + +you are talking about these vibrators, they are + +the large back massager type vibrator? + +A We have had some girls just describe + +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 + +them as a vibrator. We have had some girls just + +describe them as a back massager and then we also + +had girls describe them as both, because of the + +size of it, I think some girls are more aware of + +what a vibrator would look like due to their ages. + +You know, I don't know that everybody + +knew exactly what a sexual vibrator looked like, + +but they all vibrated, and we have actually had + +that described, and described it as both, + +a vibrator slash massager, saying that it was, you + +know, large in nature. + +Q Okay. Now in addition to using that + +massager and was + +there other sexual activity? + +A Yes. Several times during the massages, + +Mr. Epstein would have straddle him while + +he laid on his stomach and then he would reach + +between her legs and masturbate and + +occasionally -- + +Q And this is when he was laying on his + +back not his stomach? + +A I'm sorry. Did I say that? + +Q You said on his stomach. + +A He is laying on his back. She's on top + +of him straddled, and he is reaching between her + +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 + +masturbating, and he has attempted to put his + +penis on never penetrating her, but + +that was what was described to us by + +Q Now when was first interviewed + +by the Palm Beach Police? + +A She was interviewed October 6th of 2005. + +Q And at that time, did she say when her + +last visit was to Mr. Epstein's house? + +A Yes, she said October 1st, 2005, was the + +last massage that she had given Mr. Epstein. + +Q Is there any other evidence that was + +recovered from Mr. Epstein's or his household + +items that would confirm that statement? + +A We have a message pad. During the + +search warrant, several of the message pads -- I + +don't know if we referred to them at this stage. + +We may not have. + +We recovered -- well, I shouldn't say + +we, the Palm Beach Police Department recovered + +several message pads. They were carbon copy + +message pads. + +So we have several of those books from + +their search warrant and in there, there is a + +message on October 1st confirming + +appointment for the massage as well as another + +7 + +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 + +girl, + +Q And is there also evidence that + +and actually spoke on October 1st + +before that message? + +A We have cell phone calls between + +and + +was from + +as well as the message which + +to Jeffre + +the appointment for + +regarding -- confirming + +but we have a cell + +phone call I believe it was a little bit earlier + +from to )r maybe it was + +, but it is definitely between the two of + +them on that same day. + +Q All right. When + +to + +was interviewed + +by the Palm Beach Police Department, did she + +describe all of the sexual activity? + +A No, she did not. She did not tell them + +about the vibrator or the -- she didn't tell them + +about the vibrator or + +Q And, again, you said that when you + +brought up -- did you sort of confront her with + +the idea that more had occurred? + +A I did, and she was very embarrassed + +about the vibrator. I asked her at one point if + +Mr. Epstein had given her any gifts and she got + +very red in the face and began to tear up and you + +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 + +could see that she was very embarrassed. + +So we took a little bit of a break, but + +then she was able to say that Mr. Epstein had + +provided her as a birthday present a vibrator. So + +not only was there a vibrator back massager used + +on her, + +kind of + +but at this + +what got + +time -- and I think that's + +talking about the sexual + +activity that she was able to tell me that, and + +she was + +Epstein + +very, very embarrassed, but that Mr. + +had given her for her eighteenth birthday + +a vibrator. + +Q Now you mentioned that that happened + +her eighteenth birthday? + +A Yes. + +Q And was she able to tell you whether + +on + +Mr. + +Epstein knew it was her eighteenth birthday? + +A She stated that Mr. Epstein provided to + +her on + +shortly + +her eighteenth birthday the vibrator and + +well -- + +Q So before you had said that had + +instructed-to tell everyone that she was + +18; do you remember that? + +A Yes. + +Q But at some point, the people in the + +Epstein household learned that she hadn't turned + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +18 yet and her birthday was coming up? + +A Her birthday was coming up. + +Q And at some point, was a car provided + +Yes. In October of '05, + +asked Mr. Epstein is she could + +borrow one of his cars to go to Orlando and he + +stated that -- at first he said yes, and then he + +said he would get her a rental car. + +So contacted a few days + +later and said that a car had been rented for + +and that the house manager used the + +company credit card and picked up that + +car, and actually when the police interviewed her + +on October 6th, which was five or six days after + +the last massage, they were able to see that that + +Nissan Sentra that had been rented by Mr. Epstein, + +had that in her possession for at least + +through January 1st of 2006 and that car was + +rented by Mr. Epstein for at least that amount of + +time. + +describe how the massage + +appointments would be made? + +A Yes, she did. + +Q And how was that? + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +A She stated that , that + +, Jeffrey's assistant, would call her and set + +up appointments, and that sometimes she would call + +her on her cell phone from New York, from the + +Islands, and say that they were coming into town, + +was she available. + +She would also call while they + +were in town to see if she was available for + +massages, to give massages to Mr. Epstein, and + +stated that , who we have identified as + +, called her a few times as well t + +t + +appointments up. + +Q And when those appointments were made + +how would reach + +A By phone. + +Q All right. And whether she was in town + +or out of town, she would call cell + +phone? + +A Yes. + +Q All right. Now was there any -- during + +the interview with the police department, did the + +police department ask about what she + +discussed with Jeffrey Epstein during the + +massages? + +A I would have to check the police reports + +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 + +to give specifics on that. + +Q All right. + +A My answer to your question is yes. + +Q Okay. And what did she say were some of + +the topics of discussion? + +A Mr. Epstein asked her questions about + +herself, asked her if she was a soccer player or + +that -- Jeffrey knew that she was a soccer player + +and asked questions about her college, about where + +she was going to school. + +is currently going to + +and she had advised Mr. Epstein that + +she would be attending college at + +Q So that was a -- but that was her future + +plan? + +asked + +told the + +care what + +Q Now did + +A Yes. + +Q So in other words, did Mr. Epstein know + +that she was in high school at the time? + +A Yes, he did. And the Palm Beach Police + +if Jeffrey knew her age and + +Palm Beach Police Department, he didn't + +my age was. + +describe either to you + +or to the police department how she would be paid + +for these massages? + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +A She stated she was paid \$200 and that + +she received anywhere from two to \$300. + +Q With every visit? + +A With each visit. + +Q Okay. Did she say who would provide her + +with that money? + +A She said that Jeffrey paid her at the + +end of the massage. + +Q All right. You mentioned the gift of + +the vibrator. Were there other gifts that were + +given to + +Yes. The time period is unclear, but + +the vibrator was given to her for her eighteenth + +birthday. There were three sets of bra and + +underwear, panties, Victoria Secret bra and + +underwear sets that were also given teas + +gifts from Mr. Epstein. + +Q Now I know that we talked earlier about + +the fact that is the person who brought + +to Mr. Epstein's house. 'Did + +bring anyone to Mr. Epstein's house? + +A brought a female ame of + +and that was a friend of + +Q And let me show you what has been marked + +as Grand Jury Exhibit 4, and what is Grand Jury + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Exhibit 4? + +A It's a photograph of + +date of birth of + +with a + +Q How old was when took + +her to Mr. Epstein's house? + +A + +2005 and + +Q Now can you tell us now went + +to the house? + +told that she could make + +ook her there in the spring of + +was 18 at that time. + +about bringing + +A + +some money giving + +and + +together. + +a massage to Mr. Epstein and + +went to Mr. Epstein's house + +The first time that ent there, + +she did not go upstairs and give him a massage + +was working that day. But in talking to + +further, stated that she probably + +over the period of time between the spring of '05 + +and October of '05, performed around five to ten + +massages for Mr. Epstein. + +The first few of those he did not do + +anything as far as no masturbating, no sexual + +activity. She would just perform a massage. + +Q And did that change over time? + +A Yes, it did. She stated that she + +1 performed two to three massages out of those five + +2 or ten and in her underwear and bra only, and + +3 that he would push her each time. + +4 He would just push her to do more and on + +5 the third -- I believe she stated the third or + +6 fourth massage, he told her that she could make + +7 more money if she removed her clothing, because + +8 she stayed clothed during the first few massages, + +9 and she was paid \$200 for each of those massages. + +10 On the third or fourth massage, Mr. + +11 Epstein said that she could make more money if she + +12 removed her clothing. So around the fourth or + +13 fifth time, she did start taking off her clothing + +14 down to her underwear and bra only. + +15 Q And then what happened when she was at + +16 that point of being unclothed? + +17 A She would perform the massage. He + +18 attempted to touch her, but she always would say + +19 no. At one point, her bra does get undone by Mr. + +20 Epstein, but she does keep it up. + +21 Now that was the extent of his touching + +22 At some point, did he begin masturbating + +23 in front of her? + +24 A Yes, he did. Not in the very beginning, + +25 but throughout this he did. Now I should tell you + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +stated to us that because she was kind + +of reserved or held back as he made advances + +towards her, she was able to see Mr. Epstein's + +penis and that he was masturbating, but that he + +never finished, that he never ejaculated. She did + +not feel that Mr. Epstein liked her very much. + +Q But just to sort of compare what + +said with what said, they both said that + +at the beginning they remained clothed? + +A Yes. + +Q And that Mr. Epstein progressively + +pushed and pushed and pushed for more sexual + +activity? + +A Yes. + +Q Now what was the period of time that + +went to Mr. Epstein's home? + +A March of -- I'm sorry, spring of '05 is + +when said that she went there and around, + +you know, the investigation is heating up with + +Palm Beach, so we know that in September of '05, + +there was a trash pull done, and in that trash + +pull there was a message and that was found and it + +stated -- it had phone number on it and + +it stated, for a good time call + +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 + +Q And whose stationery was that? + +A It was on Jeffrey Epstein's stationery. + +Q And had Jeffrey Epstein been in a Palm + +Beach resident close to those dates? + +A Yes. + +Q Now is there evidence of telephone calls + +between and + +A Yes. + +Q And how many phone calls have you been + +able to identify? + +A At this time, there have been 14 phone + +calls. + +Q All right. And just to compare that to + +the number of phone calls with + +A With there was over 150 phone + +calls between and + +And that is sort of consistent with the + +of massages that did versus the + +of massages that did? + +It is consistent with especially the + +Q + +number + +number + +A + +activity that + +compared to the activity that + +provide. + +was providing Mr. Epstein + +would + +(Thereupon, knocking is heard at the + +Grand Jury door.) + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Let me just step out for + +one moment. + +exits the Grand Jury + +Room.) + +enters the Grand Jury + +Room.) + +Ladies and gentlemen, I + +am going to have to take a break now and we + +will be back either next week or the + +following week. Thank you very much. You + +are done for the day. + +(Witness was excused.) + +CERTIFICATE OF REPORTER + +Certified Court + +Reporter and Notary Public, do certify that the + +transcript is a true and correct transcription of + +my stenotype notes of the testimony of + +SPECIAL AGENT ■ + +**the Federal Grand** + +**taken before** + +**Jury, West Palm Beach, Florida.** + +**A ANG OCCI, CSR #4869** + +**Certified Co rt Reporter** + +UNITED STATES DISTRICT COURT + +SOUTHERN DISTRICT OF FLORIDA + +COPY + +RE: OPERATION LEAP YEAR + +TESTIMONY + +SPECIAL AGENT + +Federal Grand Jury 07-103 Federal Building U.S. Courthouse West Palm Beach, Florida Tuesday, April 24, 2007 + +APPEARANCES: + +Assistant United States Attorney + +Foreperson + +The sworn testimony of SPECIAL AGENT + +was taken before the + +Federal Grand Jury, West Palm Beach Division, + +Federal Building, U.S. Courthouse, Palm Beach + +County, State of Florida, on Tuesday, April 24, + +2007. + +Certified Court + +Reporter and Notary Public, State of Florida, + +Official Reporting Service, LLC, 524 South Andrews + +Avenue, Suite 302N, Fort Lauderdale, Florida, + +, was authorized to and did report the sworn + +testimony. + +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 + +(Witness enters the Grand Jury Room.) + +THE FOREPERSON: You do solemnly swear + +that the testimony you give will be the + +truth, the whole truth, and nothing but the + +truth, so help you God? + +THE WITNESS: I do. + +THE FOREPERSON: Thank you. Please be + +seated. + +EXAMINATION + +Q Special Agent would you + +just remind the grand jurors who you are and who + +you work for? + +A My name is + +a special agent with the FBI and I work here in + +Palm Beach. + +Q Special Agent can you tell + +the grand jurors who will be appearing before them + +this afternoon? + +A One of our victims, who was a + +minor at the time that she met Mr. Epstein. + +And have you previously testified about + +Yes, I 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 + +Q Did you attempt to interview her? She's + +going to be coming in, and she is not a minor + +anymore, so what is her full name? + +A Her name is and I did + +attempt to interview and was + +interviewed by Palm Beach Police Department and + +because of the statements she provided to the + +police department, she felt as if she needed a + +lawyer. So when I attempted to interview her, we + +ended up going through her lawyer. + +Q And just so the grand jury has a little + +bit of background, the interview with the Palm + +Beach Police Department was quite some time ago? + +A Yes, it was, + +Q And when + +in the fall of '05. + +started that + +conversation with the police, she was very + +forthcoming? + +A Yes, she was. + +Q + +A + +Q + +interview with the police? + +A The police just let + +Fully cooperative? + +Yes. + +And what happened in the middle of that + +know that she + +could be charged because brought some of the + +girls to Mr. Epstein and the police -- she was + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +very cooperative, but the police at that point had + +to let know that what she had done that she + +could be facing charges. + +Q And that wa•s after they had told her + +earlier that she didn't need an attorney present, + +correct? + +A Exactly. + +• Okay. So this happens to her with the + +Palm Beach Police Department and did the Palm + +Beach Police actually present or propose charging + +Ms. + +A + +against + +Q + +They did get a probable cause affidavit + +And is that why Ms. and her + +attorney were concerned about her testimony here? + +A Yes. + +Q Now was a subpoena issued for Ms. + +on behalf of this grand jury? + +A Yes, it was. + +Q And before Ms. would comply with + +that, did she -- did her attorney request some + +sort of order? + +A Yes. + +Q And what did he ask for? + +A He asked for immunity for + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q And let me show you the order, that is a + +sealed order in these grand jury proceedings. Now + +the immunity that has been provided for Ms. + +keeps her statements that are made here from being + +used against her? + +A Yes, it does. + +Q It doesn't -- if she commits perjury and + +she lies to the grand jury, can she still be + +charged? + +A Yes, she can. + +Q Okay. Could you read that? I know it + +is only two pages. + +A Sealed order, on application of the + +United States Attorneys for the Southern District + +of Florida and it appearing to the satisfaction of + +the court that has been called to + +testify and to provide other information before + +the United States District Court, the Southern + +District of Florida, including a grand jury + +impaneled therein. + +And number two, that in a judgment of + +the said United States Attorneys, has + +refused to testify and provide other information + +on the basis of her privilege against self + +incrimination. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +And that number three, in the judgment + +of the United States Attorneys, the testimony and + +other information from made necessary + +to the public interest. + +And number four, that the aforesaid + +application has been made with the approval of the + +Assistant Attorney General in charge of the + +criminal division of the Department of Justice or + +a duly designated acting Assistant Attorney + +General pursuant to the authority vested in him by + +Title 18, United States Code, Section 6003, and + +Title 28, Code of Federal Regulations, Section + +0.175 and 0.132, small e. + +Now, therefore, it is ordered pursuant + +to Title 18, United States Code, Section 6002, + +give testimony and provide other + +information which she refuses to give or to + +provide on the basis of her privilege against self + +incrimination as to all matters about which she + +may be interrogated before said United States + +District Court including a grand jury impaneled + +therein as well as any subsequent proceeding or + +trial. + +However, no testimony or other + +information compelled under this order or any + +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 + +information directly or indirectly derived from + +such testimony or other information may be used + +against in any criminal case except a + +prosecution for perjury giving a false statement + +or otherwise failing to comply with this order. + +It is further ordered that this order + +shall be sealed in accordance with said Federal + +Regulations Criminal. + +BY + +Q Federal Rule of Criminal Procedure. + +A Federal Rule of Criminal Procedure, it's + +abbreviated, 6, little e, 6, except that a copy of + +this order shall be provided to counsel for the + +United States who may disclose the existence of + +the order to members of the grand jury, to the + +witness, to the counsel for the witness, and to + +law enforcement officers engaged in the + +investigation pending before the grand jury. + +Those persons may review the order, but + +may not retain a copy of the order nor may it + +disclose the existence of the order to any others. + +Done and ordered the 16th day of April 2007, at + +West Palm Beach, Florida. The United States + +District Judge Donald M. Middlebrook, + +AUSA. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q All right. So has a copy or has this + +document been shown to counsel for Ms. + +A Yes, it has. + +Q And to Ms. + +A Yes. + +Q And will Ms. be here this + +afternoon? + +A Yes, she will. + +Q Have you had a chance to sit with her? + +A Yes, we have. + +Q And she has been very forthcoming? + +A She's very cooperative. + +Q Okay. + +I don't have any further + +questions for the witness. Do you have any + +questions? All right. Seeing no questions, + +you are excused and I think that right now + +you are set to come back at 1 : 15. How does + +1 :30 sound? Is that all right? + +THE FOREPERSON: Fine. + +(Witness was excused.) + +CERTIFICATE OF REPORTER + +, Certified Court + +Reporter and Notary Public, do certify that the + +transcript is a true and correct transcription of + +my stenotype notes of the testimony of + +SPECIAL AGENT taken before + +the Federal Grand Jury !Goat Palm Roach Florida + +CertItled CodYt Reporter + +UNITED STATES DISTRICT COURT + +SOUTHERN DISTRICT OF FLORIDA + +RE: OPERATION LEAP YEAR + +TESTIMONY + +OF + +COPY + +Federal Grand Jury 07-103 Federal Building U.S. Courthouse West Palm Beach, Florida Tuesday, April 24, 2007 + +APPEARANCES: + +Assistant United States Attorney + +koreperson + +The sworn testimony of was + +taken before the Federal Grand Jury, West Palm + +Beach Division, Federal Building, U.S. Courthouse, + +Palm Beach County, State of Florida, on Tuesday, + +April 24, 2007. + +Certified Court + +Reporter and Notary Public, State of Florida, + +Official Reporting Service, LLC, 524 South Andrews + +Avenue, Suite 302N, Fort Lauderdale, Florida, + +, was authorized to and did report the sworn + +testimony. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +BY + +(Witness enters the Grand Jury Room.) + +THE FOREPERSON: You do solemnly swear + +that the testimony you give will be the + +truth, the whole truth, and nothing but the + +truth, so help you God? + +THE WITNESS: I do. + +THE FOREPERSON: Thank you. Please be + +seated. + +EXAMINATION + +Good afternoon, Ms. Could you + +state and spell your name for the record? + +A + +A + +address? + +A + +Florida + +parents + +A + +appear + +A + +And where do you currently live? + +I live -- do you want me to give the + +Sure. + +kiest Palm Beach, + +33412. + +Okay. And you are living with your + +now? + +Yes. + +Were you served with a subpoena to + +before the grand jury today? + +Yes. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q And do you understand that an order was + +signed by a judge compelling you to appear and + +answer questions? + +A Yes. + +Q And that order states that what you tell + +the grand jury won't be used against unless you + +perjure yourself? + +A Yes. + +Q Do you understand that you are under + +oath, and if you don't tell the truth -- + +A I can go to jail, yes. + +Q Okay. Let's start with where you went + +to high school. + +A Royal Palm Beach High School. + +Q How old are you today? + +A + +Q + +Q + +Twenty-one. + +And what is your date of birth? + +What year did you graduate from + +A + +Q And where are you currently working? + +A I currently am not working. + +Q But you are starting a new job? + +A Thursday. + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q Where will that be? + +A Fort Lauderdale, Coral Springs. + +Q What type of position will that be? + +A Waitressing. + +Q Have you worked since the time that you + +graduated from high school? + +A Uh-huh. + +Q Can you tell the grand jury what type of + +jobs you have had? + +A I worked at + +Q When you were in high school, where did + +you work? + +A + +Q And do you know Jeffrey Epstein? + +A Yes, I do. + +Q Can you tell the grand jury how you + +first came to meet Mr. Epstein? + +A I met Epstein through two acquaintances, + +and , and I met them at a beach resort. + +They made a proposition to me. Later then I + +picked them up and they gave me directions to the + +house and that's where I was formerly introduced + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +to Mr. Epstein. + +Q Okay. And let me just go back over that + +a little bit. You mentioned that you had two + +acquaintances, and and you met them at + +a beach resort, + +A + +Q + +proposition + +A + +money and + +Yes. + +And you + +to you. + +correct? + +said that they made a + +What was that exactly? + +had asked me if I wanted to make + +she was working for this guy, Epstein, + +in Palm Beach. So I told her I was interested and + +she further went into detail about massaging him, + +that you would have to take off articles of + +clothing and there would be touching and fondling + +involved. + +Q How old were you when this happened? + +A About 16. + +Q And how old was + +A Same age. + +Q And how did you know + +A We went to middle school together. + +Q And she was in your same grade in high + +school? + +A Yeah. + +Q And you mentioned that had + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +previously worked for Epstein or was currently + +working for Epstein? + +A Yes, that's right. + +Q So they explained this proposal to you + +and you said that you would be interested? + +A Yes. + +Q What happened next? + +A Within a couple of days to a week I + +picked them up and I went to his house to work for + +him and I was introduced to , who is his + +assistant. She took me upstairs to Epstein's + +bedroom and that's where the massage took place. + +I was naked and he tried fondling me and + +I wouldn't have it, so after the massage he gave + +me another proposition to bring girls to the house + +and for every girl that I brought I would make + +\$200. + +Q All right. We'll go back over that a + +little more slowly. I know this is a lot of + +information. So let's go back to the proposition + +that and made to you. + +Did they say you would be paid for + +massaging Mr. Epstein? + +A Yes. + +And how much would you be paid? + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +A \$200. + +Q Now you said that they had told you that + +you might have to take your clothing off? + +A They told me that I was expected to take + +my clothing off and that there would be fondling. + +Q Okay. And what -- did they explain + +what fondling meant? + +A Just that he'd be touching me. + +Q Okay. And so you agreed to do that and + +you went to Mr. Epstein's home? + +A Correct. + +Q And where was that located? + +A Palm Beach, Brillo Way. + +Q B-R-I-L-L-O? + +A Yes. + +Q And when you arrived at the home, you + +said that you were driving with and + +A That is correct. + +Q Tell us how you got into the house. + +A We went through a gate on the side of + +the house that led to the back and we just rang + +the doorbell and answered the door and we + +were standing in the kitchen and then + +brought me upstairs. + +Q Okay. Now did you have any -- did + +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 + +tell you anything about what you would do when you + +got upstairs? + +A No, she never discussed that with me. + +Q Did she say anything to you about taking + +your clothes off? + +A No, she never discussed that with me. + +Q Okay. When you arrived upstairs, you + +said that you went into a bedroom? + +A That is correct. • + +Q What was in the bedroom? + +A It was a bedroom that had a door that + +led to then I want to say a bigger more than just + +a bathroom. It was a bigger room with like a + +pretty large size walk-in closet, a shower, a + +steam shower, and then two sinks on the right, and + +in the middle laid the massage table, and then to + +the left there was two couches. + +Q And so the massage table was already set + +up when you arrived? + +A That is correct. + +Q Okay. And after led you up to the + +bedroom, what did she do? + +A She had left and that's when Epstein + +came in. + +Q Okay. And when Mr. Epstein came in, + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +what was he wearing? + +A He was wearing a towel. + +Q Okay. And nothing else? + +A Nothing else. + +Q And what did he do? + +A He laid on the table and that's when the + +massage began and later on he -- when he got in, I + +took off my clothes and I was just wearing my + +bottoms, and he later tried to touch me and he + +grabbed my butt, and that's when I had a problem. + +I told him that I didn't feel comfortable. + +So later he took the towel off and he + +was laying on his back and he started to + +masturbate asking me to squeeze his nipples really + +hard to ejaculation and then after that everything + +was done. + +Q Okay. So when Mr. Epstein ejaculated + +then the massage or whatever was over? + +A Yes, it was. + +Q And once that happened, what did he do? + +A Just got up and dried himself off and + +then walked me downstairs. + +Q And you got dressed as well? + +A That's right. + +Q And when you got back downstairs, what + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +happened? + +A I went back into the kitchen and he + +pulled and aside and then we just left. + +Of course, I got paid. + +Q Okay. And tell us where you got paid, + +who paid you, and how much you received? + +A Epstein paid me. I received 200, but I + +cannot recall if it was upstairs that he paid me + +or if he waited until I got back downstairs. + +Q Okay. And when he paid you the \$200, + +was it in small bills, large bills? + +A Big bills, 100s. + +Q Okay. So two 100 dollar bills. And you + +said that he pulled -nd aside. Do you + +know what that was about? + +A He would never pay them in front of me. + +He always was funny about that. So I'm sure it + +was just paying them for bringing me. + +Q Okay. And you mentioned that you told + +Mr. Epstein that you were uncomfortable with him + +touching you? + +A That's correct. + +Q And what became of that? + +A Later on before I left he had addressed + +me to not massage him anymore, but asked me if I + +1 + +2 + +3 + +4 + +5 + +6 •1 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +could bring girls over and for every girl that I + +brought to the table he would pay me \$200. + +Q Okay. So you weren't comfortable with + +him touching you, so you weren't going to do any + +more massages? + +A No. + +Q He wanted you to find other girls? + +A That's correct. + +Q And he wanted girls that would let him + +touch them? + +A Uh-huh. + +Q After that first massage, did you + +perform any other massages at his house? + +A Absolutely not.• + +Q Did you bring girls? + +A That's correct. + +Q Tell us how you started to bring girls + +to Mr. Epstein's house. + +A Just girls that I met in high school, + +acquaintances, people that I just said hi and bye + +to. A lot of them actually heard about it through + +a couple of girls that I brought and they were + +interested. + +Some of the girls asked me about it + +Just girls in school I'd talk to, just get on the + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +subject. They had no problem with it. + +Q Okay. So when you found a girl that you + +thought would be interested, what exactly would + +you tell her? + +A I asked them if they were interested in + +making extra money and that I knew an older + +wealthier man in Palm Beach who liked to have + +massages and they would get paid \$200 + +The more they did, the more they make, + +and I would explain to them in detail what was + +expected of them when they showed up at the house + +and I also told them that if they are under age + +just lie about it and tell him that you are 18 + +Q Let's talk first about what you said + +that you tell them what was expected of them. + +A Yes. + +Q First of all, why did you tell them + +that? + +A Because that's what I was told. + +Q By whom? + +A and + +Q Okay. And did Jeffrey Epstein ever + +address you about don't bring girls over here if + +they don't know what's going to happen? + +A Absolutely. + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q Okay. So all the girls were supposed to + +know that when they got there they would be + +undressing? + +A They would be undressing. There would + +be touching. There would be fondling. He was + +very big on that. He told me never to bring a + +girl over unless they knew what was expected. + +Q Okay. And did you also tell them that + +he would be masturbating? + +A I didn't really talk to them about that. + +I didn't know if he did it with everybody or it + +was just with me that he did that. + +Q But you told them that they all would + +have to be partially naked or fully naked? + +A Partially to fully naked and there would + +be touching and fondling. + +Q Okay. How many girls do you think you + +took to Mr. Epstein's house? + +A Seven, between seven to ten. + +Q Okay. And were there any -- in addition + +to this rule about the girls had to know what was + +expected, did Mr. Epstein have any other rules in + +terms of what the girls looked like or what he + +liked? + +A 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 + +Q Okay. Were there girls that you brought + +that he didn't like? + +A There were a few girls he wasn't crazy + +about. He didn't really like. He didn't favor. + +for instance, 23, he thought she was kind + +of too old. + +Q Okay. So you brought a girl named + +who was 23 years old? + +A Yes. + +Q And you were told that she was too old? + +A Yes. + +Q Did you ever bring her back? + +A No. + +Q What about any other girls that he + +didn't like? + +A This other girl I went to high school + +with, she was maybe a year younger, and him + +and her got into an argument about money. I told + +her in detail what was expected and she, to me, + +was all for it and then when she got there, + +decided she didn't want to perform what was + +necessary. So they got into an argument about + +money and after that I never really brought her + +back. + +Q Okay. And did either Jeffrey Epstein + +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 + +or say anything to you about what happened + +with M? + +A He had made a comment just about -- I + +had asked -- he had asked me for someone to come + +over and work and when I suggested he kind of + +nodded, not really interested. He told me to find + +somebody else. So I assumed that meant he really + +didn't care for her. + +Q Okay. Now the -- you mentioned + +who was 23. What was the age range of the other + +girls that you brought to Mr. Epstein's home? + +A High school, 16 to 18. + +Q Were there any girls who were younger + +than that? + +A Yes. + +Q Who was that? + +A + +Q And how was she? + +A She was 14. + +Q Okay. Now you were interviewed by the + +Palm Beach Police Department? + +A That's correct. + +Q And during that interview, you told them + +that there were two ways to make money with + +Jeffrey Epstein. Can you explain to the grand + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +jury what those two ways are? + +A The more you did is the more you make. + +Basically, the more clothes that come off, the + +more you let him touch you, the more you just let + +him have his way with you is the more that you + +would make, otherwise, you would be demoted down + +to bringing girls over and just making money that + +way. + +Q And that's what you were doing? + +A That's correct. + +Q Was bringing girls? + +A That's correct. + +Q If you could explain to the grand jury + +how you would go about making an appointment for + +girl to come and give a massage? + +A His assistant there would call me either + +before they got into town or while he was in town + +and either she would ask me for a particular girl, + +preferably one that he favored, or if I couldn't + +get a hold of that girl just bring somebody over + +to work. + +I would call the girl. She would okay + +it. I would call back, confirm it, set an + +appointment, and then the next couple of days we'd + +go. + +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 + +Q And was the person that you always + +made the appointment with? + +A Always. + +Q Do you remember ever talking to Jeffrey + +Epstein on the telephone? + +A Never. The only time I talked to him + +was physically in person at his house. + +Q Okay. was really the person that + +you had to -- + +A Deal with + +Q Okay. Now you mentioned that sometimes + +would request a specific girl? + +A That's correct. + +Q Did she give you any reason why he + +really liked this girl or just is this girl + +available? What would happen on those calls? + +A If it was a specific girl, she would + +call me and just ask: Can this girl work? She + +would never give me a reason. She would never go + +into detail. It was just: Can she work, yes or + +no? + +work? + +Q And was saying to you can she + +A I can't recall if those were her exact + +words. I can't remember if it was: Can she come + +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 + +over and massage or can she work? I don't recall + +the exact words. + +Q Okay. And once you made those + +appointments then who would normally take you and + +the girls to the house? + +A I would. + +Q Okay. And you would drive? + +A I would drive. + +Q And were all -- was this always taking + +place at Mr. Epstein's home? + +A Yes. + +Q On Brillo Way? + +A That's correct. + +Q When you spoke with on the + +telephone, did you -- were all of these + +conversations about setting up these appointments? + +A When I would talk to ? + +Q Yes. + +A Yes. It would be pure business whenever + +I talked to . + +Q So you didn't have any sort of friendly + +relationship? + +A No friendly relationship, never + +socialized unless I was at the house. It wasn't + +like that at all. + +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 + +Q Okay. Now when you would bring a new + +girl over to the house, what would you do? + +A Walk up the same way towards the back of + +the house. They would let us in. I could sit in + +the kitchen with the girl. I would either wait + +for to come in or Jeffrey. Most of the time + +it was + +would bring the girl upstairs + +while I waited downstairs. After the massage, the + +girl would come downstairs. I would get paid and + +then we would leave. + +Q Tell us how you would get paid when you + +were the person who brought the girls. + +A What do you mean how I would get paid? + +Q Who would pay you? + +A Jeffrey Epstein would pull me aside + +whether it be in his, I guess, living room slash + +office. He would just make sure that when he paid + +me, it was just me and him, nobody else was + +around. + +Q And how much would you get paid for each + +girl? + +A \$200. + +Q And again with the two 100 dollar bills? + +A Always 100 dollar bills. + +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 + +Q Did you ever see the girl who actually + +did the massages get paid? + +A No, I never saw them get paid. He never + +paid us in front of each other. + +Q Okay. Did the girls ever tell you that + +they did get paid or how much they got paid? + +A Most of the time. + +Q Okay. And how much money would each + +girl get paid? + +A It ranges. + +Q From? + +A It ranges from 200 to some got paid 300. + +Like I said, the more you do, the more you make. + +There were a couple of girls that got paid 300, + +400, and then there were a couple of girls that + +got paid 200 maybe even 100. + +Q Now you mentioned that usually + +would take the girl upstairs? + +A That's correct. + +Q Were there ever instances where you took + +the girl upstairs? + +A Very rarely. I think it happened once + +or twice where was doing something or she + +would need me to go upstairs and set up. I would + +just go upstairs. I would show her where the + +'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 + +massage table was. + +I would set it up for them. I would + +show them where the towels were, put the towels on + +the massage table and then I would tell them + +Jeffrey would be in, in a minute and then I would + +walk back downstairs and wait in the kitchen. + +Q Okay. And when you were in these other + +instances where you led the girl upstairs, besides + +the massage table, did you ever see any other + +implements that were used during the massage? + +A I think there were maybe a few occasions + +where I would walk upstairs to show the girl or + +maybe it was even when I first massaged him, there + +was like a white massager on the table or a white + +vibrator. + +Q And can you describe that to the grand + +jury? + +A What it looked like? + +Q What it looked like, yes. + +A It was like a cylinder. It was really + +big. The head was bigger. It was white. I think + +the top of it was maybe like pink. It was big, + +that's all I remember. + +Q Okay. And did any of the girls ever + +tell you that that was used on them? + +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 + +A Yes. + +Q Okay. Now I'm going to run through the + +names of some girls that you brought just to + +confirm + +A + +Q + +A + +Q + +Q + +Q + +Q + +with the grand jury that you brought them. + +Okay. + +That's correct. + +orrec + +Correct. + +Yes. + +Q 7 + +A Yes. + +Q And then there is another girl, + +A never, ever, ever worked for + +Jeffrey. She accompanied me to his house I think + +once or twice and waited in the kitchen with me, + +but she never worked for him. + +Q Okay. But she was somebody that you + +brought along with you? + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +A That is correct. + +Q On visits? + +A Yes. + +Q Okay. In addition to those girls + +that who I just named, you mentioned a woman, + +who is 23? + +A Uh-huh. + +Q Were there any other girls that you + +recall bringing to Jeffrey Epstein's house? + +A I cannot recall bringing anybody else. + +Q Okay. Now one of those girls that we + +mentioned was correct? + +A Yes. + +Q And you told the police that Jeffrey + +liked the best? + +A Yes. + +Q How old was + +A She was around the same age as me, maybe + +a grade lower than me. + +Q Okay. So she was under age? + +A Yes, correct. + +Q And all of those girls who names I read + +were under age when you brought them there? + +A Except for + +Q Okay. What did look like? + +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 + +A was Hispanic. She kind of looks + +Korean, but she's Hispanic, Hawaiian, maybe. She + +had a dark complexion. She had hair down to the + +middle of her back, long, highlights. + +Q Was she thin or heavy? + +A No. She was maybe -- she had a boxy + +type figure, maybe a little lighter than me. + +Q And how tall do you think she was? + +A About 5'S, 5'6. + +Q Okay. And you knew that Jeffrey liked + +because he would specifically request her? + +A There was a few occasions that he would + +specifically ask for her, correct. + +Q Okay. And you mentioned that some of + +the girls told you about the massager being used, + +correct? + +A Yes. + +Q Did some of girls tell you what happened + +inside of that bedroom? + +A A few of them did. + +Q Let's talk first about + +A Okay. + +Q Did she tell you what happened? + +A All that she really told me was that + +they got into a money fight. He had tried + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +fondling her. She wasn't having it, and then she + +only got paid \$100 and she + +ripped off. + +Q Okay. What about + +felt like she was being + +, did + +she tell you about what happened? + +A Yes. + +Q what did she explain to you? + +A on the way home, had told me she + +got paid \$300, and basically let him insert + +in her and use the massager on her. + +Q Okay. And she told you those things? + +A She told me those things. + +Q That he had her and + +had used the massager? + +A That's correct. + +Q Okay. And that was -- when did she tell + +you that? + +A Right when we got outside into the + +truck. + +Q As you were driving away? + +A That's correct. + +Q Do you remember which other girls told + +you about the massager being used? + +A I can't recall. I know there was + +another one that said something about the + +2 + +3 + +4 + +5 + +6 + +7 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +massager, but I wasn't really paying attention. + +Q Now when you first went and gave Mr. + +Epstein the massage, did he ask for your telephone + +number after you were finished? + +A No, did. + +Q did. And she took down your + +telephone number? + +A She took down my name and my telephone + +number. + +Q After that, how was all contact made + +with you? + +A + +Q Directly to you? + +A Directly toward me. + +Q Okay. So were there any more instances + +where she went either through-or to + +reach you? + +A Absolutely not. + +• Okay. Now when you brought girls over + +was it the same thing where they would ask for the + +girl's name and number? + +A Yes. + +Q And when that happened, would they + +continue to go through you to set up appointments? + +A Most of time they went through me. + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Actually 99.9 percent of the time they went + +through me. On a few occasions, the girls that + +they liked the best, for instance, + +a while me and + +other and Jeffrey + +after + +stopped contact with each + +just went strictly through her. + +Q Okay. And when an appointment was made + +directly with the girl, you wouldn't necessarily + +know about it? + +A I would not necessarily know about it. + +Q And when the appointment was made + +directly with the girl then you wouldn't get paid, + +correct? + +A Correct. + +Q Did you hear or do you know whether some + +girls that you brought, brought more girls? + +A Yeah, I'm sure of it. + +Q Okay. When did you first meet + +Was it that day that you went to give the + +massage? + +A That's correct. + +Q And how did you first meet her? + +A Just walking in the kitchen and waiting + +for somebody whether it be Epstein or + +came and introduced herself as + +learned that she was Epstein's assistant. + +and I + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +Q And you said that she was the one who + +took you upstairs on the first day? + +A That's correct. + +Q And we were talking earlier about how + +appointments would be made for you to bring + +additional girls, correct? + +A Yes. + +Q How far in advance would call you + +9 to make appointments? + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22. + +23 + +24 + +25 + +A It depends. Sometimes she would call me. + +a few days in advance. Jeffrey is going to be in + +town tomorrow or this weekend, have a couple of + +girls lined up or have a girl lined up. So it + +would be anywhere between a couple of days to a + +weekend. + +Q Okay. Did you ever talk with or + +did ever tell you anything about what + +Jeffrey liked to do with the girls? + +A Absolutely not. We never discussed + +that. + +Q Did you ever talk with her about a rumor + +that you had heard that a girl had intercourse + +with Jeffrey? + +A One day I was talking on the phone with + +Sarah and I addressed her with it, asking her + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +about a rumor I heard of a girl sleeping with + +Jeffrey, having intercourse, and making \$1 ,000, + +and she denied it and said that he doesn't do that + +kind of thing, he just plays with them. + +Q Okay. So she said that he didn't have + +intercourse, he just liked to play with the girls? + +A That's correct. + +Q And when you spoke with the police, you + +said that Jeffrey liked to masturbate in front of + +the girls but not have sex? + +A That's correct. + +Q What led you to believe that? + +A He just did it. I just learned that + +Epstein just started masturbating in front of + +everybody. It was like the new thing for him, and + +it just started happening and more and more girls + +were making comments. + +Q So did know that he was + +masturbating in front of the girls? + +A Not that I know of. I didn't say + +anything and I don't think she had an idea. + +think she knew there was playing going on. + +don't think she knew of what sort. + +Q Okay. So she knew that something sexual + +was going on, but not necessarily what that + +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 + +entailed? + +A Correct. + +Q Okay. Did Jeffrey or or anyone + +else who worked for Mr. Epstein ever ask you for + +proof of someone's age? + +A Never. + +Q Did they ever specifically instruct you + +that you shouldn't bring girls who were under age + +to the house? + +A Never. + +Q And when you spoke with the police + +department you said that at some point Jeffrey + +said the younger the better? + +A That's correct. + +Q And even after that he never said to you + +but make sure that they are over 18? + +A We never discussed age. He never made a + +comment about age except for that one time + +about her being too old. He never told me to go + +find under aged girls, but at the same time never + +said make sure they are over 18. It was never + +discussed. + +Q Okay. All right. + +I 'm going to ask you to + +step outside for a minute and I will find out + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +if the grand jury has questions. Thank you + +very much. + +(Witness exits the Grand Jury Room.) + +(Witness enters the Grand Jury Room.) + +I have to remind you that + +you are still under oath. There were just two + +follow-up questions. The first one is something + +that I think you spoke about earlier, but who + +first asked you to find other girls? + +A Who first asked me to first other girls? + +Q Yes. + +A That would be Epstein. + +Okay. So Jeffrey asked you himself, + +Jeffrey Epstein himself asked you? + +A Yes. + +okay. And then the other question was: + +Are you currently in contact with anyone who works + +for Mr. Epstein or himself? + +A I don't talk to any of the females that + +I once brought over there. I haven't been in + +contact with Epstein for years. He tried + +contacting me a few times. + +I haven't contacted him back. I refuse + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +to talk to him. I refuse to talk to any of the + +girls that were involved. However, I did live + +with one of the girls in Orlando for a couple + +months to a year. I haven't spoken to her in over + +a year either. + +Q Okay. So after -- and just so the grand + +jury has a sense here, we are talking about the + +2004 to 2005 period is when you were bringing + +girls over? + +A That's correct. + +Q So since then -- + +A I don't -- to be honest with you, + +think it was more 2003, 2004. + +Q Okay. + +A My junior senior year. + +Q Okay. But anyhow it was a couple of + +years ago? + +A Several years ago. + +Q Okay. + +Is there any follow up + +on either of those points? Yes, ma'am. + +A GRAND JUROR: Was it Jeffrey Epstein + +Qimself trying to contact you or + +THE WITNESS: I don't know if it was him + +directly. I know that his number showed up + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +on my house phone. I'm assuming because + +was there, I'm assuming that she is the + +one that has been trying to contact me in the + +past years. Epstein never talked directly + +me on the phone. + +to + +Any other follow up? + +Okay. Thank you, ma'am. Thank you for + +coming. + +(Witness was excused.) + +CERTIFICATE OF REPORTER + +Reporter and Notary Public, do + +, Certified Court + +certify that the + +transcript is a true and correct transcription of + +my stenotype notes of the testimony of + +taken before the Federal Grand Jury, + +West Palm Beach, Florida. + +1 + +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION + +COPY + +IN RE: OPERATION LEAP YEAR + +SPECIAL AGENT + +APPEARANCES: + +Grand Jury #07-103 (WPB) West Palm Beach, Florida Tuesday, April 29, 2008 + +TESTIMONY + +OF + +ASSISTANT U.S. ATTORNEY FOREPERSON + +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 + +The sworn testimony of SPECIAL AGENT + +was taken before the + +Federal Grand Jury, West Palm Beach Division, + +Federal Building, U.S. Courthouse, Palm Beach + +County, State of Florida, on Tuesday, April 29, + +2008. + +Reporter and + +Certified Court + +Notary Public, + +Official Reporting Service, + +Avenue, Suite 302N, Fort Lauderdale, + +State of Florida, + +LLC, 524 South Andrews + +Florida, + +33301, was authorized to and did report the sworn + +testimony. + +1 + +2 + +3 + +(Witness enters the Grand Jury Room.) + +THE FOREPERSON: You do solemnly swear + +that the testimony you give will be the + +4 truth, the whole truth, and nothing but the + +5 truth, so help you God? + +6 THE WITNESS: I do. + +7 THE FOREPERSON: Thank you. Please be + +8 seated. + +9 EXAMINATION + +10 BY + +1 1 Q Special Agent , do you have a + +12 chart bearing the photographs of the victims with + +13 their new and old Jane Doe Numbers? + +14 A Yes, I do. + +15 : Shall we pass it out to + +16 the grand jury, please. + +17 BY + +18 Q We are going to start today with Jane + +19 Doe Number 14. The Overt Acts related to Jane Doe + +20 Number 14 begin on Page 22 of the proposed + +21 indictment. + +22 Special Agent , can you + +23 remind the grand jury who is Jane Doe Number 14? + +24 A Jane Doe Number 14 is a white female + +25 named She was born in She + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +attende High School. + +Q And have you testified about her + +previously? + +A Yes, I have. + +Q Is there anything that you want to + +clarify or add regarding your earlier testimony? + +A No. + +Q Can you remind the grand jury of the + +period of time that Jane Doe Number 14 had contact + +with Jeffrey Epstein? + +A She went to Mr. Epstein's house during + +November 2004 through March 2005. + +Q And how old was she during that time + +frame? + +A Seventeen. + +Q Please summarize the sexual activity + +that Jane Doe Number 14 was involved with, with + +Jeffrey Epstein. + +A Jane Doe Number 14 was asked by Mr. + +Epstein to pinch and rub his nipples. Mr. Epstein + +masturbated in Jane Doe Number 14's presence. + +Jane Doe Number 14 had a massager slash vibrator + +used on by Mr. Epstein. + +Mr. Epstein Jane + +Doe Number 14's He performed oral sex on + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Jane Doe Number 14. He also had sexual + +intercourse with Jane Doe Number 14. + +Q And can you just tell us briefly what + +Jeffrey Epstein's knowledge was of Jane Doe Number + +14's age? + +A Jane Doe Number 14, during the times + +that she provided the massages, on one of those + +occasions she was asked her age and she told him + +that she was 18. + +On a later visit, they were talking + +about Jane Doe Number 14's upcoming birthday and + +Mr. Epstein inquired about her 18th birthday, and + +Jane Doe Number 14 acknowledged that that would be + +her upcoming birthday. + +Epstein actually called her on that and + +said: So you are not really 18 yet? And they + +both kind of laughed about it. And so he knew + +that Jane Doe Number 14 was having her upcoming + +birthday. + +Q Does your prior testimony and your + +testimony today cover the evidence supporting the + +allegations in Overt Acts 112 through 131? + +A Yes. A review of the phone calls + +indicate telephonic contact between + +and Jane Doe Number 14 as well as and + +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 + +Jane Doe Number 14. + +A review of the carbon copy message pads + +recovered during the execution of the state search + +warrant revealed messages between Jane Doe Number + +14 and Jeffrey Epstein's Palm Beach residence. + +I have one of those here and I will read + +it for the record, which is specifically Overt Act + +126. It's a message for on January 26, + +2005, at 1 :30 p.m. It's from + +It says, you know the number, in + +parentheses. And then it says, she is confirming + +for 5:30 p.m. And it was taken by one of Mr. + +Epstein's house managers. + +We also have the statement of Jane Doe + +Number 14, which as I summarized before the + +discussion of the age, and we also have supporting + +documentation to corroborate the statement such as + +petty cash receipts from one of the house managers + +where he is documented paying Jane Doe Number 14, + +as well as a Western Union transaction that + +occurred at Christmas where Mr. Epstein provided + +Jane Doe Number 14 with \$200 as a Christmas + +present. + +Q All right. Referring to Count Eight, + +which is -- is the testimony that you summarized + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +the basis for the allegation that Jeffrey Epstein, + +, and procured Jane Doe + +Number 14 to engage in commercial sex acts knowing + +that she was under 18? + +A Yes. + +Q And referring to Count 19 is the + +evidence you just summarized the basis for the + +allegation that Jeffrey Epstein, , and + +used a facility in interstate + +commerce to persuade, induce, and entice Jane Doe + +Number 14 to engage in prostitution and in a + +sexual activity for which a person can be charged + +with an offense? + +A Yes. + +Q How many telephone calls have you been + +able to document between John Doe Number 14 and + +A We have approximately 70 phone calls + +between and Jane Doe Number 14. + +Q And what about with + +A Approximately seven. + +Q And because this is a little bit + +different than some of the other charges in + +addition to alleging procurement to engage in + +prostitution as well as an allegation of procuring + +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 + +to engage in sexual activity for which a person + +can be charged with a criminal offense, what is + +that particular sexual activity that she and + +Jeffrey Epstein engaged in that also violates + +Florida state law? + +A Sexual intercourse. + +Q Now if you could turn to Jane Doe Number + +15. Can you tell the grand jury who she is? + +A Jane Doe Number 15 is a white female + +named She was born She + +attended igh School. I have + +testified about her previously. + +Q Is there anything that you want to + +clarify or add regarding your previous testimony? + +A No. + +Q Please remind the grand jury during what + +period did Jane Doe Number 15 have contact with + +Jeffrey Epstein. + +A We have telephonic contact between + +and Jane Doe Number 15 starting on December + +of 2004 through October of 2005. We believe + +through statements that she went to Jeffrey + +Epstein's residence earlier than that. + +She stopped for a time period and then + +returned and that's when we have the phone calls + +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 + +starting up. + +Q Now during this period of the phone + +calls, how old was Jane Doe Number 15? + +A She was 17. + +Q All right. Up until her birthday, + +correct? + +A Yes. + +Q Did the phone contact continue after she + +turned 18? + +A Yes. As I mentioned, the phone calls + +continued to October of 2005 and she turned 18 in + +June. + +Q Please summarize the sexual activity + +that she was involved with, with Jeffrey Epstein. + +A Epstein requested Jane Doe Number 15 to + +pinch his nipples. Mr. Epstein would fondle and + +pinch Jane Doe Number 15's nipples. Mr. Epstein + +also engaged in masturbation in front of Jane Doe + +Number 15. + +Mr. Epstein used a massager slash + +vibrator on Jane Doe Number 15's + +Epstein also + +15's + +and Mr. + +Jane Doe Number + +Q Does your prior testimony and your + +testimony here today cover the evidence and the + +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 + +allegations in Overt Acts 132 to 148 and Overt Act + +175? + +A Yes. A review of the phone records + +indicate telephonic contact between + +and Jane Doe Number 15 as well as and + +Jane Doe Number 15. + +We also have the review of the carbon + +copy message pads that were recovered in the state + +search warrant, in the execution of the state + +search warrant, which revealed the message from + +to Epstein, and I have that. + +Specifically Overt Act 175, and it's for + +Jeffrey Epstein. The date is October 1 , 2005, at + +9:50 a.m. The message is from and the + +message reads, 7:onfirmed at 11 :00 a.m. and + +at 4 p.m. And is it signed by one of Mr. + +Epstein's house managers. + +We also have reviewed the evidence which + +was obtained in a trash pull that was conducted at + +Mr. Epstein's residence by the Palm Beach Police + +Department in April of 2005 where a piece of paper + +was recovered in the trash, which is Overt Act + +147. + +It reads, 10:30, + +Friday around 2:00. And then there's a 3 + +on + +1 + +2 + +3 + +4 + +S + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +underneath it on Mr. Epstein's stationery. We + +have the statements from Jane Doe Number 15 as + +well as other witnesses. + +Q Now with respect to Mr. Epstein's + +knowledge of Jane Doe Number 15's age, have you + +testified about that previously? + +A Yes, I have. + +Q And let me hand you two transcripts. + +One is of your testimony on March 20, 2007, and + +the second is May 15, 2007. If you would just + +read those for the grand jury. + +A The first one from Tuesday, March 20, + +2007, on page 17, starting on line 4. + +(Thereupon, the testimony of SPECIAL + +AGENT taken on + +Tuesday, March 20, 2007, before Grand Jury + +07-103 was read into the record as follows:) + +Question. Okay. And what did she say + +were some of the topics of discussion? + +Answer. Mr. Epstein asked her questions + +about herself, asked her if she was a soccer + +player or that -- Jeffrey knew that she was a + +soccer player and asked questions about her + +college, about where she was going to school. + +is currently going to Lynn + +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 + +University, and she had advised Mr. Epstein + +that she would be attending college at Lynn + +University. + +Question: So that was a -- but that was + +her future plan? + +Answer. Yes. + +Question. So in other words, did Mr. + +Epstein know + +the time? + +Answer. + +Beach Police asked + +her age and + +that she was in high school at + +Yes, he did. And the Palm + +if Jeffrey knew + +told the Palm Beach + +Police Department, he didn't care what my age + +was. + +(Thereupon, the reading of the + +transcript concluded.) + +THE WITNESS: Testimony from Tuesday, + +May 15, 2007, page 4, line 19. + +(Thereupon, the testimony of + +taken on Tuesday, May 15, 2007, + +before Grand Jury 07-103 was read into the + +record as follows:) + +Question. And just briefly can you + +remind the grand jury, did + +Mr. Epstein her age? + +ever tell + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Answer. No, they did not ever + +discuss -- she did not tell him how old she + +was, but she did tell him where she planned + +on going to school and that she was in + +soccer. + +She stated that when it came to her age + +that Mr. Epstein didn't care As I mentioned + +earlier, and + +(Thereupon, the reading of the + +transcript was interrupted.) + +THE WITNESS: Which is old Jane Doe + +Number Four, and that is not in here. + +Starting at line 24 + +(Thereupon, the reading of the + +transcript continued.) + +Answer. She stated that when it came to + +her age that Mr. Epstein + +mentioned earlier, + +very good friends and ■ + +**about** + +**and Mr. Epstein would ask** + +**when** + +**didn't care. As I** + +**were** + +**would talk about** + +**questions** + +**was providing** + +**massages, and as we will talk about when we** + +**talk about Jane Doe Number Four, which is** + +**she told Mr. Epstein that she was a** + +**junior in high school and that and** + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +her were in the same classes together and + +that they were very good friends. + +And told us that at one point + +had come to her because she had slipped + +about prom, and she was worried because + +Epstein was supposed to think she was 18 and + +dl she had talked about the prom, an + +said she never heard anything else about it + +and they never brought it up. + +Question. Because according to + +Mr. Epstein didn't care really how old the + +girls were? + +Answer. Exactly. + +Question. And she never mentioned he + +asked her for her age or asked for any form + +of identification to show whether she was or + +was not over 18? + +Answer. No. + +(Thereupon, the reading of the + +transcript concluded.) + +Q Referring to Count Number Nine is the + +evidence you just summarized the basis for the + +allegation that Jeffrey Epstein, , and + +procured Jane Doe Number 15 to engage + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +in commercial sex acts knowing that she was under + +Q And if I could refer you to Count 20. + +Is the evidence you just summarized the basis for + +the allegation that Jeffrey Epstein, + +and used a facility of interstate + +commerce to persuade, induce, and entice Jane Doe + +Number 15 to engage in prostitution? + +A Yes. + +Q How many telephone calls have you been + +able to document between Jane Doe Number 15 and + +A We have over 125 phone calls between + +and Jane Doe Number 15. + +Q And how many telephone calls between + +Jane Doe Number 15 and Ross? + +A Twenty-five approximately. + +Q Now if we could turn to Jane Doe Number + +16 and could you remind the grand jury who Jane + +Doe Number 16 is? + +A Jane Doe Number 16 is a white female + +named She was born in and + +she attended High School. + +Q Have you testified about her before? + +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 + +A Yes. + +Q Is there anything that you want to + +clarify or add regarding your earlier testimony? + +A No. + +Q Please remind the grand jury of the + +period of time during which Jane Doe Number 16 was + +involved with, with Jeffrey Epstein? + +A Jane Doe Number 16, we have telephonic + +phone calls beginning February of 2005 through + +October of 2005. + +Q And how old was Jane Doe Number 16 + +during that period? + +A She was 17. + +Q Please summarize the sexual activity + +that Jane Doe Number 16 was involved with, with + +Jeffrey + +A + +Epstein. + +Jane Doe Number 16, Mr. Epstein + +masturbated in front of Jane Doe Number 16. Mr. + +Epstein used a massager slash vibrator on Jane Doe + +Number 16's + +Mr. Epstein had Jane Doe Number 16 watch + +as Epstein engaged in + +, which Mr. + +and + +and buttocks in front + +sexual activity with + +Epstein also had + +r ondle each other breasts + +from Mr. Epstein. + +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 + +Mr. Epstein had sexual intercourse with + +Jane Doe Number 16 for which Mr. Epstein offered + +and paid Jane Doe Number 16 more money which was + +300 to \$350. + +Q Did Jane Doe Number 16 recruit anyone to + +go to Jeffrey Epstein's home? + +A She did. Jane Doe Number 16 took a + +white female by the name of who was over + +the age of 18. She also brought Jane Doe Number + +17. + +Q And before we get to that, can you + +remind the grand jury who recruited Jane Doe + +Number 16 to go to Jeffrey Epstein's house? + +A Jane Doe Number 16 -- if you can hold on + +one second -- was recruited by Jane Doe Number + +Nine. + +Q And the last time we were here, you + +testified about Jane Doe Number Nine? + +A Yes, I did. + +Q And you testified Overt Act Number 90, + +which was a payment that Jeffrey Epstein made to + +Jane Doe Number Nine for recruiting Jane Doe + +Number 16 to his home? + +A Yes. + +Q Now you mentioned that Jane Doe Number + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +16 also recruited someone who you referred to as + +Jane Doe Number 17. Can you tell the grand jury + +who that is? + +A Jane Doe + +the name of + +she attended + +Q Have you + +A No. + +Q Has she been interviewed? + +A Yes. + +Q During what period of time did Jane Doe + +Number 17 have contact with Jeffrey Epstein? + +A Jane Doe Number 17 began her contact in + +February of 2005 and went to Mr. Epstein's house + +on two occasions. + +Q How old was she during that time frame? + +A Sixteen. + +Q And how did she meet Jeffrey Epstein? + +A Jane Doe Number 16 brought Jane Doe + +Number 17 to Mr. Epstein's residence. They went, + +as I mentioned earlier, only twice did Jane Doe + +Number 17 go. Jane Doe Number 16 went much more + +than that. + +Number 17 is a white female by + +She was born in and + +High School. + +testified about her previously? + +But Jane Doe Number 17 was taken there + +twice by Jane Doe Number 16. Jane Doe Number 16 + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +and Jane Doe Number 17 performed a massage + +together wearing only their underwear. + +After a while during the massage, Mr. + +Epstein requested that Jane Doe Number 16 wait + +downstairs. Jane Doe Number 16 got dressed and + +left. Jane Doe Number 17 continued the massage. + +Mr. Epstein began to masturbate. Mr. + +Epstein paid Jane Doe Number 17, \$200. Jane Doe + +Number 17 stated that Jane Doe Number 16 had also + +received money for that day. Jane Doe Number 17 + +went back to Mr. Epstein's house approximately a + +month later. + +This time Mr. Epstein requested that + +Jane Doe Number 17 perform the massage completely + +nude. He used a vibrator on Jane Doe Number 17's + +vagina and masturbated until he ejaculated and + +then the massage was over. + +Q How much was Jane Doe Number 17 paid? + +A She was paid \$200. + +Q And you mentioned that she was 16 during + +the time of these massages? + +A Yes. + +Q Did Jane Doe Number 17 recruit anyone to + +go to Jeffrey Epstein's house? + +A No. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q Does your prior testimony and the + +testimony here today cover the evidence supporting + +the allegations in Overt Acts 90 and 149 through + +181? + +A Yes. A review of the phone records + +indicate telephonic contact between + +and Jane Doe Number 16, which also includes + +multiple text messages from to Jane + +Doe Number 16. + +and Jane Doe Number 16 and + +also telephonic contact between + +and Jane Doe Number 16. Regarding Jane Doe Number + +17, we have telephonic contact between + +and Jane Doe Number 16 and Jeffrey + +Epstein's residence and Jane Doe Number 16. + +Followed by telephonic contact between Jane Doe + +Number 16 and Jane Doe Number 17. + +Q Let me interrupt you just a second, + +Special Agent So in other words, + +because Jane Doe Number 16 is the person who + +brought Jane Doe Number 17 those two times where + +the records show contact from someone from + +Epstein's group to Jane Doe Number 16 immediately + +followed by a phone call to Jane Doe Number 17? + +A Yes. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q Okay. Sorry. Please continue. + +A We also have carbon copy messages. + +message pad. It was recovered during the + +execution of a state search warrant which + +indicates contact between Jane Doe Number 16 and + +Epstein's employee. + +Specifically Overt Act 175 and Overt Act + +178, and I will get those and read those. Overt + +Act 175 is what I read previously regarding Jane + +Doe Number 15, but I will read it again. + +It is for Jeffrey Epstein, dated October + +1st, 2005, at 9:50 a.m. The message is from + +. The message says, confirmed at 1 1 + +a.m. and 4 p.m. It's signed by a house + +manager of Mr. Epstein's. + +Overt Act 178 is a message for Jeffrey + +Epstein, dated 10-2-2005. The time is 9:05 p.m. + +I'm sorry. Strike that. + +It's a message for Jeffrey Epstein, + +dated October 3rd, 2005, at 4:10 p.m. The + +message is for and the message is, + +will be a half hour late. It's signed by Mr. + +Epstein's house manager. + +Q Is it for or it's from + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +A It is taken by Mr. Epstein's house + +manager, . The "For" line is addressed to + +Jeffrey Epstein and then the "M" line says + +called and left that message + +for Jeffrey Epstein? + +A Calling + +Q Right. Referring to Count Ten, does the + +evidence that you just summarized the basis for + +the allegation that Jeffrey Epstein, + +, and procured Jane + +Doe Number 16 to engage in commercial sex acts + +knowing that she was under 18? + +A Yes. The only other thing I'd like to + +say is that we did obtain through the trash pull + +that the Palm Beach Police Department conducted in + +April of 2005, there was a computer printout of + +messages for Mr. Epstein which showed us a message + +from which read, can work tomorrow at + +4 p.m. This is listed as Overt Act 162, and then + +we also have the statements of both Jane Doe + +Numbers 16 and 17. + +Q Can you remind the grand jury about how + +Jeffrey Epstein knew Jane Doe Number 16's age and + +whether he did anything in recognition of her age? + +A Jane Doe Number 16 told Jeffrey Epstein + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +she was 17, and Mr. Epstein also provided Jane Doe + +Number 16 with Victoria Secret lingerie for her + +upcoming 18th birthday. + +Q All right. And if we could refer to + +Count 21 . Is the evidence that you just + +summarized the basis for the allegation that + +Jeffrey Epstein, , and + +used a facility of interstate + +commerce to persuade, induce, and entice Jane Doe + +Number 16 to engage in prostitution and in sexual + +activity for which a person can be charged with an + +offense? + +Q And can you remind the grand jury what + +the sexual activity is that Mr. Epstein could be + +charged with under the state law? + +A Sexual intercourse. + +Q All right. And how many telephone calls + +have you been able to document between Jane Doe + +Number 16 and + +A We have 50 -- over 50 calls with + +and Jane Doe Number 16. We have + +approximately 25 calls with and Jane + +Doe Number 16. We have one call between + +and Jane Doe Number 16. + +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 + +Q And with respect to + +there is also the actual sexual activity that she + +engaged in with Jane Doe Number 16? + +A Yes. + +Q Okay. And referring to Count Number 22, + +is the evidence that you just summarized the basis + +for the allegation that Jeffrey Epstein and + +used a facility of interstate commerce to + +persuade, induce, and entice Jane Doe Number 17 to + +engage in prostitution? + +A Yes. + +Q Now if we could turn to Jane Doe Number + +Seven. + +A GRAND JUROR: Jane Doe Number? + +MS. VILLAFANA: Seven. + +BY MS. VILLAFANA: + +Q Who is Jane Doe Number Seven? + +A Jane Doe Number Seven is a white female + +by the name of She was born in + +She attended + +High School. + +Q Have you testified about her before? + +A No. + +• All right. So has she been interviewed? + +A Yes. + +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 + +Q And during what period of time did Jane + +Doe Number Seven have contact with Jeffrey + +Epstein? + +A During the months of June and July of + +2004. + +Q How old was she at that time? + +A Sixteen. + +Q How did she meet Jeffrey Epstein? + +A Jane Doe Number Seven was taken to Mr. + +Epstein's residence by a white female named + +and we have talked about in my previous + +testimony. at that time was 15 years old. + +and Jane Doe Number Seven arrived + +at Mr. Epstein's residence for the first time by + +taxi. The first time Jane Doe Number Seven was + +taken there, Epstein, and Jane Doe Number + +Seven went upstairs. + +Mr. Epstein took them from the kitchen + +upstairs to his master bedroom to where the + +bathroom was where the massages were performed. + +Both + +massaging + +and Jane Doe Number + +Mr. Epstein. + +At Mr. Epstein's direction, + +Seven began + +left + +the room after some time. Jane Doe Number Seven + +continued the massage. Jane Doe Number Seven was + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +wearing only her underwear at this time. + +The massage turned sexual where at this + +point Mr. Epstein was touching Jane Doe Number + +Seven's )ut on the outside of her + +underwear. + +Mr. Epstein masturbated and then the + +massage was over. Mr. Epstein paid Jane Doe + +Number Seven, \$200, and Mr. Epstein told Jane Doe + +Number Seven that if she told anybody what had + +occurred that bad things could happen to her. + +Jane Doe Number Seven went to Mr. + +Epstein's house approximately two or three more + +times after that. + +Q And how was contact made with Jane Doe + +Number Seven? + +A would telephone Jane Doe + +Number Seven. + +Q To set up appointments? + +A Yes. + +Q And can you summarize the sexual + +activity that she was involved in with Jeffrey + +Epstein? + +A Mr. Epstein instructed Jane Doe Number + +Seven to rub his chest and nipples. Mr. Epstein + +masturbated in front of Jane Doe Number Seven. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Mr. Epstein told Jane Doe Number Seven to remove + +her bra and panties on one of the subsequent + +visits, and at that point, Mr. Epstein stroked + +Jane Doe Number Seven's vagina. + +Q Did Jane Doe Number Seven recruit anyone + +to go to Jeffrey Epstein's house? + +A Yes, she did. The name of the girl is + +and we have not fully identified her nor + +have we interviewed her. + +Q All right. Did recruit anyone + +else to go to Jeffrey Epstein's house? + +A Yes. + +Q And how do we refer to that person or + +the person wh n ndictment that was + +recruited by + +A As Jane Doe Number Eight. + +Q And just for the grand jury's purpose, + +when the initials are used in that + +indictment, who does that refer to? + +Q Okay. Now turn to Jane Doe Number + +Eight. Can you tell the grand jury who she is? + +A Jane Doe Number Eight is a white female + +by the name of . She was born in + +She attended Palm Beach Central High + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +School. I have not previously testified about + +Q During what period of time did she have + +contact with Jeffrey Epstein? + +A July 2004 through October of 2004. + +Q And how old was she during that time? + +A Seventeen. + +• How did she meet Jeffrey Epstein? + +A Through . Jane Doe Number Eight + +was taken to Mr. Epstein's residence by who + +again was still 15 years old at the time. They + +traveled to Mr. Epstein's residence by taxi. + +During the massage, Jane Doe Number + +Eight was wearing a sports bra, a skirt, and thong + +underwear. The massage turned sexual. Mr. + +Epstein masturbated until he ejaculated. + +Prior to that, Mr. Epstein moved Jane + +Doe Number Eight's underwear to the side and + +rubbed her vagina. Approximately one week later, + +telephoned Jane Doe Number Eight and + +invited her to return. + +told Jane Doe Number Eight + +that Mr. Epstein would pay her if she brought a + +friend. + +Q How much was Jane Doe Number Eight paid? + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +A Mr. Epstein paid Jane Doe Number Eight + +two or \$300. She could not recall exactly. Tatum + +was also paid \$200 for bringing Jane Doe Number + +Eight, and Tatum also told Jane Doe Number Eight + +that if she brought someone she would be paid + +\$200. + +0 Now you mentioned that there was + +telephone contact directly with Jane Doe Number + +Eight after that first visit. Approximately how + +many times did Jane Doe Number Eight go to Mr. + +Epstein's house? + +A Just that time. + +Q And in addition to stroking her + +was there any other specific sexual activity that + +she was involved with, with Mr. Epstein? + +A As I think I mentioned, he masturbated + +in the presence of Jane Doe Number Eight. Mr. + +Epstein fondled Jane Doe Number Eight's bottom and + +pulled Jane Doe Number Eight's underwear to the + +side and stroked her at that time. + +Q Now you said that Jeffrey Epstein told + +Jane Doe Number Eight that she would get paid if + +she brought other people. Did she bring anyone + +else? + +A No. + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q And is your testimony today the basis + +for the allegations in Overt Acts 46 through 65? + +A Yes. The only other thing I'd like to + +mention is that there are approximately nine calls + +between and Jane Doe Number Eight, + +and Jane Doe Number Eight stated that + +would continue to call her to try to get her to + +come. + +Q How did that phone contact end? + +A I would like to refer to my notes. + +Q Sure. + +A Jane Doe Number Eight told that + +she had moved out of the state to get to + +stop calling and that's how the phone contact + +ended. + +Q And could you just review Overt Act + +Number 59, which refers to a written telephone + +message? + +A Overt Act 59 refers to the message pads + +that were recovered during the execution of the + +state search warrant. Overt Act 59 is a message + +that is written out for Mr. Epstein, dated July + +17, 2004, at 6:55. + +It looks like there is a mark through + +a.m. So I'm not sure if it's 6:55 a.m. I believe + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +that would be 6:55 p.m, and they are marking a.m. + +out, but just for the record, it shows a mark + +through a.m. + +It says, There's a phone number + +there, The message is in a quote + +and it says, me and can come tomorrow any + +time or alone. And one of Mr. Epstein's + +employees had signed the bottom. + +Q And is a number that you have + +identified with + +A Yes, it is. + +Q If I can refer you to Counts 13 and 14. + +Is your testimony here today the basis for the + +allegation in Count 13 that Jeffrey Epstein and + +used a facility or means of + +interstate commerce, that is, a telephone, to + +knowingly persuade, induce, and entice Jane Doe + +Number Seven to engage in prostitution? + +A Yes. + +Q And is it also the basis for the + +allegation in Count 14 that Jeffrey Epstein and + +used a facility or means of + +interstate commerce, that is, a telephone to + +knowingly persuade, induce, and entice Jane Doe + +Number Eight to engage in prostitution? + +I + +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 + +A Yes. + +Q All right + +A Would you like the approximate phone + +calls? + +Q Yes. + +A The approximate phone calls for Jane Doe + +Number Seven between Jane Doe Number Seven and + +are eight, and the approximate phone + +calls between and Jane Doe Number + +Eight is approximately nine. + +Q All right. + +That is what we planned + +to cover for today. Hold on. Sorry. All + +right. I forgot one + +BY + +Q With respect to + +testified about today, 14 + +thing. + +the girls that you + +through 17, and seven + +and eight, is there any evidence related to any + +by any of those girls? + +A We do have + +Number 16. She has a + +with Jane Doe + +And also in regards to their + +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 + +We are still checking on that. Jane + +Doe Number Seven during her interview she told us + +that when she went to Mr. Epstein's house, she + +would take that we + +are aware of with Jane Doe Number Seven. + +Q And with respect to Jane Doe Number 16 + +was she able to tell you when she was + +in comparison to the time that she was spending + +with Mr. Epstein? + +A I know that when we interviewed Jane Doe + +Number 16, she told us that he was not aware of + +her problem. So I would like to go back and + +re-read that interview before I make that comment. + +Q Okay. But with respect to all of the + +girls, including the two that you just spoke about + +have you been able to + +independently corroborate their statements? + +A Yes, I have, and specifically with those + +two girls, Jane Doe Number 16, we have the + +telephone records. We have the message pads. We + +have the trash pulls. We have the statements from + +the other Jane Does. + +It's much the same with Jane Doe Number + +Seven through the statements of and other + +Jane Does, message pads, the telephone phone + +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 + +records. We have been able to corroborate their + +statements. + +Q Okay. + +If I could ask you to + +step outside for a moment and I will find out + +if the grand jury has any more questions. + +(Witness exits the Grand Jury Room.) + +(Witness enters the Grand Jury Room.) + +Q Special one of the + +questions asked by a grand juror was whether any + +of the girls, any of the Jane Does listed in the + +indictment have been charged or will be charged + +e ither by the Federal Government or the State + +Attorney's Office for solicitation of + +prostitution? + +A No. + +Q Okay. Then there was also a question + +about your testimony regarding the threat that was + +placed on the Jane Doe that if anything happened + +to her -- or if she said anything something bad + +would happed to her. + +Do you have any other evidence related + +to threats made to any of the Jane Does? + +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 + +A No. This specific Jane Doe, she was + +upset. She thought she was going there to model + +lingerie or perform a massage. When it turned + +into more than that, she was upset by that. + +I think she -- I believe she told us she + +wanted to report it and she was discouraged not + +only by nut by Mr. Epstein and he stated + +that to her on one occasion, and I believe I have + +more. + +I would have to go and read it if they + +would like to hear more about some of the other + +remarks that Mr. Epstein made to her. + +A GRAND JUROR: I would. + +THE WITNESS: Jane Doe Number Seven was + +told by Epstein that she was not to tell + +anyone what had happened during the massages. + +He told her that she could not tell anyone + +what happened at the house or bad things + +could happen. + +was very scared and felt + +nervous. She knew because of Epstein's + +money, he was powerful. Each time she went, + +she was reminded not to speak of what + +happened at the house and that she would be + +contacted again. + +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 + +Stated she wanted to notify the police + +at what happened at the house. Stated she + +was scared of what could happen to her and + +her family if she notified the authorities. + +This was taken from my 302 as well as + +the Palm Beach Police report. + +BY + +Q Okay. A statement provided by Jane Doe + +Number Seven. When you referred in your testimony + +to that is Jane Doe Number Seven? + +A I'm sorry. + +Q That's okay. It is just so they know. + +Special Agent , are you aware of any + +general Federal child predator law? + +A A general? General in? + +Q Well, one of the grand juror asked + +whether he could be charged with being a child + +predator. Are you aware of any Federal law that + +covers that? + +A No. + +Q All right. + +Those were all of the + +questions for you. If you could step + +outside. There is a question for her? + +A GRAND JUROR: Yeah. I don't know if + +2 + +3 + +4 + +5 + +6 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +it's for you or for her. I am just curious + +if he has been incarcerated or if he is still + +loose? + +THE WITNESS: He has not been + +incarcerated. + +All right. + +THE WITNESS: Not in the federal system. + +Q Well, he is not in custody? + +A No, and he is not in custody in the + +state system. + +Yes. + +A GRAND JUROR: Well, I was wondering if + +there is a lot of underlying shame involved + +with, you know, that they felt like if people + +found out, you know, if he was using that on + +them too, you know, being in shame? + +THE WITNESS: Do you want me to answer? + +Okay. + +THE WITNESS: I don't think that Mr. + +Epstein used that approach. I think there + +has been a lot of shame when we have + +interviewed the girls as to what occurred, + +but I don't think Mr. Epstein's approach was + +to shame the girls. + +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 + +Okay. Thank you. + +(Witness exits the Grand Jury Room.) + +(Witness enters the Grand Jury Room.) + +BY + +Q Special Agent we have three + +more questions. The first is: Do you have any + +evidence that this conduct is continuing? + +A No, not at this time, I don't have any + +evidence. + +Q I'm sorry? + +A I don't have any evidence. + +Q Okay. Do you have -- do you know + +whether Mr. Epstein or anyone else has been + +charged by the State of Florida in connection with + +his activities? + +A Yes, Mr. Eps.tein has been. + +Q What has he been charged with? + +A Solicitation of prostitution with three + +counts of solicitation of prostitution. + +Q And in the charges that have been + +brought against him is there any reference to the + +fact that these, quote, unquote, prostitutes were + +under the age of 18? + +A None whatsoever. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q And the last question was: Why haven't + +the minors been charged with solicitation of + +prostitution? Let me break that into two + +questions. Does the Federal Government prosecute + +minors as a rule? + +A Not usually. + +Q Then with respect to the state, do you + +know whether or why the minors haven't been + +charged? + +A No, I don't know. + +Q Okay. All right. + +MS. That's all. Thank you. + +(Witness was excused.) + +CERTIFICATE OF REPORTER + +Certified Court + +Reporter and Notary Public, do certify that the + +transcript is a true and correct transcription of + +my stenotype notes of the testimony of + +SPECIAL AGENT , taken before + +the Federal Grand Jury, West Palm Beach, Florida. + +Certified Court Reporter + +UNITED STATES DISTRICT COURT + +SOUTHERN DISTRICT OF FLORIDA + +IN RE: OPERATION LEAP YEAR + +APPEARANCES: + +, ESQUIRE + +Federal Grand Jury, 07-103 + +West Palm Beach, Florida + +May 8, 2007 + +Assistant United States Attorney + +Foreperson + +TESTIMONY + +The sworn testimony of + +was taken before the Federal Grand Jury, West Palm + +Beach Division, West Palm Beach, Palm Beach County, + +State of Florida, on the 8th day of May, 2007. + +Court Reporter, was authorized to + +and did report the sworn testimony. + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +(The witness entered the grand jury room.) + +having been duly sworn by the grand jury foreperson, + +was examined and testified on her oath as follows: + +EXAMINATION + +BY MS. VILLAFANA: + +Q Could you start by reminding us of your name and + +where you're employed. + +A + +I work for the FBI here in West + +Palm Beach on their + +Q And you are one of the case agents in Operation + +Leap Year? + +A Yes, I am. + +Q Did you recently participate in an interview of + +A Yes. + +Q Can you tell us date of birth? + +A was born o + +Q And you spoke with her recently? + +A Yes, we did. + +Q So she was 18 at the time of the interview? + +A + +Q + +Yes, I believe she was. + +Who is 1 ? + +Police Department as one of the girls who had frequented + +Mr. Epstein's house. + +Q How exactly did the Palm Beach Police Department + +determine that she was one of those girls? + +A When they did their search warrant at + +Mr. Epstein's residence, some message pads were obtained + +at his residence, and they had several calls from a girl + +named and phone numbers. So they were able to + +track back those messages back to + +Q Did the Palm Beach Police Department try to + +interview Miss + +A They did. + +Q Did she agree to speak with them? + +A No. She stated that she loved Jeffrey Epstein, + +and that she would not say anything positive or negative + +about what occurred. + +Q After the FBI became involved in this + +investigation, did you try to interview Miss + +A We did, as well, with no such luck, as well. + +Q How long ago was it that you first made contact + +with Miss + +A It was back in November of '06. + +Q Did you try to serve her with a subpoena issued + +on behalf of this grand jury? + +Q What happened? + +A She refused service of the grand jury subpoena. + +But she was notified of when her appearance was expected + +here, and a subpoena was left with her. + +Q + +A + +After that, did she obtain an attorney? + +Yes, she did. + +Q Who was that? + +8 A He's a well-known defense + +attorney here in West Palm Beach. + +Q Who paid for that attorney? + +A Mr. Epstein is paying for attorney. + +Q Now once Miss secured the attorney, did + +she agree to be interviewed? + +A Yes, she did, after she was granted 6001 + +immunity. She requested immunity. + +Q Did the justice department authorize that grant + +of immunity? + +A Yes, they did. + +Q After that, did she agree to be interviewed? + +A Yeah. It was only after she was given that + +immunity that she would talk with us. + +Q When did the interview take place? + +A It took place at the end of April of this year, + +so just a few weeks ago. + +A Myself; my partner, agent ; the AUSA, + +; her attorney, Jim Eisenberg, and his + +investigator; as well as + +Q What did Miss tell you about Jeffrey + +Epstein? + +A She stated that she had met an individual by the + +name of + +a party who had asked her if she + +wanted to make a few bucks by giving a man a massage. She + +was told that Mr. Epstein preferred them to be topless, + +and she agreed to go to his house to give him a massage. + +Q How old did Miss tell you she was at that + +time? + +A She stated she was 16 when she first started + +giving Mr. Epstein massages. + +Q Based upon your review of the evidence, is that + +correct? + +A No. We have phone records where + +(phonetic), Mr. Epstein's assistant, is contacting + +on her cell phone, or using her cell phone to call + +cell phone starting in April of 2004, which makes + +15. + +Q So she said that she was 16, but your evidence + +shows that she was 15, and she said that she was told she + +could make a few bucks giving a topless massage? + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +Qwhat else did Miss tell you? + +A That she went to Mr. Epstein's residence, that + +took her there the first time, that when she went + +upstairs she was paid \$200 when she first got there by + +Sara Kellin. Then she goes upstairs, and Mr. Epstein + +comes in, he disrobes, puts on a towel, lays down on the + +massage table and she begins to massage him. + +She tells Epstein that she heard he likes + +topless massages, and he told her that he did. And she + +said, •who wouldn't?• And she ended up taking off her top + +during the first massage. But is clear that Mr. + +Epstein did not at any point touch her during the massage. + +Q But does she admit that he touched himself? + +A Yes. On the second massage, Mr. Epstein asked + +her to leave her phone number with Her phone number + +was left there. On the second massage, she returned the + +very next day and gave him another massage. This time, + +Mr. Epstein masturbated in front of her. + +Q Did Miss admit that he masturbated on + +more than one occasion in her presence? + +A Yes, masturbated. And I think her term was that + +he •released,' meaning that he ejaculated. + +Q How long of a period of time did Miss + +tell you that she performed massages? + +2 + +3 + +4 + +5 + +6 + +7 + +a + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +but just said that it was a lot, and that she had been + +giving him massages for a year. + +• You mentioned to the grand jury that Miss + +said that Mr. Epstein never touched her, correct? + +A Yes. + +Q And she was very adamant about that? + +A Yes, she was. + +Q Were there other things that she was adamant + +about in her interview with you? + +A well, she talked about what she would tell the + +girls that -- and that she told Mr. Epstein that she was + +18. I'm sorry, I take that back. She was told to say + +that she was 18, and she told us that she had a fake I.D. + +showing that she was 18. + +So she passed that information along to the + +other girls when she brought -- eventually she brought + +other girls to perform massages, and that was one of the + +things that she told -- she told us first that she brought + +18- to 20-year old girls. And then she stated that if the + +girls lied, and they were underage, she told them that + +they needed to tell Epstein that they were 18. + +Q Have you been able to identify some of the girls + +that Miss brought to Mr. Epstein's home? + +A Yes. + +A No, not that we found so far. + +Q Have any of the girls told investigators about + +what Mr. Epstein knew about their ages? + +A I'm sorry, say that again. + +Q Have any of the girls who came through + +been interviewed about what Mr. Epstein knew about + +their ages? + +A We did interview them regarding that, and I'm + +not sure if he asked them. They were all told to say they + +were 18, but not on every occasion would Mr. Epstein + +inquire about their age. + +Q Do you want to check your records on that? + +A Yes, could I do that? + +Q Yes, please do. + +A I can tell you that one of the girls that she + +brought -- this girl told Mr. Epstein that she was in high + +school, and actually told him her true age, which was + +under 18. + +Q So what told you about, that wasn't + +really the case? + +A No, that wasn't. Sorry. + +Q That's all right, I just wanted to make sure + +it's clear. + +So Miss told you that she had been told + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +fake I.D.? + +A Yes. + +Q Did she ever say that Mr. Epstein either asked + +for her age or asked to see her I.D.? + +A No, the topic never came up. + +Q Did you also ask her about how appointments were + +made? + +A + +that + +Yes. She was very clear in the fact that + +would call her to arrange the appointments, but + +would call her once Jeffrey was in town. + +Q So she was adamant that the calls only happened + +when she was already here? + +A Yes. + +• Were you made aware that Epstein's counsel was + +informed that he was being investigated for traveling to + +engage in prostitution, which means that the appointments + +would have been made before the traveling? + +A Yes. + +Q Was there anything else, besides the issue of + +age and the issue of when the appointments were made, that + +sounded + +A + +about + +which girls he would like + +coached or that she was especially adamant about? + +No, I wouldn't say coached. I mean, we talked + +the preferences that Jeffrey discussed, as far as + +o bring. + +told us that he liked different faces, so he would + +to bring other girls. We asked her if he ever + +preferences of what he preferred, and her + +was that Epstein liked girls like her, which is + +blond and attractive. + +ask her + +gave any + +response + +thin and + +Q And how old was she at the time? + +A She was 15. + +Q So thin, blonde, attractive and -- + +A Young, girls like her. I guess we asked if she + +ever made a mistake, or ever brought somebody that Mr. + +Epstein didn't take to. She said that she had screwed up + +and that she had brought a black girl to Mr. Epstein, and + +that Epstein was not interested in black girls. But he + +did pay her, and said that he wasn't a racist. He paid + +her the \$200 for her time, but did not want her to perform + +a massage for him. + +Q And he didn't allow that girl to perform a + +massage? + +19 A No. + +Q Was there anything else that Miss talked + +about in the interview that you want to share with the + +grand jury? + +A I did ask her at the end of the interview if she + +was in love with Mr. Epstein. She looked into the camera + +kind of looked into the camera and gave a wink and a smile + +and said, "But with your money, I'd marry you any time, + +Jeffrey." + +Q Did she also say that she considered him to be + +an "awesome guy"? + +A Several times she referred to him as an "awesome + +guy". She said that the girls begged her to come and that + +the girls didn't have a complaint, and the girls would + +share with her everything that happened after the massage, + +and that Jeffrey never touched any of the girls. But as I + +informed you, we did interview some of the girls that she + +took, and he has touched them. + +Q In preparation for your testimony today, did you + +also speak with someone who is considered to be an expert + +in these cases? + +A Yes. + +Q And what is that person's name? + +A + +Q Has Mr. been qualified to testify as an + +expert in federal and state courts in cases that involve + +21. what he calls "compliant victims"? + +A Yes. + +Q What does he mean by the term "compliant + +victims"? + +1 necessarily forced into the conduct that the offender + +2 wants them to engage into, that they actually consent to + +3 that kind of activity. + +4 Q So that would include minors who are subjected + +5 to sexual activity but weren't necessarily kidnapped or + +6 forced at gunpoint, or something like that? + +A Exactly. + +8 Q Did he discuss with you the difficulties that + +9 exist when you interview those types of victims? + +10 A Yes. He stated that a compliant victim is often + +11 times embarrassed that they went along with the behavior. + +12 They are also likely to deny the behavior, especially when + +13 being interviewed by investigators, that they'll deny it + +14 or they'll minimize it. Sometimes it takes two, three or + +15 multiple interviews to get compliant victims to either + +16 trust their interviewer or realize that their interviewer + +17 is not going to be judgemental. + +18 Q In this case, have you found that to be the case + +19 with some of the interviews? + +20 A Yes, I have. + +21 Q In addition to being embarrassed, sometimes + +22 these victims feel guilty about the fact that they were + +23 involved in this type of activity? + +24 A Oh, yes. + +1 preference of offenders? + +A Yes, he does. + +3 Q Did he explain why an offender would select the + +types of victims that are involved in this case, girls + +between 14 and 17-years-old? + +A This type of offender, the sexual preference he + +has is for post-pubescent females that are physically + +8 developed but not necessarily mentally matured. The girls + +ranging in this age are sometimes inexperienced, they are + +possibly naive, not as worldly. + +An offender of this type could also maybe not + +feel sexually adequate or feel competent dealing with his + +own age group. So knowing that these girls are less + +experienced, may focus on them as well. + +15 Q In addition to their emotional immaturity, did + +Mr. Lanning talk about whether or not younger girls are + +easier to manipulate than grown women? + +18 A Yes. + +19 Q Did he talk to you about 'grooming•? + +20 A Yeah. That's what an offender will use with a + +compliant victim. He told us that grooming is a technique + +where you gain the cooperation of those victims by + +focusing on their interests and playing up to those + +interests. It's a type of seduction, he called it. That + +2 + +3 + +4 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +case. + +Q Can you give us an example of some of the types + +of grooming that Mr. Epstein used? + +A With one of the girls we're going to talk about + +today, it's very apparent interviewing her how + +Epstein groomed her. She only went to three or four + +massages at this time, that she's admitted to. We feel + +that due to her phone conversations, the multiple calls, + +that there may be more there. At this point she has + +stated to us that she has performed three or four massages + +for Mr. Epstein. + +What he did is when she first went there he + +played upon -- she was very shy, and he would play upon + +that shyness. He told her that she was pretty. He asked + +her to remove her clothing, and she would not. So he kind + +of kidded around with her shyness and complimented her, + +showed interest in her, talked about her boyfriend and + +different interests she had. + +At the end of that interview, because she did + +not take off her clothes, he tells her that if she's + +willing to do more, she will make more. He also tells her + +that he would pay her if she would bring other girls. As + +the massages increased, you can see that the next time she + +time she does comply and takes off her he asked her to + +disrobe on the second massage. She takes off her blouse, + +but she refuses to take off the bra after Mr. Epstein + +4 asked her to. + +So you can see that he tries through showing + +interest. And then he actually -- when he sees that this + +isn't working, he takes a more authoritative role with her + +in the last massage. She said that throughout all of + +these massages he was very nice, and then at the end he + +10 was much more frustrated and irritated. She does get down + +to her bra and panties on that one, he's just much + +more authoritative. + +So he started with the grooming process, tried + +to get her interest, tried to use that to get her to + +comply with removing her clothes. But as often happens, + +at the end of this, he took over and was much more + +forceful with his requests. + +18 Q Have other girls described that same situation + +where every time they went back, he tried to push it one + +step further and one step further? + +A Yes. Several of the girls have said that he + +would always push for more and more. + +23 Q Did Mr. Lanning explain why it is that a + +compliant child victim cannot legally consent to the + +1 A Yeah. He stated that -- you know, we talked + +2 about how the law protects children, and stated that we + +3 hold adults accountable. When it comes to adolescents, + +4 they go through normal tendencies that mature offenders + +5 may try to take advantage of. But the law is in place for + +6 that reason, to protect -- in the federal law, to protect + +7 those individuals under the age of 18. + +8 Q And that's because of the different maturity + +9 levels of the -- + +10 A The offender versus the victims, exactly. + +11 Q Did you put together the photographs of the + +12 defendants in this case? + +13 A Yes, I did. + +14 Q Are these photographs of the four human + +1 5 defendants who are named in the proposed indictment? + +16 A Yes. + +17 Q With their names underneath them? + +18 A Yes. + +19 Q Agent, who is in the top left-hand corner? + +20 A That's Jeffrey Epstein. + +21 Q When was this photograph taken? + +22 A Recently. There was an article that just came + +23 out regarding Mr. Epstein and his connection, or his + +2 + +3 + +4 + +5 + +6 + +7 + +a + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +Who is in the top right-hand corner? + +A That's + +Q Again, this is a relatively recent photograph? + +A Yes, that's his personal assistant. + +• And the bottom left-hand corner? + +A Again, that is one of Mr. Epstein's personal + +assistants, that's + +Has Miss since gotten married? + +A Yes, her name now is + +Q And the bottom right-hand corner? + +A That is She is, again, a + +personal assistant to Mr. Epstein. There has been some + +talk that she is also romantically -- or I should say + +sexually involved with Mr. Epstein. + +Q How old are the defendants? + +A Jeffrey is in his mid-fifties, and the three + +girls are in their early twenties. + +Do you have a copy of the draft indictment in + +front of you? + +A Yes, I do. + +You mentioned when we were looking at the + +photographs that the three females work as personal + +assistants for Mr. Epstein, is that correct? + +A Yes. + +A Yes. + +2 Q Are you familiar with the property located at + +358 El Brillo Way in Palm Beach? + +4 A That's Mr. Epstein residence. + +s Q And he owns that residence? + +6 A Yes, he does. + +7 Q Are you familiar with Defendant J.E.G.E., Inc.? + +A Yes. J.E.G.E., Inc. is owned by Jeffrey + +Epstein. He is the president, the owner, the sole + +lo director. It's a business that is solely used for the + +activities of one of Mr. Epstein's airplanes, which is his + +Boeing 727. Its tail number is N908JE. + +14 the sole director. Is he also the sole shareholder? + +A Yes, he is. + +16 Q Are you familiar with Hyperion Air, Inc.? + +A Yes. Hyperion Air, Inc. is also a business + +owned by Mr. Epstein. He is also the president, the + +director and the sole shareholder of that company as well. + +That company solely does business with his other aircraft, + +which is a Gulf Stream G-1159B. It bears a tail number + +N909JE. + +Q Is that a smaller aircraft than the Boeing? + +Q And you mentioned that he is the president and + +A Yes. + +1 where the evidence has been collected in this case, was + +2 the start of your investigation information that you + +3 received from the Palm Beach Police Department? + +4 A Yes, it was. + +5 + +6 search of Mr. Epstein's home at El Brillo way? + +7 + +8 + +9 Department placed? + +10 + +11 + +12 + +13 A Yes, as well as trash pulls that the Palm Beach + +14 Police Department conducted on Mr. Epstein's residence. + +15 Q Then when the FBI became involved, the FBI did + +16 additional interviews of girls and of recruiters? + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +Q And that included evidence seized during a + +A Yes. + +Q Also controlled calls that the Palm Beach Police + +A Yes. + +Q And interviews of girls and other people by the + +Palm Beach Police Department? + +A Yes. + +Q They obtained phone records? + +A Yes, we have. + +• And records of payments? + +A Yes. + +Q Did this grand jury also subpoena travel + +records? + +A Yes. + +1 owned by Hyperion and J.E.G.E.? + +2 A Yes. + +3 Q Did you also get corporate documents related to + +4 those two planes? + +5 A Yes, we have. + +6 Q Once you had obtained all of this information, + +7 did the FBI analyze the data, specifically the call + +8 information and the flight information to put together a + +9 pattern of activity by the defendants? + +10 A Yes, we did. + +11 Q So you have a series of phone calls coming from + +12 these three assistants who were on the board, the two + +13 girls who have been identified through this investigation? + +14 A Yes. + +15 Q When you spoke with those girls, did any of them + +16 tell you that they had developed some sort of a personal + +17 relationship with the assistants so that they were just + +18 chatting over the telephone? + +19 A No, not at all. + +20 Q All of them said what about the phone calls? + +21 A Said that the phone calls were made to set up + +22 appointments for Mr. Epstein. + +23 Q And the girls referred to it as appointments to + +24 work, is that right? + +one exception, + +probably next + +that + +week. + +We're going to talk about her + +say on one or two occasions + +called her when she had gone out + +She did + +had + +to California on a trip, I believe. But that is the only + +time that that was ever mentioned. In fact, we asked, and + +those phone calls were made for the purpose of setting up + +appointments for Mr. Epstein. + +Q Is the investigation continuing? + +A Yes, it is. + +Q Are you still trying to locate and interview + +more girls? + +A Yes. + +Q Let's turn to the specific evidence reporting + +the overt acts and offenses relating to Jane Doe's 1 + +through 5. I know that every member of the grand jury has + +a copy of the draft indictment before them, and also a + +chart. + +Do you have a copy of that chart as well? + +A I do. + +Q Do you have photographs of the five girls that + +we are going to talk about today? + +A Yes. + +Q And these are photographs of the people that we + +are calling Jane Doe's 1 through 5? + +1 Q And Jane Doe Number 1, you have previously + +2 testified about her? + +3 A Yes, I have, that's + +4 Q Jane Doe Number 2? + +5 A That is + +6 Q Jane Doe Number 3? + +7 A That is + +Q Jane Doe Number 4? + +9 A Faith P. + +10 Q And Jane Doe Number 5? + +11 A That is + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +JUROR: The purpose of Epstein's business with + +his planes, did he transport? + +THE WITNESS: To travel around. + +JUROR: So it wasn't like a business of + +transporting other people? + +THE WITNESS: He flew other guests, sometimes + +unaccompanied, sometimes accompanied. + +JUROR: and do you have + +any evidence that they started young, like the rest + +of the recruits? + +THE WITNESS: We have evidence that they are his + +personal assistants employed by him, not that it was + +anything like what we were discussing. + +earlier, back in February, during one of these + +discussions, about a specific act that was performed. + +Can I ask about that? We were told back in February + +that one of the girls when interviewed had alleged + +rape, and I hadn't heard about that allegation + +recently. + +THE WITNESS: That's probably Jane Doe Number 6. + +We're going to talk about her, that he forcibly put + +her on the table and her. Yeah, she will + +be coming up. We're going to do her probably next + +week. She'll be the first one we'll talk about. + +By' + +Q So turning to Jane Doe Number 1, You + +testified about her earlier before this grand jury, + +correct? + +A Yes, I did. + +Q And she also testified before this grand jury, + +correct? + +A Yes. + +Q Can you remind us of her date of birth? + +A She was born on + +Q Could you briefly refresh the grand jury's + +recollection of how she was recruited? + +A She was approached on a beach by and + +1 and asked her if she wanted to perform massages for + +Mr. Epstein and make some money. + +Q From the review of the phone records that you + +have received, were you able to identify a telephone + +number associated with + +A Yes. + +Q In fact, has been interviewed? + +A Yes, he has. + +Q And has he admitted to being a recruiter for Mr. + +Epstein? + +A Yes, recruiter and driver. + +Q If you could take a look at Overt Act Number 2, + +which appears on page five. That states, "On or about + +March 12, 2004, defendants Jeffrey Epstein and + +caused Jane Doe Number 1 to travel to 358 Brillo Way of + +Palm Beach, Florida.• + +Can you tell us what evidence you have regarding + +that? + +A We have reviewed phone records for and + +Sara that indicate the calls took place, as well as phone + +records for and and calls that took + +place on or about those dates. We've also looked at a + +flight manifest, and were able to show that Mr. Epstein + +arrived the day before, on the 11th. We also have ■ + +2 + +3 + +4 + +took place. + +Q On that date, March 12 of 2004, + +going to Mr. Epstein's house and performing + +massage? + +described + +a sexual + +5 A Yes, on or about that day. + +6 + +7 + +Q On or about that date, what did + +about being paid? + +state + +8 A She was paid S200. + +9 Q And that relates to Overt Act Number 3? + +10 A Yes. + +11 + +12 + +Q And she stated that Mr. Epstein is the person + +who gave her that? + +13 A She told us that in her statement. + +14 Q If you could take a look at Overt Act Number 95, + +15 which is on page 17. On or about February 6, 2005, + +16 + +17 + +Epstein had Jane Doe Number 1 to make one or more + +telephone calls to Jane Doe Number 2. + +18 First of all, who is Jane Doe Number 2? + +19 A That would be ., our youngest victim. + +20 + +21 + +Can you tell us what evidence you have related + +to that overt act? + +22 A We have the girl's statements that calls were + +23 made. we also reviewed the phone records that indicated + +24 + +that there was telephonic contact between the numbers + +Q And in the statement of both girls, did they + +describe that is the person who called + +looking for someone to come and work at Mr. Epstein's + +house? + +5 A Yes. + +Looking at Overt Act Number 96. On or about + +February 6, 2005, Epstein caused Jane Doe Number 1 to + +transport Jane Doe Number 2 to 358 El Brillo way. + +9 What is the evidence related to that? + +10 A Again, the statements of support + +11 that as further evidence, and also reviewing the phone + +12 records they indicate that there was telephonic contact + +13 between and + +14 Q Overt Act Number 97, on or about February 6, + +15 2005, Epstein made a payment of \$300 to Jane Doe Number 2 + +16 and a payment of \$200 to Jane Doe Number 1. + +17 What was the evidence of that? + +18 A Both stated in their statements + +19 that was paid \$300, and was paid \$200 for + +20 bringin + +21 Q Did explain why she was paid \$300? + +22 A Yes, she was paid \$300 because she performed her + +23 massage. Mr. Epstein digitally penetrated and used a + +24 massager on + +\$300 found in + +school? + +A + +Q + +is on + +2005, + +'s purse when it was searched at her + +Yes, it was, by a school administrator. + +If you could look at Overt Act Number 117, which + +page 19, and that states that on or about March 30, + +caused one or more calls to be made to a + +telephone used by Jane Doe Number 1. + +What evidence do you have related to that? + +A We reviewed the phone records of and + +that indicate this. + +Q And Overt Act 120, on or about March 31, + +caused one or more calls to be made to a telephone used by + +Jane Doe Number 1. + +A Again, we reviewed the phone records that + +indicated there was telephonic contact between the numbers + +belonging to + +Q Then we have Overt Act Number 122, which is also + +March 31, that Epstein and caused Jane Doe Number 1 + +to make a call to a telephone used by Jane Doe Number 2. + +What evidence do you have related to that? + +A We have phone records that we have reviewed + +belonging to In this case, we also have a + +voice mail that was provided to us by the Palm Beach + +Police Department, a voice mail o leaving a voice + +1 Q And Overt Act Number 123 refers to April 1st. + +2 What evidence do you have related to that? + +3 A We have reviewed the phone records of and + +4 that indicate telephonic contact was made on this + +day. We also again have another recorded voice mail by + +6 left on phone. + +7 Q These later calls, the March-April calls, are + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +those the controlled calls that the Palm Beach Police + +Department was involved in? + +A There was controlled calls placed to + +cell phone and to place of work b under the + +supervision of the Palm Beach Police Department. + +Q And the voice mail message that you referred to + +AIM calling what information was leaving + +in that voice mail message? + +A was asking for to get back in touch, + +that she had set up an appointment for ■ **at Epstein's** + +**house on the following day, on that Saturday at around** + +**10:30 or 11:00.** + +**Q In addition to the phone records, was there** + +**anything that the Palm Beach Police Department found that** + +**also confirmed that this appointment actually was made.** + +**A As I mentioned earlier, the Palm Beach Police** + +**Department was doing trash pulls on Mr. Epstein's** + +there on Epstein's personalized stationary. + +said, •tith on Saturday at 10:30, + +Saturday wit t 10:30." That's the exact + +On it it + +and on + +message on + +the two notes that were found in his trash when they + +retrieved it on April 8. + +Q . If I could direct your attention to Count Number + +Five, which appears on page 26. That is the charge of + +enticement of a minor, referring to Jane Doe Number 1, and + +Mr. Epstein and Missi are charged. + +I know that you talked about the telephone + +traffic. The calls betweex and did + +they fall within that march 7 through March 11 time + +period? + +A A review of their telephone records do indicate + +that there were phone calls made during that time. + +Q And Jane Doe Number 1 actually went to Mr. + +Epstein's home? + +A Yes, and performed a massage for him in the + +nude. + +Q And she was paid for that? + +A Yes, she was paid S2O0. + +Q And he masturbated in front of her, correct? + +A Yes, he did. I would like to include that Sara + +Kellin took upstairs for that massage, and she also + +2 + +3 + +4 + +for + +at + +that massage. + +just so it's clear, how old + +17. + +to do + +Q And also, + +that time? + +A She was + +was + +5 Are there any questions about + +6 either how that evidence was presented or about the + +7 charges related to Jane Doe Number 1? Seeing no + +questions, we'll turn to Jane Doe Number 2. + +9 + +10 0 You previously mentioned that that was + +11 A Yes. + +12 Q Let's turn to Count Number Six, which is on page + +13 26, which is the enticement of If you could tell + +14 the grand jury about the evidence related to that. + +15 A date of birth is + +16 Q So during this period of February 5, 2005 to the + +17 6th, how old was she? + +18 A She was 14. + +19 Q Can you remind the grand jury about the evidence + +20 related to the enticement of + +21 A As we stated earlier, we talked about the + +22 telephone calls. We have shown that the facility of + +23 interstate commerce was used by the telephone calls made + +24 by their cell phones. We examined specifically + +set up and arrange appointments for Mr. Epstein to have + +his massages. + +Pertaining to , during the massage that + +occurred on those dates, February 6, in particular, I + +5 think I have discussed with you before what occurred on + +that, that he fingered -- and that was his term for + +7 it -- and that he used a massager on her. + +He did masturbate during that massage, and she + +believed he ejaculated because he wiped off his penis with + +a towel. She was paid \$300, and we know that she was 14 + +at the time. + +12 Q If we could turn to Count Number 43, which + +appears on page 31. Count 43 is one of the travel counts. + +If you could tell the grand jury, did a trip occur on + +March 31, 2005? + +A Yes, we have flight records that indicate a + +flight occurred on that date. + +Q What type of plane was used? + +19 A I'm going to refer to the J.E.G.E., Incorporated + +aircraft as just the Boeing 727. If we talk about the + +Hyperion Air, Incorporated aircraft, which is the Gulf + +Stream, I will just say the Gulf Stream. So on that date + +he did travel on his Boeing 727, on 3-31. + +24 Q And Mr. Epstein was aboard the plane on that + +1 A Yes, he was. + +Q with respect to the March 31st trip, was there + +evidence of him setting up the appointment with prior + +to that trip? + +5 A We do have telephonic contact between and + +as well as on the day before + +and the day of travel. + +Q And even though that appointment was never kept, + +that never went to that appointment, you have the + +notes that were retrieved from the garbage that showed + +that Mr. Epstein was expecting show up for that + +appointment? + +A Yes. + +0 Anything else with respect to that particular + +count? + +A We also have the controlled calls and the voice + +mails. + +Turning to Count Number 60, which appears on + +page 34, that is the attempted enticement of + +during the period of March 30 to April 1. + +Again, at that point, was how old? + +A She was 14. + +Q And we had talked about the telephone calls that + +were used. One of the things that is relevant to this + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +was 14, did you interview a girl who went with + +■ **when she went to Mr. Epstein's house back in** + +**February?** + +**A Yes, we did, that would be** + +**Q And ! was interviewed?** + +**A Yes, she was interviewed by the Palm Beach** + +**Police Department.** + +**Q What did say about appearance?** + +**That she was the youngest looking girl that** + +**Q When you talked with did talk about** + +**girls that Mr. Epstein liked in particular?** + +**A Yes.** + +**Q And was** + +**S.** + +**one of those girls?** + +**A Yes, she was one of his preferences. lso** + +**told us that Mr. Epstein said to her on one occasion, •The** + +**younger, the better.•** + +**Q And there was never any attempt to get** + +**I.D. or to confirm her actual age?** + +**A No.** + +**Q As we discussed before, never actually went** + +**to that point, right, so that is just an attempt?** + +**Are there any questions from the** + +week. Thank you. + +(Witness excused.) + +CERTIFICATE OF REPORTER + +I CERTIFY pages 1 to 35 is a true transcript of + +my shorthand notes of the testimony of + +before the Federal Grand Jury, West Palm + +Beach, Florida, on the 8th day of May, 2007. + +Dated at West Palm Beach, Florida this 23rd day + +of May, 2007. + +Court Reporter + +UNITED STATES DISTRICT COURT + +SOUTHERN DISTRICT OF FLORIDA + +IN RE: OPERATION LEAP YEAR + +APPEARANCES: + +ESQUIRE + +Federal Grand Jury, 07-103 + +West Palm Beach, Florida + +May 8, 2007 + +Assistant United States Attorney + +Foreperson + +TESTIMONY + +OF + +The sworn testimony of + +was taken + +before the Federal Grand Jury, West Palm Beach + +Division, West Palm Beach, Palm Beach County, State + +of Florida, on the 8th day of may, 2007. + +:ourt Reporter, was authorized to + +and did report the sworn testimony. + +(The witness + +having been duly + +was examined + +entered the grand jury + +room.) + +foreperson, + +as follows: + +sworn by the grand jury + +and testified on his oath + +EXAMINATION + +BY + +Q Special Agent could you state and + +spell your name for the record. + +A + +Q By whom are you employed? + +A I'm employed by the FBI. + +Q What is your position with the FBI? + +A I'm a special agent, and have been so for four + +years. + +Q Are you one of the agents assigned to the + +investigation known as Operation Leap Year? + +A Yes, I am. + +Q Were subpoenas caused to be issued on behalf of + +this grand jury in connection with that investigation? + +A Yes. + +Q And have documents been received in response to + +those? + +A Yes. + +Q What additional subpoenas have been issued, and + +1 A Additional subpoenas that have been issued + +include OLY-28 to Colonial Bank, along with OLY-29, which + +was issued to Palm Beach National Bank & Trust Company. + +That was served on March 5, 2007. It should be known that + +Palm Beach National Bank & Trust Company is now operated + +by Colonial Bank, which we learned in the issuance + +process. We did receive documents back from Colonial + +8 Bank, which covered both subpoenas, on April 25, 2007. + +9 Q And those sought information relating to bank + +accounts belonging to Mr. Epstein? + +A That is correct. + +12 Q What else? + +A Also served OLY-30 to Western Union Financial + +Services seeking documents and records related to Jeffrey + +Epstein. it was served on February 26, 2007, and we + +received items back from Western Union on two separate + +dates, and two packages, the first on April 9, 2007, and + +the second on April 11, 2007. + +19 Q And those sought records of wire transfers from + +Mr. Epstein to girls whom have been identified for this + +investigation? + +A Yes. + +23 Q What else? + +A We also served OLY-31 to Western Union Financial + +2 + +3 + +4 + +returned information which we received on May 3, 2007. + +Q The same type of information? + +A Yes, the same type of information, seeking wire + +transfer information from Jeffrey Epstein to victims. + +5 We also served OLY-32 to J.P. Morgan Chase Bank. + +6 After serving that one on February 26, 2007, they informed + +7 us by letter that they are known as Chase, not J.P. Morgan + +8 + +10 + +11 + +12 + +13 + +14 + +15 + +16 A Yes. Additionally, we served OLY-33 on Dr. + +17 Thomas Rofranno (phonetic), who's a chiropractic doctor. + +18 We were seeking records related to Jeffrey Epstein as a + +19 + +20 + +21 + +22 + +23 + +24 + +Chase. So we had to reissue another subpoena, which was + +taken care of on March 22, '07. + +We also issued OLY-40 on Chase Bank as well on + +April 4, 2007. We received records on April 13, 2007 and + +April 19, 2007 to cover all three subpoenas that were + +served. + +Q And those sought information related to bank + +accounts and credit cards related to the defendants? + +patient. The subpoena was served on March 6, 2007, and + +Thomas Rofranno provided materials on March 16, 2007. + +Also we have OLY-36, which was served on the + +Palm Beach County Health Department. It was served on + +March 5, 2007, seeking birth certificates of our victims + +that we were researching. We received the records from + +1 We also served two subpoenas on the Adult Video + +Warehouse. The first one was OLY-41, which was served -- + +3 both of these were served on April 24, 2007, and they were + +seeking any transactions that had occurred on behalf of + +Mr. Epstein or those individuals that were working for him + +6 or with him. We received items back on the OLY-41 + +subpoena on April 30, 2007. + +The second subpoena served on Adult Video + +Warehouse was OLY-34. Again, it was served on April 24, + +2007, and the Adult Video warehouse complied and provided + +us materials on April 30, 2007. + +That concludes all of the items that we have + +received to date for the outstanding subpoenas that were + +issued. + +15 Q Are the documents that you refer to in that box + +that's on the desk? + +17 A Yes, they are. + +18 : Does anyone want to review those + +documents? At this time, no one is requesting that + +they want to review the documents today. + +Would you please swear in the witness to + +maintain those documents. + +(Witness sworn in as custodian of the + +records.) + +CERTIFICATE OF REPORTER + +I CERTIFY pages 1 to 6 is a true transcript of + +my shorthand notes of the testimony of + +before the Federal Grand Jury, West Palm + +Beach, Florida, on the 8th day of May, 2007. + +Dated at West Palm Beach, Florida this 28th day + +of May, 2007. + +Court Reporter + +1 UNITED STATES DISTRICT COURT + +2 + +SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH + +3 + +4 + +5 + +6 + +7 + +8 IN RE: OPERATION LEAP YEAR + +9 + +10 + +11 + +12 + +/ + +Grand Jury #07-103 (TUES-WPB) + +West Palm Beach, Florida + +13 + +Tuesday, May 15, 2007 + +14 + +15 TESTIMONY + +16 OF + +17 + +18 + +19 + +20 + +21 APPEARANCE: + +22 ASSISTANT U. S. ATTORNEY + +23 + +FOREPERSON + +P + +24 + +25 + +1 PROCEEDINGS + +2 \_ \_ - + +3 The sworn testimony of was taken + +4 before the Federal Grand Jury, West Palm Beach Division, + +5 701 Clematis Street, West Palm Beach, Palm Beach County, + +6 State of Florida, on the 15th day of May, 2007. + +7 , Registered Merit Reporter and Notary + +8 Public was authorized to and did report the sworn + +9 testimony. + +10 Thereupon, + +11 + +12 a witness of lawful age, having been first duly sworn by + +13 the foreperson, testified on her oath as follows: + +14 BY + +15 Q Good morning, Special Agent. Could you state + +16 and spell your name for the record. + +17 A Special Agent + +18 + +19 Q And with whom do you work? + +20 A The FBI here in west Palm Beach. + +21 Q And are you here today on the continuing + +22 investigation known as Operation Leap Year? + +23 A Yes, I am. + +24 Q And you are one of the case agents on this + +25 investigation, correct? + +1 A Yes, I am. + +2 Q The last time you were here we were discussing + +3 the evidence supporting various overt acts and charges + +4 related to Jane Does number 1 and 2? + +5 A Yes. + +6 Q Today we are going to start with Jane Doe + +7 number 3. can you tell the Grand Jury who that is and + +8 summarize briefly your previous testimony about her. + +9 A Jane Doe number 3 is vanessailland she first + +10 started, we have first phone contact with + +11 starting in December of 2004, would have been 16 + +12 or 17 at that time, let me do the math real quick, she + +13 would have been 16 -- sorry, I am sorry, she would have + +14 been at that time 17, let's get it right, so she started + +15 phone contact, started calling her in + +16 September of 2004. + +17 From testimony we know that went there + +18 earlier, much earlier. which was Jane Doe + +19 number 4 you will hear about next, they were good + +20 friends and they both went in the spring of '04, prior + +21 to 17th birthday, so did start giving + +22 M . Epstein massages when she was 16, she performed a + +23 few massages for Mr. Epstein and then took kind of a + +24 little bit of a break. + +25 The sexual activity that occurred with + +1 Mr. Epstein when was under the age of 18 + +2 included , the use of a vibrator on + +3 grabbing and fondling of her breasts and her + +4 buttock, she was given gifts by Mr. Epstein, she was + +5 given a vibrator, she was given Victoria Secret + +6 underwear, she was also given a car that Mr. Epstein + +7 rented for her for a number of months, she was paid S200 + +8 by Mr. Epstein and was the one that primarily + +9 set up appointments and as you can see + +10 that began in December of '04. + +11 was also one of Mr. Epstein's + +12 favorites, according to several of the other girls. + +13 Q Just so the Grand Jury has an idea, how does + +14 that translate into the number of phone calls between + +15 and that you were able to calculate? + +16 A called her, I guess calls between + +17 the two of them ranged around 125 phone calls from + +18 December 6th, 2004 until October, 2005. + +19 Q And just briefly can you remind the Grand Jury + +20 did\_ever tell Mr. Epstein her age? + +21 A No, they did not ever discuss, she did not + +22 tell him how old she was, but she did tell him where she + +23 planned on going to school and that she was in soccer. + +24 She stated that when it came to her age that + +25 Mr. Epstein didn't care. As I mentioned earlier, + +1 and were very good friends and would talk + +2 about and Mr. Epstein would ask questions about + +3 when was providing massages and as we will + +4 talk about when we talk about Jane Doe number 4, which + +5 is she told Mr. Epstein that she was a junior in + +6 high school and that and her were in the same + +7 classes together and that they were very good friends + +8 and told us that at one point had come to + +9 her because she had slipped about prom and she was + +10 worried because Epstein was supposed to think she was 18 + +11 and she had talked about the prom and said she + +12 never heard anything else about it and they never + +13 brought it up. + +14 Q Because, according to Mr. Epstein + +15 didn't care really how old the girls were? + +16 A Exactly. + +17 Q And she never mentioned he asked her for her + +18 age or asked for any form of identification to show + +19 whether she was or was not over 18? + +20 A No. + +21 Q Now, if you could turn to the proposed + +22 indictment and if I could ask you to look at overt act + +23 number 59. + +24 A we had a little knock at the door. Do you + +25 want me to get it? + +2 + +3 + +4 + +Q + +A + +number 4, + +Yes. + +(Thereupon, there was a brief pause.) + +I will let you see a picture of Jane Doe + +who we were talking about earlier, and + +S this is Is there anyplace you want to put it + +6 right down here in front? + +7 Q And just so the record is clear, those are the + +8 photographs that we showed to the Grand Jury last week? + +9 A Yes, it is. + +10 Q So if you could turn to overt act number 59 + +11 which appears on page 12, and if you could explain to + +12 the Grand Jury the evidence we have related to that + +13 phone call or phone calls on December 6th, 2004. + +14 A On December 6th, 2004 a review of the phone + +15 records indicate that there was telephonic phone contact + +16 between the numbers belonging to and + +17 as well as we have evidence with + +18 statements of the phone calls being made to + +19 her by + +20 Q And overt act number 60? + +21 A A review of the phone records indicate + +22 telephonic contact between the numbers belonging to + +23 and on December 12, 2004. + +24 Q And overt act number 64? + +25 A A review of the phone records indicate + +1 telephonic contact between numbers belonging to + +2 and on December 14th, 2004. + +3 Q And just so that it is clear to the Grand + +4 Jury, when the overt acts says that defendant + +5 made one or more telephone calls, that means that the + +6 call is originating from phone, is that + +7 correct? + +8 A Yes, it does. + +9 Q And if you could turn to overt act number 71. + +10 A On December 20th a review of the phone records + +11 indicate that there was telephonic contact between + +12 and + +13 Q And overt act number 79? + +14 A On January 6th, 2005 a review of phone records + +15 indicate there was telephone contact between numbers + +16 belonging to and + +17 Q And number 83? + +18 A on January 14th, 2005 a review of the phone + +19 records indicate telephonic contact between numbers + +20 belonging to and + +21 Q And with respect to the other overt acts + +22 related to the phone calls which would be 94, 100, 102, + +23 104, 112, 118, 125, 129 and 132 is the evidence the + +24 same? + +25 A Yes, on or about each of those dates a review + +1 of the phone records indicated telephonic contact + +2 between the numbers belonging to and + +3 as well as-statements. + +4 Q Now, if I could direct your attention to Count + +5 number 7 which appears on page 26 of the draft + +6 indictment, that is a charge of indictment of a minor + +7 during the period of December 6th, 2004 through June 2nd + +8 of 2005, could you summarize for the Grand Jury the + +9 evidence related to that count. + +10 A on or about these dates the facility of + +11 interstate commerce, the telephone, specifically + +12 and , were utilized to set up + +13 appointments, massage appointments for Epstein. + +14 During the massages and on more than one + +15 occasion Epstein , he + +16 used a massager directly on and Epstein + +17 directed IIIIIIIIF o straddle him while he masturbated + +18 and rubbed his penis between her legs, he would + +19 masturbate, he would reach through her legs as she was + +20 straddling him, there was no penetration of his penis in + +21 , though. + +22 He touched breasts, he would + +23 masturbate. He pai n multiple occasions \$200. + +24 Both and Jeffrey Epstein have escorted + +25 upstairs for these massages and Mr. Epstein gave + +1 a vibrator, victoria secret bra and panty sets + +2 and he also rented her a car for several months. + +3 Q And just so that it is clear, you mentioned he + +4 paid her on several occasions, he paid her every time + +5 she performed these lewd acts, correct? + +6 A Yes, \$200. + +7 Q And is listed as a defendant with + +8 respect to Jane Doe number 3 as well, and can you + +9 explain to the Grand Jury a little bit more about who + +10 is and why she is charged in this count? + +11 A is one of mr. Epstein's personal + +12 assistants as well and she made appointments for him for + +13 these massages. + +14 we have contact between phone + +15 and phone, she contacted approximately + +16 25 times. + +17 Q And that's why she is also charged with + +18 someone who is either an aider or abetter or a + +19 coconspirator with respect to this? + +20 A Yes. + +21 Q okay. If I could direct your attention to + +22 Count number 32 which appears on page 30, Count number + +23 32. + +24 A I got 32. + +25 Q what is the evidence related to? + +1 A I am sorry, I didn't hear you ask me the + +2 question, I thought you said refer to it. + +3 The evidence is we have flight records that + +4 indicate on December 13th, 2004 Epstein traveled to Palm + +5 Beach County on the Gulfstream, there was telephonic + +6 contact between and the day + +7 before or the day of travel, we also have the sexual + +8 conduct between Jeffrey Epstein and as we + +9 described earlier in Count 7. + +10 Q And just to refresh the recollection of the + +11 Grand Jury, the Gulfstream aircraft is the one owned by + +12 Hyperion? + +13 A Air, Inc. + +14 Q And when you said that there was telephone + +15 contact, you recall that in overt act number 60 that we + +16 discussed phone calls on December 12th, correct? + +17 A we did. + +18 Q Okay. If I could direct you to Count number + +19 35 and if you could tell the Grand Jury about the + +20 evidence according to that count. + +21 A Again, we have flight records that indicate + +22 that on January 6th, 2005 Epstein traveled to Palm Beach + +23 County on the Gulfstream again, there was telephonic + +24 contact between and the day before, + +25 the day of that travel, we also talked about the sexual + +1 conduct between Jeffrey and between Epstein and + +2 + +3 Q And can you tell us again what aircraft they + +4 flew on on January 6th? + +5 A That was the Gulfstream which was owned by + +6 Hyperion Air, Inc. + +7 Q Okay. If I could direct you to Count 36 and + +8 again if you could summarize that evidence. + +9 A we have flight records that indicate that on + +10 January 14th, 2005 Epstein, and traveled to + +11 Palm Beach County on the Boeing 727 that Mr. Epstein + +12 owns, there was telephonic contact between + +13 and the day before, the day of that + +14 travel, as well as we have the sexual conduct between + +15 Jeffrey Epstein and as we described + +16 earlier, and I will tell you that is -- + +17 Mr. Epstein's personal assistant, and is + +18 we talked about just a few minutes ago, + +19 Mr. Epstein, another of Mr. Epstein's personal + +20 assistants. + +21 Q And if I could direct your attention to Count + +22 37 and ask you to summarize the evidence related to that + +23 count. + +24 A we have flight records that indicate that on + +25 February 3rd, 2005 M . Epstein and traveled + +1 to Palm Beach County on the Boeing 727, there was + +2 telephonic contact between and + +3 he day before or the day of travel and we have + +4 the sexual conduct between Epstein and + +5 Q And if I could direct your attention to Count + +6 number 38. + +7 A In Count number 38 we have flight records that + +8 indicate on February 10th, 2005 Mr. Epstein, + +9 and traveled to + +10 Palm Beach County on the Gulfstream, there was telephone + +11 contact between and the day + +12 before or the day of travel, we also have the sexual + +13 conduct between Mr. Epstein and + +14 Q Now, I am sorry, on Count number 38, which + +15 airline were they on? + +16 A They were on the Gulfstream. + +17 Q Can I ask you to double-check that? There is + +18 an inconsistency between the chart and the indictment or + +19 we can save that for a later date. + +20 A It is right here. + +21 Q 1 will mark that we need to check on Count + +22 number 38. + +23 A I have the flight manifest with me if you want + +24 me to check, I don't know if you want me to do that now. + +25 Q Yes, if you don't mind. + +1 (Thereupon, there was a brief pause.) + +2 A In Count 38, flight records indicate on + +3 February 10th, 2005 that Mr. Epstein, + +4 and were in fact on the + +5 Boeing 727. + +6 Q So the draft indictment contains the correct + +7 information? + +8 A Yes, it does. + +9 Q What company owns the Boeing 727? + +10 A JEGE, Inc., Incorporated. + +11 Q And if I could take you to Count number 39. + +12 A Evidence shows through flight records that on + +13 February 21st, 2005 Epstein, + +14 and traveled to Palm Beach County on + +15 the Boeing 727, there was telephonic contact between + +16 and the day before or the day + +17 of travel, there was also the sexual conduct between + +18 Epstein and IME + +19 Q And if I could take you to Count number 40, + +20 please. + +21 A we have flight records that indicate on + +22 February 24th, 2005 Epstein, + +23 traveled to Palm Beach County on the Boeing + +24 727, there was telephonic contact between + +25 and the day before, the day of travel, and + +1 there was sexual conduct between Jeffrey Epstein and + +2 as we described earlier in Count 7. + +3 Q And if you could do Count 42. + +4 A we have evidence that shows flight records, + +5 that flight records indicate that on march 18th, 2005 + +6 Epstein traveled to Palm Beach County on the Boeing 727, + +7 there was telephonic contact between and + +8 the day of or the day before travel, we + +9 have the sexual conduct between Mr. Epstein and + +10 Q And just referring to that count, + +11 is named, although she was not on the flight that day, + +12 is that correct? + +13 A Yes. + +14 Q And you said that she made the telephone calls + +15 with correct? + +16 A Yes, and we also do have -- we have + +17 interviewed Mr. Epstein's pilots and one of the pilots + +18 indicated that was the one that arranged all of + +19 Mr. Epstein's travel arrangements and so she is + +20 responsible for making his arrangements to travel to + +21 Palm Beach as well as call the girls for the + +22 appointments. + +23 Q If I could take you to Count number 43, + +24 please. + +25 A Flight records indicate that on march 31st, + +1 2005 Mr. Epstein traveled to Palm Beach County on the + +2 Boeing 727, there was telephonic contact between + +3 and the day before or the day of travel, + +4 we also have the sexual conduct between Epstein as + +S Vanessa described earlier in Count 7. + +6 Q Again, in Count 44, what is the evidence + +7 related to that? + +8 A Flight records indicate that on April 8th, + +9 2005 Epstein and traveled to Palm Beach + +10 County on the Gulfstream and there was telephonic + +11 contact between and zylus on the + +12 day before or the day of travel, we also have the sexual + +13 conduct between Mr. Epstein and + +14 Q And if you could go through 45, 46 and 47. + +15 A Count 45 we have flight records that indicate + +16 on April 27th, 2005 Epstein and traveled to + +17 Palm Beach County on the Gulfstream, there is telephone + +18 contact between and the day + +19 before or the day of travel and we have the sexual + +20 conduct between Jeffrey and . + +21 In Count 46 we have flight records that + +22 indicate that on may 6th, 2005 Epstein, and + +23 traveled to Palm Beach County on the + +24 Gulfstream. + +25 we have also telephonic contact between + +1 and either the day before or the + +2 day of travel and we have the sexual conduct between + +3 Epstein and , and in Count 47 on may 19th, 2005 + +4 we have flight records that indicate Epstein, + +5 and traveled to Palm Beach County on + +6 the Gulfstream and we have telephone contact between + +7 and the day before or the day + +8 of travel. + +9 we also have the sexual conduct between + +10 Epstein and as described in the earlier + +11 count, count 7. + +12 Q Now, if I could direct your attention to count + +13 number 51 which appears on page 33, that is the sex + +14 trafficking of a minor involving Jane Doe number 3, and + +15 could you briefly summarize that, the evidence related + +16 to that. + +17 A As we discussed earlier in count 7, I told you + +18 uys about the sexual conduct between Epstein and + +19 the monies that were paid to by + +20 Mr. Epstein, the hone activit we discussed between + +21 and it began in December, + +22 and we also have phone calls beginning in January from + +23 to at that time was 17 + +24 years of age, and we also have statements from + +25 and regarding Mr. Epstein's knowledge of their + +1 ages. + +2 Q And with respect to the affect on interstate + +3 commerce related to that count we have both the + +4 telephone calls, correct? + +S A Yes. + +6 Q As well as Mr. Epstein actually traveling in + +7 interstate commerce to engage in this activity, correct? + +8 A Yes, we do. + +9 Q is there anything else that you would like to + +10 mention about Jane Doe number 3? + +11 A NOt at this time, no. + +12 Q If I could direct you to Jane Doe number 4 and + +13 if you could summarize for the Grand Jury the + +14 information related to Jane Doe number 4's activities. + +15 A Jane Doe number 4 is , I think you + +16 wanted their birth dates, her birth date is + +17 she was 16 years old and attended + +18 High School. + +19 + +20 + +21 indicates and shows that was clearly 16 years of + +22 age when she started going to Mr. Epstein's + +23 performing massages for Mr. Epstein. + +24 ur Jane Doe number 1, was the one + +25 who recruited she basically told that she + +we first have contact through phone calls from + +to on April 25th, 2004 which + +and + +1 could make \$200, she needed to dress cute, he might try + +2 to touch you, but if you feel uncomfortable just let him + +3 know and he will stop, and the first massage that + +4 did he repeatedly told , and I mentioned this to + +5 you in the last Grand Jury session, she was very shy and + +6 he would repeatedly tell her not to be so shy, that she + +7 didn't have to be so shy. + +8 Epstein asked her to remove her clothing and + +9 she told him no, and throughout the massage he would + +10 + +11 + +12 + +13 + +14 + +15 + +repeatedly grab at + +masturbate through + +clothes, she would + +that. + +upon leaving + +told that if + +her, + +this + +pull + +the + +he grabbed her butt, he did + +first massage and pulled her + +away and she was paid \$200 for + +first massage Mr. Epstein + +was willing to do more she + +16 would get paid more. He also informed that if she + +17 would bring her pretty friends he would also pay her for + +18 bringing her pretty friends. He told that + +19 would get her phone number. + +20 says that she performed three to four + +21 massages for Mr. Epstein. we have with + +22 approximately a hundred phone calls between + +23 and + +24 when i interviewed she became very upset + +25 when we got to the sexual massages that she did for + +1 Mr. Epstein. At this point, this is as much as we know + +2 at this point of what occurred with Mr. Epstein and + +3 + +4 she did three to four massages and those last + +5 massages they became more sexual in nature, he asked her + +6 again to remove her clothing, this time she took her + +7 shirt off, he asked her to take her bra off, she said + +8 no. + +9 He again would touch her breasts, he would + +10 touch her butt, he did continue to masturbate, this time + +11 she believes he ejaculated. He continued to compliment + +12 her, tell her she had a nice body and that she was + +13 pretty. + +14 says that he was very nice and engaged + +15 her in conversation, asked her, you know, if she had a + +16 boyfriend. In the last massage she discusses with me, + +17 and this massage Mr. Epstein told her to stop being shy + +18 and asked her to take her clothes off and said + +19 that she had a boyfriend and she didn't feel comfortable + +20 taking her clothes off and he told her you should know + +21 what to expect by now when you come here, and he jerked + +22 on her pants as to like jerk them down, so she did on + +23 this last massage get down to her bra and underwear. + +24 She describes his tone at this time being + +25 frustrated and irritated, she stayed in her bra and + +1 underwear, but during the massage he grabbed her bra and + +2 pulled it down and fondled her breasts, he had + +3 instructed her to pinch his chest, his nipples while she + +4 was massaging his chest, he tried to grab her all over, + +5 he knew that she was upset with this massage. + +6 At one point mr. Epstein asked her if she had + +7 sex with her boyfriend, informs him that she is + +8 still a virgin and he responds what, you don't like sex? + +9 And that's pretty much the way that last massage went. + +10 Q NOW, Special Agent just to + +11 interrupt you, you mentioned that Jane Doe number 4 + +12 became very upset as you were asking her about the + +13 massages, correct? + +14 A Yes. + +15 Q And when she was describing this incident with + +16 him grabbing at her breast and trying to pull her pants + +17 down and instructing her to remove her pants, correct? + +18 A ves. + +19 Q You had talked last week about the expert that + +20 you had spoken with about interviewing victims of these + +21 types of offenses? + +22 A Right. + +23 Q And you had told us about how a victim may be + +24 reticent at first to tell the entire story until a + +25 rapport is built? + +1 A Right. + +2 Q Can you tell the Grand Jury your impressions + +3 of your interview with + +4 A she became so visibly upset, and a lot of the + +5 girls are embarrassed of what took place, but when she + +6 talked about the last massage and him grabbing her + +7 breasts and fondling her breasts she was in tears and we + +8 stopped the massage and we calmed her down, trying to go + +9 back there was just too difficult, I could not get her + +10 back to discussing anything further that had taken + +11 place. + +12 I have since then -- I have since talked to + +13 again and I feel there is more there, but I just + +14 don't think she is ready to disclose what took place. + +15 Q So based upon the more than 60 telephone calls + +16 as well as -- + +17 A Approximately a hundred. + +18 Q -- 100 telephone calls and your conversations + +19 with you think there is probably more than four + +20 massages that happened? + +21 A Yes, I do. + +22 Q was there anything else that you wanted to + +23 discuss with the Grand Jury? + +24 A Just, as I stated in the beginning of those + +25 massages, they engaged in conversation and throughout + +1 that conversation, you know, she did inform Mr. Epstein + +2 that she was a junior in high school and again she is + +3 one of the girls that talks about being Mr. + +4 Epstein's favorite, so because Mr. Epstein knew they + +5 were friends they would engage in conversation about + +6 IIIIIIII, and would mention they were in the same + +7 classes at school and they would discuss the friendship + +8 they had between the two girls with Mr. Epstein and I + +9 think that's it. + +10 Q All right. If we could turn to the + +11 post-indictment to overt act number 4 which appears on + +12 page number 5. + +13 Did you obtain telephone records for Jane Doe + +14 number 4? + +15 A Yes. + +16 Q And did you compare those with the phone + +17 records of and others? + +18 A Yes, I did. + +19 Q And can you tell us with respect to overt act + +20 number 4 what evidence you have related to that? + +21 A A review of the phone records indicate that + +22 there was telephonic contact between the numbers + +23 belonging to and as well as + +24 statements that would call her to make + +25 appointments. + +1 Q And if we could go through overt acts 6, 8, 9 + +2 and 11, all of which appear on page 6. + +3 A A review of the phone records on May 3rd, + +4 2004, may 14th, 2004, may 20th, 2004 and June 3rd, 2004, + +5 a review of those phone records indicate that there was + +6 telephonic contact between numbers belonging to + +7 and as well as statements. + +8 Q If I could take you to overt acts 14, 15 and + +9 19 which appear on page 7. + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +A A review of the phone records on June 11th, + +2004, June 20th, 2004 and July 10th, 2004, they indicate + +that there is telephonic contact between the numbers + +belonging to and + +Q And if I could ask you to turn to page 8 and + +if you could address overt acts 24 and 25. + +A A review of the phone records on July 18th, + +2004 and July 22nd, 2004, a review of and + +hone records indicate there is + +telephonic contact belonging to both of them as well as + +tatements that would arrange + +appointments with her. + +Q If I could take you to page 9 of the draft + +proposed indictment and ask about overt acts 29 and 30. + +A A review of the phone records indicate there + +is telephonic contact on July 22nd, 2004 and August 4th, + +1 2004 between numbers belonging to and + +2 as well as statements. + +3 Q If I could take you to page 10 of the draft + +4 proposed indictment and ask you about overt acts 37 and + +5 43. + +7 + +A A review of phone records indicate telephonic + +contact on August 25th, 2004 and October 3rd, 2004 + +8 between numbers belonging to and + +9 + +10 Q And if you could turn to page 11 of the draft + +11 proposed indictment and if you would address overt acts + +12 47 and 48. + +13 A A review of the phone records indicate + +14 telephonic contact on October 30th, 2004 and November + +15 4th, 2004 between numbers belonging to and + +16 , as well statements. + +17 Q Okay. And if you could go to page 14 of the + +18 draft proposed indictment and address overt act number + +19 77. + +20 A A review of phone records indicate that on + +21 January 4th, 200 elephonic contact between + +22 and as well as + +23 statements. + +24 Q I'm sorry. If you could turn to page 16 of + +25 the draft proposed indictment and address overt act + +1 number 87. + +2 A A review of the phone records indicate that on + +3 January 22, 2005 there is telephonic phone contact + +4 between numbers belonging to and and + +5 I believe I said on January 22nd, 2005. + +6 Q Okay. And if you could go to page 17 and + +7 address overt act number 101. + +8 A On February 14th, 2005 a review of the phone + +9 records indicate that there was telephonic contact on + +10 that day between numbers belonging to and + +11 as well as statements. + +12 Q If you could turn to pages 18 and 19 and if + +13 you would address overt acts 106, 114 and 116. + +14 A A review of the phone records indicate that + +15 there is telephonic contact between and + +16 on February 24th, 2005 as well as + +17 statements. + +18 Q Overt act number 114 says on March 18th, 2005 + +19 defendant prepared a written message to defendant + +20 Epstein regarding Jane Doe number 4, could you tell the + +21 Grand Jury what the evidence is related to that? + +22 A we have a review of the message pads that were + +23 recovered during the search warrant that the State + +24 served that showed that wrote a message to + +25 Epstein regarding and that was done on March 18th, + +1 2005. + +2 + +3 said? + +4 + +5 + +6 + +7 + +8 + +9 + +10 reads is it okay if + +11 a question mark. + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q Do you happen to remember what the message + +A I have those with me. + +Q would you mind getting them out? + +A Do you want to mark it? + +Q If you could just read it to the Grand Jury. + +A It is a message written by for Jeffrey + +on 3/18/2005, it looks like 4:21 p.m., and the message + +will come at 5:00 and there is + +Q And if I could direct you to overt act number + +116, what the evidence is related to that. + +A A review of the phone records on march 29th, + +2005 indicate that there is telephonic contact between + +and as well as her -- + +statements. + +Q And if I could take you to overt act number + +127 which is on page 20. + +A A review of phone records on April 11th, 2005 + +indicate that there is telephonic phone contact between + +the numbers belonging to and as well + +as statements. + +Q Now, if you could go to Count number 8, which + +alleges that between April 25th, 2004 and June 29th, + +1 + +2 + +3 + +4 + +2005 Jeffrey Epstein, + +Jane Doe number 4 to engage in + +prostitution. + +A On or about these dates + +enticed + +or + +facility of + +sexual activity + +we have a + +5 interstate commerce, specifically the telephones, + +6 and which were utilized to + +7 + +8 + +set up, arrange massage + +have taking + +appointments for Epstein, we + +upstairs to set up the + +9 massage table, she would set the massage table up as + +10 well as set up the lotions and the oils, we have during + +11 those massages Epstein would grab and pull closer + +12 to him as he masturbated, he repeatedly would ask her to + +13 + +14 + +remove her clothing, wearing her bra and underwear, + +Epstein would pull down her bra and grabbed at her + +15 + +16 + +17 + +18 + +19 + +breast, he attempted to touch he at one point + +but she stopped him, he masturbated, she believes that + +he ejaculated, he paid her \$200, he told her that he + +would pay her to bring her pretty friends and would pay + +her more if she would do more. + +20 Q And just so that this is clear to the Grand + +21 Jury, June 29th of 2005 is the day before Jane Doe + +22 + +23 + +24 + +25 + +number 4 turned 18, is that correct? + +A Yes. + +Q So was there activity that continued past her + +18th birthday? + +1 A Yes. + +2 Q If I could direct you to Count number 17, + +3 which appears on page 28, and tell us about the evidence + +4 related to that. + +5 A we have evidence through flight records that + +6 indicate on May 21st, 2004 that Epstein and + +7 traveled to Palm Beach County on the + +8 Gulfstream, we have telephonic contact between and + +9 the day before or the day of travel and we + +10 have the sexual conduct between Epstein and as we + +11 described earlier in Count 8. + +12 Q And if you could go through Counts 18 and 19. + +13 A we have flight records that indicate on June + +14 4th, 2004 Epstein and traveled to Palm + +15 Beach County on the Gulfstream, we have telephone + +16 contact between and the day before, + +17 the day of travel, we have sexual conduct between + +18 Mr. Epstein and as discussed earlier. + +19 we have also Count 19 on June 20th, 2004 we + +20 have flight records that indicate that Epstein and + +21 traveled to Palm Beach County on the Boeing + +22 727. + +23 we have the telephone contacts between + +24 and i the day before, the day of travel, we + +25 also have the sexual conduct between Jeffrey and + +1 + +2 + +3 + +as we described earlier in Count 8. + +Q Could you do the same for Counts 22 and 23, + +please. + +4 A Count 22 we have flight records that indicate + +5 on July 22nd, 2004 Epstein, + +6 traveled to Palm Beach County on the Boeing + +7 727, we have the telephonic phone contact between + +8 and the day before or the day of travel, we + +9 also have the sexual conduct between Jeffrey Epstein and + +10 as we described earlier, and Count 23 we have + +11 flight records that indicate on August 6th, 2004 Epstein + +12 and traveled to Palm Beach County on the + +13 Boeing 727, we have telephonic contact between + +14 and two days prior to Epstein and + +15 traveling to Palm Beach County, we have sexual + +16 conduct between Jeffrey Epstein and i as we + +17 described earlier. + +18 Q And if you could do the same for Count number + +19 28, please. + +20 A Count number 28 we have flight records that + +21 indicate on November 5th, 2004 Epstein, + +22 traveled to Palm Beach County on the + +23 Gulfstream, we have telephonic contact between + +24 and the day before or the day of travel, + +25 we have the sexual conduct between Epstein and + +1 Q And if I could direct you to Count number 35, + +2 you testified previously about the people who were + +3 aboard the plane. + +4 was there also telephone contact on January + +5 6th -- excuse me, shortly before the flight on January + +6 6th, 2005 between and this Jane Doe? + +7 A ves, two days before. + +8 Q And if you look at Count number 40, again, you + +9 had previously told us about who was on board the plane. + +10 Can you tell us whether there was also telephone contact + +11 shortly before that? + +12 A There was telephone contact the day of or the + +13 day before. + +14 Q All right. Between who and who? + +15 A Between and . + +16 Q Okay. And if you could look at Count 43, you + +17 also had testified previously about who was aboard the + +18 plane on that day. + +19 was there also telephone contact between Jane + +20 Doe number 4 -- excuse me, Jane Doe number 4 and + +21 ? + +22 A Yes, two days before. + +23 Q And if I could direct you to Count number 52, + +24 which is the sex trafficking offense, and if you could + +25 summarize again for the Grand Jury the evidence related + +1 to that. + +2 A we discussed in Count 8 the sexual conduct + +3 that occurred between and Epstein during the + +4 massages that took place, we talked about the money that + +5 was paid to her by Mr. Epstein and the offer of more + +6 money if she would do more as well as if she would bring + +7 her friends. + +8 Through statements we have also that + +9 has paid her in the past for bringing a + +10 friend, we have the phone activity between + +11 and which started in April, 2004, we know + +12 was 16 at the time, we also have phone activity between + +13 and beginning in the spring of 2005 + +14 when would be 17, with the statements of and + +15 the knowledge that Mr. Epstein knew their age, + +16 and we have gone through that regarding informing + +17 M . Epstein that she was a junior in high school , that + +18 she was classmates with and then + +19 statements that was concerned because she was + +20 discussing prom with Mr. Epstein, and both girls at that + +21 time of the phone calls were under the age of 18. + +22 Q Just again so it is clear for the Grand Jury, + +23 neither ever specifically said hey, + +24 Jeffrey, I am 17, but they provided information that + +25 should have caused him to try to figure out whether in + +1 fact they were adults? + +2 A Yes. + +3 Q Any questions about Jane Doe number 4 before + +4 we turn to Jane Doe number 5? YeS, ma'am. + +5 A GRAND JUROR: I have to say something here, + +6 if it is a stupid question forgive me if it is, + +7 from what I heard, maybe I heard wrong, there were + +8 three to four massages that Jane Doe, or + +9 + +10 a few sexual contact. + +11 How do you know about this, do you have + +12 records, how do you know they were sexual contact? + +13 THE WITNESS: Through interviewing + +14 A GRAND JUROR: She said she only had three to + +15 four massages. + +16 A GRAND JUROR: Her question is more like + +17 there is 20 phone calls. + +18 A GRAND JUROR: There is tons of them. + +19 THE WITNESS: Exactly, that is what we were + +20 discussing earlier when we discussed that there is + +21 more than what is willing to admit at this + +22 time. + +23 A GRAND JUROR: I got it. So she said she + +24 only had three to four. + +25 A GRAND JUROR: There is a hundred phone + +said that she had and you enumerated quite + +1 calls. + +2 A GRAND JUROR: You said you found out through + +3 ■, **I am a little bit confused about that.** + +**4 THE WITNESS: Through interviewing she** + +**5 stated that she had three or four massages from** + +**6 Mr. Epstein.** + +**7 BY** + +**8 Q Special Agent the sexual activity** + +**9 that you described that went through, that is what** + +**10 she said happened during those three to four massages,** + +**11 correct?** + +**12 A Right.** + +**13 Q Does that answer your question?** + +**14 A GRAND JUROR: Not really. How do we know** + +**15 like about all these 25, 30?** + +**16 A GRAND JUROR: There is more dates that match** + +**17 up with the amount of massages.** + +**18 A GRAND JUROR: There were a hundred phone** + +**19 calls.** + +**20 A GRAND JUROR: Are we supposed to assume a** + +**21 phone call was made each time they had sexual** + +**22 contact?** + +**23 THE WITNESS: No. There are lots of phone** + +**24 calls made arranging appointments between the** + +**25 girls, that doesn't mean that every phone call that** + +1 was made was a trip over to Mr. Epstein's house to + +2 perform a massage. + +3 Yes, ma'am. + +4 A GRAND JUROR: Couldn't they put anything in + +5 this indictment about stalking her, are there any + +6 rules against stalking children? + +7 : I will address -- that is a + +8 legal question that I will address when the Special + +9 Agent is outside of the Grand Jury. Any other + +10 factual questions related? + +11 A GRAND JUROR: I don't have a question + +12 relating to Jane Doe number 4, it was a question I + +13 asked last week, what does Mr. Epstein do for work, + +14 how does he make his money? I asked that late, + +15 late in the game last week. + +16 MS. VILLAFANA: Okay, I guess we can just + +17 address that now. + +18 BY + +19 Q what is Mr. Epstein's state of profession? + +20 A He is an investor. + +21 Q And he manages portfolios valued at about a + +22 billion or more? + +23 A Yes. + +24 Q who is his best known client? + +25 A The owner of the Limited and Victoria Secret. + +1 + +2 + +3 + +4 + +Q And you mentioned that as gifts Mr. Epstein + +tended to give victoria Secrets panties and bra sets? + +A Yes. + +Q Does that answer the question? + +S A GRAND JUROR: Yes. + +6 Yes, ma'am. + +7 A GRAND JUROR: Count 28 I thought I heard + +8 that -- I thought I heard the detective say that it + +9 was the Gulfstream rather than the Boeing 727 on + +10 flight records, just for your info. + +11 Count number 28, let's go back + +12 there. + +13 B1 + +14 Q Could you restate for the Grand Jury which + +15 company owns the Gulfstream? + +16 A The Gulfstream is owned by Hyperion Air, Inc. + +17 Q And the Boeing is owned by whom? + +18 A JEGE, Inc. + +19 Q Any other questions before we go on to Jane + +20 Doe number 5? We have four minutes. + +21 Special Agent why don't I ask you + +22 to step outside so I can answer that question for the + +23 Grand Jury and address some issues. + +24 (The witness was excused from the Grand Jury + +25 room.) + +1 (Questions posed by the Grand Jury.) + +2 (The testimony of the witness was concluded + +3 before the Grand Jury.) + +5 I certify pages 2 through 36 are a true transcript of my + +6 shorthand notes of the testimony of + +7 efore the Federal Grand Jury, West Palm + +8 Beach, Florida on the 15th day of Tuesday, 2007. + +CERTIFICATE OF REPORTER + +Commission + +Expires May 8, 2008 + +1 UNITED STATES DISTRICT COURT + +2 + +SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH + +3 + +4 + +5 + +6 + +7 + +8 IN RE: OPERATION LEAP YEAR + +9 + +10 / + +11 + +Grand Jury #07-103 (TUES-WPB) + +12 West Palm Beach, Florida + +Tuesday, May 15, 2007 + +13 + +14 + +15 TESTIMONY + +16 OF + +17 + +18 + +19 + +20 + +21 APPEARANCE: + +22 + +23 + +24 + +25 + +1 + +2 + +3 + +4 + +S + +7 + +8 + +9 testimony. + +10 Thereupon, + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +PROCEEDINGS + +The sworn testimony of was taken + +before the Federal Grand Jury, West Palm Beach Division, + +701 Clematis Street, West Palm Beach, Palm Beach County, + +State of Florida, on the 15th day of May, 2007. + +, Registered merit Reporter and Notary + +Public was authorized to and did report the sworn + +a witness of lawful age, having been first duly sworn by + +the foreperson, testified on her oath as follows: + +BY MS. VILLAFANA: + +Q Good morning, Special Agent. Could you state + +and spell your name for the record. + +A Special Agent + +Q And with whom do you work? + +A The FBI here in west Palm Beach. + +Q And are you here today on the continuing + +investigation known as Operation Leap Year? + +A Yes, I am. + +Q And you are one of the case agents on this + +investigation, correct? + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +A Yes, I am. + +Q The last time you were here we were discussing + +the evidence supporting various overt acts and charges + +related to Jane Does number 1 and 2? + +A Yes. + +Q Today we are going to + +number 3. Can you tell the Grand Jury who + +summarize + +A Jane Doe number 3 is + +briefly your previous testimony about + +start with Jane Doe + +that is and + +her. + +and she first + +10 + +11 + +started, we have first phone contact + +starting in December of 2004, + +with + +would have been 16 + +12 or 17 at that time, let me do the math real quick, she + +13 would have been 16 -- sorry, I am sorry, she would have + +14 been at that time 17, let's get it right, so she started + +15 phone contact, started calling her in + +16 September of 2004. + +17 From testimony we know that went there + +18 earlier, much earlier. which was Jane Doe + +19 number 4 you will hear about next, they were good + +20 friends and they both went in the spring of '04, prior + +21 to 17th birthday, so did start giving + +22 Mr. Epstein massages when she was 16, she performed a + +23 few massages for Mr. Epstein and then took kind of a + +24 little bit of a break. + +25 The sexual activity that occurred with + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +1 Mr. Epstein when + +2 included + +3 grabbing and fondling of her breasts and her + +4 buttock, she was given gifts by Mr. Epstein, she was + +5 given a vibrator, she was given victoria secret + +6 underwear, she was also given a car that Mr. Epstein + +7 rented for her for a number of months, she was paid S200 + +8 by Mr. Epstein and was the one that primarily + +called■ + +**that began** + +**favorites,** + +**was under the age of 18** + +**the use of a vibrator on** + +**to set up appointments and as you can see** + +**in December of '04.** + +**was also one of Mr. Epstein's** + +**according to several of the other girls.** + +**Q Just so the Grand Jury has an idea, how does** + +**that translate into the number of phone calls between** + +**and that you were able to calculate?** + +**A called her, I guess calls between** + +**the two of them ranged around 125 phone calls from** + +**December** + +**did** + +**tell** + +**6th, 2004 until October, 2005.** + +**Q And just briefly can you remind the Grand Jury** + +**Hier tell Mr. Epstein her age?** + +**A No, they did not ever discuss, she did not** + +**him how old she was, but she did tell him where she** + +**planned on going to school and that she was in soccer.** + +**She stated that when it came to her age that** + +**Mr. Epstein didn't care. A5 I mentioned earlier,** + +1 and were very good friends and would talk + +2 about and mr. Epstein would ask questions about + +3 when was providing massages and as we will + +4 talk about when we talk about Jane Doe number 4, which + +5 is she told Mr. Epstein that she was a junior in + +6 high school and that and her were in the same + +7 classes together and that they were very good friends + +8 and told us that at one point had come to + +9 her because she had slipped about prom and she was + +10 + +11 + +12 + +worried because Epstein was supposed to think she was 18 + +and she had talked about the prom an said she + +never heard anything else about it and they never + +13 brought it up. + +14 Q Because, according to , mr. Epstein + +15 didn't care really how old the girls were? + +16 A Exactly. + +17 Q And she never mentioned he asked her for her + +18 age or asked for any form of identification to show + +19 whether she was or was not over 18? + +20 A No. + +21 Q Now, if you could turn to the proposed + +22 indictment and if I could ask you to look at overt act + +23 number 59. + +24 A we had a little knock at the door. Do you + +25 want me to get it? + +1 + +2 + +3 + +4 + +5 + +Q + +A + +number + +this is + +4, + +Yes. + +(Thereupon, + +I will + +there was a brief pause.) + +let you see a picture of Jane Doe + +who we were talking about earlier, and + +Is there anyplace you want to put it + +6 right down here in front? + +7 Q And just so the record is clear, those are the + +8 photographs that we showed to the Grand Jury last week? + +9 A Yes, it is. + +10 Q So if you could turn to overt act number 59 + +11 which appears on page 12, and if you could explain to + +12 the Grand Jury the evidence we have related to that + +13 phone call or phone calls on December 6th, 2004. + +14 A On December 6th, 2004 a review of the phone + +15 records indicate that there was telephonic phone contact + +16 between the numbers belonging to and + +17 as well as we have evidence with + +18 statements of the phone calls being made to + +19 her by + +20 Q And overt act number 60? + +21 A A review of the phone records indicate + +22 telephonic contact between the numbers belonging to + +23 and on December 12, 2004. + +24 Q And overt act number 64? + +25 A A review of the phone records indicate + +1 + +2 + +3 + +4 + +telephonic + +and + +Q + +Jury, when + +contact between numbers belonging to + +on December 14th, 2004. + +it is clear to the Grand + +says that defendant + +And just so that + +the overt acts + +5 made one or more telephone calls, that means that the + +6 + +7 + +call is originating from phone, is that + +correct? + +8 A Yes, it does. + +9 Q And if you could turn to overt act number 71. + +10 A On December 20th a review of the phone records + +11 + +12 + +indicate that there was telephonic contact between + +and + +13 Q And overt act number 79? + +14 A on January 6th, 2005 a review of phone records + +15 indicate there was telephone contact between numbers + +16 belonging to and + +17 Q And number 83? + +18 A On January 14th, 2005 a review of the phone + +19 records indicate telephonic contact between numbers + +20 belonging to and + +21 Q And with respect to the other overt acts + +22 related to the phone calls which would be 94, 100, 102, + +23 + +24 + +104, 112, 118, 125, 129 and 132 is the evidence the + +same? + +25 A Yes, on or about each of those dates a review + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +of the phone records indicated telephonic contact + +between the numbers belonging to and + +as well as statements. + +Q Now, if I could direct your attention to count + +number 7 which appears on page 26 of the draft + +indictment, that is a charge of indictment of a minor + +during the period of December 6th, 2004 through June 2nd + +of 2005, could you summarize for the Grand Jury the + +evidence related to that count. + +10 + +11 + +12 + +A + +interstate + +and + +on or about these + +commerce, the + +dates the facility of + +telephone, specifically + +were utilized to set up + +13 appointments, massage appointments for Epstein. + +14 During the massages and on more than one + +15 occasion Epstein , he + +16 used a massager directly on he and Epstein + +17 directed to straddle him while he masturbated + +18 and rubbed his penis between her legs, he would + +19 masturbate, he would reach through her legs as she was + +20 straddling him, there was no penetration of his penis in + +21 though. + +22 He touched breasts, he would + +23 masturbate. He pai' on multiple occasions \$200. + +24 Both and Jeffrey Epstein have escorted + +25 upstairs for these massages and mr. Epstein gave + +1 + +2 + +3 + +4 + +vibrator, Victoria Secret bra and panty sets + +rented her a car for several months. + +And just so that it is clear, you mentioned he + +on several occasions, he paid her every time + +and he also + +Q + +paid her + +5 she performed these lewd acts, correct? + +6 A Yes, \$200. + +7 Q And is listed as a defendant with + +8 respect to Jane Doe number 3 as well, and can you + +9 explain to the Grand Jury a little bit more about who + +10 is and why she is charged in this count? + +11 A is one of Mr. Epstein's personal + +12 assistants as well and she made appointments for him for + +13 these massages. + +14 we have contact between phone + +15 and phone, she contacted approximately + +16 25 times. + +17 Q And that's why she is also charged with + +18 someone who is either an aider or abetter or a + +19 coconspirator with respect to this? + +20 A Yes. + +21 Q okay. If 1 could direct your attention to + +22 Count number 32 which appears on page 30, Count number + +23 32. + +24 A I got 32. + +25 Q what is the evidence related to? + +1 A I am sorry, I didn't hear you ask me the + +2 question, I thought you said refer to it. + +3 The evidence is we have flight records that + +4 indicate on December 13th, 2004 Epstein traveled to Palm + +5 Beach County on the Gulfstream, there was telephonic + +6 contact between and the day + +7 before or the day of travel, we also have the sexual + +8 conduct between Jeffrey Epstein and as we + +9 described earlier in Count 7. + +10 Q And just to refresh the recollection of the + +11 Grand Jury, the Gulfstream aircraft is the one owned by + +12 Hyperion? + +13 A Air, Inc. + +14 Q And when you said that there was telephone + +15 contact, you recall that in overt act number 60 that we + +16 discussed phone calls on December 12th, correct? + +17 A we did. + +18 Q Okay. If I could direct you to Count number + +19 35 and if you could tell the Grand Jury about the + +20 evidence according to that count. + +21 A Again, we have flight records that indicate + +22 that on January 6th, 2005 Epstein traveled to Palm Beach + +23 County on the Gulfstream again, there was telephonic + +24 contact between and the day before, + +25 the day of that travel, we also talked about the sexual + +1 + +2 + +conduct between Jeffrey and between Epstein and + +3 Q And can you tell us again what aircraft they + +4 flew on on January 6th? + +5 A That was the Gulfstream which was owned by + +6 Hyperion Air, Inc. + +7 Q Okay. If I could direct you to Count 36 and + +8 again if you could summarize that evidence. + +9 A we have flight records that indicate that on + +10 January 14th, 2005 Epstein, and traveled to + +11 Palm Beach County on the Boeing 727 that Mr. Epstein + +12 owns, there was telephonic contact between + +13 one the day before, the day of that + +14 travel, as well as we have the sexual conduct between + +15 Jeffrey Epstein and as we described + +16 earlier, and I will tell you that is -- + +17 , Mr. Epstein's personal assistant, and is + +18 we talked about just a few minutes ago, + +19 Mr. Epstein, another of Mr. Epstein's personal + +20 assistants. + +21 Q And if I could direct your attention to Count + +22 37 and ask you to summarize the evidence related to that + +23 count. + +24 A we have flight records that indicate that on + +25 February 3rd, 2005 Mr. Epstein and traveled + +1 to Palm Beach County on the Boeing 727, there was + +2 telephonic contact between and + +3 the day before or the day of travel and we have + +4 the sexual conduct between Epstein and + +And if I could direct your attention to Count + +6 number 38. + +7 A In Count number 38 we have flight records that + +8 indicate on February 10th, 2005 Mr. Epstein, + +9 and traveled to + +10 Palm Beach County on the Gulfstream, there was telephone + +11 contact between and the day + +12 before or the day of travel, we also have the sexual + +13 conduct between Mr. Epstein and + +14 Q Now, I am sorry, on Count number 38, which + +15 airline were they on? + +16 A They were on the Gulfstream. + +17 Q Can I ask you to double-check that? There is + +18 an inconsistency between the chart and the indictment or + +19 we can save that for a later date. + +20 A It is right here. + +21 Q I will mark that we need to check on count + +22 number 38. + +23 A I have the flight manifest with me if you want + +24 me to check, I don't know if you want me to do that now. + +25 Q Yes, if you don't mind. + +1 + +2 + +3 + +4 + +A + +February + +(Thereupon, there + +In Count 38, + +10th, 2005 that + +and + +was a + +flight records + +mr. Epstein, + +brief pause.) + +indicate on + +, + +were in fact on the + +5 Boeing 727. + +6 Q So the draft indictment contains the correct + +7 information? + +8 A yes, it does. + +9 Q what company owns the Boeing 727? + +10 A JEGE, Inc., Incorporated. + +11 Q And if I could take you to Count number 39. + +12 A Evidence shows through flight records that on + +13 February 21st, 2005 Epstein, + +14 and traveled to Palm Beach County on + +15 the Boeing 727, there was telephonic contact between + +16 and the day before or the day + +17 of travel, there was also the sexual conduct between + +18 Epstein an + +19 Q And if 1 could take you to Count number 40, + +20 please. + +21 A we have flight records that indicate on + +22 February 24th, 2005 Epstein, + +23 traveled to Palm Beach County on the Boeing + +24 727, there was telephonic contact between + +25 and the day before, the day of travel, and + +1 there was sexual conduct between Jeffrey Epstein and + +as we described earlier in count 7. + +And if you could do Count 42. + +we have evidence that shows flight records, + +2 + +3 Q + +4 A + +5 that flight records indicate that on March 18th, 2005 + +6 Epstein traveled to Palm Beach County on the Boeing 727, + +7 there was telephonic contact between and + +8 the day of or the day before travel , we + +9 have the sexual conduct between Mr. Epstein and + +10 And just referring to that count, + +11 is named, although she was not on the flight that day, + +12 is that correct? + +13 A Yes. + +14 Q And you said that she made the telephone calls + +15 with correct? + +16 A Yes, and we also do have -- we have + +17 interviewed Mr. Epstein's pilots and one of the pilots + +18 indicated that was the one that arranged all of + +19 Mr. Epstein's travel arrangements and so she is + +20 responsible for making his arrangements to travel to + +21 Palm Beach as well as call the girls for the + +22 appointments. + +23 Q If I could take you to count number 43, + +24 please. + +25 A Flight records indicate that on March 31st + +1 2005 Mr. Epstein traveled to Palm Beach County on the + +2 Boeing 727, there was telephonic contact between + +3 and the day before or the day of travel, + +4 we also have the sexual conduct between Epstein as + +5 described earlier in Count 7. + +6 Q Again, in Count 44, what is the evidence + +7 related to that? + +8 A Flight records indicate that on April 8th, + +9 2005 Epstein and traveled to Palm Beach + +10 + +11 + +12 + +County on the Gulfstream and there + +contact between and + +day before or the day of travel, + +was telephonic + +on the + +we also have the sexual + +13 conduct between Mr. Epstein and + +14 Q And if you could go through 45, 46 and 47. + +15 A Count 45 we have flight records that indicate + +16 on April 27th, 2005 Epstein and traveled to + +17 Palm Beach County on the Gulfstream, there is telephone + +18 contact between and the day + +19 before or the day of travel and we have the sexual + +20 conduct between Jeffrey and + +21 In Count 46 we have flight records that + +22 indicate that on May 6th, 2005 Epstein, and + +23 traveled to Palm Beach County on the + +24 Gulfstream. + +25 We have also telephonic contact between + +1 and either the day before or the + +2 day of travel and we have the sexual conduct between + +3 Epstein and and in Count 47 on May 19th, 2005 + +4 we have flight records that indicate Epstein, + +S and traveled to Palm Beach County on + +6 + +7 + +8 + +the Gulfstream and + +and + +of travel. + +we have telephone contact between + +the day before or the day + +9 we also have the sexual conduct between + +10 Epstein and as described in the earlier + +11 count, count 7. + +12 Q Now, if I could direct your attention to Count + +13 number 51 which appears on page 33, that is the sex + +14 trafficking of a minor involving Jane Doe number 3, and + +15 could you briefly summarize that, the evidence related + +16 to that. + +17 A As we discussed earlier in Count 7, I told you + +18 guys about the sexual conduct between Epstein and + +19 the monies that were paid to by + +20 mr. Epstein, the phone activity we discussed between + +21 and , it began in December, + +22 and we also have phone calls beginning in January from + +23 to at that time was 17 + +24 years of age, and we also have statements from + +25 and regarding Mr. Epstein's knowledge of their + +1 ages. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q And with respect to the affect on interstate + +commerce related to that count we have both the + +telephone calls, correct? + +A Yes. + +Q AS well as Mr. Epstein actually traveling in + +interstate commerce to engage in this activity, correct? + +A Yes, we do. + +Q Is there anything else that you would like to + +mention about Jane Doe number 3? + +A Not at this time, no. + +Q If I could direct you to Jane Doe number 4 and + +if you could summarize for the Grand Jury the + +information related to Jane Doe number 4's activities. + +A Jane Doe number 4 is I think you + +wanted their birth dates, her birth date is + +she was 16 years old and attended + +High School. + +We first have contact through phone calls from + +to on April 25th, 2004 which + +indicates and shows that was clearly 16 years of + +age when she started going to Mr. Epstein's and + +performing massages for Mr. Epstein. + +our Jane Doe number 1, was the one + +who recruited she basically told that she + +1 could make \$200, she needed to dress cute, he might try + +2 to touch you, but if you feel uncomfortable just let him + +3 know and he will stop, and the first massage that + +4 did he repeatedly told , and 1 mentioned this to + +5 you in the last Grand Jury session, she was very shy and + +6 he would repeatedly tell her not to be so shy, that she + +7 didn't have to be so shy. + +8 Epstein asked her to remove her clothing and + +9 she told him no, and throughout the massage he would + +10 repeatedly grab at her, he grabbed her butt, he did + +11 masturbate through this first massage and pulled her + +12 + +13 + +clothes, she would pull away and she was paid \$200 for + +that + +14 upon leaving the first massage Mr. Epstein + +15 told that if was willing to do more she + +16 would get paid more. He also informed that if she + +17 would bring her pretty friends he would also pay her for + +18 bringing her pretty friends. He told that + +19 would get her phone number. + +20 says that she performed three to four + +21 massages for Mr. Epstein. we have with + +22 + +23 + +approximately + +and + +a hundred phone calls between + +24 when i interviewed she became very upset + +25 when we got to the sexual massages that she did for + +1 Mr. Epstein. At this point, this is as much as we know + +2 at this point of what occurred with Mr. Epstein and + +3 + +4 She did three to four massages and those last + +massages they became more sexual in nature, he asked her + +6 again to remove her clothing, this time she took her + +7 shirt off, he asked her to take her bra off, she said + +8 no. + +9 He again would touch her breasts, he would + +10 touch her butt, he did continue to masturbate, this time + +11 she believes he ejaculated. He continued to compliment + +12 her, tell her she had a nice body and that she was + +13 pretty. + +14 says that he was very nice and engaged + +15 her in conversation, asked her, you know, if she had a + +16 boyfriend. In the last massage she discusses with me, + +17 and this massage Mr. Epstein told her to stop being shy + +18 and asked her to take her clothes off and said + +19 that she had a boyfriend and she didn't feel comfortable + +20 taking her clothes off and he told her you should know + +21 what to expect by now when you come here, and he jerked + +22 on her pants as to like jerk them down, so she did on + +23 this last massage get down to her bra and underwear + +24 she describes his tone at this time being + +25 frustrated and irritated, she stayed in her bra and + +1 + +2 + +3 + +4 + +5 + +6 + +7 sex with her boyfriend, + +8 + +9 + +10 + +11 + +12 + +13 massages, correct? + +14 A Yes. + +15 + +16 + +17 down and + +18 A + +19 Q + +20 + +21 + +22 + +23 + +24 + +25 rapport is built? + +underwear, but during the massage he grabbed her bra and + +pulled it down and fondled her breasts, he had + +instructed her to pinch his chest, his nipples while she + +was massaging his chest, he tried to grab her all over, + +he knew that she was upset with this massage. + +At one point Mr. Epstein asked her if she had + +informs him that she is + +still a virgin and he responds what, you don't like sex? + +And that's pretty much the way that last massage went. + +Q Now, Special Agent just to + +interrupt you, you mentioned that Jane Doe number 4 + +became very upset as you were asking her about the + +Q And when she was describing this incident with + +him grabbing at her breast and trying to pull her pants + +instructing her to remove her pants, correct? + +Yes. + +You had talked last week about the expert that + +you had spoken with about interviewing victims of these + +types of offenses? + +A Right. + +Q And you had told us about how a victim may be + +reticent at first to tell the entire story until a + +1 A Right. + +2 Q Can you tell the Grand Jury your impressions + +3 of your interview with 7 + +4 A She became so visibly upset, and a lot of the + +5 girls are embarrassed of what took place, but when she + +6 talked about the last massage and him grabbing her + +7 breasts and fondling her breasts she was in tears and we + +8 stopped the massage and we calmed her down, trying to go + +9 back there was just too difficult, I could not get her + +10 + +11 + +12 + +back to discussing anything further that had taken + +place. + +1 have since then -- 1 have since talked to + +13 again and 1 feel there is more there, but I just + +14 don't think she is ready to disclose what took place. + +15 Q so based upon the more than 60 telephone calls + +16 as well as -- + +17 A Approximately a hundred. + +18 Q -- 100 telephone calls and your conversations + +19 with you think there is probably more than four + +20 massages that happened? + +21 A Yes, 1 do. + +22 Q was there anything else that you wanted to + +23 discuss with the Grand Jury? + +24 A Just, as I stated in the beginning of those + +25 massages, they engaged in conversation and throughout + +1 + +2 + +that conversation, you know, she + +that she was a junior in high school + +did inform mr. Epstein + +and again she is + +3 one of the girls that talks about being mr. + +4 Epstein's favorite, so because Mr. Epstein knew they + +5 were friends they would engage in conversation about + +6 and 'would mention they were in the same + +7 classes at school and they would discuss the friendship + +8 they had between the two girls with Mr. Epstein and I + +9 think that's it. + +10 + +11 + +12 + +Q All right. If we could turn to the + +post-indictment to overt act number 4 which appears on + +page number 5. + +13 Did you obtain telephone records for Jane Doe + +14 number 4? + +15 A Yes + +16 Q And did you compare those with the phone + +17 records of and others? + +18 A Yes, I did. + +19 Q And can you tell us with respect to overt act + +20 number 4 what evidence you have related to that? + +21 A A review of the phone records indicate that + +22 there was telephonic contact between the numbers + +23 belonging to and as well as Mil + +24 statements that would call her to make + +25 appointments. + +1 Q And if we could go through overt acts 6, 8, 9 + +2 and 11, all of which appear on page 6. + +3 A A review of the phone records on may 3rd, + +4 2004, may 14th, 2004, may 20th, 2004 and June 3rd, 2004, + +5 a review of those phone records indicate that there was + +6 telephonic contact between numbers belonging to + +7 and as well as statements. + +8 Q If I could take you to overt acts 14, 15 and + +9 19 which appear on page 7. + +10 A A review of the phone records on June 11th, + +11 2004, June 20th, 2004 and July 10th, 2004, they indicate + +12 that there is telephonic contact between the numbers + +13 belonging to and + +14 Q And if I could ask you to turn to page 8 and + +15 if you could address overt acts 24 and 25. + +16 A A review of the phone records on July 18th, + +17 2004 and July 22nd, 2004, a review of and + +18 phone records indicate there is + +19 telephonic contact belonging to both of them as well as + +20 statements that would arrange + +21 appointments with her. + +22 Q If I could take you to page 9 of the draft + +23 proposed indictment and ask about overt acts 29 and 30. + +24 A A review of the phone records indicate there + +25 is telephonic contact on July 22nd, 2004 and August 4th, + +1 tween numbers belonging to and + +2 as well as statements. + +3 Q If I could take you to page 10 of the draft + +4 proposed indictment and ask you about overt acts 37 and + +5 43. + +6 A A review of phone records indicate telephonic + +7 contact on August 25th, 2004 and October 3rd, 2004 + +8 between numbers belonging to and + +9 + +10 + +11 + +Q And if you could turn to page 11 of the draft + +proposed indictment and if you would address overt acts + +12 47 and 48. + +13 A A review of the phone records indicate + +14 telephonic contact on October 30th, 2004 and November + +15 4th, 2004 between numbers belonging to and + +16 as well statements. + +17 Q Okay. And if you could go to page 14 of the + +18 draft proposed indictment and address overt act number + +19 77. + +20 A A review of phone records indicate that on + +21 + +22 + +23 + +January 4th, 2005 + +and + +statements. + +there was telephonic contact + +as well as + +between + +24 Q I'm sorry. If you could turn to page 16 of + +25 the draft proposed indictment and address overt act + +1 number 87. + +2 A A review of the phone records indicate that on + +3 January 22, 2005 there is telephonic phone contact + +4 between numbers belonging to and and + +5 I believe I said on January 22nd, 2005. + +6 Q Okay. And if you could go to page 17 and + +7 address overt act number 101. + +8 A On February 14th, 2005 a review of the phone + +9 records indicate that there was telephonic contact on + +10 between numbers belonging to and + +11 as well as statements. + +12 Q If you could turn to pages 18 and 19 and if + +13 you would address overt acts 106, 114 and 116. + +14 A A review of the phone records indicate that + +15 there is telephonic contact between and + +16 on February 24th, 2005 as well as + +17 statements. + +18 Q Overt act number 114 says on March 18th, 2005 + +19 defendant prepared a written message to defendant + +20 Epstein regarding Jane Doe number 4, could you tell the + +21 Grand Jury what the evidence is related to that? + +22 A we have a review of the message pads that were + +23 recovered during the search warrant that the State + +24 served that showed that wrote a message to + +25 Epstein regarding and that was done on March 18th, + +1 2005. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 statements. + +18 + +19 + +20 + +21 + +22 the + +23 as + +24 + +25 + +Q Do you happen to remember what the message + +said? + +A I have those with me. + +Q would you mind getting them out? + +A Do you want to mark it? + +Q If you could just read it to the Grand Jury. + +A It is a message written by for Jeffrey + +on 3/18/2005, it looks like 4:21 p.m., and the message + +reads is it okay if will come at 5:00 and there is + +a question mark. + +Q And if 1 could direct you to overt act number + +116, what the evidence is related to that. + +A A review of the phone records on March 29th, + +2005 indicate that there is telephonic contact between + +and as well as her -- + +Q And if 1 could take you to overt act number + +127 which is on page 20. + +A A review of phone records on April 11th, 2005 + +indicate that there is telephonic phone contact between + +numbers belonging to + +s tatements. + +Q Now, if you could + +and as well + +go to Count number 8, which + +alleges that between April 25th, 2004 and June 29th, + +8 + +9 + +10 + +11 those massages Epstein would grab and pull + +12 + +13 + +1 2005 Jeffrey Epstein, enticed + +2 Jane Doe number 4 to engage in sexual activity or + +3 prostitution. + +4 A On or about these dates we have a facility of + +5 interstate commerce, specifically the telephones, + +6 and which were utilized to + +7 set up, arrange massage appointments for Epstein, we + +have taking upstairs to set up the + +massage table, she would set the massage table up as + +well as set up the lotions and the oils, we have during + +closer + +to him as he masturbated, he repeatedly would ask her to + +remove her clothing, wearing her bra and underwear, + +14 Epstein would pull down her bra and grabbed at her + +15 breast, he attempted to touch he 't one point + +16 but she stopped him, he masturbated, she believes that + +17 he ejaculated, he paid her \$200, he told her that he + +18 would pay her to bring her pretty friends and would pay + +19 her more if she would do more. + +20 Q And just so that this is clear to the Grand + +21 Jury, June 29th of 2005 is the day before Jane Doe + +22 number 4 turned 18, is that correct? + +23 A Yes. + +24 Q So was there activity that continued past her + +25 18th birthday? + +1 A Yes. + +2 Q If I could direct you to Count number 17, + +3 which appears on page 28, and tell us about the evidence + +4 related to that. + +5 A we have evidence through flight records that + +6 indicate on May 21st, 2004 that Epstein and + +7 traveled to Palm Beach County on the + +8 Gulfstream, we have telephonic contact between and + +9 the day before or the day of travel and we + +10 have the sexual conduct between Epstein and as we + +11 described earlier in Count 8. + +12 Q And if you could go through Counts 18 and 19. + +13 A we have flight records that indicate on June + +14 4th, 2004 Epstein and traveled to Palm + +15 Beach County on the Gulfstream, we have telephone + +16 contact between and the day before, + +17 the day of travel, we have sexual conduct between + +18 Mr. Epstein and as discussed earlier. + +19 we have also Count 19 on June 20th, 2004 we + +20 have flight records that indicate that Epstein and + +21 traveled to Palm Beach County on the Boeing + +22 727. + +23 we have the telephone contacts between + +24 and the day before, the day of travel, we + +25 also have the sexual conduct between Jeffrey and + +1 as we described earlier in Count 8. + +2 Q Could you do the same for Counts 22 and 23, + +3 please. + +4 A Count 22 we have flight records that indicate + +5 on July 22nd, 2004 Epstein, + +6 traveled to Palm Beach County on the Boeing + +7 727, we have the telephonic phone contact between + +8 and the day before or the day of travel, we + +9 also have the sexual conduct between Jeffrey Epstein and + +10 as we described earlier, and Count 23 we have + +11 flight records that indicate on August 6th, 2004 Epstein + +12 and traveled to Palm Beach County on the + +13 Boeing 727, we have telephonic contact between + +14 and two days prior to Epstein and + +15 traveling to Palm Beach County, we have sexual + +16 conduct between Jeffrey Epstein and as we + +17 described earlier. + +18 Q And if you could do the same for Count number + +19 28, please. + +20 A Count number 28 we have flight records that + +21 indicate on November 5th, 2004 Epstein, + +22 traveled to Palm Beach County on the + +23 Gulfstream, we have telephonic contact between + +24 and the day before or the day of travel, + +25 we have the sexual conduct between Epstein and + +1 Q And if I could direct you to Count number 35, + +2 you testified previously about the people who were + +3 aboard the plane. + +4 was there also telephone contact on January + +5 6th -- excuse me, shortly before the flight on January + +6 6th, 2005 between and this Jane Doe? + +7 A yes, two days before. + +8 Q And if you look at Count number 40, again, you + +9 had previously told us about who was on board the plane. + +10 Can you tell us whether there was also telephone contact + +11 shortly before that? + +12 A There was telephone contact the day of or the + +13 day before. + +14 Q All right. Between who and who? + +15 A Between and . + +16 Q Okay. And if you could look at Count 43, you + +17 also had testified previously about who was aboard the + +18 plane on that day. + +19 was there also telephone contact between Jane + +20 Doe number 4 -- excuse me, Jane Doe number 4 and + +21 ? + +22 A yes, two days before. + +23 Q And if I could direct you to Count number 52, + +24 which is the sex trafficking offense, and if you could + +25 summarize again for the Grand Jury the evidence related + +1 + +2 + +3 + +4 + +to that. + +A we discussed in Count 8 the sexual conduct + +that occurred between and Epstein during the + +massages that took place, we talked about the money that + +5 was paid to her by Mr. Epstein and the offer of more + +6 money if she would do more as well as if she would bring + +7 her friends. + +8 Through statements we have also that + +9 has paid her in the past for bringing a + +10 friend, we have the phone activity between + +11 and which started in April, 2004, we know + +12 was 16 at the time, we also have phone activity between + +13 and beginning in the spring of 2005 + +14 when would be 17, with the statements of and + +15 , the knowledge that Mr. Epstein knew their age, + +16 and we have gone through that regarding informing + +17 Mr. Epstein that she was a junior in high school, that + +18 she was classmates with I and then + +19 statements that was concerned because she was + +20 discussing prom with Mr. Epstein, and both girls at that + +21 time of the phone calls were under the age of 18. + +22 Q Just again so it is clear for the Grand Jury, + +23 neither nor ever specifically said hey, + +24 Jeffrey, 1 am 17, but they provided information that + +25 should have caused him to try to figure out whether in + +1 fact they were adults? + +2 A Yes. + +3 Q Any questions about Jane Doe number 4 before + +4 we turn to Jane Doe number 5? Yes, ma'am. + +5 A GRAND JUROR: I have to say something here, + +6 if it is a stupid question forgive me if it is, + +7 from what I heard, maybe I heard wrong, there were + +8 three to four massages that Jane Doe, or + +9 said that she had and you enumerated quite + +10 a few sexual contact. + +11 How do you know about this, do you have + +12 records, how do you know they were sexual contact? + +13 THE WITNESS: Through interviewing + +14 A GRAND JUROR: She said she only had three to + +15 four massages. + +16 A GRAND JUROR: Her question is more like + +17 there is 20 phone calls. + +18 A GRAND JUROR: There is tons of them. + +19 THE WITNESS: Exactly, that is what we were + +20 discussing earlier when we discussed that there is + +21 more than what is willing to admit at this + +22 time. + +23 A GRAND JUROR: I got it. So she said she + +24 only had three to four. + +25 A GRAND JUROR: There is a hundred phone + +1 + +2 + +calls. + +A GRAND JUROR: You said you found out through + +3 I am a little bit confused about that. + +4 THE WITNESS: Through interviewing she + +5 stated that she had three or four massages from + +6 mr. Epstein. + +7 BY MS. VILLAFANA: + +8 Q Special Agent the sexual activity + +9 that you described that went through, that is what + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +she said happened during those three to four massages, + +correct? + +A Right. + +Q Does that answer your question? + +A GRAND JUROR: Not really. How do we know + +like about all these 25, 30? + +A GRAND JUROR: There is more dates that match + +up with the amount of massages. + +A GRAND JUROR: There were a hundred phone + +calls. + +A GRAND JUROR: Are we supposed to assume a + +phone call was made each time they had sexual + +contact? + +THE WITNESS: No. There are lots of phone + +calls made arranging appointments between the + +girls, that doesn't mean that every phone call that + +1 was made was a trip over to Mr. Epstein's house to + +2 perform a massage. + +3 MS. VILLAFANA: Yes, ma'am. + +4 A GRAND JUROR: Couldn't they put anything in + +5 this indictment about stalking her, are there any + +6 rules against stalking children? + +7 MS. VILLAFANA: I will address -- that is a + +8 legal question that I will address when the Special + +9 Agent is outside of the Grand Jury. Any other + +10 factual questions related? + +11 A GRAND JUROR: I don't have a question + +12 relating to Jane Doe number 4, it was a question I + +13 asked last week, what does Mr. Epstein do for work, + +14 how does he make his money? I asked that late, + +15 late in the game last week. + +16 MS. VILLAFANA: Okay, I guess we can just + +17 address that now. + +18 BY MS. VILLAFANA: + +19 Q what is Mr. Epstein's state of profession? + +20 A He is an investor. + +21 Q And he manages portfolios valued at about a + +22 billion or more? + +23 A Yes. + +24 Q who is his best known client? + +25 A The owner of the Limited and Victoria Secret. + +1 Q And you mentioned that as gifts mr. Epstein + +2 tended to give Victoria Secrets panties and bra sets? + +3 A Yes. + +4 Q Does that answer the question? + +5 A GRAND JUROR: Yes. + +6 MS. VILLAFANA: Yes, ma'am. + +7 A GRAND JUROR: Count 28 I thought I heard + +8 that -- I thought I heard the detective say that it + +9 was the Gulfstream rather than the Boeing 727 on + +10 flight records, just for your info. + +11 MS. VILLAFANA: Count number 28, let's go back + +12 there. + +13 BY • + +14 Q could you restate for the Grand Jury which + +15 company owns the Gulfstream? + +16 A The Gulfstream is owned by Hyperion Air, Inc. + +17 Q And the Boeing is owned by whom? + +18 A JEGE, Inc. + +19 Q Any other questions before we go on to Jane + +20 Doe number 5? we have four minutes. + +21 Special Agent why don't I ask you + +22 to step outside so I can answer that question for the + +23 Grand Jury and address some issues. + +24 (The witness was excused from the Grand Jury + +25 room.) + +1 (Questions posed by the Grand Jury.) + +2 (The testimony of the witness was concluded + +3 before the Grand Jury.) + +1 CERTIFICATE OF REPORTER + +5 I certify pages 2 through 36 are a true transcript of my + +6 shorthand notes of the testimony of + +7 before the Federal Grand )ury, west Palm + +8 Beach, Florida on the 15th day of Tuesday, 2007. + +Commission + +Notary Public + +Expires May 8, 2008 + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +UNITED STATES DISTRICT COURT + +SOUTHERN DISTRICT OF FLORIDA + +RE: OPERATION LEAP YEAR + +ORIGINAL + +SPECIAL AGENT + +APPEARANCES: + +/ + +TESTIMONY + +OF + +Federal Grand Jury 07-103 Federal Building U.S. Courthouse West Palm Beach, Florida Tuesday, May 22, 2007 + +Assistant Unite States Attorney + +o + +Foreperson + +r + +The sworn testimony of SPECIAL AGENT + +was taken before the + +Federal Grand Jury, West Palm Beach Division, + +Federal Building, U.S. Courthouse, Palm Beach + +County, State of Florida, on Tuesday, May 22, + +2007. + +Certified Court + +Reporter and Notary Public, State of Florida, + +Official Reporting Service, LLC, 524 South Andrews + +Avenue, Suite 302N, Fort Lauderdale, Florida, + +, was authorized to and did report the sworn + +testimony. + +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 + +BY + +(Witness enters the Grand Jury Room.) + +THE FOREPERSON: You do solemnly swear + +that the testimony you give will be the + +truth, the whole truth, and nothing but the + +truth, so help you God? + +THE WITNESS: I do. + +THE FOREPERSON: Thank you. Please be + +seated. + +EXAMINATION + +Q Good afternoon, Special Agent. + +A Good afternoon. + +Q Could you remind the grand jury oL your + +name and with whom you are employed? + +A It's + +I'm a + +special agent with the FBI here in West Palm Beach + +and I work violent crimes. + +Q Are you the case agent on Operation Leap + +Year? + +A Yes, I am. + +Q Okay. Before we get back to our review + +of the draft proposed indictment, I know that a + +question was raised regarding whether the grand + +jury transcripts are being made available to + +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 + +counsel for the defense, are they? + +A No. + +Q And is Mr. Epstein considered a high + +flight risk by the FBI and the U.S. Attorney's + +Office? + +A Yes, he is. + +So is the status of the investigation in + +terms of when an indictment might be returned + +considered highly confidential? + +A Yes. + +• And are there any personal relationships + +between any members of the U.S. Attorney's Office + +and counsel for Mr. Epstein? + +A Yes. + +Q And is that one of the reasons why we + +have decided to use, In Re: Abbott, when referring + +to this case? + +A Yes. + +Q Okay. Now we had left off just prior to + +the beginning of the discussion of Jane Doe Number + +Five. Could you tell the grand jury a little bit + +about Jane Doe Number Five? + +A Jane Doe Number Five is ▪ **Her** + +**date of birth is We have phone** + +**activity that began with when she was 1** + +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 + +years old beginning in November of 2004, going + +through to almost April, I guess, to the end of + +March 2005. + +We have contact, + +between and + +telephone + +with + +contact + +approximately 70 phone calls in that time period + +as well as approximately seven phone calls with + +regarding the setting up of + +appointments to provide massages to Mr. Epstein. + +Q Now did explain how she was + +first introduced to Mr. Epstein? + +A Yes, she did. + +that approached + +there. + +High School + +. was the one + +also attends + +as well as our other + +the Jane Does up + +told her that she would need to + +wear something sexy, that she would be providing + +Mr. Epstein with a massage and that she would + +receive \$200, and if she was asked she should tell + +Mr. Epstein that she was 18. + +On the first massage that went + +to Mr. Epstein's house, she removed her shirt at + +his request and she performed the massage. She + +was paid \$300 for that massage. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +During that massage, she told Mr. + +Epstein that she was 18 years of age. He asked + +her age. They also discussed many things that + +was interested in. + +They talked about his ranch. They + +talked about horses. They actually also talked + +about cars. At one point later on, Mr. Epstein + +let's her drive a brand new Lexus, test drive a + +brand new Lexus. So those were some of her + +interests and Mr. Epstein talked to her about + +that. + +told us that the massages became + +more sexual in nature and she stated that she did + +more than ten massages, but that she couldn't + +quite put a number on how many massages she + +provided to Mr. Epstein, but it was definitely + +more than ten. + +She was not when she was interviewed + +by the Palm Beach Police Department, she did tell + +them that it was more around five or six massages. + +She stated that she minimized to the detectives + +when they came to interview her. + +They came to her house and her dad was + +due home any time and what was foremost on her + +mind was my dad is going to be here any minute. + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +She cooperated. + +She told them what had happened, but she + +minimized it more in an effort that she just + +wanted them to leave before her parents got home. + +At this point, her parents were not aware of what + +took place. + +As the massages became more sexual in + +nature, she describes that the first sexual + +massage -- he always instructed her on what to do, + +and on the first massage he had asked her to + +remove her clothing. + +She was down to her underwear at this + +point. He asked her to straddle him while he laid + +face up and continued to massage his chest and + +pinch his nipples and rub his chest. He at that + +point reached through her legs and masturbated. + +On another occasion, she was completely + +nude and she did several of the massages in the + +nude for Mr. Epstein. + +In this particular massage, she stated + +that Mr. Epstein licked his hand and went down and + +stroked and actually penetrated her + +She pulled away and he said that he + +wanted to touch her and that he also wanted to + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +taste her. He stopped at that time, but then + +before the massage was over, he + +her again. + +He had used a back massager on her on at + +least two occasions. she did not like that and + +she told him that and he responded something to + +the effect: What are you scared to have pleasure? + +And she told him she didn't like it. + +On the second to the last massage that + +gave Mr. Epstein, she was giving him a + +massage and he took her into the bedroom and asked + +her to get fully unclothed. + +He actually took a phone call and told + +her that she should get undressed and lay on the + +bed completely naked. He just wanted to'look at + +her. He took his phone call. + +up + +After the phone call was over, he ended + +as well as + +performing oral sex on She said that she + +felt very dirty after that massage or after that + +time and she had decided that the next massage + +would be her last massage, that she did not want + +to go back. + +During the last massage she gave, she + +kept looking at the clock. Mr. Epstein commented + +1 + +2 + +3 + +4 + +S + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +and noticed that she was looking at the clock and + +she made reference to that her boyfriend was + +waiting and Mr. Epstein said that, you know, she + +was ruining his massage and that if she didn't + +want to be here she Should leave. + +She told him at this time this would be + +her last massage. She was paid anywhere from \$300 + +to \$600 during the time that she worked for Mr. + +Epstein. It was who took her upstairs that + +first time or took her upstairs and set up the + +massage table. + +She was given some gifts by Mr. Epstein + +as well. She received bra and pantie sets from + +him, Victoria Secret bra and pantie sets. She + +also received a book of poetry from Mr. Epstein. + +She was Western Unioned a wire of \$200 + +as a Christmas bonus to from Mr. Epstein. + +Q How did get to and from Mr. + +Epstein's home? + +A She had a vehicle that she would drive + +if she didn't ride with one of the other girls. + +If she was grounded and could not get to Mr. + +Epstein's house, he would send a car for her. + +There was a local taxi service and she + +stated that on several occasions it was a Lincoln + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Town Car that was sent and there was an individual + +by the name of that she got to know pretty + +well on the drives to and from Mr. Epstein's + +house, but that even when she didn't have + +transportation on those particular times, that a + +car was + +house. + +Q + +sent for her to bring her to Mr. Epstein's + +Is there anything else that you wanted + +to tell the grand jury about + +A That's it. + +Q All right. If I could direct you tn the + +proposed draft indictment, draft proposed + +indictment, and ask you to look at the Overt Arts + +that involve Jane Doe Number Five and + +. Specifically Overt Acts 53, 58, 61 , 65, + +69, 74, 81 , 91 , 98, 107, and 11 1 . + +Can you explain to the grand jury what + +the evidence is supporting those Overt Acts? + +A We have reviewed phone records that + +indicates that there was telephonic contact + +between and on those dates as + +well as statements that was + +arranging the appointments. + +Q All right. And if I can refer you to + +Overt Act Number 72, which states on or about + +1 + +2 + +3 + +4 + +S + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +December 23, 2004, Defendant Epstein caused a + +Western Union wire transfer order to be sent to + +Jane Doe Number Five. + +What evidence do you have to support + +that? + +A We have + +have the Western + +received + +Q + +issued + +A + +Q + +Number + +[statements and we also + +Union receipt showing that she + +that amount of money. + +And those were in response to a subpoena + +on behalf of this grand jury? + +Yes. + +If I could direct you to Overt Act + +82 involving What is the + +basis for that Overt Act? + +A Again, a review of the phone records + +from and telephone indicate + +that they had contact at that time. + +Q And Overt Act Number 88 states that on + +or about January 26, 2005, Defendant reviewed + +a telephone message from Jane Doe Number Five. + +What is the basis for that allegation? + +A We have reviewed the message pads that + +were recovered during the execution of the state + +search warrant and recovered a message that + +left for confirming an appointment + +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 + +that I have a copy of that if you want me to read + +that to you. + +Q Sure. + +A It's a message for dated January + +26th, 2005, at 1 :30 p.m. It's from and it + +says, in parentheses, you know the number, and it + +says she is confirming 5:30 p.m. + +Q All right. And then with respect to + +Overt Acts Numbers 108 and 1 15 related to Ms. + +, what is the evidence supporting those Overt + +Acts? + +A Again, a review of the phone records of + +and We show that there was + +telephonic contact on those dates. + +Q And then if I could refer you to + +substantive offense Count Number Nine, which is + +the enticement charge. Can you just remind the + +grand jury of the evidence supporting that + +allegation? + +A On or about those dates, a facility of + +interstate commerce was used, specifically the + +telephone between , and + +Those telephones were used to set up and + +arrange appointments for Mr. Epstein. As we + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +discussed earlier during the massage the sexual + +activity that took place, the straddling of him by + +where he began to masturbate between + +his -- between her legs, excuse me, while she + +continued to massage him and rub his nipples, him + +asking her to become completely nude. + +He her, as we + +talked about. He used a back massager on her on + +at least two occasions, and he had sexual + +intercourse with Felicia as well as performed oral + +sex on + +He paid anywhere from \$300 to + +\$600. He provided her with gifts, a poetry book, + +Victoria Secret underwear. It was + +who had set up the room with the massage table and + +set out the oils. + +And then, of course, we did discuss the + +private car that was sent to her when she wasn't + +available to drive herself. He did pay a -- I + +didn't mention this earlier -- he paid a truck + +payment for her when she was short on money. So + +that was another thing that Mr. Epstein provided + +to and she was 17 during all of this + +activity. + +Q All right. And if I could refer you to + +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 + +Count Number 53, which is the sex trafficking + +offense. Is the information that you just + +summarized the same information that supports that + +count? + +A Yes. The only thing I wanted to tell + +you regarding her age, she told Mr. Epstein that + +she was 18 on the first visit. A couple of visits + +later they discussed her birthday. They were + +talking about her birthday and her plans for her + +birthday and Mr. Epstein asked her -- said + +something to the effect like: You are going to be + +18? And she said yes. + +And he said: So you are not 18? She + +laughed and said no and they kind of laughed and + +they continued on with the massage. So Mr. + +Epstein was aware through that conversation that + +had not yet turned 18. + +Q All right. + +Are there any questions + +regarding before we continue? All + +right. Let's turn now to Jane Doe Number + +Six. + +THE WITNESS: Did we do the count, the + +traveling count? + +No, we are not going to + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +BY + +do those today. + +THE WITNESS: Okay. + +Q And if you could tell us Jane Doe Number + +Six's first name and her date of birth? + +A Jane Doe Number Six is . She + +also attended + +date of birth + +Q + +introduced to + +A + +High School and her + +is + +How did Jane Doe Number Six come to be + +Mr. Epstein? + +also contacted -- or told + +about providing massages to Mr. Epstein. She told + +which I'm going to refer to her as + +That's what she goes by, but her name is + +That he wanted cute girls to give him + +massages and that he would pay \$200. + +We had have contact starting with + +in July of 2000 between and that + +phone contact continues until September 2005. + +Between this time period, we have over 200 -- + +approximately 225 calls between and + +brought + +Durin first massage, + +over there and was paid \$200 by Mr. + +Epstein. She left. performed the first + +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 + +massage topless. He asked her to take her skirt + +and her shirt off. + +She said no at first and later in the + +massage, the way puts it, is that he talked + +her into it and she removed her shirt, which she + +was not wearing a bra at the time. + +Mr. Epstein fondled her breasts. He + +asked her to remove her panties and she said no. + +He masturbated and as soon as he ejaculated, the + +massage was over. She was paid \$200 for that. + +She, at that point, she did start + +working for Epstein on a regular basis. She + +indicated that she had been there hundreds of + +times over this time period. + +She told us -- and I'm going to read a + +quote to you that she said to me or said to not to + +me but to law enforcement -- she said -- and this + +is referring to after the first time that she went + +there. + +She said I first told him that I had a + +problem with it, what happened the first time, + +but \$200 for 45 minutes that was a lot for a + +16-year-old girl making six bucks an hour. + +Now that was a statement she made to law + +enforcement. Going through her phone records and + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +during her interview with law enforcement, she + +goes back and forth on whether she is 16 or 17. + +It's now over a year since she started + +working -- a year and a half since she started + +working for Mr. Epstein and going back and trying + +to retrace her age, she did say that, but we + +believe at that time she was 17 due to the phone + +contact. + +So we are not sure when that first + +massage started, but the phone contact with + +began in July of '04 when she would have + +been 17. + +Q And just to be clear, during that + +interview with law enforcement, did have + +access to her phone records? + +A No. + +Q And the interviewing officer also didn't + +have access to those records, correct? + +A No. + +Q So she was just saying she couldn't + +remember if she was 16 or 17 at the time? + +A Right. + +As I said, she became kind of a regular. + +He increased her pay to \$300 to \$400 as long as he + +could touch her. She stated that the massages + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +would progress over time and at first she would + +not take off her panties, then she did. + +She performed the massages naked. He + +would rub He also + +He performed oral sex on + +He would masturbate while rubbing himself on + +breasts. + +Later in the times that was + +performing the massages, he requested that she + +become sexually involved with + +Mr. Epstein asked + +and + +that if she + +to perform oral sex on + +• + +refused and Mr. Epstein told her + +was to perform oral sex on for + +five minutes, he would give her another \$200. So + +she did. + +and engaged in sexual + +activity less than five times. Mr. Epstein would + +also partake in that sexual activity as well. On + +one occasion with all three of them, as we had + +mentioned earlier in a grand jury session, + +the massage was over and was standing up near + +the massage table and Mr. Epstein bent her face + +down and held her head and + +I think she described it as that he went + +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 + +four or five times with his penis and + +she had a rule with Mr. Epstein that at first was + +that he would not ever penetrate her with any + +object, anything. + +And when he first + +her on the first time, she, you know, asked him + +why he was doing that. He said: Oh, I thought we + +had done this before. + +And later he continues to + +her. On this occasion, she said: What + +are you doing? And he said that he just wanted + +to see this. + +Q So at the time that that occurred, she + +still had a rule with him, but the rule was that + +he would not penetrate her vagina with his penis? + +A Right. + +And Mr. Epstein gave -- we'll talk + +about several gifts. One of the gifts that Mr. + +Epstein gave was a 2005 Dodge Neon. It only had + +seven miles on it. + +believes that that car was bought + +for her. We have reason to believe it was most + +likely rented and we are determining that right + +now, but he gave her this. + +It only had seven miles and she gave + +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 + +that back to him before she got out of high + +school. And she said, and this is her quote: It + +got too sticky for me. He wanted more than I was + +willing to give. + +She stated that Epstein requested her to + +have sex with him multiple times and also wanted + +him to -- wanted her to perform oral sex on him + +and she refused to do that, and Mr. Epstein knew + +that that was not going to happen. + +And, again, that's one of the reasons + +why she ended up giving back the car because it + +just was getting a little bit, as she referred to, + +sticky for her. + +After that occasion, where he did + +penetrate her vagina, he paid her \$1 ,000 after + +that. Some of the gifts that she received other + +than the car, she describes that as Victoria + +Secret underwear and a bra and pantie set she + +received. + +She received Christmas bonuses, movie + +tickets, VIP show tickets. She went to the David + +Copperfield show. She met with him. She went to + +the after party. She received a Louis Vuitton + +bag. + +was in a play at her high school + +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 + +and Mr. Epstein sent her a dozen roses -- or two + +dozen roses, I believe, to her high school, had + +them delivered to her high school while she was + +performing at this play. + +He also for her 18th birthday, he flew + +her to New York for her 18th birthday, and she was + +flown up there on her birthday and that was done + +because Mr. Epstein didn't want to have to deal + +with the parental consent needed to fly somebody + +under the age of 18 to New York. + +So on her 18th birthday with his + +funding, she flew to New York. She received show + +tickets to the Phantom of the Opera. Epstein was + +not present in New York at this time. He was + +called away and was not there. + +So she does have friends in New York and + +she stayed with those friends and attended the + +show that Mr. Epstein had purchased those tickets + +for. The other thing about is she said that + +she would get paid every time she would go over + +there and she said she feels like she went over + +there hundreds of times. + +She said that sometimes he would just + +have her naked watching TV or reading a book. He + +would sometimes just ask her to lay with him + +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 + +naked. She was still always paid and he would + +invite her over for breakfast. + +He would invite her to dinner and + +sometimes just to use the pool, but that she was + +always paid for coming over there. + +Q Let me ask about a couple of other + +things. You mentioned the specific conversation + +about she could only fly up on her 18th birthday + +so that he wouldn't have to get parental consent + +for her flight? + +A Yes. + +Q And you mentioned the delivery of the + +roses to the high school. In addition to those, + +were other events that occurred that should have + +led Mr. Epstein or probably did lead Mr. Epstein + +to know that she was under the age of 18? + +A Yes. One of the things that told + +me is that she believed she stayed with him so + +long because she believed that he was going to + +help her get into New York University, NYU. + +She provided him on multiple occasions + +paperwork. One being her transcript. Trying to, + +you know, do what she could to keep her grades up, + +do what she could in the hopes that Mr. Epstein + +with his influence residing in New York was going + +1 + +2 + +3 + +4 + +5 + +7 + +8 + +to be able to get her into NYU. + +That again is one of the reasons why she + +stayed because she felt that if she held on for + +so long hoping that this dream would come true. + +She is currently attending + +and doing very well. + +Q Do we have any other documentation of + +receiving payments from someone who worked + +9 for Mr. Epstein? + +10 A We have + +11 manager + +12 his petty cash + +for Mr. Epstein + +receipts + +13 that he paid out of + +14 Q Now was + +15 lineup? + +16 + +17 + +18 defendants? + +19 + +20 + +21 shown to her? + +22 + +23 + +24 defendants aware of + +25 Epstein? + +It was a house + +and we were able to get + +and in there is a payment + +his funds to **=.** + +**ever shown any photo** + +**A Yes, she was.** + +**Q And was she able to identify any of the** + +**A She identified** + +**Q And was that the photo array that was** + +**A Yes, it was.** + +**Q Was are counsel for the** + +**allegations against Mr.** + +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 + +A Yes. + +Q And have they attempted to discredit + +her? + +A Yes. + +Q And is one of the bases for their + +attempt to discredit her the fact that she didn't + +appear before the State Grand Jury? + +A Yes. + +Q Are you aware of whether or not was + +ever subpoenaed to appear before the State Grand + +Jury? + +A There was a subpoena issued to her. I'm + +not sure if she received that. Either she + +received it the day before or she didn't receive + +it + +she + +at + +is + +all + +up + +and + +in + +I would need to check + +mind you. + +my notes and + +So she was either served the day before + +that grand jury convened or she never received it + +and I would need to check with probably the + +detective for sure on that. + +Q Okay. Let's talk about the allegations + +related to Jane Doe Number Six in the proposed + +indictment. If I could refer you to Overt Acts + +Numbers 21 , 26, 34, 38, 49, 51 , 52, 55, 62, 68, + +and 73. + +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 + +If you could tell the grand jury what + +the evidence is that supports those allegations? + +A Review of those phone records on those + +dates indicate that there was telephonic contact + +between and as well as + +statements that she was called by prior to + +and while Mr. Epstein was in town. + +Q All right. And if I could refer you to + +Overt Act Number 57, which states on or about + +December 4, 2004, Defendant provided a + +written message to Defendant Epstein regarding + +Jane Doe Number Six and Jane Doe Number Seven. + +Could you tell the grand jury about + +that? + +A We have reviewed message pads that, + +again, were obtained in the execution of a state + +search warrant that indicates that left a + +message for Mr. Epstein regarding and + +Britnay, who is Jane Doe Number Seven, and I have + +that here. If I can read it to you? + +Q Sure. + +A For Jeffrey, dated 12-4-2004. The time + +is 2:55 p.m. It's from would like + +to work at 4 p.m. if possible. In parentheses, + +is scheduled for 5:00 today. The movie is at + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +7:30. + +Q Okay. And if I could refer you to Count + +Number Ten, and if you could summarize for the + +grand jury -- first, if you could refer to the + +dates contained in that count, on July 15th, 2004, + +until December 29th, 2004, what was the + +significance of those dates? + +A This would be the time period that ■ + +**is still under the age of 18.** + +**Q That she was receiving phone calls from** + +**someone who worked for Mr. Epstein?** + +**A Yes.** + +**Q Okay. And then if you could just** + +**summarize the remainder of the evidence according** + +**to that count?** + +**A Okay. On or about those dates a** + +**facility of interstate commerce was used,** + +**specifically the telephone, specifically** + +**and telephones were utilized to** + +**set up and arrange appointments for Mr. Epstein.** + +**During the massages, Epstein** + +**breasts. Epstein used the back** + +**and vibrator directly on** + +**performed oral sex on** + +**fondled** + +**massager** + +**vagina. Epstein** + +**and Epstein penetrated** + +**Alex's with his penis.** + +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 + +Mr. Epstein introduced + +into the sexual activity with . and + +engaged in sexual activity while Epstein + +watched and masturbated. + +Epstein + +on and when + +for five minutes. + +asked to perform oral sex + +she refused he offered her \$200 + +complied. There were + +different sex toys used on including a + +strap-on dildo that used. + +Epstein paid \$200 up to \$1 ,000 + +depending on the sexual activity that took place. + +had taken upstairs. She set up + +for the massage. + +Epstein paid for a trip to New York for + +her 18th birthday, gave her Phantom of the Opera + +tickets. He rented or provided a car to + +He delivered roses to her high school, gave her a + +Louis Vuitton bag, gave her a Victoria Secret bra + +and pantie set. + +He also provided her with a bathing suit + +on a return trip he had to Brazil. He told her + +that he was going to help her get into New York + +University. She believed that was the case. She + +provided him with her high school transcript and + +she was 17 at the time. + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q And with respect to Count Number 54, is + +that the same evidence that supports that count? + +A Yes, it does. + +Q Okay. Before we go on, I know that you + +mentioned with respect to both Jane Doe Number + +Five and Jane Doe Number Six that they were + +introduced to Mr. Epstein by + +Is another Jane Doe who will be + +discussed at a later time? + +A Yes. + +MS. VILLAFANA: Any questions about Jane + +Doe Number Six? + +Yes. + +A GRAND JUROR: I don't know if I'm + +allowed to ask this, and you don't have to + +answer it, but how did the parents -- do they + +ask where she got the car and a Louis Vuitton + +purse? I mean, how do they not know anything + +like a car? + +BY MS. VILLAFANA: + +Q Did you have you interviewed + +parents? + +A . No. + +MS. VILLAFANA: Yes. + +A GRAND JUROR: My question is that I + +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 + +noticed you are skipping all the travel. Is + +that something that you are going to discuss? + +MS. VILLAFANA: In the future. As I + +mentioned before, there's -- that question + +is pending and I want to get a definitive + +answer before we go through that. + +A GRAND JUROR: I must have missed that. + +A GRAND JUROR: I don't see a Count 54 + +on this. + +A GRAND JUROR: Because it is on the + +next page. + +A GRAND JUROR: Okay. I'm sorry. Thank + +you. + +THE WITNESS: Just to answer a question. + +The Palm Beach Police Department -- did + +tell the Palm Beach Police Department that + +her mother believed that she worked there, + +and I would need to go back and check, but I + +believe that she worked there as a -- I want + +to say like an assistant or answered the + +phones or something like that. + +And at one point, her mother thought + +there might have been more going on and + +actually did end going over there for a + +time period, but then she did resume later. + +1 A GRAND JUROR: Okay. + +2 MS. VILLAFANA: Any other questions? + +3 Okay. + +4 BY MS. VILLAFANA: + +5 Q And we will turn to Jane Doe Number + +6 Seven. Could you tell the grand jury the first + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +name of Jane Doe Number Seven and her date of + +birth? + +A Jane Doe Number Seven is and + +her date of birth is + +Q How did come to go to Mr. + +Epstein's house? + +A worked + +illip + +Jane Doe Number Six told + +through working at + +at the mall, and that + +the mall, and or + +that she could + +make extra money by providing a massage to Mr. + +Epstein. + +naked for this massage, + +she didn't + +told her that she may have to be + +but if she didn't want to + +have to. We have the contact, the + +telephonic contact between and + +beginning in July 2004 and through + +November of 2005. + +There is approximately 100 calls between + +and and there is around + +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 + +seven calls, approximately seven calls to + +in between and and approximately + +eight calls between and + +stated that she went about 15 + +times to Mr. Epstein's house. is the + +first Jane Doe we have talked about that goes to + +High School and does not attend + +High School. + +On first massage, took + +upstairs for the first massage and set up + +the room. Epstein instructed to leave the + +room. During the massage, Epstein asked + +to remove her clothing. She removed only her + +shirt. + +she described + +converse with + +different + +described Epstein as being + +him as a respective guy, who would + +her. She said that they discussed + +life issues such as where wanted + +to attend college in the future. + +He also gave her advice. She didn't + +have the best credit, so he gave her advice on her + +credit. He also gives her advice on dealing with + +her parents. She performed this massage and she + +was paid \$200 for the massage. + +told us that as the massages + +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 + +continued, they would then progress and become + +more sexual. Epstein would try to go further and + +further with + +By the third massage, had + +completely removed all of her clothing. She was + +completely nude at Mr. Epstein's respect. Epstein + +would fondle breasts. + +He rubbed hei He did not + +penetrate did not digitally penetrate her, but + +did stroke and rub on the outside. She + +would tell him no on occasions and she would also + +take his hand and remove his hand from places that + +she did not want him to touch. + +Mr. Epstein did use a massager directly + +on while he continued to + +masturbate during these massages. On at least two + +occasions, Mr. Epstein -- at Mr. Epstein's + +direction, assisted in giving the + +massage. + +us that + +And on -- the first time tells + +was setting up the room and she + +remained in the room and started to undress. + +was surprised. + +She was never asked or told this was + +going to happen. This is just kind of the way it + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +went. and both massage Mr. Epstein. + +and Epstein began performing sexual acts in + +front of + +Epstein used a massager on 's + +in front of as well as they both + +performed oral sex in front of on each + +other. + +away. + +also touched breasts. + +She touched her -- touched 1 + +She took hand and placed it on + +and pulled it back, pulled It + +did use the massager directly on + +Some of the gifts that + +received, she did receive also a bathing suit, + +which we have from Mr. Epstein's Brazilian trip. + +She received four tickets for her 18th + +birthday. Mr. Epstein gave her David Copperfield + +tickets, and on two occasions Mr. Epstein and + +, they wired money t + +In June of 2005, on senior + +trip, her senior graduation trip, they went to + +She ran out of money and they + +sent her -- wired her, Western Unioned her \$350, + +and then she took a trip in July of '05 to San + +Diego, California, and she also received \$200 by + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Western Union. + +Q All right. + +Anything you want to ask + +before we go to the Overt Acts? No. All + +right. + +BY MS. VILLAFANA: + +Q If I could refer you first to Overt Act + +Number 23, which says on July 16th, 2004, + +Defendant caused Jane Doe Number Six to + +make one or more telephone calls to a telephone + +used by Jane Doe Number Seven. + +Could you explain what the evidence is + +supporting that? + +A Yes. A review of phone records from + +phone and indicated they had + +telephonic contact at that time. + +Q And that was following a telephone + +contact between and Jane Doe Number + +Six? + +A Yes, it was. + +Q All right. And is that consistent with + +what Jane Doe Number Seven told you about how she + +was recruited to go to Mr. Epstein's house? + +A Yes. + +Q Now with respect to Overt Acts 27, 32, + +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 + +39, 41 , 44, 45, 66, 75, 85, 89, and 90, what is + +the evidence related to those Overt Acts? + +A Can we skip 89? + +Q Oh, yes. Let's skip 89. + +A A review of the phone records indicate + +that there was telephonic contact between + +and on those specific dates as well + +as the statements of that Sarah + +would call her in advance or call her while Mr. + +Epstein was in town. + +Q All right. And those records show that + +the phone calls originated with + +telephone? + +A Yes. + +Q Now if I could direct you to Overt Act + +Number 57, which says on December 4, 2004, + +Defendant provided a written message to + +Defendant Epstein regarding Jane Doe Number Six + +and Jane Doe Number Seven. + +Is that the phone message that you + +mentioned earlier today? + +A Yes, it is. + +Q Now we skipped Overt Act Number 89, and + +can you tell the grand jury what the evidence is + +related to Overt Act Number 89? + +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 + +arrange massage appointments + +During the massages, Epstein asked + +remove her clothing. + +Starting with + +was completely nude and + +A That would be a review of the phone + +records from + +phone records from + +telephonic contact + +Q From Ms. + +A Yes. + +Q And then + +as well as a review of the + +on that day. + +to + +that there was + +telephone? + +Overt Act Number 92, can you + +tell us what the evidence is related to that? + +A That is on that day a review of their + +phone records of phone records + +and indicates that there was telephonic + +contact between the two of them on that date. + +Q Now if I could refer you to Count Number + +11 , and if you could summarize for the grand jury + +what the evidence is related to that count? + +A On or about these dates, a facility of + +interstate commerce was used, specifically the + +telephone, between + +, and + +These phones were utilized to set up and + +for Mr. Epstein. + +the third massage, + +Epstein touched + +to + +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 + +breasts. He stroked her vagina. He used a back + +massager on + +during the massages. + +On at least two occasions Epstein + +involved + +activity. + +the massager on + +which + +stroked + +He masturbated + +into the sexual + +and used + +also placed hand on her + +pulled back. Epstein paid + +\$200 on each these occasions. Epstein + +also provided her with a bathing suit, four + +tickets to see David Copperfield on her 18th + +birthday, provided those tickets for her 18th + +birthday. + +Epstein and Western Unioned + +on at least two occasions and Epstein + +provided with advice dealing with her bad + +credit, with her parents, and her plans for going + +to college, and was 17 when all this + +activity took place. + +Q Okay. So the dates that appear in Count + +11 run through the day before her 18th birthday, + +correct? + +A Yes, they do. + +Q Now with respect to Count Number 55, is + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +that the same evidence that relates to the sex + +trafficking charge? + +A Yes. + +Q Okay. And the date ranges between up + +until she turns 18? + +A Yes, it is. + +Q All right. + +BY + +: Any questions about Jane + +Doe Number Seven? All right. We'll go on to + +Jane Doe Number Eight. + +Q And if you could tell the grand jury + +Jane Doe's first name and her date of birth? + +A Jane Doe Number Eight is + +was born She attended + +High School and she had been + +Epstein's house approximately 15 times. + +Q And who first introduced + +Epstein? + +A + +She + +to Mr. + +Jane Doe Number Six. + +Q And tell us how + +A told + +\$200 if she provided + +that contact began. + +that she could make + +Mr. Epstein with a massage. + +She told her that she would have to take off her + +clothes, but that she could keep her underwear nn. + +1 + +2 + +3 + +4 + +S + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16. + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +on the first massage, we have -- I guess I + +should tell you, we have phone contact between + +and starting February 25, + +2005, and that phone contact continues through + +October of 2005. + +We have over 50 calls between + +and + +calls between + +first massage, + +and we have approximately 25 + +and On that + +brought and set up the + +massage table. left the room. + +Shortly after that, Mr. Epstein entered + +wearing only a towel. massaged Mr. + +Epstein's leg and back. Mr. Epstein masturdated + +during this massage. + +I should tell you that told us + +that -- told law enforcement, that he has the + +girls take off their clothes, and in this massage + +she did remove her clothing down to her underwear. + +She kept her underwear on. + +He would touch her breasts and he would + +also grab her buttock while he was masturbating. + +The massages became more sexual. Mr. Epstein used + +a massager on over her panties, + +old us that on one or two occasions + +she was completely nude and he did use the + +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 + +massager directly on + +On one of the times that she was + +completely nude, Mr. Epstein had cracked + +back before and she -- Epstein told to lay + +down and that he was going to crack er •ack like + +he had done before. + +When she laid down, Mr. Epstein + +performed sexual intercourse on + +stated + +of + +She + +that he did pull out and ejaculated outside + +He gave her an extra 100, \$150. + +had made \$200 up to this point, so it would be + +300, \$350 that Mr. Epstein paid her. + +On another occasion, was brought + +into the massage. nd Mr. Epstein engaged + +in sexual acts while ould continue to + +massage Mr. Epstein. + +Epstein did ask and to kiss + +and he watched as they touched each other. + +I guess, touched -- I should say touched + +breasts and continued to touch Mr. + +Epstein as well as this all went on. + +As + +provided to + +as well as a digital camera. + +far as the gifts that Mr. Epstein + +he gave her a photography book + +told us that + +actually gave her the camera, but it was per + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +S + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Mr. Epstein's instructions. She was 17 at the + +time all this activity + +Epstein's + +A + +She told + +And what did + +knowledge of + +She told Mr. + +occurred. + +say about Mr. + +her age? + +Epstein how old she was. + +him that she was 17. + +Q Now was interviewed shortly after + +the activity ended, correct? + +A Yes. + +Q Do you remember the approximate date + +when Mr. Epstein left Palm Beach County and has + +returned only for court appearances? + +A I believe it was October 6th. It was + +the beginning of October was the last time we have + +him -- or + +Q And + +shortly after + +A Yes, she + +when he left the area. + +was interviewed by the police + +that time? + +was interviewed on November 8. + +Q And during that interview, did she + +explain when the last time was when she had seen + +Mr. Epstein? + +A She had said shortly before her + +birthday. + +Q And she said it was actually the first + +week in October? + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +A Yes. + +Q Now was + +before + +A + +later called to appeal + +the State Grand Jury? + +Yes. + +Q And during that testimony, did she -- + +did she confuse the last day that she saw Mr. + +Epstein? + +A Yes. She stated -- and this was done I + +believe in July of '06, so this would have been + +over a year and some months. She did state that + +the last time she saw Mr. Epstein was the day + +before her birthday and that is when the sexual + +intercourse took place. + +Q Okay. So she thought it was the day + +before her birthday, but based on her earlier + +statement and the records that we have, we know it + +was a few days before her birthday? + +A + +Q Okay. + +Let's -- actually, + +before we go to the Overt Acts, do you mind + +if I ask the agent a question outside? I + +think I caught another error. Excuse us for + +a moment. + +and the witness exit the + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Grand Jury Room.) + +( + +Grand Jury Room.) + +and the witness enter the + +MS. VILLAFANA: There is a discrepancy + +in Overt Act Number 138. The chart that I + +provided to you says -- has the name as + +the relevant defendant and in the indictment + +. So we are trying to confirm + +who the right caller was. + +A GRAND JUROR: Can I ask a question? + +Sure. + +A GRAND JUROR: You had said that he had + +not been in Florida? + +Uh-huh. + +A GRAND JUROR: How do they know that he + +has not come into Florida? + +Okay. We can address + +that without the agent. + +A GRAND JUROR: Could I ask a question? + +Sure. + +A GRAND JUROR: Is there any way that he + +might have been filming this? Does anybody + +know about it, I mean, you know? + +DIcay. We will answer + +those after we finish going through these + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +BY + +items. + +A GRAND JUROR: I knew there was a + +reason you were hauling all those records + +back and forth. + +A GRAND JUROR: After the case is over, + +how long do you actually have to keep all + +that? + +This is all on the + +record. + +A GRAND JUROR: Yeah. It's curiosity. + +Okay. All right. + +Q So from your review of the phone + +records, Special Agent Overt Act + +Number 138 relates to + +A Yes. + +Okay. All right. Now let's run through + +Overt Acts 110, 128, 133, 136, 138, 139, 141 , 142, + +145, 152, 154, and 156. + +Could you let the grand jury know what + +the evidence is supporting those Overt Acts? + +A A review of the phone records indicate + +on those dates there was telephonic contact + +between the and as well as + +statements that called her + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +and in advance as to when Mr. Epstein was in town + +to set up appointments. + +Q And if you could look at Overt Acts 124, + +146, and 149. + +A A review of phone records between + +and indicates there was + +telephonic phone contact on those dates. + +Q Phone calls originating with + +ending with + +A Yes. + +Q And Overt Act Number 147? + +A Overt Act 147, a review of the pihonc + +records indicate that there was telephonic contact + +between and on that + +date as well. + +Q And then Overt Act Number 150, says that + +on September 8, 2005, Defendant received a + +telephone call from Jane Doe Number Eight, and + +what is the evidence related to that? + +A The evidence on that date is that a + +review of those phone records indicates that + +contacted + +Q So with respect to that one, the phone + +call originated with + +with + +as opposed to being + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q Okay. Now if you could turn to Count + +Number 12 and summarize for the grand jury the + +evidence supporting that charge of the enticement + +of a minor? + +A On or about these dates, a facility of + +interstate commerce was used, specifically the + +telephone, specifically + +, and phones were + +u tilized to set and arrange massages, massage + +appointments for Mr. Epstein. + +During the massages, Epstein would ask + +to remove her clothing. She would perform + +the massages either in her underwear or completely + +nude. Epstein masturbated while + +these massages. + +Epstein used a massager on + +vagina with her panties on and with them off. + +Epstein had intercourse with + +performed + +ejaculated outside + +On one occasion, Epstein brought + +into the sexual activity, introduced + +into the sexual activity. They performed + +sex acts on each other, that being + +and Jeffrey Epstein, in front of + +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 + +and she continued to massage Mr. Epstein. + +At Mr. Epstein's request, and + +did kiss as well as touched + +LeascS. Epstein paid 200 to 300 to \$350 to + +nd that depen d e sexual activity. + +Epstein gav book on + +photography as well as a digital camera provided + +to her by + +and + +of age. + +as well as bra and underwear sets, + +told Mr. Epstein that she was 17 years + +Q All right. And is that the same + +evidence with respect to Count Number 56? + +A Yes, it is. + +Q Okay. + +Before we go to those + +other two questions that were posed, are + +there any questions that relates to Jane Doe + +Number Eight? + +Yes, sir. + +A GRAND JUROR: Is there any explanation + +from any of the girls about the number of + +calls versus the number of times they say + +they went there? + +more time. + +I'm sorry. Say it one + +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 + +BY + +A GRAND JUROR: The number of times they + +went to visit versus the number of phone + +calls. There seems to be a big difference. + +THE WITNESS: Yes. There's a lot of + +phone calls and we have phone calls showing + +up prior to his arrival and during his + +arrival and some of the phone calls are + +lengthy and some of them are, you know, + +seconds. + +So either maybe they didn't get through. + +We are looking at a cell phone bill and + +getting those totals from looking at the cell + +phone bill and the calls just vary in time + +length and, you know, the only explanation I + +guess, you know, would be -- and that's just + +me giving you my opinion -- is that, you + +know, either they didn't reach each other, so + +they would continue to call back and forth. + +There was a lot of calls between these + +teenage girls or these adolescent girls as + +well as the phone activity between and + +and with the girls. + +Q All right. And also Special Agent + +, I know that you testified about this + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +earlier in terms of the tendency of victims of + +this type of offense to minimize the number of + +visits, for example, minimize the conduct that + +they engaged in? + +A That is true as well. + +Q So it is possible that the girls went + +more than five times or ten times? + +A Yes. I mean, it's difficult to try to + +get them to tell you an exact number and that's + +why we have approximated, and, again, they have + +minimized either with local law enforcement and + +now when we go back either through time or just + +being able to -- you know, the approach, they have + +been able to tell us a little more of what took + +place. + +Again, stated she went hundreds of + +times. Can we put her down to a number? Two + +hundred and twenty-five phone calls. You know, we + +just know that she went a lot of times. + +You can look at the phone activity of + +seeing the phone calls that are made prior to his + +arrival and during his arrival to try to gage when + +they were there. + +All right. Any other + +questions related to Jane Doe Number Eight? + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +BY + +Okay. + +Q Then we have two questions that were + +raised earlier. One of which was whether there is + +any evidence to suggest that Mr. Epstein filmed + +any of these encounters? + +A We don't have any evidence at this time. + +Some of girls were asked that question but there's + +no evidence to show that he did or indicate that + +he did. + +Q All right. And then the second one was + +we had talked earlier about Mr. Epstein leaving + +Florida and not returning. What evidence do you + +have regarding where Mr. Epstein has been since + +October of 2005? + +A He has -- and I may have misspoke if I + +said he has not ever come back. He has come back + +because of the state charges he has faced. He has + +had to come into Palm Beach County for that. + +We do not believe that he has been here + +other than that since the investigation broke in + +October of '05, other than having to appear before + +the state charges. + +We know where Mr. Epstein resides and we + +have a partner, ICE, Immigration and Customs + +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 + +Enforcement, who can -- is helping us monitor his + +plane activity, and, although, we were not privy + +to all of his domestic flights when he comes in + +and out of the country, we are alerted to that. + +Q And you mentioned earlier that you + +interviewed + +A Yes. + +, correct? + +Q Who currently serves in what position of + +Mr. Epstein? + +A He is currently the house manager for + +Mr. Epstein and maintains the property over in + +Palm Beach. + +Q And what did he tell you about Mr. + +Epstein? + +A He also said that Mr. Epstein has not + +been back. + +Q Okay. + +Any other questions? + +All right. You guys get a break next. All + +right. We will see you -- I will be out of + +town next week and i will probably see you + +the week after that. + +(Witness was excused.) + +CERTIFICATE OF REPORTER + +Certified Court + +Reporter and Notary Public, do certify that the + +transcript is a true and correct transcription of + +my stenotype notes of the testimony of + +SPECIAL AGEN taken before + +certitiea our Reporter + +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 + +UNITED STATES DISTRICT COURT + +SOUTHERN DISTRICT OF FLORIDA + +UNITED STATES OF AMERICA, + +Plaintiff, + +vs. + +EIN, + +and 7 , + +Defendants. + +SPECIAL AGENT + +APPEARANCES: + +TESTIMONY + +OF + +COPY + +Federal Grand Jury 07-103 Federal Building U.S. Courthouse West Palm Beach, Florida Tuesday, March 18, 2008 + +M bib L411L tes Attorney + +Foreperson + +1 imony of SPECIAL AGENT + +2 as taken before the + +3 Federal Grand Jury, West Palm Beach Division, + +4 Federal Building, U.S. Courthouse, Palm Beach + +5 County, State of Florida, on Tuesday, March 18, + +6 2008. + +7 Certified Court + +8 Reporter and Notary Public, State of Florida, + +9 Official Reporting Service, LLC, 524 South Andrews + +10 Avenue, Suite 302N, Fort Lauderdale, Florida, + +11 33301, was authorized to and did report the sworn + +12 testimony. + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +BY + +(Witness enters the Grand Jury Room.) + +THE FOREPERSON: You do solemnly swear + +that the testimony you give will be the + +truth, the whole truth, and nothing but the + +truth, so help you God? + +THE WITNESS: I do. + +THE FOREPERSON: Thank you. Please be + +seated. + +EXAMINATION + +Q Good afternoon, Special Agent + +Would you just remind the grand jury + +of your name and for whom you work? + +A I am + +in West Palm Beach. + +My official name is + +and I work for the FBI here + +Q All right. And you are still one of the + +case agents on Operation Leap Year? + +A Yes, I am. + +Q Have additional subpoenas been issued on + +behalf of this grand jury regarding Leap Year? + +A Yes, they have. + +Q And have documents been received in + +response to those subpoenas? + +A Yes, they have. + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +a + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q What subpoenas were issued and what + +items were received? + +A The items that are received are in this + +box for your review at a later time, but starting + +with the first subpoena that we had received + +documents back for would be from American Express. + +The subpoena was issued and we received + +credit card account information. + +Q Okay. + +A Do you want me just to -- + +Q You can just go through them. + +A A subpoena was issued to J. Epstein + +Virgin Island Foundation, Inc., J. Epstein and + +Company, Epstein Interests, Financial Trust + +Company, Inc., and we received documents on all + +three of those except for -- all four of those + +except for Jeffrey Epstein and Company -- + +J. Epstein and Company, which we received a letter + +of no response. + +The next subpoena was issued to the Palm + +Beach County School Board and we received + +transcript request forms. The next grand jury + +subpoena was issued to , Airport + +Executive, Town Car Services. We received a + +verbal that there were no records from Mr. + +2 + +3 + +4 + +S + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +We issued a grand jury subpoena to the + +custodian of records for Majestic Theater, which + +we received ticketing records for. + +We issued a grand jury subpoena or you + +issued a grand jury subpoena for the custodian of + +records at the Broward Center for the Performing + +Arts and we received ticketing records. + +We issued a subpoena for the custodian + +of records for the Kravis Center for the + +Performing Arts and received a letter of no + +records response. + +We issued a subpoena for the custodian + +of records for Live Nation Theatrical Broadway + +Across America. Again, received a response letter + +of no records. + +We issued another subpoena for the + +custodian of records from Live Nation Theatrical + +Broadway Across America and that we did receive + +some ticketing records. + +We issued a subpoena to Bear Sterns and + +Company, Inc., and we received personnel files and + +account information. We issued a grand jury + +subpoena for Wolf Camera and we received + +transaction records. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +We have issued a grand jury subpoena to + +Amazon.com and received order records. We issued + +a grand jury subpoena to Federal Express and + +received shipping records, and all that is + +contained in this box. + +Q All right. + +BY + +And at the end of our + +preservation, you will be welcome to look + +through any of those records and we also will + +bring them to the next session. + +A GRAND JUROR: I have a question. + +Yes. + +A GRAND JUROR: We subpoenaed + +information from theaters. I heard you say + +ticketing information or records from a few + +of them. + +Did we subpoena that information to + +establish location of the defendant or I + +guess he's not a defendant yet? + +THE WITNESS: Just as corroborating + +evidence of testimony provided by the girls. + +Their statements provided to us. + +A GRAND JUROR: Okay. + +A: + +Q Okay. Special Agent each + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +member of the grand jury has before them a copy of + +a chart. Do you also have a copy of this chart + +entitled Revised Indictment Summary Chart + +(by victim)? + +A Yes. + +Q And then you also provided to everyone a + +list of Jane Does with photographs? + +A Yes, I did. + +Q Okay. Can you just explain to the grand + +jury how -- which Jane Does we are going to be + +talking about today? + +A We are going to talk about Jane Does One + +through Six and Nine and Ten, and what you have + +here is a Jane Doe list of One through 19. We + +will be going through the first Six and Nine and + +Ten. + +As you can see, if you look at these two + +columns you'll see in the indictment we have + +before you is going to have the new Jane Doe + +numbers and the column to the right of that shows + +you what their Jane Doe number used to be. + +So Jane Does Nine and Ten, when we spoke + +about those two before, and we will go through + +that a little bit later, we referred to those as + +Jane Does Six and Seven. From here on out, we + +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 + +will refer to them as Jane Does Nine and Ten. + +A GRAND JUROR: I have a question about + +Jane Doe Number One, and pointed this + +out. The date of birth is The + +range of activity dates is 1988 to 2003? + +THE WITNESS: That's a typo. That + +should be + +Thank you for catching + +that. + +A GRAND JUROR: I was about ready to + +have a problem here. I was having a real + +problem. Yeah. + +Okay. Thank you. + +A GRAND JUROR: I was about to take the + +law into my own hands. + +THE WITNESS: Let there be noted on the + +summary chart, there is a typo correction for + +Jane Doe Number One. The range of activity + +for her is 1998 to 2003. + +This chart is a chart that we put + +together because I have testified in the past + +as well as you may have heard other testimony + +regarding some of the Jane Does, and we are + +going to be talking about them today and in a + +later session. + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +We want we provided this to you sort + +of as an aid so that you can go back and + +access the grand jury transcripts and go to + +the date that the testimony was provided. + +If you look at the last column where it + +says, Grand Jury Transcript Pages, on this + +form it will tell you the date of the grand + +jury, who provided that testimony, and the + +page number where you can find testimony + +related to those specific Overt Acts and + +substantive counts. + +So the two columns next to that -- let's + +just take Jane Doe Number Two and run through + +that real quick. Jane Doe Number Two, we + +have not testified about before. So that is + +her number and will always remain her number. + +Her date of birth is + +The range of activity and that reflects the + +range of activity that we have her connected + +to Mr. Epstein and his assistants. + +The next two columns are the Overt Acts + +and the associated substantive counts. The + +Overt Acts support those substantive counts + +and again the last column you would at that + +point go to my testimony on May 8th, 2007, + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +and look on the transcript on Pages Six and + +Seven, and that would be my testimony for the + +Overt Acts, the supporting evidence and + +testimony for Overt Acts One + +through 18. + +BY MS. VILLAFANA: + +Q But, Special Agent just so + +that it is clear, when you testified back in May, + +you weren't testifying specifically about Jane Doe + +Number Two, but her name came up in -- with + +respect to one of the other Jane Does? + +A Exactly. + +Q Okay. So any information related to + +those Jane Does would be in the transcript pages? + +A Yes. + +Does that make sense to + +everyone how we have organized that? + +BY + +Q Now Special Agent , if you + +could look at the proposed indictment, and I'm + +looking at the Background section of the + +indictment specifically Paragraphs One through + +Nine, which deal with Mr. Epstein's background and + +who he employed. + +Have you testified about that material + +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 + +in the past? + +A Yes, I have. + +Q And let me just direct you to Overt Two, + +which is at the top of Page Two. There is a + +reference to L.G., and I don't believe we have + +talked about L.G. before. + +Can you tell the grand jury who that is? + +and she is a + +personal assistant or an assistant for Mr. Epstein + +in his New York office. + +Q All right. And just for the court + +reporter, is + +is that correct? + +A Yes, it is. + +Q Then Paragraph Three talks about three + +individuals, , and Can you tell + +the grand jury who those persons are? + +Q And if you look at the summary chart on + +the second page, there are columns for and + +Do you see those at the bottom of Page Two? + +A Yes, I see them. + +Q And those refer to and + +where you have testified about + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +them before or where was + +testified about them? + +A Yes. + +Q I know that you have testified about + +Mr. Epstein's residence here in Palm Beach, but if + +you could look at Paragraph Five of that + +introductory section, which is on Page Two. + +Are you -- can you provide the grand + +jury with the location of Mr. Epstein's New York + +residence? + +A Mr. Epstein currently has a property + +located at 9 East 71st Street, New York, New York. + +Q If I could direct you to Page Five of + +the proposed indictment in Paragraphs 18 through + +25 of the introductory section. + +Can you tell the grand jury about where + +the various victims in this case attended high + +school? + +A I can. Starting with Paragraph 18. + +Would you like me to just run through them? + +Q Sure. + +Mho + +A Jane Doe Number Four attended + +High School and High School. + +Jane Doe Number Five attended igh + +School. Jane Doe Numbers Six, Eight, and 12, + +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 + +attended High School. + +I should state that all of these high + +schools are located in Jane + +Doe Number Seven attended High + +School in + +Jane Doe Numbers Nine, 14, 15, 16, 17, + +18, and 19 attended + +in + +High School + +Jane Doe Number Ten + +attended High School in + +Jane Doe Number 1 1 attended the + +school located in area; + +Jane Doe Number 13 attended + +High School in and the Jane + +Does attended these high schools during some point + +of the contact with Mr. Epstein. + +Q Now Special Agent I know + +that not each and everyone of the Jane Does is + +listed in this. Did some of the Jane Does leave + +school before they began their relationship with + +Mr. Epstein? + +A Yes, they did. + +Q Now everyone was handed a copy of a + +document entitled, Merged Flight Manifests. If I + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +could ask you to take a look at that, and in the + +proposed indictment if you could turn to Page 32. + +Special Agent I'm going to + +ask you about Overt Acts 191 through 225. Can + +you tell the grand jury what the basis is for the + +allegations set forth in 191 through 225? + +A We received through the issuance of a + +grand jury subpoena the flight manifest from Mr. + +Epstein's pilot and that is our evidence to show + +the travel that Mr. Epstein did, which is + +displayed in Overt Acts 191 through 225. + +Q And the chart that is entitled Merged + +Flight Manifests, what does that include? + +A This chart will show the grand jury that + +in January 2004 through -- basically, Mr. + +Epstein's travel in '04 and '05 on his two + +personal aircrafts, which would be the Boeing 727 + +and the Gulfstream. + +If you look at this chart, the first + +column is the date of departure, the date that he + +left, and you'll see airport codes in the next + +column that tells you the airport that he left and + +what time he left would be the next time, the + +departure time. + +It will tell you what airport he was + +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 + +arriving in and what time he arrived at that + +airport, and the last would be the actual + +aircraft itself, which aircraft he was traveling + +on, and just to remind the grand jury, Hyperion + +is the Gulfstream and JEGE is the Boeing 727. + +Q And who created this chart, the Merged + +Flight Manifests Chart? + +A The FBI. + +Q And where did they gather this + +information from? + +A We subpoenaed or the grand jury issued a + +subpoena to the pilot and pilots of Mr. Epstein + +and through counsel the pilots gave us a copy of + +the flight manifest for those two years and I have + +here a set of the flight manifests that were + +provided to us by the grand jury subpoena and have + +marked each of the Overt Acts from 191 to 225 + +So that if any time the grand jury would + +like to come and look at the actual manifest the + +pilots gave us, you'll be able to see the data + +that this form was taken from. + +Q Okay. Thank you. + +Before I go on, does + +anyone have any questions about those Overt + +Acts and where this information came from? + +1 + +2 + +3 + +4 + +Yes, sir. + +A GRAND JUROR: Is there something that + +ties in these travel itineraries to the + +actual fact that there was a meeting or + +6 + +something planned? I mean, where does that + +tie together? Traveling is not against the + +7 law. + +8 Right. The way that we + +9 had the indictment organized before was an + +10 attempt to do this in chronological order, + +1 1 which seems to be more confusing rather than + +12 less confusing. + +13 So when you look at the -- when you hear + +14 the testimony from Special Agent + +15 and when you look at the Overt Acts related + +16 to the victims and when he went to see them, + +17 you'll see that the dates of travel relate to + +18 the dates of his meeting with the victims. + +19 Does that make sense? + +20 A GRAND JUROR: Yes. + +21 BY + +22 Q Is there anything else, Special Agent + +23 that I should add to that? + +24 A No. It will become clear once we + +25 testify about the travel count. + +1 + +2 + +3 + +4 + +S + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +BY + +A GRAND JUROR: Can I just ask which + +airport is ISM? + +THE WITNESS: You know, I can in the + +next session, I would be happy to bring the + +airport codes. + +A GRAND JUROR: Okay. + +THE WITNESS: Obviously, we focused in + +on his times when he traveled into the Palm + +Beach County area and that would be PIMA or + +PBI, but I can certainly provide all the + +airport codes at our next session. + +Q All right. Now throughout the Overt + +Acts portion where there are discussions of + +various Jane Does, there will be mentioned a + +telephone call. + +So, for example, if you look at Page + +Ten, Paragraph 17, it says on or about April 23rd, + +2004, Defendant placed a telephone + +call to a telephone used by Jane Doe Number Two. + +Do you see that? + +A Yes. + +Q And Special Agent what is + +the evidence that we have related to the telephone + +calls that are mentioned in the Overt Acts? + +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 + +A We have issued administrative subpoenas + +to telecommunication companies for cell phone + +records for Mr. Epstein's assistants as well as + +many of the Jane Does. + +These specific Overt Acts are reflected + +in those telephone records and we have also + +prepared for the grand jury -- I brought with me + +today, and I will bring with me next time, all of + +the telephone records for -- that we have received + +via administrative subpoenas. + +Today I brought the ones pertaining to + +the Overt Acts and what we have done is we have + +taken those cell phone records and we have marked + +for the grand jury all the Overt Acts that are + +listed in the indictment. + +You'll note when you go to that page, + +there will be a little mark by the telephone call + +that we are specifically talking about in the + +Overt Acts. + +Q And can you just remind the grand jury + +what information will be on those records? + +A It will be telephonic contact between + +or + +, telephonic contact between his + +assistants and the Jane Does. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q + +was called + +the call? + +It will show the telephone number that + +and the dates and time and length of + +A Yes, it will. + +Q All right. + +Any questions before we + +start talking about the sexual activity + +between the defendant and the victims? Okay. + +No questions. + +BY + +Q Let's talk first about Jane Does One and + +Two. They are grouped together in Overt Acts One + +through 18. Who is Jane Doe Number One? + +A Jane Doe Number One is a white female. + +Her name is She was born in + +and she lived in the Palm Beach County area + +during the time that she had contact with Mr. + +Epstein. + +Q Has she been interviewed? + +A Statements have been provided to the FBI + +by Jane Doe Number One. + +Q In addition to her statements, who else + +has provided information regarding Jane Doe Number + +One? + +A Jane Doe Number Two and Jane Doe Number + +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 + +One's boyfriend at the time she had contact with + +Mr. Epstein, which is + +Q Who is referred to as in the + +indictment? + +A Yes. + +Q During what period of time, did Jane Doe + +Number One have contact with Mr. Epstein? + +A Jane Doe Number One met Mr. Epstein when + +she was 15. So that would be in the last half of + +1998 until 2003 that we are aware of. + +Q How did she meet Jeffrey Epstein? + +A She met Mr. Epstein at age 15 and + +according to her boyfriend when she was 20, Mr. + +Epstein sent her to Thailand for massage therapy + +school. + +So she -- the time frame that she was + +with Mr. Epstein was from the age of 15 until we + +are aware of is age 20. never + +saw Jane Doe Number One again after she went to + +Thailand. + +She would contact him by telephone, but + +she never returned back. + +She never came back that he is aware of. + +So the time frame tiCat we had Jane Doe Number One + +with Mr. Epstein is from age 15 to 20. + +1 + +2 + +3 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +I'm sorry, the question you asked me + +was: How did they meet? They met by a friend of + +Mr. Epstein's. Jane Doe Number One was working at + +and a friend of Mr. Epstein's, + +Ghislaine Maxwell. + +Would you like the spelling? + +THE REPORTER: Yes, please. + +THE WITNESS: G-H-I-S-L-A-I-N-E, + +Maxwell, who was a friend of Mr. Epstein, met + +Jane Doe Number One at Mar-a-Lago and Jane + +Doe Number One soon after began working and + +providing massages for Mr. Epstein. + +BY + +Q What sexual activity was Jane Doe Number + +One involved in with Jeffrey Epstein? + +A Through the statements provided by Jane + +Doe Number Two, when Jane Doe Number Two was 14 + +years of age, she saw Jane Doe Number One naked + +and engaged in what she believed to be sexual + +intercourse with Mr. Epstein. + +Q Now did Jane Doe Number One recruit any + +one else to go to Jeffrey Epstein's home? + +A At this time, the only Jane Doe that we + +are aware of is Jane Doe Number Two or the only + +individual we are aware of is Jane Doe Number Two. + +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 + +Q Okay. So let's talk about Jane Doe + +Number Two. Who is she? + +named + +A Jane Doe Number Two is + +She was born in + +a white fethale + +She lived in Palm Beach County, Florida, at the + +time she had contact with Mr. Epstein. + +Q And how has she been interviewed? + +A Yes. + +Q During -- how old was she during the + +time frame that Jane Doe Number Two was involved + +with Mr. Epstein? + +A She was 14 at the time that she first + +met Mr. Epstein. + +Q And she was involved with him until she + +was 17? + +A We have in or about the beginning of + +2001 , which would make her 14 up until 2004. + +Q And how did she come to meet Mr. + +Epstein? + +A Jane Doe Number One brought Jane Doe + +Number Two to Mr. Epstein's residence for the + +first time. Mr. Epstein was introduced to Jane + +Doe Number Two by Jane Doe Number One. + +There was a massage that took place with + +the two of them and then Jane Doe Number One + +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 + +engaged in sexual activity that I mentioned + +earlier where Jane Doe Number Two informed us that + +she sat on the couch and observed what she + +believed the two of them to engage in sexual + +intercourse. + +Q And at the time, Jane Doe Number One was + +17 and Jane Doe Number Two was 14? + +A Yes. + +• All right. + +A And I'm not sure if that was actually + +the first or second visit that she went. So it + +was either the first visit or the second that the + +sexual activity that I described took place. + +They may have gone there the first time + +and just performed a massage for Mr. Epstein, but + +on the second occasion the sexual activity that I + +described took place. + +Jane Doe Number Two stated that, you + +know, the three years that we discussed from 2001 + +to 2004, she provided Mr. Epstein with over, in + +that three-year period, over 100 massages and all + +but three of the massages were sexually in nature. + +Q How much was she paid for performing + +sexual massages for Epstein? + +A She was paid between 200 and \$400. + +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 + +A would schedule Jane Doe Number Two + +and sometimes would be out of town and be in + +New York and scheduled her to come and work, but + +guess she was + +Number + +Q + +primary role was to schedule or I + +the one that would schedule Jane Doe + +Two to come and perform the massages. + +Did ever actually lead Jane + +Doe Number Two upstairs up to the bedroom? + +A Yes. After Jane Doe Number One took + +Jane Doe Number Two, Jane Doe Number Two started + +going by herself. The first time that Jane Doe + +Number Two arrived at Mr. Epstein's by herself, + +took Jane Doe Number Two from the + +kitchen and took her upstairs for the massage that + +was to be performed for Mr. Epstein. + +Q Now you mentioned the sexual activity + +that Jane Doe Number two observed between Jane Doe + +Number One and Mr. Epstein. Was there ever any + +other females involved in the sexual activity? + +A Yes. Mr. Epstein introduced an + +unidentified female who performed oral sex on Jane + +Doe Number One -- I'm sorry, on Jane Doe Number + +Two while Mr. Epstein had sexual intercourse with + +the unidentified female. + +Q Now you mentioned that at some point, + +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 + +Mr. Epstein asked Jane Doe Number Two to start + +bringing girls; is that correct? + +A Yes. + +Q And did he describe what exactly he + +wants, the type of person that he wanted her to + +bring? Did she report that he asked her if she + +had any younger friends that would be interested + +in performing massages? + +A Yes. He asked her -- can I just have a + +moment? + +Q Of course, yes. + +A I'm sorry. Jane Doe Number Two, Mr. + +Epstein asked her if she had any friends that + +would be interested in performing these massages + +and then he also inquired if she had any younger + +friends that would -- that she could bring to him + +and then he offered to pay her \$100 for each + +person that she brought. + +Q In addition to the sexual activity with + +Mr. Epstein, did ever involve Jane + +Doe Number Two in any specific activity? + +A Yes. contacted Jane Doe + +Number Two by telephone and asked her to come to + +Mr. Epstein's residence that Mr. Epstein wanted + +to take pictures of Jane Doe Number Two. + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +paid Jane Doe Number Two \$500 to + +take naked photographs of Jane Doe Number Two at + +Mr. Epstein's residence in and around the house + +and pool area at the request of Mr. Epstein. + +Q And approximately how old or how old + +does Jane Doe Number Two believe she was at the + +time? + +A Jane Doe Number Two informed us that she + +was 16 years old when took the + +photographs of her naked. + +Q What did Jane Doe Number Two say about + +whether Jeffrey Epstein knew her true age? + +A Jane Doe Number Two was informed by Jane + +Doe Number One to say if asked her age that she + +was -- she should respond that she was 17. When + +they went -- and went to Mr. Epstein's residence + +and were upstairs performing massages, Mr. Epstein + +asked Jane Doe Number Two her age. + +She responded four --. And then he + +said, so you're 14? And Mr. Epstein informed Jane + +Doe Number Two that they would just keep that + +between them. + +Q So in other words, he knew that she was + +14 when she started seeing him? + +A Yes. She did not remember to say 17 and + +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 + +just naturally came out four --. And then he + +finished that statement for her, so you're 14? + +And then stated that they would keep that between + +them. + +Q Now is the -- can you summarize -- does + +your testimony cover the evidence supporting the + +allegations in Overt Acts One through 18? + +A Yes, it does. + +Q And if I could ask you to refer to Count + +Two, which appears on Page 38. Is the evidence + +that you have just summarized the basis for the + +allegation that Jeffrey Epstein and + +procured Jane Doe Number Two to engage in + +commercial sex acts knowing that she was under 18? + +A Yes. + +Q So is there anything else that you + +wanted to mention with respect to either Jane Doe + +Numbers One or Two? + +A The only other thing I didn't bring up + +was the gifts that Mr. Epstein provided to Jane + +Doe Number Two and Mr. Epstein would provide her + +with lingerie. + +He gave her tickets to a concert, a + +local concert. He would also send her via FedEx + +packages to her residence, and in one of those + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +packages Jane Doe Number Two informed us that + +there was a Massage for Dummies book that she + +received by FedEx from Mr. Epstein. + +And the grand jury should know that we + +have received records from FedEx which corroborate + +Mr. Epstein's address and packages going to Jane + +Doe Number Two's residence. + +Q And those records relate to Mr. + +Epstein's personal Federal Express account? + +A Yes. + +A GRAND JUROR: Jane Doe Number Two, do + +we know how old she was when Mr. Epstein + +asked her to bring younger friends? Was she + +already in his eyes up there and he wanted + +them younger? + +THE WITNESS: When Jane Doe Number Two + +was 16, about midway through her 16th year, + +and at that point she did + +not provide Mr. Epstein with anymore + +massages. + +So I know she went away for a time + +period and when she came back, you know, she + +and did not want to do massages + +anymore. So at that point, she may have + +brought her friends as well as prior to that. + +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 + +BY + +Q Do you know exactly when she started + +bringing other girls? + +A I don't know that I want to say that it + +was before or after. We just know that she was + +asked by Mr. Epstein to bring other females and he + +would pay \$100. + +The only other thing we haven't talked + +about is we have message pads that were recovered + +in the execution of the state search warrant on + +Mr. Epstein's residence, and I think the grand + +jury has seen copies of some of those message + +pads. + +We do have a message pad for Jane Doe + +Number Two that gives you an example of -- and I + +can pull that out and read that to the grand jury, + +if you would like? + +Q Sure. + +A This particular message pad is + +basically -- it's a carbon copy message that again + +was recovered during the execution of the state + +search warrant at Mr. Epstein's residence and this + +shows that this was dated on March 11 , 2003. + +It's from with her phone number + +and it's marked that she telephoned and it's + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +marked, please call, and it was signed by one of + +Mr. Epstein's employees. So again the date that + +the contact here is March 11 , 2003. + +Q And Jane Doe Number Two was still under + +the age of 18 at that time? + +A Yes, she was. + +Q Okay. Now if we could turn to Jane Doe + +Number Three and who is she? + +A Jane Doe Number Three is a white female + +named She was born and she + +lived in the Palm Beach County area. + +Q Has she been interviewed? + +A Yes. + +Q And during what period of time did Jane + +Doe Number Three have contact with Jeffrey + +Epstein? + +A Beginning in or around 2003 to up 2005. + +Q And how old was she during that time + +frame? + +A She was 15 when she first met Mr. + +Epstein. + +Q And how did she meet him? + +A Jane Doe Number Two brought Jane Doe + +Number Three to Mr. Epstein's house. They + +traveled by taxi there. Jane Doe Number Two took + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Jane Doe Number Three upstairs to meet Mr. + +Epstein. + +They provided Mr. Epstein a massage in + +their underwear. Mr. Epstein asked Jane Doe + +Number Two to leave and Jane Doe Number Three + +finished the massage. + +Mr. Epstein masturbated in front of Jane + +Doe Number Three on that first occasion, and Jane + +Doe Number Three, after the massage, she was paid + +\$200 and she left the residence. + +Q All right. + +A On other occasions after that, + +would be the one to contact Jane Doe Number + +Three to come to the residence to provide massages + +for Mr. Epstein. + +Q And you have phone records showing calls + +from + +Three's + +A + +phone? + +Yes, I do. + +phone to Jane Doe Number + +Q In addition to that, the masturbation + +during that massage, was there other sexual + +activity that occurred between the two of them? + +A Yes, there was. Mr. Epstein requested + +that Jane Doe Number Three rub his chest and + +nipples while he masturbated. He also used a + +1 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +massager slash vibrator on Jane Doe Number Three's + +He touched Jane Doe Number Three's + +He also instructed Jane Doe Number Three + +to straddle an unidentified female and fondle the + +unidentified female as he used she believed it was + +a vibrator or a massaging device on the + +unidentified female's + +Q And on each of those occasions was she + +paid? + +A Yes, she was. + +Q And did she tell you about the range of + +of money that she would receive for each visit? + +A She received \$200 for the time period + +when she would provide Mr. Epstein during the + +massages. + +Q Did Jane Doe Number Three recruit anyone + +to go Mr. Epstein's house? + +A Yes. + +Q And did she tell you anything about what + +Epstein's requests were in terms of who she should + +bring? + +A Yes. Mr. Epstein asked her to bring + +other females. Jane Doe Number Three stated that + +Mr. Epstein's preferences were short little white + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +girls. Jane Doe Number Three brought girls ages + +15 to 25 years of age. + +Q Were there girls whom Jane Doe Number + +Three brought to Mr. Epstein's home whom he did + +not like? + +A Yes. Mr. Epstein informed Jane Doe + +Number Three that he didn't want girls with + +tattoos, older girls, or black girls. + +He also expressed frustration with Jane + +Doe Number Three when she didn't have new females + +for him. + +Q And how would he express that + +frustration? + +A He hung up on her. He telephoned her. + +He also would telephone her. and Mr. + +Epstein would call Jane Doe Number Three and on + +this particular occasion when she didn't have a + +female for him, he hung up. + +Q Now if we could go back to the girls + +whom Mr. Epstein didn't like. You said older + +girls, girls with tattoos, and black girls. When + +Jane Doe Number Three brought those girls to his + +home, did he allow them to massage him? + +A No. + +So those girls were just sent away? + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +A They were, but they were paid for + +coming. + +Q Now if I could just refer you to Overt + +Acts 29 and 31 , which are on Page 12. There is a + +reference to two written telephone messages and + +could you just remind the grand jury of where that + +information comes from? + +A I actually have copies. Overt Acts 29 + +and 31 are message pads or carbon copy messages + +that were found at Mr. Epstein's residence when + +the Town of Palm Beach Police Department executed + +a state search warrant on his residence. + +The first one, Overt Act 29, is a + +message dated November 8, 2004. It was taken at + +1 :15 p.m. The message is for Mr. Epstein from + +Cortney with her cell phone number and in + +quotations it says, I have a female for him. At + +the bottom is an + +house manager, + +employee of Mr. Epstein, the + +Overt Act 31 is a message for Mr. + +Epstein dated January 29, 2005. It looks like the + +time was 4:10 p.m. It is from with her + +phone number on it and in quotations, I have a + +female for him. Again, initialed by Mr. Epstein's + +house manager, + +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 + +Q Now does your testimony today summarize + +the evidence supporting the allegations in Overt + +Acts 19 through 31? + +A Yes. + +Q And if I could just refer you to Count + +12, which appears on Pages 40 and 41 of the + +proposed indictment. Is this the evidence that + +you just summarized the basis for the allegations + +that Jeffrey Epstein and used a + +facility of interstate commerce to persuade, + +induce, and entice Jane Doe Number Three to engage + +in prostitution and in sexual activity for which a + +person can be charged with a criminal offense? + +A Yes. + +Q Was Jane Doe Number Three under the age + +of 16 during part of her interactions with Mr. + +Epstein? + +A Yes, she was. + +Q And under Florida law, could Mr. Epstein + +have been charged with lewd and lascivious + +molestation, lewd and lascivious conduct, and lewd + +and lascivious exhibition based upon his touching + +of Jane Doe Number Three's breasts, genitals, his + +solicitation of Jane Doe Number Three in a lewd + +and lascivious act and his masturbation and + +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 + +exposure of his genitals to her? + +A Yes. + +Q All right. Let's turn to Jane Does + +Four, Five, and Six, please, and could you tell + +the grand jury who Four, Five and Six are? + +A Jane + +female named + +Doe Four, Number Four is + +She was born in + +a white + +She attended both High School + +High School in Palm Beach + +County. + +Jane Doe Number Five is a white female + +named . She was born in + +She attended High School in Palm Beach + +County, Florida. + +Jane Doe Number Six is a white female + +named She was born in and + +she' attended High School in + +Palm Beach County, Florida. + +Q Have the three Jane Does Four, Five, and + +Six been interviewed? + +A Yes. + +Q And during what period of time did they + +have contact with Jeffrey Epstein? + +A In or around the first half of 2004 + +possibly going into the summer months is when we + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Four's underwear was pulled aside by Mr. Epstein + +and he stroked her + +o And she was paid following that massage + +as well? + +A Yes, she was. + +Q Who led Jane Does Four and Five up to + +the bedroom during that first massage? + +A Jane Does Four and Five went upstairs. + +They were taken upstairs by + +And what evidence is there regarding + +Jeffrey Epstein's knowledge of Jane Doe Number + +Four's true age? + +A Jane Doe Number Four told Mr. Epstein + +how old she was. + +Q In respond to his question about her + +age? + +A Yes. I'm sorry. Mr. Epstein asked her + +age and she informed Mr. Epstein of her true age + +at the time. + +Q Now during -- you mentioned that the + +first massage that the two of them were together, + +Jane Does Four and Five, and did Mr. Epstein + +masturbate in front of them at that time? + +A Yes, he did, and I should say that Mr. + +Epstein requested them to remove their clothing + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +during that massage as well. + +Q Okay. And did he ever instruct Jane Doe + +Number Four to play with his nipples? + +A Yes. + +Q You said that Jane Doe Number Four + +returned after that first massage, correct? + +A Yes. + +Q How was she contacted to set up those + +later massages? + +A Jane Doe Number Four was contacted by + +Q Via telephone? + +A Via telephone, yes. + +Q Did Jane Doe Number Four bring anyone + +else to Jeffrey Epstein's home? + +A Jane Doe Number Four brought Jane Doe + +Number Six. Jane Doe Number Four and Jane Doe + +Number Six performed the massage together and then + +Jane Doe Number Four was asked to leave. + +At that point, the sexual activity that + +was performed on Jane Doe Number Six by Mr. + +Epstein was the digital penetration of Jane Doe + +Number Six' as well as the use of a + +massager slash vibrator on Jane Doe Number Six's + +vagina. He did masturbate. + +1 + +2 that massage, and Jane Doe Number Six did not + +3 return again after that massage. + +4 + +5 Jane Doe in terms of her age or something that + +6 would indicate her age? + +7 + +8 school. + +9 + +10 A Yes, she told him she went t + +He did pay Jane Doe Number Six \$200 for + +Q Did Mr. Epstein ask anything related to + +A He asked them where they went to high + +Q And did she respond? + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +Q Does your testimony cover the evidence + +supporting the allegations in Overt Acts 32 + +through 45? + +A Yes. + +Q And if I could refer you to Count Three, + +which is on Page 39, is the evidence that you just + +summarized the basis for the allegation that + +19 Jeffrey Epstein and procured Jane Doe + +20 Number Four to engage in commercial sex acts + +21 knowing that she was under 18? + +22 A Yes. + +23 Q So in other words, Jeffrey Epstein knew + +24 her age before he asked her that the second time? + +25 I A Yes. + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q And referring to Count 13, which is on + +Page 41 and 42, is this evidence that you just + +summarized the basis for the allegations that + +Jeffrey Epstein and used a facility + +of interstate commerce to persuade, induce, and + +entice Jane Doe Number Four to engage in + +prostitution? + +A Yes. We have the testimony of Jane Doe + +Numbers Four, Five, and Six as well as others and + +we also have telephonic contact between Jane Doe + +Number Five by just shortly before + +her 18th birthday. + +Q All right. If I could refer you to Jane + +Does Number Nine and Ten at this point. The Overt + +Acts related to them start on Page 17. + +Let's start with Jane Doe Number Nine. + +Can you remind the grand jury who Jane Doe Number + +Nine is? + +A Jane Doe Number Nine is a white female + +named She was born in and + +she attended High School. + +Q And have you testified about her + +previously? + +A Yes. + +Q Is there anything that you want to + +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 + +either clarify or add regarding your earlier + +testimony? + +A There is one thing that I'd like to add + +that I didn't testify to earlier about an incident + +that occurred in November, specifically, November + +28, 2004. + +Jane Doe Number Nine was 17 years of age + +and we have a police document in the Town of Palm + +Beach that shows that Jane Doe Number One + +mean, Jane Doe Number Nine was provided with an + +envelope filled with money that Mr. Epstein had + +arranged for one of his employees to give Jane Doe + +Number Nine. + +The reason the Palm Beach Police + +Department were called in is the employee didn't + +recognize Jane Doe Number Nine's car, which was + +parked in the driveway. So he contacted the + +police. + +Once the police came out though, Mr. + +Epstein's employee went and retrieved an envelope + +and it had money in it. The employee told the + +police that Jane Doe Number Nine was a massage + +therapist and continued with the officer stating + +off the record that Mr. Epstein had many young + +girls that come over for that. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q And that related to Overt Act Number 80 + +on Page 18? + +A Yes, it does. + +Q Okay. And can you just remind the grand + +jury during what period of time Jane Doe Number + +Nine had contact with Jeffrey Epstein? + +A Jane Doe Number Nine had contract + +between July 2004 and September of 2005, during + +that time period. + +Q And how old was she during that time + +frame? + +A She was 17 up until her birthday, which + +is the end of December of 2004, but continued to + +have contact with Mr. Epstein after she was 18. + +Q And can you summarize the sexual + +activity that Jane Doe Number Nine was involved in + +with Mr. Epstein? + +A Yes. Mr. Epstein fondled Jane Doe + +Number Nine's breasts. Mr. Epstein masturbated + +in front of Jane Doe Number Nine. Mr. Epstein + +used a massager slash vibrator on Jane Doe Number + +Nine's + +He Jane Doe Number + +Nine. He performed oral sex on Jane Doe Number + +Nine. Mr. Epstein his penis + +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 + +into the of Jane Doe Number Nine. + +Jane Doe Number Nine watched per Mr. + +Epstein's request as Mr. Epstein engaged in oral + +sex and sexual intercourse with + +Mr. Epstein paid Jane Doe Number Nine to + +perform oral sex on When Jane + +Doe Number Nine didn't want to do that, Mr. + +Epstein offered her an additional \$200 if Jane Doe + +Number Nine would perform oral sex on + +for five minutes, which Jane Doe Number + +Nine did. + +Q And how much was Jane Doe Number Nine + +paid? + +A Jane Doe Number Nine was paid -- on the + +first visit we have that she was paid \$200. She + +was paid anywhere from \$300 to \$1 ,000. + +Q And what did that depend on? + +A The sexual activity. \$300 to \$600 was + +the sexual activity. The one time we have noted + +that she was given \$1 ,000 was when he + +of her. + +Q And you mentioned that Jane Doe Number + +Nine was still seeing Mr. Epstein after she turned + +18. What evidence do you have that corroborates + +her statements that these activities that we are + +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 + +talking about occurred before she was 18? + +A We have phone records. We have message + +pads. We have obtained documents that are from + +Majestic Theater and from Jet Blue that indicate + +that Mr. Epstein purchased a ticket for Jane Doe + +Number Nine for her 18th birthday. + +She actually flew to New York on her + +18th birthday. Mr. Epstein thought it would be + +better for her to travel when she turned 18. So + +she traveled to New York and Mr. Epstein purchased + +tickets -- or paid for her to see the Phantom of + +the Opera, which was being performed at the + +Majestic Theater. + +Q Now when you say Mr. Epstein, who was + +actually making the calls? + +A I'm sorry. Mr. Epstein's assistant, + +Q Okay. Let's talk about Jane Doe Number + +Ten as well because they are related. Can you + +remind the grand jury who Jane Doe Number Ten is? + +A Jane Doe Number Ten is a white female + +named and she was born in + +She attended High School, and I talked + +about her prior. + +Q You have talked about her previously? + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +A Yes. + +Q Is there anything that you want to + +clarify or add related to that testimony? + +A No, nothing. + +Q And can you remind the grand jury during + +what period of time Jane Doe Number Ten was + +involved with Mr. Epstein? + +A She went to Mr. Epstein's residence in + +July of 2004 to November 2005. We have her still + +in contact with Mr. Epstein. + +Q And how old was she during that time + +frame? + +A She was 17. Up until + +she turned 18. + +Q And how is Jane Doe Number Ten related + +to Jane Doe Number Nine in connection with these + +events? + +A Jane Doe Number Nine brought Jane Doe + +Number Ten to Mr. Epstein's residence. + +Q Now if I could refer you to Overt Act + +Number 67, and it says on or about July 16, 2004, + +Defendant caused Jane Doe Number Nine + +to make one or more telephone calls to a telephone + +used by Jane Doe Number Ten. + +Do you see that? + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +A Yes. + +Q Can you tell us in addition to the + +testimony from Jane Doe Number Nine what the + +telephone records show? + +A An examination of Jane Doe Number Nine's + +cell phone records show that she contacted Jane + +Doe Number Ten, and if you examine + +records you will see that there was contact + +between Jane Doe Number Nine and + +Q On the same day? + +A On the same day. + +Q All right. What was the sexual activity + +that Jane Doe Number Ten was involved with, with + +Jeffrey Epstein? + +A I'm sorry. One second. I just want to + +look at this. Okay. I'm sorry. What was your + +question? + +Q What was the sexual activity that Jane + +Doe Number Ten was involved in with Mr. Epstein? + +A Mr. Epstein fondled Jane Doe Number + +Ten's breasts. Mr. Epstein masturbated in front + +of Jane Doe Number Ten. Mr. Epstein used a + +massager slash vibrator on Jane Doe Number Ten's + +and he also touched Jane Doe Number Ten's + +1 + +2 + +3 + +4 + +S + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q How much did Jane Doe Number Ten + +receive? + +A Jane Doe Number Ten was paid \$200. + +Q And she went to Mr. Epstein's home more + +than once? + +A Yes. + +Q Can you give the grand jury an idea of + +how many phone calls there were between + +and Jane Doe Number Nine + +A Yes. There were approximately 225 phone + +calls. + +Q And they are in the documents and + +records that you have? + +A Yes. + +Q And what about Jane Doe Number Ten? + +A There were over 100 phones calls between + +and Jane Doe Number Ten, and there + +were also phone calls between Jane Doe Number Ten + +and and those were approximately + +eight calls between Jane Doe Number Ten and + +with only one being prior to her 18th + +birthday. + +There were also approximately seven + +calls with with all but one after + +her 18th birthday. That one was actually on her + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +18th birthday. + +Q And those calls that you are referring + +to relate only to the cellular telephone records + +that you have, correct? + +A Yes. + +Q So if there were calls from Jeffrey + +Epstein's phone numbers to or from that number + +that couldn't necessarily be captured? + +A No. + +Q Okay. Now if I could just ask you to + +look at Count Four. Does your testimony today and + +your prior testimony summarize the basis for the + +allegation that Jeffrey Epstein and + +procured Jane Doe Number Nine to engage in + +commercial sex acts knowing she was under 18? + +A Yes. + +Q And in Count 15 is the evidence that you + +just summarized the basis for the allegation that + +Jeffrey Epstein and used a facility + +of interstate commerce to persuade, induce, and + +entice Jane Doe Number Nine to engage in + +prostitution? + +A Yes. + +Q And also the offense charges using a + +facility of interstate commerce to persuade, + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +induce, and entice Jane Doe Number Nine to engage + +in sexual activity for which the person can be + +charged with a criminal offense. + +With respect to Jane Doe Number Nine, + +what is this offense that Mr. Epstein could have + +been charged with, with respect to that activity + +with her? + +A The sexual intercourse . Epstein + +penetrated Jane Doe Number Nine' with his + +penis. + +Q And then with respect to Jane Doe Number + +Ten, Count Five charges that Jeffrey Epstein and + +procured Jane Doe Number Ten to + +engage in commercial sex acts knowing that she was + +under 18. How do you summarize for us the + +evidence supporting that? + +A Yes. The only thing I'd like to add to + +that is we also do have message pads that were + +obtained through the Town of Palm Beach with the + +execution of the search warrant at Mr. Epstein's + +residence as well as trash pulls that the Town of + +Palm Beach conducted in the spring of '05, 2005, + +and one of those trash pulls I believe -- is it + +Overt Act 81? + +Q Yes, 81 . + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +A The trash pull -- found in the trash + +pull conducted by the Town of Palm Beach was + +Jeffrey Epstein's letterhead and on it handwritten + +that says 10:30, and then on + +Friday around 2:00, and then there's a + +underneath it. This was obtained on April 1st, + +2005. + +And then the message pad that I referred + +to -- I'm sorry, the trash pull was Overt Act 147. + +The Overt Act was 81 , and that message pad is + +that message is from Jeffrey Epstein dated + +December 4, 2004. The time is 2:55 p.m. + +The message is from and it's + +written, would like to work at 4:00 p.m. + +if possible, and then in parenthesis, is + +scheduled for 5:00 today. At the bottom it says, + +the movie is at 7:30. + +Q And you said that was written by + +Defendant and it's addressed to + +Jeffrey Epstein? + +A Yes. + +THE FOREPERSON: We need a break. + +Okay. Should we take + +ten minutes? + +THE FOREPERSON: Is this a good time? + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +This is fine. + +(Witness exits the Grand Jury Room.) + +(Thereupon, a short break was taken.) + +(Witness enters the Grand Jury Room.) + +We are back on the + +record. Is there a quorum? + +THE FOREPERSON: Yes. + +BY L: + +Q We were just finishing up with Jane Doe + +Number Ten. Special Agent you + +summarized a lot of evidence relating to Jane Doe + +Number Ten. + +Is the evidence that you summarized also + +the basis for the allegation in Count 16 that + +Jeffrey Epstein and used a facility + +of interstate commerce to persuade, induce, and + +entice Jane Doe Number Ten to engage in + +prostitution? + +A Yes. + +Q Okay. I just want to review with you, + +Special Agent that you did, in fact, + +previously testify about background information + +regarding the defendants in this indictment? + +A Yes. + +Q And that was in one of your earlier + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +transcripts? + +A Yes. + +Q Okay. I also wanted to ask you about + +the victims who we have discussed today. We have + +discussed eight victims, Jane Does One through Six + +and Nine and Ten. + +Are you aware of whether any of those + +victims have used illicit drugs or have had + +mental health issues? + +A Yes. + +Q And can you summarize that for the grand + +jury? + +A Jane Doe Number -- we'll start with Jane + +Doe Number Two. After the contact or during the + +contact, but after she had met Mr. Epstein, Jane + +Doe Number Two between ages 15 and + +17. + +I guess what I am trying to say is that + +she first had contact with Mr. Epstein when she + +was 14 years of age. So when I interviewed Jane + +Doe Number Two, she informed me that + +started between the ages 15 to 17. + +She had a + +1 + +Her mother had + +Doe Number Two told me that helped her + +Q Meaning you can be + +health issues? + +Q I did. + +A And she had also been i + +Jane + +A Yes. And did you ask me about mental + +Jane Doe Number Two revealed to us that + +when she was very young, + +and has suffered from that ever + +since. + +Q Any other Jane Does? + +A Yes. Jane Doe Number Three also has a + +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 + +She dropped out of school at an early age + +Jane Doe Number Three expressed that + +she just wanted to feel numb. + +She stayed with a lot of she did not + +stay at home a lot after age 15 due to the fact + +that + +Q Okay. + +A And then the last Jane Doe that we + +talked about would have been Jane Doe Number Nine, + +and we do have information that she has + +Q With respect to those Jane Does, did you + +go about getting independent corroboration for + +their statements so that you weren't relying + +exclusive on what they told you about Mr. Epstein? + +A Yes. We talked about that today. + +Specifically, with Jane Doe Number Two, we have + +her statement, but along with that statement we + +have telephone records. + +Those telephone records indicate + +telephonic contact with We have the + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +message pads recovered during the search warrant, + +recovered during the execution of the state search + +warrant that indicates the contact here. + +We have statements from other Jane Does + +and witnesses that corroborate. We also have + +received the FedEx records indicating packages + +were sent to Jane Doe Number Two from Mr. + +Epstein. + +When you look at Jane Doe Number Three, + +the same thing, we have telephone records that + +indicate telephonic contact. We have message pads + +recovered in the state search warrant, execution + +of the state search warrant. + +Then we have the statements of other + +Jane Does, and in regards to Jane Doe Number Nine, + +again, we have the telephone records which + +indicate telephonic contact with We + +have the message pads. + +In addition to that, we have the message + +pads that were recovered by the state search + +warrant and they also found her high school + +transcript. It was found at Mr. Epstein's + +residence. + +We have statements from other Jane Does, + +and then we also have the records for her from the + +1 Jet Blue, you know, showing the travel on her + +2 birthday. Majestic Theater showing that she + +3 attended the theater. + +4 We have -- after her 18th birthday, she + +5 was involved in a play where Mr. Epstein had his + +6 assistant deliver flowers to the high school. She + +7 was 18 at the time, but we do have records showing + +8 the purchase of those flowers and a note with + +9 instructions for the house manager on what to do + +10 and how to pick up the flowers and deliver them, + +11 as well as rental car records. + +12 Q So we are not relying exclusively on + +13 their statements? + +14 A No. + +15 Q Okay. Now I know that there has been + +16 some coverage in the press of civil lawsuits that + +17 were filed against Mr. Epstein. Are your aware of + +18 the press coverage? + +19 A Yes. + +20 + +21 + +22 + +23 A Yes. + +24 + +25 + +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 + +BY + +A No. + +A No. + +If I could ask you to + +step outside. I want to find out if the + +grand jurors have any questions for you. + +(Witness exits the Grand Jury Room.) + +(Witness enters the Grand Jury Room.) + +Q Special Agent + +question was about + +, the first + +Are there other victims of + +whom you are aware of or are not on the Jane Doe + +One through 19 list? + +A Yes. + +Q Okay. Now there was a question about + +Jane Doe Number One. You testified that she had + +left to go to Thailand and her boyfriend, + +her former boyfriend, hadn't had contact + +with her in a long while. + +Have other people had contact with her + +more recently? + +A Yes. + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +• 16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Q Including people from the FBI? + +A Yes. + +Q So there is no -- she's not in any harm + +or danger? + +A No, and I didn't mean to imply. There + +is also a question of a \$3,000 phone bill that + +Jane Doe Number One said that she would take care + +of when she got back. She never returned. + +Her stuff that was in their apartment, + +the dog, she never came back, and I think there + +was some concern on his part, but we know where + +Jane Doe Number One is. + +Q Just so the grand jury knows. Where is + +she living now? + +A + +Q There also was a question about Jane Doe + +Number Two. You testified that + +BY + +A Not that we are aware of. + +Q Okay. + +Those were all the + +questions. Any follow up on those three + +questions? Okay. + +Q One of the things I wanted to just + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +1 1 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +discuss with the grand jury is our next + +presentation and I had asked you to bring all of + +the items that were procured under the grand jury + +subpoena. + +Can you tell the grand jury about some + +particularly bulky items that you are hoping they + +will forgo? + +A We have from the execution of the state + +search warrant by the Town of Palm Beach, they + +have three massage tables or one chiropractic + +table and two massage tables that are rather + +large, that if you would like to see them, we can + +bring two of the ones that were located upstairs. + +So what I'd like to do + +is we are going to step outside to leave you + +with some time to review the transcripts of + +the earlier testimony. + +Before you leave, if you could decide + +• + +whether or not you want us to bring those + +large massage tables up from the Miami lock + +up for you to see or if Special Agent + +description is sufficient. + +A GRAND JUROR: Just bring a picture. + +A GRAND JUROR: How about a picture? + +A GRAND JUROR: Would that be + +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 + +sufficient? + +We can do that. We will + +step outside and if that is what you decide, + +that is what we will do, and so what I'm + +going to do now is step outside. + +I have 13 -- I don't know why I picked + +13, but we have 13 copies all of the previous + +transcripts. Please take your time reviewing + +them, and just let us know when you are + +finished and then we will collect all of the + +paperwork that we submitted to you and the + +transcripts and we will bring them the next + +time as well. + +Any questions before I go? We'll just + +be outside. Please feel free to call on us. + +Before we step outside, we also have left + +here the materials that were returned today + +as well as the phone records of the flight + +manifest if you want to take a look at + +those. + +(1 the witness, and the + +court reporter exit the Grand Jury Room.) + +the witness, and the + +court reporter enter the Grand Jury Room.) + +We are back on the + +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 + +record. I understand that there was a + +question regarding two of the CDs that were + +in one of the files. + +BY MS. VILLAFANA: + +Q Special Agent could you + +just tell the grand jury what those are in + +response to? + +A These are in response to the subpoena + +that was issued to the custodian of records of + +Bear Sterns and it's basically account statements + +for Mr. Epstein. + +Q Okay. And when we come back next time, + +are you planning on bringing computer equipment + +that will allow the grand jury to open the CDs + +that we have? + +A Yes. We will have a cassette tape for + +audio tapes. We will have a DVD player. We will + +have a computer. We will have a TV with a VCR. + +We will have all kinds of audio videos and + +electronic equipment for you guys to be able to + +look at any of this as well as you will see in + +all the grand jury material that we have collected + +things that you may be interested in viewing on + +these visual aids or these audio visual. + +Q Okay. + +1 + +Any other questions? + +2 A GRAND JUROR: Are we going to get + +3 pictures of this table thing instead of + +4 bringing them in? + +5 A GRAND JUROR: We don't really care. A + +6 picture is sufficient. + +7 Okay. We will have + +8 pictures of the massage tables. Any other + +9 questions? Are you all finished for today? + +10 A GRAND JUROR: I don't know. Are we? + +11 A GRAND JUROR: Yeah, we are. + +12 You are finished with + +13 me. Okay. Great. Thank you so much. + +14 THE WITNESS: Excuse me. Audio visual + +15 aids will be provided in the next grand jury + +16 session. + +17 (Witness was excused.) + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +CERTIFICATE OF REPORTER + +, Certified Court + +Reporter and Notary Public, do certify that the + +transcript is a true and correct transcription of + +my stenotype notes of the testimony of + +SPECIAL AGENT taken before + +the Federal Grand Jury, West Palm Beach, Florida. + +Certified Court Reporter + +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 + +first have them having contact, I believe, they + +have contact with Mr. Epstein. + +Q And how old were they during that time + +frame in early 2004? + +A Both Jane Doe Numbers Four and Five + +would have been 17 at that time, and Jane Doe + +Number Six would have been 16. + +Q What sexually activity did Jane Does + +Four and Five engage in with Jeffrey Epstein? + +A Jane Doe Numbers Four and Five took a + +taxi to Mr. Epstein's house and went upstairs and + +provided Mr. Epstein a massage. Jane Doe Numbers + +Four and Five, the sexual contact that took place + +was or conduct was that Mr. Epstein masturbated in + +the presence of both Jane Doe Number Four and Jane + +Doe Number Five. + +He also instructed Jane Doe Number Four + +to play with his nipples and rub his chest. Both + +Jane Doe Numbers Four and Five were paid \$200 for + +this. 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as to US Attorney Strauss. You may want to let her know that the report will be coming to her (and you), for review and whatever comment your office may wish to offer OPR, and we'll ask for any comments within a couple of weeks. We will be also asking that the draft be closely held. + +Don't hesitate to let me know if you have any questions. + +Best regards, + +Counsel Office of Professional Responsibility U.S Department of Justice + +Washin ton, D.C- 20530 \ No newline at end of file diff --git a/marker2/ds9/EFTA00085681/EFTA00085681.metadata.json b/marker2/ds9/EFTA00085681/EFTA00085681.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bef8f34b79bbacc34d9eabe2276619d2cd61d63f --- /dev/null +++ b/marker2/ds9/EFTA00085681/EFTA00085681.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085681.pdf", + "engine": { + "marker_major": "2", + "marker_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": 0.49, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 50 + ], + [ + "Line", + 24 + ], + [ + "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/EFTA00085681" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085682/EFTA00085682.md b/marker2/ds9/EFTA00085682/EFTA00085682.md new file mode 100644 index 0000000000000000000000000000000000000000..a54198ece918e9c5dd8625847b38c355c694ba27 --- /dev/null +++ b/marker2/ds9/EFTA00085682/EFTA00085682.md @@ -0,0 +1,59 @@ +From: To: + +Subject: FW: Report for ODAG- DB + +Date: Wed, 05 Aug 2020 14:04:24 +0000 + +Attachments: 2020.08.05\_Deutsehe\_Bank\_Urgent\_Report.docx + +PP + +From: + +Sent: Wednesday, August 5, 2020 9:56 AM + +To: + +Cc: + +Subject: FW: Report for ODAG- DB + +This is MLARS's draft UMR on the Deutsche Bank. As larified when I followed up, despite the language below about it going up this morning, MLARS is holding off pending your being briefed on the investigative step. + +From: + +Sent: Wednesday, August 5, 2020 9:39 AM + +To: + +Subject: Fwd: Report for ODAG- DB + +FYI. Tracks our thinking. + +Sent from my iPhone + +Begin forwarded message: + +From: + +Date: August 5, 2020 at 9:37:21 AM EDT + +To: Cc: + +Subject: Report for ODAG- DB + +Begin forwarded message: + +From: + +Date: August 5, 2020 at 9:32:40 AM EDT + +To: + +( [REDACTED] I couldn't find the misspelled Deutsche). + +\*\*\*\*\* + +[REDACTED] + +--- \ No newline at end of file diff --git a/marker2/ds9/EFTA00085682/EFTA00085682.metadata.json b/marker2/ds9/EFTA00085682/EFTA00085682.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a106a87e5a4adfb0a248594d158400436475726b --- /dev/null +++ b/marker2/ds9/EFTA00085682/EFTA00085682.metadata.json @@ -0,0 +1,76 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085682.pdf", + "engine": { + "marker_major": "2", + "marker_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": 866, + "elapsed_seconds": 2.23, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "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": "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/EFTA00085682" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085684/EFTA00085684.md b/marker2/ds9/EFTA00085684/EFTA00085684.md new file mode 100644 index 0000000000000000000000000000000000000000..0f78e9b9dbf70bc01b9dafa6e528b9e41c3a7e97 --- /dev/null +++ b/marker2/ds9/EFTA00085684/EFTA00085684.md @@ -0,0 +1,769 @@ +To: + +Subject: Re: SDNY News Clips Wednesday, July 31, 2019 + +Date: Wed, 31 Jul 2019 23:27:22 +0000 + +Ha, really? In that case pretty sure I've seen the filing but will take a look. Thanks + +Sent from my iPhone + +On Jul 31, 2019, at 7:24 PM, ) < > wrote: + +That article is a reference to a government filing from over a month ago (Spencer Kuvin seems especially interested in being quotes in belated but inflammatory fashion on these issues) — but in any event, the NDGA filing from then is attached. + +From: + +Sent: Wednesday, July 31, 2019 17:14 + +To: + +Subject: FW: SDNY News Clips Wednesday, July 31, 2019 + +It looks like NDGa just filed something in the CVRA litigation — do you have a copy by any chance? + +From: + +Sent: Wednesday, July 31, 2019 5:12 PM + +Cc: + +Subject: SDNY News Clips Wednesday, July 31, 2019 + +# SDNY News Clips + +Wednesday, July 31, 2019 + +### Contents + +Public Corruption. 2 + +Epstein. 2 + +Collins. 18 + +Securities and Commodities Fraud. 20 + +Stewart 20 + +Thompson. 22 + +Pinto-Thomaz. 24 + +Narcotics. 26 + +Castro. 26 + +The U.S. said a California cherry-picker went to Pakistan for terrorist training. Now the case has collapsed. 32 + +Fed Cuts Interest Rates for First Time Since 2008 Crisis. 35 + +### Public Corruption + +Epstein + +#### Jeffrey Epstein Hoped to Seed Human Race With His DNA + +New York Times + +By James B. Stewart, Matthew Goldstein and Jessica Silver-Greenberg 7/31/19 + +Jeffrey E. Epstein, the wealthy financier who is accused of sex trafficking, had an unusual dream: He hoped to seed the human race with his DNA by impregnating women at his vast New Mexico ranch. + +Mr. Epstein over the years confided to scientists and others about his scheme, according to four people familiar with his thinking, although there is no evidence that it ever came to fruition. + +Mr. Epstein's vision reflected his longstanding fascination with what has become known as transhumanism: the science of improving the human population through technologies like genetic engineering and artificial intelligence. Critics have likened transhumanism to a modern-day version of eugenics, the discredited field of improving the human race through controlled breeding. + +Mr. Epstein, who was charged in July with the sexual trafficking of girls as young as 14, was a serial illusionist: He lied about the identities of his clients, his wealth, his financial prowess, his personal achievements. But he managed to use connections and charisma to cultivate valuable relationships with business and political leaders. + +Interviews with more than a dozen of his acquaintances, as well as public documents, show that he used the same tactics to insinuate himself into an elite scientific community, thus allowing him to pursue his interests in eugenics and other fringe fields like cryonics. + +Lawyers for Mr. Epstein, who has pleaded not guilty to the sex-trafficking charges, did not respond to requests for comment. + +Mr. Epstein attracted a glittering array of prominent scientists. They included the Nobel Prize-winning physicist Murray Gell-Mann, who discovered the quark; the theoretical physicist and best-selling author Stephen Hawking; the paleontologist and evolutionary biologist Stephen Jay Gould; Oliver Sacks, the neurologist and best-selling author; George M. Church, a molecular engineer who has worked to identify genes that could be altered to create superior humans; and the M.I.T. theoretical physicist Frank Wilczek, a Nobel laureate. + +The lure for some of the scientists was Mr. Epstein's money. He dangled financing for their pet projects. Some of the scientists said that the prospect of financing blinded them to the seriousness of his sexual transgressions, and even led them to give credence to some of Mr. Epstein's half-baked scientific musings. + +Scientists gathered at dinner parties at Mr. Epstein's Manhattan mansion, where Dom Perignon and expensive wines flowed freely, even though Mr. Epstein did not drink. He hosted buffet lunches at Harvard's Program for Evolutionary Dynamics, which he had helped start with a \$6.5 million donation. + +Others flew to conferences sponsored by Mr. Epstein in the United States Virgin Islands and were feted on his private island there. Once, the scientists — including Mr. Hawking — crowded on board a submarine that Mr. Epstein had chartered. + +The Harvard cognitive psychologist Steven Pinker said he was invited by colleagues — including Martin Nowak, a Harvard professor of mathematics and biology, and the theoretical physicist Lawrence Krauss — to "salons and coffee klatsches" at which Mr. Epstein would hold court. + +While some of Mr. Pinker's peers hailed Mr. Epstein as brilliant, Mr. Pinker described him as an "intellectual impostor." + +"He would abruptly change the subject, A.D.D.-style, dismiss an observation with an adolescent wisecrack," Mr. Pinker said. + +Another scientist cultivated by Mr. Epstein, Jaron Lanier, a prolific author who is a founding father of virtual reality, said that Mr. Epstein's ideas did not amount to science, in that they did not lend themselves to rigorous proof. Mr. Lanier said Mr. Epstein had once hypothesized that atoms behaved like investors in a marketplace. + +Mr. Lanier said he had declined any funding from Mr. Epstein and that he had met with him only once after Mr. Epstein in 2008 pleaded guilty to charges of soliciting prostitution from a minor. + +Mr. Epstein was willing to finance research that others viewed as bizarre. He told one scientist that he was bankrolling efforts to identify a mysterious particle that might trigger the feeling that someone is watching you. + +At one session at Harvard, Mr. Epstein criticized efforts to reduce starvation and provide health care to the poor because doing so increased the risk of overpopulation, said Mr. Pinker, who was there. Mr. Pinker said he had rebutted the argument, citing research showing that high rates of infant mortality simply caused people to have more children. Mr. Epstein seemed annoyed, and a Harvard colleague later told Mr. Pinker that he had been "voted off the island" and was no longer welcome at Mr. Epstein's gatherings. + +Then there was Mr. Epstein's interest in eugenics. + +On multiple occasions starting in the early 2000s, Mr. Epstein told scientists and businessmen about his ambitions to use his New Mexico ranch as a base where women would be inseminated with his sperm and would give birth to his babies, according to two award-winning scientists and an adviser to large companies and wealthy individuals, all of whom Mr. Epstein told about it. + +It was not a secret. The adviser, for example, said he was told about the plans not only by Mr. Epstein, at a gathering at his Manhattan townhouse, but also by at least one prominent member of the business community. One of the scientists said Mr. Epstein divulged his idea in 2001 at a dinner at the same townhouse; the other recalled Mr. Epstein discussing it with him at a 2006 conference that he hosted in St. Thomas in the Virgin Islands. + +The idea struck all three as far-fetched and disturbing. There is no indication that it would have been against the law. + +Once, at a dinner at Mr. Epstein's mansion on Manhattan's Upper East Side, Mt Lanier said he talked to a scientist who told him that Mr. Epstein's goal was to have 20 women at a time impregnated at his 33,000square-foot Zorro Ranch in a tiny town outside Santa Fe. Mr. Lanier said the scientist identified herself as working at NASA, but he did not remember her name. + +According to Mr. Lanier, the NASA scientist said Mr. Epstein had based his idea for a baby ranch on accounts of the Repository for Germinal Choice, which was to be stocked with the sperm of Nobel laureates who wanted to strengthen the human gene pool. (Only one Nobel Prize winner has acknowledged contributing sperm to it. The repository discontinued operations in 1999.) + +Mr. Lanier, the virtual-reality creator and author, said he had the impression that Mr. Epstein was using the dinner parties — where some guests were attractive women with impressive academic credentials — to screen candidates to bear Mr. Epstein's children. + +Mr. Epstein did not hide his interest in tinkering with genes — and in perpetuating his own DNA. + +One adherent of transhumanism said that he and Mr. Epstein discussed the financier's interest in cryonics, an unproven science in which people's bodies are frozen to be brought back to life in the future. Mr. Epstein told this person that he wanted his head and penis to be frozen. + +Southern Trust Company, Mr. Epstein's Virgin Island-incorporated business, disclosed in a local filing that it was engaged in DNA analysis. Calls to Southern Trust, which sponsored a science and math fair for school children in the Virgin Islands in 2014, were not returned. + +In 2011, a charity established by Mr. Epstein gave \$20,000 to the Worldwide Transhumanist Association, which now operates under the name Humanity Plus. The group's website says that its goal is "to deeply influence a new generation of thinkers who dare to envision humanity's next steps." + +Mr. Epstein's foundation, which is now defunct, also gave \$100,000 to pay the salary of Ben Goertzel, vice chairman of Humanity Plus, according to Mr. Goertzel's résumé. + +"I have no desire to talk about Epstein right now," Mr. Goertzel said in an email to The New York Times. "The stuff I'm reading about him in the papers is pretty disturbing and goes way beyond what I thought his misdoings and kinks were. Yecch." + +Alan M. Dershowitz, a professor emeritus of law at Harvard, recalled that at a lunch Mr. Epstein hosted in Cambridge, Mass., he steered the conversation toward the question of how humans could be improved genetically. Mr. Dershowitz said he was appalled, given the Nazis' use of eugenics to justify their genocidal effort to purify the Aryan race. + +Yet the lunches persisted. + +"Everyone speculated about whether these scientists were more interested in his views or more interested in his money," said Mr. Dershowitz, who was one of Mr. Epstein's defense lawyers in the 2008 case. + +Luminaries at Mr. Epstein's St. Thomas conference in 2006 included Mr. Hawking and the Caltech theoretical physicist Kip S. Thome. One participant at that conference, which was ostensibly on the subject of gravity, recalled that Mr. Epstein wanted to talk about perfecting the human genome. Mr. Epstein said he was fascinated with how certain traits were passed on, and how that could result in superior humans. + +Mr. Epstein appears to have gained entree into the scientific community through John Brockman, a literary agent whose best-selling science writers include Richard Dawkins, Daniel Goleman and Jared Diamond. Mr. Brockman did not respond to requests for comment. + +For two decades, Mr. Brockman presided over a series of salons that matched his scientist-authors with potential benefactors. (The so-called "billionaires' dinners" apparently became a model for the gatherings at + +In 2004, Mr. Brockman hosted a dinner at the Indian Summer restaurant in Monterey, Calif., where Mr. Epstein was introduced to scientists, including Seth Lloyd, the M.I.T. physicist. Mr. Lloyd said that he found Mr. Epstein to be "charming" and to have "interesting ideas," although they "turned out to be quite vague." + +Also at the Indian Summer dinner, according to an account on the website of Mr. Brockman's Edge Foundation, were the Google founders Sergey Brin and Larry Page and Jeff Bezos, who was accompanied by his mother. + +"All the good-looking women were sitting with the physicists' table," Daniel Dubno, who was a CBS producer at the time and attended the dinner, was quoted as saying. Mr. Dubno told The Times that he did not recall the dinner or having said those words. + +Mr. Brockman was Mr. Gell-Mann's agent, and Mr. Gell-Mann, in the acknowledgments section of his 1995 book "The Quark and the Jaguar," thanked Mr. Epstein for his financial support. + +However impressive his roster of scientific contacts, Mr. Epstein could not resist embellishing it. He claimed on one of his websites to have had "the privilege of sponsoring many prominent scientists," including Mr. Pinker, Mr. Thome and the M.I.T. mathematician and geneticist Eric S. Lander. + +Mr. Pinker said he had never taken any financial or other support from Mr. Epstein. "Needless to say, I find Epstein's behavior reprehensible," he said. + +Mr. Thome, who recently won a Nobel Prize, said he attended Mr. Epstein's 2006 conference, believing it to be co-sponsored by a reputable research center. Other than that, "I have had no contact with, relationship with, affiliation with or funding from Epstein," he said. "I unequivocally condemn his abhorrent actions involving minors." + +Lee McGuire, a spokesman for Mr. Lander, said he has had no relationship with Mr. Epstein. "Mr. Epstein appears to have made up lots of things," Mr. McGuire said, "and this seems to be among them." + +Some of Jeffrey Epstein's victims don't want new charges in South Florida + +South Florida Sun Sentinel + +By Marc Freeman + +7/30/19 + +Financier Jeffrey Epstein has been branded a pervert and an abuser, but not all of his victims want to see him prosecuted further in South Florida. + +Some of the girls Epstein assaulted at his Palm Beach mansion before 2008 have already reached financial settlements with him and fear they'll lose their anonymity. Federal prosecutors — the ones who approved his lenient plea deal to begin with — say they fully support that position. + +Epstein faces separate federal sex trafficking charges in New York, but the debate about prosecuting him in South Florida will be resolved soon enough. A federal judge in West Palm Beach is considering whether to strike down parts of a controversial 2007 deal that gave him and unnamed co-conspirators immunity from federal charges. + +U.S. District Judge Kenneth Marra ruled in February that Epstein's non-prosecution agreement violated the federal Crime Victims' Rights Act. Dozens of victims were improperly kept in the dark about it until after it had been finalized. + +Marra must decide how to rectify this violation 12 years later, after receiving arguments from lawyers for two of Epstein's victims, prosecutors and Epstein. + +The victims in the case, cited as Jane Does, say the necessary remedy is for Epstein to face what they say are long overdue charges in Florida. + +"To be sure, Jane Doe 1 and 2 very much appreciate the laudable efforts of the diligent prosecutors in New York," their lawyers wrote. "But those New York charges, important though they are, still leave Epstein's crimes in Florida uncharged and all of his co-conspirators at large." + +Lawyers for the U.S. government disagree. + +They concede that prosecutors back then "fell short" of treating victims properly as they reached a settlement with Epstein. But the attorneys now contend "the past cannot be undone" and the deal must be upheld under the law. + +Among their arguments is that many victims clearly want to let it go, because they are content with financial settlements they obtained from Epstein, and his 2008 guilty plea to two state prostitution charges. That plea resulted in 13 months in Palm Beach County Jail and registering as a sex offender. + +The prosecutors say they reached this position based on "conversations" with the victims and their lawyers, without giving a specific number. + +Attorney Spencer Kuvin of West Palm Beach said he represents one victim who met with the U.S. Attorney's Office in April. + +"She said she'd like to see him prosecuted and put in jail," Kuvin said. "She said, `I don't know if that's a realistic possibility, but that's what I want.'" + +He said it's not surprising that other victims are less inclined to participate. + +"When you have so many victims, you're going to have just as many different opinions as to how it should be handled," Kuvin said. "But that shouldn't stop the prosecution of a predator. One victim that wants to come forward ... is enough to put him away." + +The federal prosecutors explained that while some victims "would like to see Epstein prosecuted for his crimes, they valued anonymity above all and were not willing to speak with law enforcement or otherwise participate in any criminal or civil litigation due to the risk that their involvement may become known to family, friends, or the public." + +This is not to say there aren't many victims who are eager to see Epstein face new charges in South Florida, wrote Byung J. Pak, U.S. Attorney for the Northern District of Georgia, and Jill E. Steinberg and Nathan P. Kitchens, special attorneys for the Southern District of Florida. + +But they conclude that reopening their cases against Epstein in South Florida still "exacerbates the harm to victims who have attempted to readjust their lives in the interim." + +Kuvin said he agrees, "It's a valid concern for some of the victims." + +Attorneys for two victims in the pending Crime Victims' Right Act litigation blasted the government's reasoning to leave Epstein's non-prosecution agreement in place. + +Lawyers Bradley Edwards, Paul Cassell and Jack Scarola say any South Florida victims who are not willing to prosecute Epstein because of privacy concerns can simply decline to do so and remain anonymous. + +The lawyers say there's no way that prosecuting Epstein for some victims would harm other victims unless the prosecutors somehow disclose their identities in the process. + +"The Government's argument thus boils down to a stop-us-before-we-do-something-bad claim that deserves no credence from the Court," wrote Edwards and his co-counsel on behalf of the two women, identified as Jane Doe 1 and Jane Doe 2. + +They also pointed out that the prosecutors weren't asserting the alleged "risk" to some victims outweighs obtaining justice for their clients. + +"But in any event, on closer examination, the Government's argument turns out to be vaporous," they wrote this month. + +Epstein's lawyers told the judge they support the South Florida prosecutors' arguments that the once-secret deal shouldn't be blown up to allow new charges. + +Jeffrey Epstein faces `a million pages' of evidence: defense lawyer + +New York Post By Andrew Denney and Bruce Golding 7/31/19 + +Prosecutors have 1 million pages of evidence against Jeffrey Epstein, his lawyer revealed in court Monday without shedding any new light on the jailhouse incident that left the convicted pedophile with bruises on his neck. + +No marks were visible on Epstein's neck, and he never appeared to be in pain during the 15-minute hearing in Manhattan federal court. + +The judge overseeing the case tentatively scheduled Epstein's trial for June 2020 after a prosecutor said the child sex-trafficking charges against him should be resolved as "swiftly as possible." + +"We don't think any delay in this is in the public interest," Manhattan Assistant US Attorney said. + +Epstein's trial is expected to last four to six weeks, and the defense will have all the prosecution's evidence against the multimillionaire financier by Oct. 31, she said. + +Defense lawyer Martin Weinberg objected to starting the trial before September 2020, saying, "We need time to review a million pages of discovery." + +But Judge Richard Berman said he was blocking out time in June 2020 on the presumption that the defense would be ready by then. + +Weinberg didn't make any mention of the July 23 incident in which law enforcement sources have said Epstein, 66, was found sprawled on the floor of his cell in the Metropolitan Correctional Center, where he's being held without bail. + +Weinberg declined to answer questions about the incident outside court. + +Epstein, who wore dark blue jail scrubs over a brown T-shirt, didn't speak during the hearing. + +He's pleaded not guilty to accusations he sexually abused dozens of underage girls - some as young as 14 in his Upper East Side townhouse and his waterfront mansion in Palm Beach, Florida, between 2002 and 2005. + +Berman set a Sept. 13 deadline for defense motions in the case, and Weinberg said he planned to seek dismissal of a conspiracy charge on grounds of double jeopardy tied to allegations that underpinned a non-prosecution agreement that Epstein struck in 2008 with then-Miami US Attorney Alex Acosta. + +That deal was exposed last year in an award-winning series of stories by the Miami Herald, and controversy that erupted following Epstein's July 6 arrest forced Acosta to resign as President Trump's labor secretary. + +#### Jeffrey Epstein appears in court for first time since reported jail injuries + +The Guardian By Victoria Bekiempis 7/31/19 + +Financier Jeffrey Epstein looked physically healthy when he appeared in court in New York on Wednesday in his sex trafficking case, about a week after reportedly being found unconscious in his jail cell with neck injuries. + +He wore dark blue jail scrubs during his brief appearance in Manhattan federal criminal court on Wednesday morning, in a proceeding scheduled before the apparent incident behind bars last week. + +There were no signs of injuries that had been reported at the time and he appeared well and more neatly presented than at some previous hearings. + +The Jeffrey Epstein scandal + +His lawyers did not bring up the incident in court and refused to comment on the topic following the hearing, which focused on scheduling issues. + +Prosecutor asked for a June 2020 trial date to be set, telling the judge: "We don't think that any delay in this case is in the public interest." + +The Manhattan US attorney's office alleged earlier in July that Epstein "sexually exploited and abused dozens of minor girls" from 2002 to 2005. Some of his victims were just 14 years old, prosecutors alleged. + +The disgraced financier, who was arrested on 6 July, pleaded not guilty several weeks ago. + +Epstein has long been accused of sexually abusing underage girls. He also has purported connections to Donald Trump, Bill Clinton and Prince Andrew, and moved in elite circles, including for several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. + +Epstein and the Miami US attorney's office, headed at the time by Alexander Acosta, brokered a plea deal in 2008 that closed a federal inquiry involving at least 40 teenage girls. + +Under this arrangement, Epstein pleaded guilty to state charges, which presented far less potential jail time than if he had faced federal charges. The Miami Herald reporter Julie K Brown exposed the secretive nature of this agreement. Acosta resigned from his post as Trump's labor secretary following extensive criticism of the deal. + +Epstein has unsuccessfully requested bail while awaiting trial. The 66-year-old, who registered as a sex offender following the Florida case, had maintained through lawyers that he neither posed a danger nor risk of flight. + +In rejecting Epstein's request, Judge Richard Berman said, "the government has established danger to others and to the community by clear and convincing evidence", adding: "I doubt that any bail package can overcome a danger to the community." + +Epstein's lawyers are appealing against the decision, according to court filings. + +Late last week, Judge Berman also ruled in favor of prosecutors' proposed protective order, which will keep case materials relating to "the government's ongoing investigation of uncharged individuals" under wraps. + +Associated Press By Larry Neumeister and Jim Mustian 7/31/19 + +A subdued Jeffrey Epstein listened passively in court Wednesday as a judge said he won't face trial on sex trafficking charges before June 2020, and more likely a few months afterward. + +There was no mention at the Manhattan federal court appearance or any visible sign of injuries after the 66 year-old financier was found on the floor of his cell last week with neck bruises. + +Epstein's lawyer, Martin Weinberg, refused to say what might have left his client with neck bruises after the court hearing. + +Assistant U.S. Attorney urged a June trial date for the man accused of arranging to have sex with girls as young as age 14, saying there is "a public interest in bringing this case to trial as swiftly as possible." + +But Weinberg said the case is far from "ordinary," adding the defense team won't be ready before Labor Day 2020. He said prosecutors delayed bringing charges that relate to alleged crimes that occurred in the early 2000s at Epstein's residences in Manhattan and Florida. + +U.S. District Judge Richard M. Berman said a trial projected to last four to six weeks could tentatively begin June 8, but he'll likely defer to defense lawyers' needs if they are not ready. + +Epstein's demeanor in court was noticeably different from previous appearances, when he was actively engaged with his lawyers and looking through papers. + +On Wednesday, he sat quietly, his hands folded in front of his face through much of the 20-minute proceeding. Occasionally, he looked toward courtroom artists and reporters seated in a jury box. + +Epstein has remained at the Metropolitan Correction Center, which is adjacent to the downtown Manhattan courthouse. + +He has pleaded not guilty to sex trafficking charges that carry the potential for up to 45 years in prison. + +Berman refused bail after concluding he is a danger to the community and a flight risk. Prosecutors have said they fear he might try to influence a growing number of witnesses who support charges that he recruited and abused dozens of girls in New York and Florida in the early 2000s. His lawyers had argued he should be allowed to stay under house arrest in his Manhattan mansion. + +His lawyers say an agreement reached with federal prosecutors a dozen years ago disallows the charges and they say he has committed no new crimes. + +The lawyers agreed to file written arguments about the agreement and double jeopardy claims by Sept. 13. Oral arguments will occur in October. + +The non-prosecution deal was reached before he pleaded guilty in state court in Florida to prostitution-related charges involving underage girls. Afterward, he was required to register as a sex offender and pay restitution to many victims. While he served a 13-month jail term, he was permitted to leave jail to work for 12 hours a day, six days a week. + +Epstein was arrested July 6 when he arrived at a New Jersey airport on a private jet from Paris, where he has a home. + +Victims of Jeffrey Epstein share the emotional toll that sexual abuse has taken on them — even years after the abuse occurred. Miami Herald reporter Julie K. Brown interviewed the young women, most speaking for the first time about Epstein. BY EMILY MICHOT I JULIE K. BROWN For the first time since he was found semi-conscious in his jail cell with telltale bruise marks on his neck, accused sex trafficker Jeffrey Epstein appeared in a Manhattan court room. + +Epstein — onetime friend of the rich and powerful, including current President Donald Trump and past President Bill Clinton — learned Wednesday that he will not face trial until at least next June. + +The multimillionaire part-time resident of Palm Beach sat subdued in front of U.S. District Court Judge Richard M. Berman. The 66-year-old defendant wore dark blue jail scrubs and glasses. + +His lawyer, Martin Weinberg, declined to reveal any details about the incident at the Metropolitan Correctional Center, which occurred July 23, including whether it was a suicide attempt, an attack by a fellow detainee or something else. His client is being held without bond. + +Wednesday's hearing in New York City lasted just 15 minutes. + +Epstein, a financier who owns homes around the world, including a waterfront estate in Palm Beach, was arrested July 6, nearly eight months after the Miami Herald published Perversion of Justice, a two-year investigation of a much-reviled secret plea deal in 2007-2008 that spared Epstein a sweeping federal indictment despite allegations of sexual abuse by nearly three dozen underage girls. + +He had just arrived from France at New Jersey's Teterboro airport on his private jet when authorities met him and took him into custody. + +During the early- and mid-2000s, Epstein allegedly ran what amounted to a sexual pyramid scheme, using recruiters to lure girls as young as 14 to his lavish Palm Beach and Manhattan mansions with the promise that they would receive \$200 to give a man a massage. The girls have alleged that they were coerced into sex. + +The girls were paid additional money if they would recruit others girls, police and court records allege. Epstein had assistants schedule as many as three visits a day. + +Rather than face federal charges that could have put him away for life, Epstein pleaded guilty in state court to minor prostitution charges and served just a year in the county stockade — which permitted him to leave the lockup for his luxurious downtown West Palm Beach office for 12 hours a day, six days a week. This "work release" arrangement, highly unusual for a sex offender, is now under criminal investigation by order of the Palm Beach sheriff, Ric Bradshaw, who oversees the stockade and approved the work release. + +Although Assistant U.S. Attorney said it is important to move swiftly ahead with Epstein's court case, his defense attorney said he needs time in light of the approximately one million pages of documents that that comprise the evidence collected against his client. + +Labor Secretary Alex Acosta held a press conference to defend his role in handling the Jeffrey Epstein sexual abuse case. Acosta was a U.S. Attorney who approved the Epstein plea deal in 2008. By CSPAN In the meantime, Epstein will be given a chance to argue that the non-prosecution agreement, executed in 2008, gave him, his schedulers, his alleged madam and others immunity from federal charges and that the new charges constitute impermissible double jeopardy. + +In its series of articles, the Herald highlighted the role of Alexander Acosta, then-U.S. attorney for the Southern District of Florida, in approving the immunity agreement, including a controversial stipulation that Epstein's accusers not be told of the arrangement. Facing searing criticism after Epstein's arrest, Acosta resigned his post as President Trump's labor secretary. + +Reuters + +7/31/19 + +Financier Jeffrey Epstein could go to trial on charges of sex trafficking involving dozens of underage girls as early as next June, though his lawyers told a court on Wednesday they may need more time. + +At a hearing in Manhattan federal court, prosecutors sought a June 2020 trial date, while a lawyer for Epstein asked that it wait another three months. + +The lawyer, Martin Weinberg, said Epstein and his legal team needed more time to review evidence, expected to total more than 1 million pages. + +U.S. District Judge Richard Berman said he would tentatively set aside time for a trial beginning June 8, but revisit the issue later. He said he normally allowed defendants more time to prepare if they wished. + +Assistant U.S. Attorney said a trial is expected to last four to six weeks. + +Prosecutors have accused Epstein of arranging for girls under the age of 18 to perform nude "massages" and other sex acts, and of paying some girls to recruit others. Epstein has pleaded not guilty. + +Wednesday's hearing occurred one week after Epstein was reportedly found unconscious and with neck injuries in his jail cell at the Metropolitan Correctional Center in downtown Manhattan. + +Epstein, dressed in blue jail scrubs, had no visible injuries on Wednesday. His lawyers declined to comment on the reports after the hearing. + +Epstein is appealing Berman's July 18 denial of his request to remain under house arrest in his \$77 million mansion on Manhattan's Upper East Side while awaiting trial. + +The charges against Epstein focus on alleged misconduct from at least 2002 to 2005. + +They followed Epstein's 2008 guilty plea to state prostitution charges in Florida, in exchange for the Justice Department's agreement not to prosecute him on similar charges. + +Epstein served 13 months in jail and agreed to register as a sex offender under the 2008 agreement, which is now widely considered too lenient. + +His lawyers have argued this month that the agreement barred federal prosecutors in Manhattan from pursuing the current case over the same conduct. Weinberg said at Wednesday's hearing that they intended to file motions on the issue. + +U.S. Attorney Geoffrey Berman, whose office is overseeing the current case, has said there is no such bar. Epstein Lawyers Ask for a Year to Review a Million Pages + +Bloomberg + +By Chris Dolmetsch , Bob Van Voris , and Patricia Hurtado 7/31/19 + +Jeffrey Epstein's lawyers say they need at least a year to review a blizzard of documents prosecutors have gathered against the fund manager as they prepare to defend him against charges of sex trafficking in minors and conspiracy. + +Prosecutors asked a judge to schedule Epstein's trial for next June, but defense attorney Martin Weinberg said his team wanted to wait until September 2020, because they haven't yet begun to receive documents from the government. + +"We need time to receive a million pages of discovery and prepare to defend a four- to six-week trial," Weinberg said during a brief hearing in Manhattan on Wednesday. "We need time to assess events that occurred 14 to 17 years ago." + +The judge set a tentative trial date of June 8 and asked the parties to keep him updated on their progress. + +Epstein, who didn't speak in court, was arrested on July 6 after stepping off his private plane in New Jersey from a trip to Paris. He has pleaded not guilty and said he has fully complied with the law for more than 14 years. + +#### Marks on Neck + +Epstein is accused of molesting teenage girls from 2002 to 2005. He pleaded guilty in 2008 to Florida state charges of soliciting prostitution, after striking a non-prosecution agreement with the U.S. Federal prosecutors in New York say they are not bound by the deal as they now pursue their own charges. + +In court Wednesday, there was no discussion of what happened to the 66-year-old Epstein last week at New York's Metropolitan Correctional Center, where he has been held since his arrest. People familiar with the matter said he was found injured and unresponsive in his cell, with marks on his neck. Authorities are investigating whether he was assaulted, possibly by another inmate, or whether the injuries were self-inflicted. Weinberg declined to respond to questions about the incident outside court. + +Also in court was Gloria Allred, the activist lawyer who has represented women accusing Roy Moore, Bill Cosby and President Donald Trump of sexual assault. After the hearing, she said she was representing other Epstein accusers who "were not in the Florida case." She said other women have approached her about their experiences with Epstein but were reluctant to discuss them for fear of retaliation. + +The U.S. attorney in Manhattan, Geoffrey Berman, has urged others who may be victims to come forward and cooperate with the government. Allred declined to say whether her clients have spoken to prosecutors. + +The case is U.S. v. Epstein, 19-cr-490, U.S. District Court, Southern District of New York (Manhattan). + +#### Collins + +### Editorial: Failures of ethics + +Buffalo News By News Editorial Board 7/29/19 + +The ethics specialists are right and so are the members of a special ethics panel, including both Democrats and Republicans, who are paying attention. Good for them. The conduct of Rep. Chris Collins, R-Clarence, exposed a range of issues Congress needs to treat as tumors, and cut them out. + +Collins was indicted last year on allegations of insider trading. But he was routinely smashing ethical standards — of both formal and common sense varieties — before he was ever charged with a crime. + +A year before Collins was indicted, the Office of Congressional Ethics reported that it found "a substantial reason to believe" that Collins violated federal law by touting the stock of Innate Immunotherapeutics, an Australian biotech firm, based on inside information. + +The office also said Collins may have broken House ethics rules by persuading National Institutes of Health officials to meet with a staffer from that company. + +At least as troubling are the actions Collins took that were not deemed to be ethical violations. Speaking to a bipartisan House task force charged with drawing up new ethics rules based on Collins' arrest, ethics experts worried about lawmakers who sit on the boards of privately owned companies, or who serve as partners in other businesses or who are directors of nonprofit organizations. Collins still does all three. + +Earlier this year, in response to Collins' arrest, the House barred lawmakers from serving on the boards of publicly traded companies. Collins did that, too, as a board member — and leading stockholder — of Innate Immunotherapeutics. It's how prosecutors say he obtained the insider information that led to his arrest. + +There was more. Collins authored a provision of the 2016 "21st Century Cures Act" that sped drug approval for companies like Innate. Collins, with a straight face, claimed there was no conflict because Innate had no business before U.S. regulators. But in 2017, the company practically beamed that it had "received clearance from the U.S. Food and Drug Administration for the Company's Investigational New Drug (IND) application lodged last month." + +The fact that Collins' role in the legislation could also have benefited other companies — and may even have been worthy of passage — does nothing to change the associated fact that he was pushing for legislation whose adoption could have lined his pockets. It was classic self-dealing. + +The drug in question was meant to treat multiple sclerosis. It failed in clinical trials in 2017 and prosecutors say Collins illegally spread the word to family and others who were able to sell their stock before its price collapsed on the bad news. + +Collins has pleaded not guilty to the charges. His trial is scheduled for February. But regardless of what a judge or jury ultimately decides about Collins, he has shown himself to be indifferent to the need for a member of Congress to conduct himself in a way that reflects well on the institution and on the voters who entrust him with public office. + +In that, he has shown Congress that it needs to act. It can't count on its members using good judgment, especially when millions of dollars are at stake. + +The good news is that it seems ready to meet that public obligation. It is considering measures that would prohibit lawmakers from serving as partners in limited liability corporations, joining committees that oversee their business interests and serving on the boards of nonprofit organizations. Staff members would also be barred. + +Sadly, some Republican members have defended Collins, despite the clear conflicts of interest. But the Republican on the ethics task force, Rep. Van Taylor of Texas, expressed no disagreement with the panel's Democrat, Pennsylvania Rep. Susan Wild, who said she expected to move "rather quickly" on writing new rules. + +Taylor sees the tasks as "very narrow," focused on preventing lawmakers from serving in outside positions that could pose conflicts. The remarkable thing is that those restrictions need to be put in writing. Thank Collins for that. + +# Securities and Commodities Fraud + +Stewart + +Forbes By Walter Pavlo 7/30/19 + +Sean Stewart was indicted on insider trading charges back in May 2015 during U.S. Attorney Preet Bharara's reign over the Southern District of New York. Now, over four years since his indictment, Sean can reflect back on a wild journey of being convicted, sentenced to 3 years prison, having that conviction overturned, being released from prison halfway through his term and, now, having a new date to go back to trial to face the charges again. + +Sean Stewart was indicted on insider trading for passing material non-public information on potential deals to his father, Robert, who then passed it on to his former friend and trader, Richard Cunniffe. Sean, a Yale graduate who had worked in investment banking at JPMorgan Chase and Perella Weinberg, mentioned some details about his work while talking to Robert. Sean's information made it to Cunniffe who made over a million dollars on the trades, sharing a small amount (less \$100,000) with Robert. How much did Sean make on the trades? ZERO dollars. He had no idea that Cunniffe traded because he did not even know who Cunniffe was. + +It was a clear case of misappropriation where information was used without Sean's knowledge, so it was not a "classical" insider trading case. However, Bharara's team of U.S. attorneys was looking for cases that targeted wealthy Wall Street traders who seemed to have an advantage over the average trader. Sean's case was a good fit. + +Cunniffe was busted by the FBI and soon became a government informant, taping calls and other meetings with Robert. In one of those calls, Robert stated that Sean said of the information he had passed on to Cunniffe, "I can't believe it. I handed you this on a silver platter and you didn't invest." So the primary evidence in the case, the case that came to be known as the "silver platter" case, was based on a statement that was attributed to Sean. It's a phrase that Sean's new defense team wants to be excluded from the proceedings. + +When Robert was arrested, under duress of FBI questioning, he said nine (9) times that Sean was not in on his scheme with Cunniffe (here is entire tape transcript here). Robert also admitted his own role and that of Cunniffe's during the interrogation. When it came to trial, neither that tape nor Robert's testimony was allowed because of legal maneuvering by prosecutors. The video tape was suppressed and Robert did not testify due to threats from prosecutors that he would be charged for perjury due to his conflicting accounts. Here is what the jury missed from that tape: + +FBI AGENT: Tell me about the first time that Sean gave you information on a deal. + +ROBERT STEWART: Well, uh, I wouldn't characterize any of these as — I mean Sean would mention stuff. I don't think he had any idea that I would trade on any of this stuff. Uh, I've never mentioned that I did, to him. Umnun + +AGENT: If that's true, how do you explain the comment you made to Rick [Cunniffe] that Sean got angry with you when he gave you this information on a silver platter and you didn't invest. + +ROBERT: Uhh, I think I was just saying that to Rick because Sean said, oh, you know, ahh, all these deals, you know, you — if you were trading you could make like millions of dollars. And I said, you know, Sean, no one's going to trade and make millions of dollars on this stuff. That wasn't his intention. + +Robert took the 5th but did submit an affidavit that if he were to testify he would have said Sean did not know about the trades by Cunniffe. + +Looking back at the trial, there was not a single email, document, or text message that suggested that Sean was a knowingly participated in the trading scheme. This is interesting since there were so many incriminating + +documents between Cunniffe and Robert. There were no witnesses who gave testimony on Sean's knowledge and intent, including Cunniffe, the cooperator, who on the stand acknowledged that he never knew Sean. Furtnermore, trading records and actions undertaken by Sean suggest he did not know trading had taken place. + +Last fall, the 2nd Circuit overturned Sean's conviction, something rare in most cases, especially a reversal on an evidentiary ruling, which suggests the 2nd Circuit felt that Sean may be innocent and the judge's mistakes resulted in an unfair trial. The appellate court ruled that Robert's post-arrest video interrogation should have been allowed. Sean was released from prison and has been in legal limbo until the SDNY decided that they would move to move forward with another trial on the same charges. + +Stewart will have a new judge this time around. U.S. District Judge Laura Taylor Swain was replaced by Judge Rakoff, a man who seems to be on a mission to define insider trading laws himself. He also has new attorneys Steven M. Witzel, Lawrence Gerschwer, R. David Gallo and Leigh G. Rome of Fried Frank Harris Shriver & Jacobson LLP. + +If Sean is found guilty, he would face the prospect of being sentenced to prison and returning to prison to complete a term. On the other hand, it would not be out of the question for Judge Rakoff to give him "time served" in prison even if Sean is found guilty. Rakoff, not a fan of the Federal Sentencing Guidelines, seems to be one of those judges that uses common sense in his approach to sentencing. Earlier this week, Rakoff sentenced a man to 14 months in prison for knowingly leaking insider information on Sherwin Williams' acquisition of Valspar. + +While Sean may have made some mistakes, these could have been handled by the companies he worked for and, at the most severe, an enforcement action by the Securities and Exchange Commission. The SDNY seems intent on trying to interpret insider trading laws by putting on elaborate trials with the threat of putting people in prison for years. It is a waste of resources. + +It looks like the ghost of Bharara still haunts the SDNY. + +### Thompson + +### Easton man accused of stealing \$7M via fake Bitcoin transactions + +Lehigh Valley Live By Sarah Cassi 7/30/19 + +An Easton man who headed a cryptocurrency escrow company was arrested last week on federal charges he allegedly stole \$7 million from two companies by lying about Bitcoin transactions. + +Jon Barry Thompson, also known as J. Barry Thompson, was the principal of Volantis, which included a cryptocurrency escrow company called Volantis Escrow Platform LLC and a related company, Volantis Market Making LCC. + +The 48-year-old Thompson was arrested in Easton, and was charged with two counts each of commodities fraud and wire fraud. Easton police assisted in serving the arrest warrant at 6:15 a.m. Thursday at Thompson's West Burke Street home on College Hill. + +What happens to the money when a criminal's stash is in bitcoin? + +When a criminal's stash is in bitcoin, the stakes are now much higher in forfeiture cases with the soaring value of the virtual currency. + +Thompson was released after posting \$500,000 bond. Messages left for comment at a phone number listed for Thompson and for his defense attorney, Matthew Siembieda, were not immediately returned. + +Prosecutors said Thompson stole \$7 million from two companies after lying about transactions of the peer-topeer digital currency Bitcoin -- \$3 million from one company and \$4 million from a second. + +Thompson offered minimized settlement default risk in cryptocurrency transactions, and claimed there was no risk of default, prosecutors allege. + +In June and July 2018, Thompson convinced the first company to send Volantis more than \$3 million for a Bitcoin purchase, prosecutors allege. Thompson allegedly assured the company he had the Bitcoin in hand and that money could not be lost. + +Thompson took the money, but never provided the company the promised Bitcoin or returned its money, prosecutors said. + +Thompson allegedly gave the company a fake account statement showing he had the company's money but in reality sent the more than \$3 million to a third-party entity purportedly in exchange for Bitcoin without first receiving any of the Bitcoin in hand. + +In July 2018, Thompson allegedly convinced a second company to send Volantis more than \$4 million for Bitcoin purchases. Again, Thompson is accused of sending a substantial portion of the money to a third party without first receiving any Bitcoin in return, prosecutors allege. + +Thompson never gave the second company any Bitcoin and did not return its money, prosecutors said. + +"Jon Thompson induced investors to engage in cryptocurrency transactions through his company, Volantis Market Making, by touting a transaction structure that would eliminate any risk of loss during the purchase," Manhattan U.S. Attorney Geoffrey S. Berman said in a news release. "As his clients soon realized, however, Thompson's representations were false, and these cryptocurrency investors ultimately lost all of the money they had entrusted with him because of his lies." + +FBI Assistant Director-in-Charge Sweeney said Thompson used phrases and terminology that the victimized companies didn't understand, and he "allegedly preyed on their ignorance of the emerging cryptocurrency." + +"Thompson allegedly thought no one would ask where their actual money went when they trusted him to invest in Bitcoin," Sweeney said. + +The complaint doesn't identify the companies allegedly victimized by Thompson. + +Forbes previously reported Symphony, an Irish investment company that specializes in trading cryptocurrencies, gave Thompson 3.6 million Euros to purchase Bitcoin on its behalf. + +Symphony never received any Bitcoin and its money was never returned. + +In that case, the plaintiff withdrew the complaint it had brought in federal court in Pennsylvania and, instead, reached a private settlement with Thompson. Thompson then breached the agreement by failing to make the first settlement payment, Forbes reported. + +Pinto-Thomaz + +Patch By Chris Dehnel 7/30/19 + +A former analyst for a major financial ratings agency is to spend more than a year in prison for an insider trading scheme involving his hairdresser, a jeweler and two major paint brands sold prominently in Connecticut. + +Geoffrey S. Berman, the United States Attorney for the southern district of New York, announced that Sebastian Pinto-Thomaz, 34, a former credit ratings analyst at Standard & Poor's, was sentenced in Manhattan federal court to 14 months in prison for participating in two schemes to trade on material, nonpublic information in advance of the Sherwin-Williams Company's acquisition of the Valspar Corporation. + +Valspar is the brand sold by Lowe's. + +Pinto-Thomaz was convicted on April 26, following a jury trial before U.S. District Judge Jed S. Rakoff, who also imposed Monday's sentence. + +In summarizing the case, Berman said, "As an employee of Standard & Poor's, Sebastian Pinto-Thomaz was privy to potentially lucrative information about business acquisition plans. Instead of protecting that information, as he had sworn to do, he shared it with a friend and with his hairdresser. In turn, they bet on a stock that they knew to be a sure thing, and raked in nearly \$300,000 in profits. Pinto-Thomaz painted himself into a corner when he and his co-defendants exploited insider information to reap illegal profits. Now they all face time in prison for their misdeeds." + +When a company announces an acquisition, the acquiring company often seeks the opinion of a credit rating agency regarding the potential impact that the acquisition could have on the acquiring company's creditworthiness, Berman said. Therefore, companies often contact rating agencies before an acquisition is publicly announced in order to secure the rating agency's views on how a possible acquisition could impact a company's credit rating, he said. + +All major rating agencies offer a service — sometimes known as a Rating Evaluation Service, or RES — that provides the company with a rating committee decision with respect to a proposed acquisition. + +In March 2016, Standard and Poor's, a credit rating agency in New York, assigned Pinto-Thomazto work on a RES for the Sherwin-Williams Company in advance of its contemplated but unannounced acquisition of the Valspar Corporation, according to casae records. + +In connection with the assignment, Pinto-Thomaz received material, nonpublic or "inside" information the deal about Sherwin-Williams's planned acquisition of Valspar prior to the public announcement of the acquisition. S&P's written policies prohibited the unauthorized disclosure of confidential information, which included the inside information, Berman said. + +During his tenure at S&P, Pinto-Thomaz reviewed and certified his duties of loyalty and confidentiality to S&P and its clients, according to case records. + +In March 2016, Pinto-Thomaz passed the inside information about the paint merger to Jeremy Millul, a friend, and to Abell Oujaddou, his hairdresser, so that they could "use it to make profitable trades in Valspar stock and options.," Berman said. + +On March 21, 2016, the first trading day after the public announcement of the acquisition, the price of Valspar stock increased approximately 23 percent over the prior day's close. + +Millul, a Manhattan jeweler opened a brokerage account on March 13, 2016, and shortly thereafter purchased 480 shares of Valspar common stock, case records show. On March 18, 2016, the last trading day before the acquisition was publicly announced, Millul also purchased 75 out-of-the-money Valspar call options, according to case records. + +After the acquisition was publicly announced, Millul sold his Valspar stock and options for approximately \$106,806 in profits, Berman said. + +Oujaddou, a Manhattan hairstylist and salon owner who has known Pinto-Thomaz for years and is a close friend with his mother, was given inside information during a haircut on March 8 or 9, 2016, according to case records. On March 10 through March 18, 2016, Oujaddou, who had never previously purchased Valspar or Sherwin-Williams purchased 8,630 shares of Valspar stock, case records show. + +After the acquisition was publicly announced, Oujaddou sold his Valspar shares for approximately \$192,080 in profits, according to case records. + +Following the trading, Oujaddou met Pinto-Thomaz in the paint aisle of a hardware store and paid him a kickback, Berman said. + +Pinto-Thomaz denied having a relationship with anyone on the list of pre-merger trading. + +In addition to his prison term, Pinto-Thomaz was sentenced to three years of supervised release and ordered to pay a fine of \$15,000 and a forfeiture money judgment in the amount of \$7,500. + +Millul and Oujaddou each previously pled guilty and were to be sentenced on July 30. + +## Narcotics + +Castro + +### Drug Dealer Forfeits Over \$41%,1 in Bitcoin as Part of a Guilty Plea + +All Stocks + +By Ravi Rd + +7/31/19 + +According to a July 25 press release from the United States Attorney's Office of the Southern District of New York, the very active Bitcoin drug dealer Richard Castro has pleaded guilty of committing illicit activities such as money laundering and distributing three controlled substances through the dark web and encrypted emails. + +Castro was charged by the US Department of Justice (DoJ) and agreed to forfeit more than \$4 million including cryptocurrency funds available in his seven different Bitcoin wallets. + +Castro, 36-year-old based in Windermere, Florida, operated under multiple badges, such as "Chems\_usa," "Chemical\_usa" and "Jagger109" to distribute three controlled opioid substances namely carfentanil, fentanyl, and phenyl fentanyl. Dream Market and AlphaBay were two of his primary market places on the dark web, where he sold drugs in exchange for cryptocurrency. + +The three controlled opioid substances were sold from November 2015 to 2019 by Castro and another coconspirator, Luis Fernandez. Fentanyl, the first of these three is considered to be significantly stronger than heroin while Carfentanil is believed to be 100 times stronger than fentanyl. Castro sold these substances under the three aforementioned monikers which ultimately used to prove that he is indeed the leader of this conspiracy. + +On Dream Market, Castro once boasted about 3,200 transactions that he had completed on various dark web marketplaces. Out of these 3,200 transactions, 1,800 transactions were successfully completed on AlphaBay alone. The conspirators apparently also received many positive reviews for the quality of synthetic opioid substance they were selling. + +In June 218, Castro informed his clients that he would only accept orders received by encrypted emails and declared the organization is getting the business off from the dark web. Customers who wanted to buy narcotics had to acquire the address of the encrypted email from "Chems\_usa" by paying certain fees. Unfortunately for Castro, an undercover law enforcement officer also obtained the encrypted email and placed an order, which ultimately led to his arrest. + +Castro was accepting the payments in Bitcoin which were later distributed in seven different BTC wallets. + +Manhattan U.S. Attorney Geoffrey S. Berman said: + +"As he admitted today, for years, Richard Castro used the dark web to distribute prolific quantities of powerful opioids, including fentanyl and carfentanil. Castro thought he could hide behind the anonymity of the intemet, and use online pseudonyms to deal drugs — like `Chems\_usa' and `Chemical\_usa.' Thanks to our law enforcement partners, `Chems\_usa' is now in U.S. prison." + +Castro has agreed to forfeit \$4,156,198.18 including the funds on those seven Bitcoin wallets. + +Rochester Drug Company + +Distributor Has Been Shipping Excess Opioids to Small Towns + +Legal Reader + +By Sara E. Teller + +7/31/19 + +Miami-Luken Inc., an Ohio drug wholesale distributor, and four people including two former executives have been charged with selling millions of pills amid the opioid epidemic despite knowing the dangers. The indictment charged the Springboro, Ohio-based company; Anthony Rattini, the company's former president; James Barlay, former compliance officer, and two pharmacists with "conspiring to distribute controlled substances." Prosecutors have alleged "Miami-Luken ignored obvious signs that drugs were being diverted to illegal users and dealers between 2011 and 2015." The company was shipping 4.9 million pills to Miller-West's drugstore in Oceana, W.Va., where the population is just under 1,400. + +"Miami-Luken and the executives failed to guard against the dangerous drugs it was shipping to pharmacies in five states from being diverted for illegal uses or to report suspicious orders to the U.S. Drug Enforcement Administration," they added. + +The distributor shipped millions of pills to desolate and rural areas of Appalachia which was hit especially hard by the epidemic. "Records show Miami-Luken also distributed 3.7 million hydrocodone pills from 2008 to 2011 to a pharmacy in Kermit, West Virginia, a town of just 400 people," prosecutors said. The pharmacists charged were Devonna Miller-West, the owner of Oceana, West Virginia's Westside Pharmacy, and Samuel Ballengee, owner of Williamson, West Virginia's Tug Valley Pharmacy. + +The company was also shipping some to other "unnamed pharmacists and physicians," the indictment alleged. + +"There's a need, in my opinion, to devote sufficient charges right here and now to stop the dying," United States Attorney Benjamin C. Glassman said, adding investigators found "many overdose deaths that could arguably be linked to the conduct of people accused in the conspiracy." + +In April of this year, criminal charges were brought against Rochester Drug Co-operative. Geoffrey S. Berman, the United States Attorney for the Southern District of New York, and Ray Donovan, the Special Agent in Charge of the New York Division of the U.S. Drug Enforcement Administration (DEA), announced the charges. Rochester Drug Co-Operative is one of the 10 largest pharmaceutical distributors in the United States. Charges were also filed against Laurence F. Doud III, the company's former chief executive officer; and William Pietruszewski, the company's former chief compliance officer. The indictment was specifically for "unlawfully distributing oxycodone and fentanyl, and conspiring to defraud the DEA," according to court documents. + +Berman said at the time, "This prosecution is the first of its kind: executives of a pharmaceutical distributor and the distributor itself have been charged with drug trafficking, trafficking the same drugs that are fueling the opioid epidemic that is ravaging this country. Our Office will do everything in its power to combat this epidemic, from street-level dealers to the executives who illegally distribute drugs from their boardrooms." The company paid \$20 million to resolve the charges. + +DEA Special Agent in Charge Ray Donovan said, "Today's charges should send shock waves throughout the pharmaceutical industry reminding them of their role as gatekeepers of prescription medication. The distribution of life-saving medication is paramount to public health; similarly, so is identifying rogue members of the pharmaceutical and medical fields whose diversion contributes to the record-breaking drug overdoses in America. DEA investigates DEA Registrants who divert controlled pharmaceutical medication into the wrong hands for the wrong reason. This historic investigation unveiled a criminal element of denial in RDC's compliance practices and holds them accountable for their egregious non-compliance according to the law." + +## Civil + +Life Spine + +### Lawsuit against Huntley-based medical device company alleges kickback scheme + +Northwest Herald By Drew Zimmerman 7/30/19 + +Life Spine, a medical technology manufacturer in Huntley, is the defendant in a federal lawsuit alleging violations of the False Claims Act by offering lucrative incentives to surgeons in exchange for their use of Life Spine products. + +The suit, which was filed last week by the U.S. Attorney's Office in the Southern District of New York, alleges that the company entered into agreements with dozens of surgeons as a means to pay more than \$7 million in illegal kickbacks — including consulting fees, royalties and intellectual acquisition payments - for the surgeon's use of Life Spine's equipment. + +The suit also alleges that these agreements, spanning an estimated seven-year period, were done with the knowledge, involvement and participation of Life Spine President and CEO Michael Butler and Vice President of Business Development Richard Greiber, who also are being charged. + +"Defendants are liable for damages based on the payment of claims submitted to Medicare and Medicaid for medical services and procedures involving Life Spine Products that were tainted by illegal kickbacks," the suit reads. + +About half of Life Spine's total domestic sales of spinal products between January 2012 and at least December 2018, were attributable to surgeries performed by these paid surgeons, according to the suit. + +In addition to the consulting fees and royalties being paid, surgeons also were treated to dinners at high-end restaurants, Chicago Cubs games and other perks. + +"As alleged, Life Spine and its senior management flagrantly ignored the law by paying surgeons millions of dollars in fees and royalties to get them to use Life Spine products during spinal surgeries," Manhattan U.S. Attorney Geoffrey S. Berman said in a release. "Kickbacks to doctors can alter or compromise their judgment about the medical care and services to provide to patients, and can increase healthcare costs." + +For the first two counts of violating the False Claims Act — which are against Life Spine, Butler and Greiber the plaintiff is seeking treble damages and civil penalties to the maximum amount allowed by state law. + +For the third count of unjust enrichment — which is only against Life Spine — the plaintiff is seeking damages to the extent allowed by law. + +The plaintiff also is seeking pre- and post-judgment interest, costs and any other relief the court deems appropriate. + +A statement from Life Spine said that both parties are engaged in discussions and look forward to resolving the matter. + +## Matters of Interest + +The U.S. said a California cherry-picker went to Pakistan for terrorist training. Now the case has collapsed. + +Washington Post By Meagan Flynn 7/31/19 + +It was a month after 9/11, and Osama bin Laden's face flashed across the news on Naseem Khan's TV screen. + +The FBI was sitting in his living room in Bend, Ore., and Khan sensed an opportunity. The agents had come for an entirely different purpose and were ready to leave — until Khan pointed at the screen and said he thought he could help with something else. A few years ago, he said, he saw bin Laden's second-in-command, Ayman al-Zawahiri, one of the most wanted terrorists in the world, at a mosque in the wine-country town of Lodi, Calif. + +The agents perked up, intrigued by the possibility. Had they really just stumbled into a hot tip on al-Qaeda while speaking to a 28-year-old McDonald's worker and convenience store clerk? The FBI thought Khan was onto something — a possible "sleeper cell" of terrorism hidden in Lodi — and decided to dispatch him there as a confidential informant. + +Khan wouldn't find any associates of Zawahiri at the mosque in Lodi, and U.S. officials and terrorism experts now doubt his initial claim about Zawahiri was ever true. But Khan would find 19-year-old Hamid Hayat who would soon become the face of homegrown terrorism in post-9/I1 America. + +They met at the mosque, and Khan learned Hayat was taking a trip to Pakistan with family. Over and over, in recorded conversations, he returned to the same question: Would Hayat commit to attending a terrorist training camp, as he had promised? + +Now, a judge's order on Tuesday casts doubt on whether Hayat ever actually did. + +Hayat, a cherry-picker and son of an ice cream truck driver, was convicted of attending the alleged terrorist training camp and sentenced to 24 years in prison in 2006. Prosecutors, relying on Khan and Hayat's own statements, alleged that he attended the camp for three to six months sometime in 2003. The case would become one of the most high-profile examples of the government's fight against terrorism in the immediate aftermath of 9/11, especially because Hayat, after hours of interrogation by FBI agents, confessed to attending the camp. + +But on Tuesday, U.S. District Judge Garland E. Burrell Jr. vacated his conviction and sentence, finding that Hayat had inadequate defense during the 2006 trial while casting doubt on the facts of the case. Burrell questioned whether jurors would have convicted him had they heard evidence from witnesses in Pakistan, which the judge said likely would have "undermined" jurors' confidence in Hayat's confession alone. His attorneys have maintained the confession was coerced during an exhausting interrogation. + +Had the defense attorney actually interviewed any witnesses in Pakistan who spent significant time with Hayat during his trip, she would have discovered that they recalled Hayat spent most of his time playing video games and cricket and that the purpose of his visit was for his family to find him a wife, according to Burrell's order. No one identified any prolonged disappearance that would have allowed him to visit a terrorist training camp for three to six months as prosecutors alleged and Hayat said in the confession, Burrell noted. Burrell, who oversaw Hayat's original trial, found the witnesses gave consistent statements and could have provided Hayat a credible alibi. + +"Showing that Hayat could not have been at a jihadi training camp for the `period of months' specified in the indictment would have been completely consistent with the defense that Hayat's confession should not be credited and the government lacked other supporting evidence," a U.S. magistrate wrote in making the recommendation that Hayat's conviction be vacated. Burrell adopted most of the magistrate's findings of fact. + +The government has not decided yet whether to appeal the decision, a spokeswoman in the U.S. attorney's office in the Eastern District of California said in a statement, the Sacramento Bee reported. "We are in the process of reviewing the district court decision and assessing what steps, if any, should be taken and considering all our options," the statement said. + +Hayat, now 36, is currently being held in a federal prison in Phoenix. His attorneys are seeking his immediate release. + +The case against Hayat and his father, Umer, who was accused of lying to the FBI, heaped international attention on the Northern California town of Lodi. Seemingly overnight, the town went from the zinfandel capital of the world to an alleged terrorism "sleeper cell" — a claim authorities would later walk back. + +At the time he met Khan in August 2002, Hayat lived in his parents' garage and didn't have many friends, as the Intercept recounted in a 2016 investigation. Posing as a radical Islamist, Khan nudged Hayat into conversations that were anti-American and supportive of Islamic fundamentalist groups, and to his delight Hayat went along with it, according to recorded conversations cited in federal court documents. Hayat approved of the beheading of Wall Street Journal journalist Daniel Pearl by Pakistani militants. He told Khan he believed jihadists had attended his grandfather's religious school in Pakistan and claimed his grandfather was so politically well connected that the Pakistani president enlisted him in efforts to persuade the Taliban to turn over bin Laden after 9/11. + +Then came the terrorist camps. Hayat said he had seen one in an online video — and expressed interest in going himself. Khan, feeding the intel to the FBI, egged him on. + +But once in Pakistan, Hayat kept making excuses, according to the judge's order. When Khan told him he was being "lazy," Hayat claimed the climate had changed and it got too hot outside — the terrorist camp was canceled, he said. Khan was starting to get mad. His nudges turned to threats. + +"God willing, when I come to Pakistan and I see you, I'm going to ... force you to, get you from your throat and ... throw you in the madrassa," Khan said in one expletive-laden recorded conversation, as the Intercept reported. + +"Oh yeah, you will go," Khan told him. "Yeah, you will go. You know what? Maybe I can't fight with you in America, but I can beat your a-- in Pakistan, so nobody's going to come to your rescue." + +In their last conversation, according to the Intercept, which obtained all the recordings, Hayat said he "never intended on going to a camp." + +Hayat denied attending a camp in his first interview with the FBI in Japan, before flying to San Francisco. He confessed during his second interview in California upon his return in June 2005. + +"FBI: Al Qaeda plot possibly uncovered," rang a CNN headline in June 2005, saying those involved "Trained on how to kill Americans." + +Months after Hayat's arrest, then-director of national intelligence, John D. Negroponte, testified in a congressional hearing that a "network of Islamic extremists in Lodi, Calif., for example, maintained connections with Pakistani militant groups, recruited United States citizens." + +But ultimately, no other terrorism cases arose from the investigation except for the one against Hayat. Two imams were investigated but were never criminally charged with anything. They had overstayed religious worker visas, authorities discovered. + +A retired FBI agent who watched Hayat's interrogation and the resulting confession told the Los Angeles Times it was "the sorriest interrogation, the sorriest confession, I've ever seen," believing the agents fed Hayat the details they wanted to hear and that Hayat repeated them so he could leave. He was barred from offering his testimony at trial. Burrell found that the failure to challenge the validity of the confession by presenting a false confession expert also contributed to his finding that Hayat had ineffective counsel. + +Khan was ultimately paid nearly \$230,000 for assisting the FBI over three years. During Hayat's trial, his defense attorney questioned how one fast-food worker's implausible claim that he saw the world's most wanted terrorist in a small-town mosque could have "sparked this whole investigation with this ridiculous claim," the Times reported in 2006. + +Hayat's attorneys filed an appeal in 2014 and ultimately sought to interview numerous witnesses in Pakistan who could account for his whereabouts during the trip from 2003 to 2005. They appeared for sworn depositions on video in 2018. When Hayat's attorney, Dennis Riordan, asked his uncle whether he "would have known" if Hayat disappeared from their rural hamlet, Muhammad Anas said, "Naturally, I would have noticed," the Marshall Project reported then. + +The judge found that the witnesses "corroborated each other on some important points," regarding trips the family took throughout Pakistan and who they visited. Once or twice a month, they traveled to a hospital for his mother's medical treatment. + +On Tuesday, Hayat's family issued a statement applauding the judge's decision to throw out Hayat's conviction, the Sacramento Bee reported. + +"We have been waiting 14 long years for Hamid to be freed," the statement read. "Hamid cannot get those 14 years of his life back, but we are relieved to see the case take such a big step forward. We miss him and hope to be reunited with him soon." + +By Jeanna Smialek 7/31/19 + +The Federal Reserve cut interest rates for the first time in more than a decade on Wednesday as it attempted to guard the record-long economic expansion against mounting global risks. + +The widely expected quarter-point move, the Fed's first since it cut rates to near zero in 2008, is meant to protect the economy against the potentially harmful effects of a growth slowdown in China and Europe and uncertainty from President Trump's trade war. + +"In light of the implications of global developments for the economic outlook as well as muted inflation pressures, the committee decided to lower the target range for the federal funds rate," according to the Federal Open Market Committee's policy statement. + +But the Fed did not indicate that this was the beginning of a rate-cutting campaign, suggesting instead that the cut was a minor adjustment intended to help the economy weather any challenges from slowing global growth and Mr. Trump's trade fights. + +Subscribe to With Interest Catch up and prep for the week ahead with this newsletter of the most important business insights, delivered Sundays. + +While Jerome H. Powell, the Fed chair, left the door open to additional rate moves if the economy showed signs of sputtering, he did not indicate the central bank was poised to engage in the sort of deep cutting cycle that the Fed has done in the past to avert or offset recessions. + +"It's not the beginning of a long series of rate cuts - I didn't say it's just one," Mr. Powell said at a news conference following the Fed's two-day policy meeting. "What we're seeing is that it's appropriate to adjust policy to a somewhat more accommodative stance over time, and that's how we're looking at it." + +The widely expected move from the central bank was initially greeted with a shrug in financial markets, where investors have been factoring in a rate cut for months. But the stock market turned lower after Mr. Powell began his news conference at 2:30 p.m., as investors absorbed the chair's comments as indicating the Fed was unlikely to make additional cuts anytime soon, as investors had hoped. + +By the end of the day, the S&P 500 was down 1.1 percent. It was the benchmark index's worst decline since May 31. + +The Fed dropped its target rate to a range between 2 percent to 2.25 percent. Officials also announced an early end to its efforts to shrink the Fed's balance sheet, another attempt to keep the economy moving. The central bank's holdings of government-backed bonds swelled during the financial crisis as it bought assets to try to reinvigorate growth. Policymakers have been slowly siphoning off securities to return their balance sheet to a more normal size, and that process was slated to end in September. It will now conclude Aug. 1. + +Why the Federal Reserve Cut Interest Rates The move is what's called an "insurance cut" — one that central bankers are making to keep growth chugging along. + +Both Eric Rosengren, the president of the Federal Reserve Bank of Boston, and Esther George, the president of the Federal Reserve Bank of Kansas City, voted against Wednesday's decision, preferring instead to leave rates unchanged. Those dissents marked the second and third of Jerome H. Powell's term as chair. + +While Fed officials said they expect economic expansion to continue and the labor market to remain strong "uncertainties about this outlook remain." + +Mr. Powell said the Fed's move was "intended to insure against downside risks from weak global growth and trade tensions." + +He said that manufacturing around the world was weakening and that Mr. Trump's trade dispute was continuing to spook American businesses. "The ongoing uncertainty is making some companies more cautious about their capital spending," he said. + +Officials did not indicate in their statement whether this cut would be followed by additional moves. The Fed's June economic projections suggest policymakers envision cutting rates slightly to shore up the economy, rather than beginning an easing cycle that will return rates to zero. + +"As the committee contemplates the future path of the target range for the federal funds rate, it will continue to monitor the implications of incoming information for the economic outlook and will act as appropriate to sustain the expansion," the Fed said in its statement, seemingly leaving its options open. + +Mr. Powell said the committee viewed the move as a "mid-cycle adjustment to policy," suggesting that the Fed sees this cut as more similar to two instances in the 1990s, during which the Fed moved rates down slightly to get the economy through periods of uncertainty, rather than the beginning of a rate-cutting campaign. + +The Fed's rate cut carries political risks, given Mr. Trump's attacks on the central bank. Mr. Trump has been denouncing the Fed in speeches and on Twitter for the past year, criticizing its four 2018 rate increases and blaming its policies for slowing the American economy. Some onlookers may see Wednesday's move as caving to the president. + +The Fed operates independently of the White House. It attributed the change, which officials have been signaling for months and which investors fully expected, to growing economic concerns. + +"We also don't conduct monetary policy to prove our independence," Mr. Powell said. + +The central bank is trying to extend a record-long economic expansion, because officials believe that doing so will allow the Fed to achieve its goals of maximum employment and slow but steady inflation. The unemployment rate is hovering around its lowest level in 50 years, but that has yet to push wages dramatically higher in a way that forces companies to lift prices more quickly. + +Inflation has run shy of the Fed's 2 percent goal since the central bank formally adopted it in 2012. A little inflation helps to grease the wheels of a healthy economy, allowing businesses to raise wages faster and lifting interest rates, giving the central bank more room to cut in the event of a downturn. + +Prices picked up just 1.6 percent in the year through June, not counting volatile food and fuel costs. + +Wages are growing only moderately. An index of employment costs climbed by 2.7 percent in the second quarter from a year earlier, less than expected and a slowdown from earlier in 2019, according to data released on Wednesday. + +Global policy uncertainty has also increased, and manufacturing is slumping the world over. Growth is slowing in China and Europe, and Mr. Trump's trade war with China and threats of further tariffs on United States trading partners are stoking uncertainty and causing businesses to hold off on investment. + +Those developments threaten the economic outlook, even as growth remains solid, consumer spending is robust and the job market holds up for now. \ No newline at end of file diff --git a/marker2/ds9/EFTA00085684/EFTA00085684.metadata.json b/marker2/ds9/EFTA00085684/EFTA00085684.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a43db0ec15339de425a506a9dddba2568fef6350 --- /dev/null +++ b/marker2/ds9/EFTA00085684/EFTA00085684.metadata.json @@ -0,0 +1,1287 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085684.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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UNITED STATES OF AMERICA, RESPONDENT. + +Civil Action No. 08-80736-CIV-MARRA + +• Government's Response to Petitioners' Submission on Proposed Remedies The United States of America, by Byung J. Pak, United States Attorney for the Northern District of Georgia, and and Petitioners' proposed remedies. files this response to + +#### INTRODUCTION + +The question before this Court is what remedies, if any, should be accorded Petitioners under the Crime Victims Rights Act (CVRA) based on this Court's finding that the government failed to confer with Petitioners prior to entering into a non-prosecution agreement (NPA) with Jeffrey Epstein? Petitioners seek + +1This Court previously found that Petitioners are crime victims under the CVRA; a crime victim's rights under the CVRA attach before the government brings formal charges against a defendant; the CVRA's "reasonable right to confer" extends to conferring about non-prosecution agreements; the CVRA authorizes the rescission of a non-prosecution agreement reached in violation of a prosecutor's conferral obligations; and the government violated the CVRA by failing to advise the victims that it intended to enter into the NPA with Epstein. The government will not + +what they call "rescission remedies," "apology remedies," "informational remedies," "educational remedies," and "miscellaneous remedies" —all of which constitute equitable relief, and none of which is authorized by the CVRA. But even if the statute did allow equitable relief, Petitioners are not entitled to the specific relief they are seeking. + +Nevertheless, the government believes that it should have communicated its resolution of the federal criminal investigation of Epstein to his victims more effectively and in a more transparent manner. Although we cannot turn back time and put the victims back in the position they would have been in over a decade ago, the government believes the following proposed remedies would respect their rights under the CVRA, balance the constitutional and statutory obligations imposed on the government, and bring some level of finality to all the parties. + +#### DISCUSSION + +## 1. The Government's Proposed Remedies. + +# A. The government should have communicated in a more transparent way with victims. + +As a matter of law, the government's position is that the legal obligations under the CVRA do not attach prior to the government charging a case. Nor does the CVRA authorize any of the remedies sought by the Petitioners —in part because the CVRA does not contemplate its invocation in the context of + +revisit these findings here except to note that it maintains all of its objections. + +uncharged criminal conduct.2 At the same time, the government strives to communicate with crime victims effectively and as transparently as possible. + +There are myriad reasons why a prosecutor may decline to indict a case or resolve a case with a plea to a less serious charge. These considerations are highly contextual and involve a host of factors based upon the current state of the law and provable evidence, as well as the experience that prosecutors and their law enforcement partners develop working cases over many years. There are instances when victims of a crime or third parties may disagree with a prosecutor's decision, but that decision nevertheless remains with the prosecutor and her supervisors, and this discretion is expressly preserved in the CVRA. See 18 U.S.C. § 3771(d)(6). + +Although the CVRA may not have required it, here, the government engaged with the Petitioners about the status of the investigation and advised them that the case was being actively pursued. At the same time, potential federal charges were being resolved with a state court guilty plea in conjunction with the NPA. Regardless of whether the government ultimately chose to pursue, decline, or + +2 Indeed, under the CVRA, "crime victim" is a person directly and proximately harmed as a result of the "commission of a Federal offense." 18 U.S.C. § 3771(e)(2)(A). Thus, without identifying exactly which federal offense was committed by filing formal charges, it is difficult to determine who was directly and proximately harmed. Moreover, the crime victims rights are tied to a court proceeding, see 18 U.S.C. § 3771(b)(1), which indicates that formal charges are required prior to the attachment of rights under the CVRA. By Department policy and practice, however, federal prosecutors usually go above and beyond the obligations defined by the CVRA and interact with victims early on in a case. + +otherwise resolve federal prosecution— a decision upon which we do not opine here—the government should have communicated with the victims in a straightforward and transparent way. Because the government did not communicate more clearly and directly with the victims, the resolution in this case has led some to conclude that the government chose for improper reasons not to prosecute Epstein, a conclusion that remains unsubstantiated. The government places high value in its work to support victims of crime, and its communications with victims must reflect that value. The government regrets that the manner in which it communicated the resolution of the Epstein case to the victims fell short. + +# B. The Department of Justice's commitment to victims of human trafficking and child exploitation supports targeted remedies to give the Epstein victims a voice, an explanation, and finality. + +Over the past decade, the Department of Justice has made combatting human trafficking and child exploitation a national priority.3 Between Fiscal Years (FY) 2009 and 2016, the Department increased the number of human trafficking cases + +3 See Department of Justice Releases First National Strategy for Child Exploitation Prevention and Interdiction (Aug. 2, 2010), https://www.justice.gov/opa/pr/ department-justice-releases-first-national-strategy-child-exploitation-preventionand (Eric Holder comments); Introduction by Attorney General Loretta Lynch, National Strategy to Combat Human Trafficking (January 2017), https://www.justice.gov/humantrafficking/page/file/922791/download (hereinafter National Strategy to Combat Human Trafficking); Attorney General Jeff Sessions Delivers Remarks at National Law Enforcement Training on Child Exploitation (June 6, 2017), https://www.justice.gov/opa/speech/ attorney-general-jeffsessions-delivers-remarks-national-law-enforcement-training-child. + +charged, defendants charged, and defendants convicted by roughly 70 percent in comparison to the prior eight years, in addition to higher prosecution results in cases involving child sex trafficldng.4 In FY 2009, the Department charged 2,315 child exploitation cases involving 2,427 defendants; in FY 2015, that number almost doubled to 4,211 cases involving 4,458 defendants.5 In addition, through its Office of Justice Programs, the Department funds 61 coordinated task forces to fight internet-facilitated crimes against children (ICAC).6 In FY 2008, the task forces were funded at \$16.9 million; in FY 2018 the funding for the ICAC program was \$28.6 million? Through its Office for Victims of Crime (OVC), the Department provides more grant funding than any other federal agency to programs that provide direct services to victims of human trafficking .5 Indeed, this month, OVC announced its FY 2019 grant, which will award millions of + +4 National Strategy to Combat Human Trafficking at 1. + +5 National Strategy for Child Exploitation Prevention and Interdiction (Aug. 2010), at 5, https://www.justice.gov/psc/docs/natstrategyreport.pdf; National Strategy for Child Exploitation Prevention and Interdiction (Apr. 2016), at 110-11, https:/ /www.justice.gov/psc/file/842411/ download (hereinafter 2016 National Strategy for Child Exploitation Prevention). + +6 Program Summary, Internet Crimes Against Children Task Force Program, https://www.ojjdp.gov/programs/ProgSummary.asp?pi=3. + +7 1d. + +8Announcements, Office for Victims of Crime, https://ovc.ncjrs.gov/humantrafficicing/announcements.htrnl. + +dollars in funding to assist victims of trafficicing.9 In April 2016, the Department published a comprehensive strategy, in conjunction with several other federal agencies, to combat child exploitation, including child sex trafficking 10 In 2013, the Department and other agencies published a victim-dedicated action plan that described the process by which the government will combat trafficking offenses with a focus on providing support and services to victims.11 + +These programs and accomplishments matter because they reflect a commitment on the part of the Department of Justice, which includes all federal prosecutors, to combat human trafficking and crimes against children and fully support and protect victims of crime. Any remedy the Court imposes in this matter should reflect the fact that any mistakes made in this case stand in contrast to the Department's commitment to victims. + +Any remedy the Court imposes should also have a nexus to the purpose of the CVRA, which is to give victims a voice in the criminal justice process, but not decision-making authority over prosecution decisions. Here the Court found that the government violated the CVRA by failing to confer with the victims about the NPA. The past cannot be undone; the government committed itself to the terms of the NPA, and the parties have not disputed that Epstein complied with + +9 OVC Fiscal Year (FY) 2019 Direct Services to Support Victims of Human Trafficking, https://www.ovc.gov/grants/pdfbd/FY19-Direct-Services-Human-Trafficking-Solicitation.pdf. + +10 2016 National Strategy for Child Exploitation Prevention. + +11 Federal Strategic Action Plan on. Services for Victims of Human Trafficking, https://www.ovc.gov/pubs/FederalHumanTrafficldngStrategicPlan.pdf. + +its provisions. A number of Epstein's victims subsequently invoked the NPA to enter into civil settlements with Epstein and, in that respect, also relied on its terms.12 Any remedy for the CVRA violation should thus serve to give the victims a voice, even though the prosecution decision remains out of their hands. As such, the government proposes the following remedies: + +- The Department of Justice will designate a representative to meet with Petitioners, and any other Epstein victim who wishes to participate, to discuss the government's decision to resolve the Epstein case and engage in an open dialogue about that decision. +- The government will participate in a public court proceeding, presided over by this Court, in which the Petitioners, and any other Epstein victim who wishes to participate, can make a victim impact statement. That hearing would be handled in a manner similar to the way the Court would handle victim impact statements in the context of a criminal sentencing. +- All criminal prosecutors in the United States Attorney's Office for the Southern District of Florida (USAO-SDFL) will undergo additional training on the CVRA, victim rights, and victim assistance issues to be completed no later than one year from the date of the Court's final order in this case. + +# 2. The CVRA Specifies the Enforcement Mechanism To Address Violations of Its Terms and Does Not Authorize the Equitable Remedies Petitioners Seek. + +The government offers the proposed remedies above, not because it is required to do so by law, but because it believes these corrective actions are + +12 Based on information provided in response to the government's recent efforts to confer with victims, more than a dozen victims invoked the NPA to enter civil settlements with Epstein while protecting their anonymity. + +necessary to give a voice to the victims of Jeffrey Epstein and an opportunity for them to understand the true reasons why the government resolved the case in the manner it did since they did not have that opportunity at the time. These remedies are generally consistent with several remedies proposed by Petitioners. But the law does not authorize this Court to grant other remedies Petitioners seek, nor would such remedies promote the underlying purpose of the CVRA to promote victims participatory rights in the criminal justice process while respecting their dignity and privacy. + +Although Petitioners assert that the CVRA gives this Court "broad power to craft appropriate remedies," Doc. 458 at 7, the statute's plain language says otherwise. That language explicitly provides that a crime victim may not seek damages against the United States: + +No cause of action. — Nothing in this chapter shall be construed to authorize a cause of action for damages or to create, to enlarge, or to imply any duty or obligation to any victim or other person for the breach of which the United States or any of its officers or employees could be held liable in damages. + +18 U.S.C. § 3771(d)(6) (emphasis in original). + +Perhaps because Congress provided no cause of action for damages, it sought compliance a different way: it included a section in the CVRA entitled "Procedures to [P]romote [C]ompliance," in which it directed the United States Attorney General to "promulgate regulations to enforce the rights of crime victims and to ensure compliance by responsible officials with the obligations" + +set out by statute. 18 U.S.C. § 3771(f). Congress further directed that these regulations: (1) designate someone within the Department of Justice to receive and investigate complaints relating to a rights violation; (2) require that DOJ officials be trained on crime victims rights and assist such employees in responding to crime victims needs; (3) provide "disciplinary sanctions, including suspension or termination from employment, for employees of the Department of Justice who willfully or wantonly fail to comply with provisions of Federal law pertaining to the treatment of crime victims"; and (4) instruct that the "Attorney General, or the designee of the Attorney General, shall be the final arbiter of the complaint, and that there shall be no judicial review of the final decision of the Attorney General by a complainant." Id. at (f)(1)(A)-(D). + +The Department of Justice did as Congress directed, and the resulting regulations are found at 28 C.F.R. § 45.10. These regulations outline the procedures a crime victim shall take when he or she believes that one of their CVRA rights has been violated. 28 C.F.R. § 45.10(c). Notably here, the regulations provide that the Department of Justice Victims' Rights Ombudsman is "the final arbiter of the complaint," and the complainant "may not seek judicial review" of that determination. Id. at (c)(7)-(8). The Ombudsman alone decides whether to notify the complainant of the result of the investigation. Id. at (c)(9). Empowering the Ombudsman to remedy a victim's complaint without the risk of delay from prolonged litigation is consistent with congressional intent that the CVRA's administrative remedy should "create[] a framework to quickly enforce victims rights." 150 Cong. Rec. 7312 (statement of Sen. Orrin Hatch). + +With respect to disciplinary sanctions, if the Ombudsman finds that a DOJ employee violated a crime victim's rights, but not in a willful or wanton manner, the Ombudsman shall require the employee "to undergo training on victims' rights." 28 C.F.R. § 45.10(d). If, however, the Ombudsman finds that the DOJ employee willfully or wantonly violated a crime victim's rights, the Ombudsman shall recommend "a range of disciplinary sanctions." Id. at (e)(1). "Disciplinary sanctions" means "those sanctions provided under the Department of Justice Human Resources Order, 1200.1," which include written reprimands, suspensions, reductions in grade or pay, removals, and furloughs for 30 days or less. Id. at (e)(2); DOJ Human Resources Order, 1200.1, Part 3, B(2). Thus, the CVRA provides sanctions that the government and its employees may be subjected to if they violate the CVRA. + +The CVRA's plain text lays out the procedures that crime victims must follow when they believe their CVRA rights have been violated, the actions DOJ must take when it receives a complaint, and the sanctions DOJ may employ when a violation has occurred. And this carefully crafted and detailed enforcement scheme undermines any suggestion that Congress intended, but simply forgot, to provide additional remedies beyond those already specified. Courts agree. See United States v. Monzel, 641 F.3d 528, 542 (D.C. Cir. 2011) (holding that the CVRA's "carefully crafted and detailed enforcement scheme," provides "strong evidence that Congress did not intend to authorize other remedies that it simply forgot to incorporate expressly") (quoting Mertens v. Hewitt Associates, 508 U.S. 248, 254 (1993)); United States v. Hunter, 548 F.3d 1308, 1315 (10th Cir. 2008) + +(declining to "to read additional remedies" into the CVRA beyond those expressly contained in the Act); see also Karahalios v. Nat'l Fed'n of Fed. Employees, 489 U.S. 527, 533 (1989) ("[I]t is ... an 'elemental canon of statutory construction that where a statute expressly provides a remedy, courts must be especially reluctant to provide additional remedies.") (quoting Transamerica Mortgage Advisors, Inc. v. Lewis, 444 U.S. 11, 19 (1979)); Nat'l R.R. Passenger Corp. v. Nat'l Ass'n of R.R. Passengers, 414 U.S. 453, 458 (1974) ("[W]hen legislation expressly provides a particular remedy or remedies, courts should not expand the coverage of the statute to subsume other remedies."); McDonald a Southern Farm Bureau Life Ins. Co., 291 F.3d 718, 725 (11th Cir. 2002) ("When Congress creates certain remedial procedures, we are, 'in the absence of strong indicia of contrary congressional intent, . . . compelled to conclude that Congress provided precisely the remedies it considered appropriate.") (quoting Karahalios, 489 U.S. at 533). Because Petitioners seek remedies not authorized by the CVRA's plain language, their requests should be denied. + +What's more, the plain text is supported by the CVRA's location in the United States Code. Specifically, the CVRA is found in Part II of Title 18, which is the part of the United States Code specifically devoted to "Criminal Procedure." The CVRA does not contemplate civil litigation, and the civil remedies that Petitioners seek are simply unavailable under the CVRA. Doc. 147 at 15-19. Instead of authorizing a victim to institute a civil action, the CVRA created a specific victims-rights-enforcement scheme within the federal criminal justice process - indeed, within Title 18 of the United States Code, which addresses + +"Crimes and Criminal Procedure." That rights-enforcement scheme is based on the filing of a "motion asserting a victim's rights" - not a civil complaint or a civil lawsuit. 18 U.S.C. § 3771(d)(3); see Sieverding v. U.S. Dept. of Justice, 693 F. Supp. 2d 93,110 (D.D.C. 2010) (recognizing that it is "only through a motion" that the CVRA "permits" individuals to assert statutory rights arising under the CVRA, such as the "right to confer" and '"discuss ... allegations of criminal acts and [DOJ's] decisions to prosecute or not prosecute"') (citing 18 U.S.C. § 3771(d)(3)); see also, e.g., In re Antrobus, 563 F.3d 1092, 1097 (10th Cir. 2009) ("The CVRA contemplates that individuals asserting victim status may bring a motion in the district court even when criminal proceedings are not ongoing, and that the district court's denial of such a motion is reviewable by mandamus.") (citing 18 U.S.C. § 3771(d)(3)); compare Fed. R. Civ. P. 3 ("A civil action is commenced by filing a complaint with the court."). Congress expressly recognized in enacting the CVRA that the statute did not "[a]llow[] victims to vindicate their rights through separate proceedings for damages instead of through mandamus actions in the criminal case." 150 Cong. Rec. 7306 (2004) (statement of Sen. Patrick Leahy) (expressing regret that the CVRA "den[ied] victims any cause of action for damages in the event that their rights are violated"); 150 Cong. Rec. 7312 (statement of Sen. Orrin Hatch) ("For those who may be concerned that this bill might lead to new tort causes of action, let me assure you, that victims are not seeking to sue the government and get rich. . . . Accordingly, the bill states that there will be no cause of action for damages."). + +The cases cited by Petitioners do not advance their efforts to expand the CVRA into a civil remedial scheme allowing for civil equitable relief. Those cases support the unremarkable proposition that courts generally have power to grant appropriate relief for recognized civil causes of action, but, as previously explained, there is no civil cause of action under the CVRA. And the case to which they do cite, In re Dean, 527 F.3d 391 (5th Cir. 2008), is not applicable here. Specifically, in In re Dean, a criminal charge was actually filed, and the case involved a plea agreement that the court would have to accept or reject; here, however, the NPA was never before this Court. Regardless, the Court in In re Dean never opined on the types of equitable relief Petitioners seek here. + +In addition, Petitioners identify no other federal statute under which they can bring their claims for relief. Because the law does not provide Petitioners an avenue for the relief they seek, this Court must find that it does not have the authority to order the government to do as Petitioners ask, but may still accept the government's proposed remedies. + +# 3. Even if the CVRA Allows for Civil Relief, the Remedies Petitioners Seek Go Well Beyond What Is Appropriate. + +But even if the CVRA or some other statute allowed equitable relief, the remedies that Petitioners seek go well beyond what equity allows. + +## A. Petitioners' request for partial rescission + +Petitioners have repeatedly requested some form of rescission of the NPA, but their submission on remedies is telling more for what they seek to preserve from that agreement than what they seek to rescind. Specifically, Petitioners do not + +ask the Court to scrap the agreement in its entirety; instead, Petitioners request that the Court leave in force all but three sentences of the agreement and stress that they "are only seeking that these particular provisions be set aside." Doc. 458 at 13 n.5, 19. + +Petitioners effort to preserve almost the entirety of the NPA is understandable because eliminating the complete agreement could harm many of the very victims the CVRA was designed to protect. As the Court is well aware, the NPA guaranteed a felony conviction and more than a year of incarceration for Epstein, which he agreed not to appeal; required him to register as a sex offender; provided for an attorney representative for victims, at Epstein's expense; and gave victims the equivalent of uncontested restitution by mandating that he waive his right to contest liability for victims who pursued a claim for damages under 18 U.S.C. § 2255. Doc. 48-5. Rescission could imperil these penalties as well as the benefits and settlements obtained by the more than dozen victims who invoked the NPA terms. + +Petitioners attempt to avoid that outcome by asking the Court to spare provisions of the NPA they like while excising portions they do not. Given the potential harm that complete rescission would pose for many victims, the government understands this proposal to be well-meaning. Indeed, the government itself would benefit from partial rescission by reaping the advantages arising from Epstein's concessions without having to abide by its own commitments in the agreement. But partial rescission is not a proper remedy in this action because it would harm certain victims, has no basis under the law,13 and would undermine the CVRA's purpose to encourage proper treatment of victims. + +#### i. Partial rescission would pose harm to, and is contrary to the desires of, certain victims. + +Despite Petitioners best intentions, partial rescission would pose a significant risk of harm to certain victims, which must be considered in crafting an equitable remedy. The Eleventh Circuit has admonished courts considering equitable remedies to "bear in mind that a poorly crafted remedy may achieve justice for one by working a substantial injustice on another." Walters a City of Atlanta, 803 F.2d 1135, 1149 (11th Cir. 1986); see also Doll v. Brown, 75 F.3d 1200, 1205 (7th Cir. 1996) ("Of course the effect on innocent third parties is a factor to be taken into account in the formulation of an equitable remedy"); Byron v. Clay, 867 F.2d 1049 (7th Cir. 1989) (noting that "equitable" relief "may have effects on third parties . . . and so should not be entered without consideration of those effects"). + +13 For the reasons stated in the Government's prior filings, Docs. 119 & 147, the Government respectfully maintains that rescission is not an authorized remedy under the CVRA for the agreement in this matter. Petitioners submission highlights the problematic logic underpinning their request for any form of rescission. Petitioners claim that the CVRA's limitations on efforts to "reopen a plea" under 18 U.S.C. § 3771(d)(5) do not apply here because rescission of a non-prosecution agreement is not a request to re-open a plea, Doc. 458 at 9, but the Court found that rescission of a non-prosecution agreement was authorized under Section 3771(d)(5) precisely because re-opening a non-prosecution agreement is akin to re-opening a plea. Doc. 189 at 7-9. Petitioners thus embrace the Court's finding while contradicting its underlying reasoning, all in an effort to avoid the consequences of their inability to fulfill all of the conditions on relief outlined in Section 3771(d)(5). Petitioners cannot have it both ways. + +The government's recent effort to confer with victims has established that eliminating the immunity provisions would benefit certain victims and harm others. The government contacted all attorneys representing victims known to the government at the time of the NPA, attempted to locate other victims known at the time of the NPA, and conferred with additional victims who were not known at the time of the NPA. Indeed, the government has repeatedly invited Petitioners to confer with U.S. Attorney Pak in person "to share with [him] directly their thoughts about how the government should handle every aspect of this matter, both in civil and potential criminal proceedings." Letter from Byung J. Pak to Paul G. Cassell (May 7, 2019), attached as Exhibit 1. This invitation remains open. The government's efforts to speak with victims are ongoing, and it will seek leave to make a supplemental filing summarizing the steps taken to confer with victims and the victims opinions on a proper remedy to ensure that their diverse voices are heard. + +Based on the conversations with victims to date, it is apparent that any form of rescission would cause unintended harm to many of them. During these discussions with victims and their representatives, several victims passionately expressed their desire to see Epstein be prosecuted and were eager to serve as witnesses in any investigation of Epstein. On the other hand, other victims stated, through their counsel, that while they would like to see Epstein prosecuted for his crimes, they valued anonymity above all and were not willing to speak with law enforcement or otherwise participate in any criminal or civil litigation due to the risk that their involvement may become known to family, + +friends, or the public. Several victims previously expressed, during the investigation of Epstein, that they suffered emotional distress and were troubled by the prospect of any involvement in the government's investigation. Doc. 403- 18 ¶ 12. For these victims, setting aside the immunity provisions in a partial rescission could only undermine their desire to stay anonymous more than ten years after obtaining settlements from Epstein. + +The passage of more than ten years since the NPA was entered only compounds the potential harm to victims that would arise from partial rescission. The Court is well aware of "Petitioners counsel's initial 'indecision' on whether to seek rescission, as expressed at an earlier hearing held in August 2008," Doc. 189 at 12 n.6, in which counsel stated that "because of the legal consequences of invalidating the current agreement, it is likely not in my clients' best interest to ask for the relief that we initially asked for." Doc. 403-21 at 4. Petitioners' counsel told the Court in 2008 that "an immediate resolution was not necessary, Doc. 99 at 4, and the CVRA case then "stalled" for eighteen months "as petitioners pursued collateral civil claims against Epstein," resulting in the CVRA case being administratively closed in late 201014 Doc. 189 at 5. Even if rescission is a permissible remedy for certain violations of the CVRA, the more than decade-long delay here renders this remedy inappropriate given these + +14 For the reasons stated in its prior filings, Doc. 147 at 8-12; Doc. 401-2 at 28- 29, the government maintains that Petitioners should be estopped from seeking any form of rescission based on this delay. + +unique circumstances and exacerbates the harm to victims who have attempted to readjust their lives in the interim.15 + +## ii. Partial rescission contravenes governing tenets of contract law. + +In addition to the potential harm posed to innocent third parties, the law unfortunately restricts the government's and Court's ability to rewrite the NPA a decade later. It is not uncommon for one party to a contract to wish to rework or eliminate terms after entering the agreement. But no matter how regrettable an agreement may appear in hindsight, fundamental tenets of contract law prohibit the rewriting of terms when the parties intended the agreement to be fulfilled in its entirety. Such principles bind the government's hands in this case. + +Although the parties agree that the NPA should be governed by principles of contract law, Doc. 458 at 18, Petitioners cite no authority providing for partial rescission of a prosecutorial agreement, including a non-prosecution agreement, and ignore precedent foreclosing such a remedy when "the entire fulfillment of the contract is contemplated by the parties as the basis of the arrangement." Local No. 234 v. Henley & Beckwith, 66 So. 2d 818, 821 (Fla.1953); see also Frankenmuth Mutual Ins. v. Escambia County, 289 F.3d 723, 728 (11th Cir. 2002) (interpreting + +15 Although Petitioners' counsel have not spoken with the majority of the victims, they acknowledge that certain victims would be eager for rescission while a "large group ... will respond by saying 'I have buried these experiences deep in the past and I don't want to do anything at all to unearth all the hurt and pain it has taken me this long to process." Julie K. Brown, Prosecutors finally want to hear from Jeffrey Epstein's victims, MIAMI HERALD, 2019, https://www.miamiherald.com/news/state/florida/article230275434.html (last visited June 21, 2019). + +Florida law). Partial rescission of an agreement is "a remedy that is not generally cognizable under Florida law except in the unusual circumstances where a contract is clearly divisible." Galaxy Cable, Inc. v. Cablevision of Marion Cty., LLC, No. 5:05-CV-303-OC-GRJ, 2006 WL 2265419, at \*3 (M.D. Ha. Aug. 8, 2006). A contract is considered to be "indivisible" when "each and all of its parts appear to be interdependent and common to one another and to the consideration." Local No. 234, 66 So. 2d at 822 (holding that contract was indivisible when "it is impossible to conclude that the very significant promise on one side. .. can be entirely eliminated from the contract and still leave a valid working arrangement fairly reflecting the original mutual understanding between the parties"); see also Wilderness Country Club Partnership v. Groves, 458 So. 2d 769, 771 (Fla. Dist. Ct. App. 1984) (concluding that, despite the illegality of only one contract provision, partial rescission was improper because illegal term was "vital," and severing that term "eliminates the essence of the contracting parties agreement"). Courts determine whether an agreement is divisible based on the "intention of the parties" as revealed "by a fair construction of the terms and provisions of the contract itself, and by the subject matter to which it has reference." Local No. 234, 66 So. 2d at 822 (quotation marks omitted). + +Here, excising the "immunity" or non-prosecution provisions plainly would eliminate the essence of the "Non-Prosecution Agreement." The three sentences that Petitioners seek to write out of the agreement are the only contractual consideration that the government provided in exchange for Epstein's concessions to a felony conviction, prison sentence, sex offender registration, and uncontested restitution settlements. Doc. 48-5. Moreover, the agreement expressly states that its provisions were indivisible, noting that "each of these terms is material to this agreement and is supported by independent consideration," and a breach of any condition allowed the government to terminate the entire agreement. Id. at 7. Accordingly, omitting the immunity provisions "eliminates the essence of the contracting parties' agreement," and the NPA is thus an indivisible agreement not subject to partial rescission. Wilderness Country Club Partnership, 458 So. 2d at 771. Petitioners' request thus must be denied as a matter of law. + +Petitioners point to authority setting aside agreements containing illegal provisions in support of their request, Doc. 458 at 15-17, but this argument is meritless for two reasons. First, while Petitioners contend that the government failed to accord victims their rights in communicating the terms of the NPA, Petitioners have not identified any illegal provision in the NPA itself. Doc. 147 at 4-5. Petitioners cite no precedent authorizing the rescission of an agreement containing legally valid terms based solely on an extrinsic violation in communicating the terms of that agreement to a third party. Second, none of Petitioners cases authorizes partial rescission, the remedy they request here.16 + +16 See United States a Walker, 98 F.3d 944 (7th Cir. 1996) (holding that complete rescission of plea agreement was only permissible remedy when defendant was induced to enter plea based on mistake of law); Craig v. People, 986 P.2d 951, 966 (Colo. 1990) (noting that if plea was induced by illegal promise, proper remedy was defendant's option to withdraw from plea agreement in its entirety); State v. Garcia, 582 N.W.2d 879, 882 (Minn. 1998) (holding that if plea agreement could not be fulfilled based on illegal term, only remedy was withdrawal from entire + +#### iii. Partial rescission would reward, not remedy, a violation of the CVRA. + +Even if there were a legal basis for partial rescission, granting partial rescission in this matter would have the perverse effect of harming certain victims, who must be treated with "respect for [their] dignity and privacy" under the CVRA, 18 U.S.C. § 3771(a)(8), while rewarding the government for what the Court determined was a violation of the CVRA. The parties appear to have agreed for the purposes of this litigation that Epstein has fully performed his obligations under the NPA. By eliminating the immunity provisions of the agreement, Petitioners proposal would thus allow the government to enjoy all the benefits of Epstein's compliance without binding it to its commitments under the NPA. Accordingly, Petitioners would place the government in a more favorable position than if it had fully conferred with victims prior to entering the NPA. Such a result would not encourage strict adherence to the CVRA, and partial rescission in this case would not foster the goals of the CVRA. + +# B. Petitioners' request for declaratory relief + +Petitioners also request that this Court declare that the Constitution permits the government to prosecute Epstein in the event of rescission, but they cite no legal basis for this request. Declaratory relief serves only to clarify the legal relationship between the parties and does not serve to make factual + +plea agreement); State v. Wall, 502 S.E.2d 585, 588 (N.C. 1998) (same); Ex parte Rich,194 S.W.3d 508, 515 (Tex. Crim. App. 2006) (same); State v. Mazzone, 572 S.E.2d 891, 897 (W.Va. 2002) ("[A] plea agreement which cannot be fulfilled based upon legal impossibility must be vacated in its entirety."). + +determinations. See Medmarc Cas. Ins. Co. v. Pineiro & Byrd PLLC, 783 F. Supp. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. a White Oak Equity Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D. Fla. 2009); Eisenberg v. Standard Ins. Co., No. 09-80199, 2009 WL 1809994, at \*3 (S.D. FIa. June 25, 2009)). But that is precisely what Petitioners seek here. Accordingly, Petitioners fail to allege a basis on which declaratory relief would be appropriate. + +# C. Petitioners' request for injunctive relief + +Next, Petitioners ask this Court to: + +- order the government to issue a letter of apology, Doc. 458 at 5, 22-23; +- enjoin the government to make its "best efforts" to protect the victims rights and confer with the victims and give them accurate and timely notice of future cases, id. at 5, 21; +- order DOJ to provide training to the USAO-SDFL, id. at 6, 29; +- order the government to meet with the victims, confer about the case, and explain why it chose not to prosecute Epstein, id. at 5, 23; +- hold a hearing where victims can be heard, id. at 5, 23-24; and +- order that the government provide all information in its possession; provide all grand jury materials; provide any information regarding FBI Miami's investigation, including un-redacted 302s; provide all sealed materials previously submitted for in camera review; and provide all materials covered by its previously filed motions, id. at 5-6, 24-29. + +As a threshold matter, Petitioners do not have standing to seek injunctive relief. As the Supreme Court held in City of Los Angeles v. Lyons, 461 U.S. 95, 102- 03 (1983), "federal courts are without jurisdiction to entertain" claims for + +injunctive relief where a defendant points only to "past exposure to illegal conduct," and does not show "a continuing, present adverse effect." But even if Petitioners had standing to bring their request for injunctive relief, each request fails. + +With respect to Petitioners request for a letter of apology, such a remedy is not cognizable. In Woodruff v. Oilman, 29 F. App'x 337, 346 (6th Cir. 2002), the Sixth Circuit held that the district court exceeded its equitable powers when it ordered a party to apologize. In so holding, the court cited the Ninth Circuit, which has recognized that courts "are not commissioned to run around getting apologies," and reasoned that the law is not usually concerned with procuring apologies to make morally right a legal wrong done to the plaintiff. Id. (quoting McKee v. Turner, 491 F.2d 1106, 1107 (9th Cir. 1974)). And certainly, a court may not order a defendant to speak in a manner that may contravene the beliefs the defendant holds. See id.; see also Burkes v. Tranquilli, No. 08474, 2008 WL 2682606, at \*4 (W.D. Pa. 2008) (citing Woodruff 29 F. App'x at 346) ("Here, the district court exceeded its equitable power when it ordered [defendant] to apologize."). + +Petitioners request that this Court order the government to use its "best efforts" to comply with the CVRA and "confer" with the victims pursuant to the CVRA asks the Court to order the government to follow the law.17 Such "obeythe law" injunctions are "disfavored because they often run afoul of Rule 65(d)'s + +17 Petitioners request that the Court enjoin the government to confer with Jane Doe 1 and 2 is particularly unnecessary and unjustified in light of the government's standing invitation for them to do precisely that. See Exhibit 1. + +requirement that injunctions state their terms specifically and 'describe in reasonable detail' the 'act or acts restrained or required." United States v. Askins & Miller Orthopaedics, P.A., 924 F.3d 1348, 1361 (11th Cir. 2019) (quoting Fed. R. Civ. P. 65(d)). Obey-the-law injunctions are proper only when the "statutory terms are specific and the defendant clearly knows what conduct is prohibited or required." Id. at 1362 (citing SEC v. v. Goble, 682 F.3d 934, 950 (11th Cir. 2012)). Accordingly, such injunctions are permissible if they require parties to follow statutory terms with "specific, objective criteria for compliance," Goble, 682 F.3d at 951, or specify "numerous concrete actions for the defendants to take ... well beyond" what the law requires, Askins & Miller Orthopaedics, 924 F.3d at 1362. Obey-the-law injunctions concerning statutes lacking specific terms, or that require consultation with an "ever-changing judicial landscape" to interpret, do not inform the defendant of what conduct is forbidden under Rule 65(d). Goble, 682 F.3d at 951-52 (noting that "in some instances an injunction which merely tracks the language of the securities statutes and regulations will not clearly and specifically describe permissible and impermissible conduct"). Here, a statute requiring the government to make its "best efforts" to protect victims, 18 U.S.C. § 3771(c)(1), plainly does not provide "specific, objective criteria for compliance," Goble, 682 F.3d at 951. The requested obey-the-law injunction is thus both unwarranted and in violation of Rule 65(d). + +So too would any order requiring the government to conduct training. The CVRA itself mandates that DOJ regulations "require a course of training for employees .. . of the Department of Justice that fail to comply" with victim + +protections under federal law. 18 U.S.C. § 3771(0(2)(B). DOJ regulations do so. 28 C.F.R. § 45.10(d). There is no need to require the government to do what it has already undertaken to do, and prescribing the specific content or duration of such training would contravene the constitutional doctrine of separation of powers. Still, the government recognizes that training is always beneficial and offers to do so, as explained above. + +Next, Petitioners seek to meet with the government, attend a hearing, and review all government documents as a way of putting themselves in the position they would have been in had the government conferred with them before entering into the NPA. See Doc. 458 at 23 (explaining that "[a] chance to discuss this matter with Mr. Acosta to get answers about that and other related questions will, Jane Doe 1 and 2 believe, provide the kind of information that they would have received had the U.S. Attorney's Office properly conferred in a timely fashion back in 2007"); id. at 24-25 ("If the Government had properly conferred with the two Jane Does ... [t]hese events would have provided Jane Doe 1 and 2 with much more information about Epstein's criminal conspiracy and its scope and operation," and "[s]ince one of the harms that flows from that illegality is the loss of any chance to obtain information, the obvious remedy is to disclose that information"). But the problem with Petitioners requests is that they, if granted, would place Petitioners in an entirely different position than the CVRA allows. The law does not countenance such a result. See Feldkamp v. Long Bay Partners, LLC, 773 F. Supp. 2d 1273, 1285 (M.D. Fla. 2011) (holding that an injured party + +shall not be placed in a position "better than that which he would have occupied had the contract been performed"). + +To begin, while the CVRA grants victims the right to "confer" with the government, this means only that, and not necessarily that the government is required to explain the "next steps" it intends to make or to share confidential information, including grand jury materials or sensitive information from other witnesses. Petitioners request would intrude on the government's exercise of prosecutorial discretion, which is expressly prohibited by the CVRA. 18 U.S.C. § 3771(d)(6). Moreover, such an order would violate, or fall perilously close to violating, the separation-of-powers doctrine undergirding our democracy. It is axiomatic that "federal district courts cannot order a United States Attorney to conduct an investigation or to initiate a prosecution because it would violate the doctrine of separation of powers." O'Connor v. Nevada, 507 F. Supp. 546, 549 (D. Nev. 1981) (citing United States v. Cox, 342 F.2d 167,171 (5th Cir. 1965) ("[T]he attorney for the United States is .. . an executive official of the Government, and it is as an officer of the executive department that he exercises a discretion as to whether or not there shall be a prosecution in a particular case . . . and courts are not to interfere with the free exercise of the discretionary powers of the [United States attorneys] in their control over criminal prosecutions."). The decision whether to prosecute Epstein lies solely within the Executive Branch, and any order today, by this Court, as to what the government must do in the future would be wholly inappropriate. + +Nor does it mean that the government must give victims the discovery in the criminal case. As one court has explained, the CVRA does "not authorize an unbridled gallop to any and all information in the government's files." United States v. Rubin, 558 F. Supp. 2d 411, 425 (E D N Y. 2008); see also United States a Moussaoui, 483 F.3d 220, 235 (4th Cir. 2007) (noting that CVRA did not empower district court in a civil matter to order disclosure of documents to victims); United States v. Hunter, 548 F.3d 1308, 1317 (10th Cir. 2008) (holding "that the CVRA does not provide 'victims' with a right of access to the government's files"); cf. In re Slier, 571 F.3d 604, 609 (6th Cir. 2009) (holding that "the CVRA does not provide an independent right to obtain PSRs"); Kenna v. United States, 453 F.3d 1136, 1137 (9th Cir. 2006) (affirming district court's rejection of victim's argument that the CVRA conferred a general right for crime victims to obtain disclosure of PSRs). The CVRA provides victims with rights associated with the defendant's trial, such as notice of proceedings against the defendant, the right to be heard at a proceeding, and the right to confer with the government's attorney, but is silent as to documents offered during the trial. See In re Slier, 571 F3d at 609-10. + +Petitioners argument that they are entitled to grand jury records similarly fails. The traditional rule of grand jury secrecy may be set aside under certain circumstances prescribed by Federal Rule of Criminal Procedure 6(e). The Supreme Court has explained that a party seeking disclosure of grand jury materials must make a showing of a "particularized need." United States v. Aisenberg, 358 F.3d 1327, 1348 (11th Cir. 2004) (citing Douglas Oil Co. a Petrol + +Stops Northwest, 441 U.S. 211, 222 (1979)). For the reasons previously found by the Court, Petitioners have not, and cannot, make such a showing. Doc. 330 at 7-10. + +In addition, the law enforcement investigative privilege protects the documents Petitioners seek. The purpose of this privilege is "to prevent disclosure of law enforcement techniques and procedures, to preserve the confidentiality of sources, to protect witnesses and law enforcement personnel, to safeguard the privacy of individuals involved in an investigation, and otherwise to prevent interference with an investigation." In re Dep't of Investigation of the City of New York, 856 F.2d 481, 482 (2nd Cir. 1988) (citations omitted). Disclosure to third parties of the interview reports of the young women sexually abused by Epstein could cause their identities to become widely known and result in their harm or embarrassment. The disclosure of information contained in the FBI investigative file to third parties could cause additional psychological trauma, disruption of family relationships or professional careers, and possible public release of personal information.18 + +The law enforcement investigative privilege is recognized under the Freedom of Information Act (FOIA), 5 U.S.C. § 552, which specifically exempts from + +18 Disclosure of information from the FBI file would also reveal sensitive FBI investigative and operational methods, procedures, and techniques. Information contained within an FBI investigative file, if revealed, might compromise the effective use of such methods in future cases. The FBI's investigative tools must remain confidential so that law enforcement can retain an element of surprise and prevent the use of countermeasures by targets and suspects to thwart effective law enforcement. + +disclosure "records of information compiled for law enforcement purposes" that "could reasonably be expected to constitute an unwarranted invasion of personal privacy" or "would disclose techniques and procedures for law enforcement investigations or prosecutions .. . . " 5 U.S.C. § 552(b)(7)(C) and (E). Certainly Congress did not contemplate granting victims an end-run around the FOIA disclosure exemptions when it drafted the CVRA. + +## D. Petitioners' request for monetary damages + +Finally, Petitioners assert that they are entitled to "monetary sanctions," attorneys' fees, and restitution. As explained above, however, the CVRA explicitly prohibits a cause of action for damages against the United States arising from any violation of the CVRA. 18 U.S.C. § 3771(d)(6). Attempting to recast a claim for damages as monetary "sanctions" does not make it any less an impermissible claim for damages. + +Regarding restitution, Petitioners are entitled under the CVRA to "[t]he right to full and timely restitution as provided in law." 18 U.S.C. § 3771(a)(6). Congress modified a crime victim's entitlement to restitution by restricting it to only those circumstances "provided in law," thus recognizing that there would be numerous situations when it would be impossible for a victim to receive restitution. See In re W.R. Huff, 409 F.3d 555, 563 (2d Or. 2005). The statute under which Petitioners urge this Court to award restitution does not make the government liable for restitution for harms caused by others. Calling something "restitution" does not make it so. In reality, Petitioners seek money damages from the government, and this they cannot do. + +With respect to attorneys' fees, the doctrine of sovereign immunity bars an award of attorneys fees against the United States unless there is express statutory authorization for such an award. Joe v. United States, 772 F.2d 1535, 1536 (11th Cir. 1985). Waivers of sovereign immunity are to be strictly construed in favor of the sovereign. Id. (citing United States v. Sherwood, 312 U.S. 584, 590 (1941)). The CVRA does not provide for attorneys' fees against the United States, and thus Petitioners argument that they are entitled to attorneys fees must be rejected. + +## CONCLUSION + +Regardless of what the CVRA required the government to do in this matter, the victims are right to expect better from their Justice Department. The government's commitment in the decade since this action was filed to combat human trafficking and child exploitation and protect victims of such offenses underscores that its conduct in this matter, no matter how well-intentioned, fell short of the government's dedication to serve victims to the best of its ability. While the Court cannot unwind the past, the remedies proposed by the government would give the victims a meaningful opportunity to have their voices heard and to understand, if not accept, the decisions made in this matter. Petitioners requested remedies, on the other hand, run afoul of the remedial scheme contemplated by the CVRA, are contrary to law, and may cause unintended harm to the victims whose interests are also protected by the CVRA. + +For the foregoing reasons, the Court should endorse the government's proposed remedies. + +Respectfully submitted, + +BYUNG J. PAK +*United States Attorney* + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +## Certificate of Service + +I served this document today by filing it using the Court's CM/ ECF system, which automatically notifies the parties and counsel of record. + +June 24, 2019 + +Spedal Attorney + +# EXHIBIT 1 + +![](_page_33_Picture_1.jpeg) + +#### U.S. Department of Justice United States Attorney Northern District of Georgia + +600 us. Caseation IS Ted Tine Dna SW. Admit Genie X1103 + +May 7, 2019 + +Paul G. Cassell, . + +Re: Doe v. United States, Case No 9:08-CV-80736-ICAM + +Dear Mr. Cassell• + +Thank you for your letter of May 2, 2019. I write to clarify a few issues raised in your letter in advance of our call on May 9. + +While we understand your position regarding prior efforts by the U.S. Attorney's Office for the Southern District of Florida to communicate with victims, my office has expressed our intention to speak with victims in this matter from the outset of our designation. In our first letter to you on March 6, 2019, we noted our commitment to having a "full and open discussion with you and your clients" and "ensuring that we hear and understand your clients' concerns." And in my letter on April 30, 2019, I expressed our desire to confer with each victim in person, if the victim wishes to do so, and invited your clients to confer with us in person. In short, our commitment to confer with victims has been. and will remain. firm. + +While we appreciate your statement that you "are not opposed to giving the Government time to confer with any victims about this case," this claim appears to be inconsistent with your opposition to the government's request for time to do precisely that. Your letter explains your opposition to this request by pointing to past acts by a different office at a different time with a different procedural posture. + +As you know, the Court granted an extension for the government to review the voluminous pleadings in this matter and to confer with you regarding a proposed schedule to determine an appropriate remedy. We have worked diligently on that task, including multiple discussions with you regarding an appropriate schedule in accordance with the Court's order. In light of the purpose of this extension, your suggestion that the government 'has had enough time to confer' with victims during this time does not align with what the Court ordered us to do. Nor do we agree with your suggestion that your proposed schedule of requiring the + +government to propose a remedy within two weeks of a scheduling order gives the government "more than enough" time to speak with victims. + +As explained in my letter of April 30, 2019, we believe it is vital to confer with victims before proposing a remedy that may have a profound impact on their lives. The necessity of this step seems all the more apparent after we learned that you have consulted with only a subset of the victims, particularly when the parties agree that victims are likely to hold varying opinions about an appropriate remedy, including victims who are likely to oppose rescission of the non-prosecution agreement (NPA). The victims' diverse voices and concerns deserve to be heard as the Court is undertaking the difficult task of crafting an appropriate remedy. + +To that end, I repeat my desire to confer with your clients in person. We are considering all remedies that you have previously proposed in briefing, including rescission of the NPA. Given that consideration, I invite your clients to share with me directly their thoughts about how the government should handle every aspect of this matter, both in civil and potential criminal proceedings. If they have specific concerns or views about how the government should proceed if the NPA were not in place, I want to hear them. + +We also have been considering your suggestion for a mediation. As you know, our proposed schedule contemplates a mediation between the parties, which would take place after the parties have briefed their positions on potential remedies. We think the mediation will be most productive if the parties have a clear understanding about what each side is willing to consider prior to meeting. + +We look forward to discussing this issue further on Thursday. + +Sincerely, + +![]()BYUNG J. 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Corruption Unit + +U.S. Attorney's Office for the + +Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00085744/EFTA00085744.metadata.json b/marker2/ds9/EFTA00085744/EFTA00085744.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d2155d37f043d7bb0a2bd8f89b1ce4b2585eb91e --- /dev/null +++ b/marker2/ds9/EFTA00085744/EFTA00085744.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085744.pdf", + "engine": { + "marker_major": "2", + "marker_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": 194, + "elapsed_seconds": 0.5, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + 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Conference + +9 Before: + +10 11 HON. RICHARD M. BERMAN District Judge + +12 + +13 APPEARANCES + +14 + +15 16 17 18 GEOFFREY S. BERMAN United States Attorney for the Southern District of New York Assistant United States Attorneys + +19 + +20 21 REID H. WEINGARTEN MARTIN G. WEINBERG MARC FERNICH Attorneys for Defendant + +22 Also Present: + +23 24 25 - Special Agent FBI - NYPD - Probation Officer - Probation Officer + +x New York, N.Y. July 8, 2019 2:00 p.m. + +2 THE COURT: Good afternoon. + +3 4 5 6 7 I think I'm pretty much up to speed as to where you are in the sense that I am aware that you have been before Magistrate Judge Pitman earlier this morning and up to some few minutes ago for purposes of presentment, arraignment, and some preliminary discussion of bail. Is that accurate? + +9 10 11 12 13 That's correct, your Honor. I don't want to speak for defense counsel, but my understanding is they expect to put in some sort of written submission and return to argue the rest of the bail hearing on Thursday before Judge Pitman at 2:00. That is, if your Honor refers the bail hearing to Judge Pitman on that basis as well. + +14 15 16 THE COURT: I might just take that bail application before me. We'll figure out a time when that would be comfortable for all of you. How is that? + +17 18 MR. WEINGARTEN: That's fine with the government, your Honor. + +19 20 21 22 23 24 25 THE COURT: I have a few items on my list. I want to make mention, I'm sure Magistrate Judge Pitman did, of our presumption of innocence. Even though in some of these discussions, and probably more so when we get to bail, it may sound like we are talking about merits of the case, it's important that we underscore that the presumption of innocence pertains to Mr. Epstein, now and until such time, if it comes, 1 2 that there is a guilty determination by a jury or by the Court, that he is presumed to be innocent. + +3 4 5 6 7 I did have these questions. One has to do with persons who are categorized as victims. I want to get some assurance from the U.S. Attorney's office that they have been notified about this case and that you will keep them abreast of developments in this case. + +9 10 11 Yes, your Honor, we are acutely aware of our obligations to the victims in this case. We have notified them and we expect to continue to do so as the case moves forward. + +12 13 14 15 16 17 18 THE COURT: Second, for my background, I am aware that there are certain conditions that attach to Mr. Epstein's sex offender status resulting from his Florida state prosecution in or about 2008. One result is that under New York law - correct me if I'm wrong about any of this -- he is considered to be at high risk of committing another sex crime with minors. Is that a fair characterization of his sex offender status? + +19 20 21 22 23 Your Honor, as the government set forth in its submission to Judge Pitman, and we copied this Court, it is our understanding that the defendant is a tier 3 sex offender in New York and that that is characterized as high-risk individual. + +24 25 THE COURT: The question that I have is what are the implications, if any, of the search conducted by the U.S. + +1 2 3 4 5 Attorney's office over the weekend of Mr. Epstein's residence on East 71st Street for the terms and conditions of his sex offender status, if any? Are there any consequences or relationship between what was uncovered and what he is obliged to do? + +6 May I have one moment, your Honor? + +7 THE COURT: Yes. + +8 9 10 11 12 13 14 15 16 Your Honor, in response to that question, at the outset I should say that we don't have particular interaction with state authorities with respect to those types of notifications. We are, I would say, in the early stages of reviewing those materials. With respect to the defendant's obligations or potential consequences in the New York State system, we certainly will notify whichever authorities are appropriate. I don't think that we have a role other than that. + +17 18 19 20 I will say that they are extremely concerning with respect to bail here, with respect to the conduct here, and expect we will get into that more in our submissions and bail argument. + +21 22 THE COURT: By the way, if defense counsel wants to jump in at any point, feel free to do that? + +23 24 MR. WEINGARTEN: On that, we have not seen the pictures. + +25 THE COURT: I haven't either. + +1 2 3 4 MR. WEINGARTEN: I understand. It is our expectation that they are ancient, that they are pre his spending time in prison, and/or they are erotic pictures of adults who voluntarily engaged in that conduct. + +5 6 7 THE COURT: I have a question about the Southern District of Florida nonprosecution agreement dated probably in 2008 -- is that correct? + +9 THE COURT: Is that a public document? + +10 11 MR. WEINGARTEN: It is, your Honor. It's been publicly filed in connection with other civil litigation. + +12 13 14 THE COURT: Does that agreement bear on in any way the search and results of the search that were conducted at Mr. Epstein's townhouse over the weekend? + +15 16 17 18 Not in ways that I am aware of now, your Honor. Again, we are very much in progress on the search. We will continue to consider any other implications beyond this case as we continue to review those materials. + +19 20 21 22 23 24 25 On a separate note, your Honor, I want to add the government noted it is aware of its victim obligations. In terms of notification, we have made notification to individuals that we are in particular aware of. We also have listed a phone number for victims to be in touch with the FBI, with the U.S. Attorney's office. We have also put a website up and have asked victims to be in touch with us through those sources as + +It's dated in 2007, your Honor. + +1 well. That is just to round out the notification that the U.S. 2 Attorney's office has made. + +3 MR. WEINGARTEN: May I be heard briefly on that? + +4 THE COURT: Sure. + +5 MR. WEINGARTEN: For us, your Honor, the NPA is the 6 center of the universe for everything, search included, because 7 the NPA was the result of an extensive 3-year investigation by 8 law enforcement in Florida. In essence, the Feds made Mr. 9 Epstein plead to a state offense and they declined prosecution 10 federally, and that is translated in the NPA. Mr. Epstein did 11 his time, Mr. Epstein is on the registration list, and Mr. 12 Epstein paid the alleged victims. + +13 As I am sure you have noted from the indictment, that 14 conduct too is an ancient history. That conduct is 2002 to 15 2005. It is our belief that this is basically a re-do. This 16 is basically the Feds today, not happy with what happened in 17 the decision that led to the NPA, redoing the same conduct that 18 was investigated 10 years ago and calling it, instead of 19 prostitution, calling it sex trafficking. We think that is the 20 heart of everything, and that will be the centerpiece of our 21 defense, at least legally. + +22 THE COURT: My understanding of what the government is 23 asserting is that the episodes that occurred in Manhattan were 2.1 not included in the nonprosecution agreement in Florida and 25 that there is a separate basis not only for a sex trafficking + +2 3 4 5 6 7 MR. WEINGARTEN: We have had good conversations with the prosecutors, and we like and respect them. We are looking forward to getting discovery. We are interested to see whether the prosecutors in Florida, who are now under severe criticism 10 years later, steered the alleged victims to New York, whether or not they violated their responsibilities under the NPA. + +9 10 THE COURT: Whether the federal prosecutors in Florida violated their terms and conditions? + +11 MR. WEINGARTEN: That will certainly be germane. + +12 THE COURT: Is that the point? + +13 MR. WEINGARTEN: Yes. + +14 THE COURT: Got it. + +15 16 Your Honor, if I could very briefly respond to those points? + +17 THE COURT: Sure. + +18 19 20 21 22 23 I expect this will be briefed and argued on Thursday. I don't intend to go into extensive details about that. I just want to flag for the Court that defense counsel is saying that this conduct is ancient. What he is not saying is it is beyond the statute of limitations, because it is not. + +24 25 Second, the allegation that this is some kind of a conspiracy within the Department of Justice is just false. + +1 2 3 There is no evidence to support that. The investigation was begun and conducted entirely separate from any other district. It began in the Southern District of New York. + +4 5 6 7 9 10 Certainly there is evidence that was gathered that is consistent with and even overlapping with the prior investigation. But as the Court noted, in particular an entire count of this indictment is with respect to New York victims. And that is before we even get to the fact that the nonprosecution agreement does not bind the Southern District of New York. + +11 12 THE COURT: I was going to ask you about that too. Now that you have mentioned the topic, explain that, would you. + +13 14 15 16 17 18 Yes, your Honor. I do expect that we can brief this, but the short version is that this prosecution is not precluded by the nonprosecution agreement entered into by the defendant in the Southern District of Florida. That agreement expressly referred to that federal district. It didn't purport to bind any other office or district. + +19 20 21 22 23 24 25 It is well-settled in the Second Circuit that a plea agreement in one U.S. Attorney's office does not bind another unless otherwise stated. That is even if, based on case law, the agreement refers generally to "the government." Again, additionally, as set forth in the indictment returned by the grand jury, the substantive count alleges acts occurring in New York and alleges New York-based victims. + +1 2 3 4 5 That is in spite of the fact that the Southern District is not bound, is not a signatory to, and otherwise has no connection to the NPA. And there is no evidence that we have come across that the Southern District of New York was consulted, asked, involved, notified as far as we have seen. + +6 7 For those reasons and others I'm sure we will brief, we don't think the NPA applies to us. + +9 THE COURT: Yes. + +10 11 12 13 14 15 16 17 MR. WEINBERG: I have been one of Mr. Epstein's counsel through the CVRA litigation which started in 2008 and continues. In fact, our briefing is today. The NPA provided him with immunity for any offenses arising from a joint FBI/grand jury/U.S. Attorney investigation that led to a decision by Mr. Epstein to plead to a higher state offense than the state prosecutors contemplated. He went to jail, signed an agreement, and has lived up to its terms 100 percent. + +18 19 20 21 22 23 24 25 We have seen in the paperwork of the CVRA, in the Southern District of Florida, in writing at docket 205-2 the government's motion to dismiss CVRA, urging that the witnesses there go to the Southern District of New York and essentially try to motivate them to prosecute for the very same conduct, in other words, the conduct that Mr. Epstein was immunized, including travel between two states, telephonic communications between two states. Florida immunized him for the same travel + +MR. WEINBERG: If I may reply briefly, your Honor? + +2 In addition, the Department of Justice reviewed the 3 NPA on several occasions in 2008 and essentially confirmed that 4 the exercise of discretion shown in Florida was appropriate. 5 But the most important thing is that there was communication 6 between the prosecutors in Florida, perhaps through prosecutors 7 in Georgia that took over the case because the Florida 8 prosecutors were recused as a result of Judge Marrah's 9 decisions in the CVRA case. + +10 We know the government is relying in part on evidence 11 that was generated by the Southern District of Florida case 12 back in 2007. They have talked about message pads, telephone 13 records. They are the same message pads and telephone records 14 that reflect conduct that was exclusively 15, 16, 17 years ago. 15 So we do have a principal position that we will put to the 16 Court at the appropriate time regarding the legality of this 17 prosecution and whether or not it is appropriately barred. + +18 I can say as a criminal defense lawyer of 45 years, 19 when there is an interstate wire, mailing, travel, and there is 20 one district that is conducting an investigation, you negotiate 21 with that district and count on the Department of Justice to 22 what it does every day decade after decade after decade, which 23 is not to go to the second jurisdiction that received the mail 2.1 that was sent from the immunizing jurisdiction and have a 25 prosecution on the very same conduct. We will be briefing + +2 THE COURT: Do you anticipate that there is going to 3 be any discussion here about the legality of the NPA? + +4 MR. WEINBERG: Not the legality of the NPA. I th\_-k 5 the discussion here is going to be about its scope. + +6 THE COURT: From the defense, yes. You don't think 7 you expect to hear anything from the government, for example? + +8 MR. WEINBERG: In the Southern District case, the CVRA 9 case, maybe two weeks ago the Northern District of Georgia 10 prosecutors, who are proxy for the Southern District of 11 Florida, filed the submission before District Judge Marrah in 12 the CVRA case totally supporting the constitutionality and 13 legality of the NPA, their discretion to enter into it, and 14 that there absolutely has never been a charge that Mr. Epstein 15 ever did anything other than fully perform his end as a citizen 16 who is expecting the benefits of a contract that he lived up 17 to. + +18 THE COURT: I thought there had been some contention 19 that the way that the victims vis-a-vis the Florida NPA were 20 dealt with or not dealt with was one basis for attacking the 21 legality of that arrangement. + +22 MR. WEINBERG: The petitioners are vigorously and have 23 vigorously for many years challenged, many years starting quite 2.1 frankly after Mr. Epstein performed his obligations to go to 25 jail and challenged it, claiming that there was no consultation + +2 3 4 5 6 7 The Department of Justice at the time did not believe the CVRA extended absent a federal charge. The predicate is a federal crime that harms a victim. The petitioners have vigorously asserted a different position. Judge Marrah, in a summary judgment motion, agreed with the petitioners as to the fault of the government in not conferring. The issue of remedy is before Judge Marrah at the present time, your Honor. + +9 THE COURT: Okay. + +10 Your Honor, if I may very briefly? + +11 THE COURT: Yes. + +12 13 14 15 16 17 18 19 20 The crux of the defense argument here I think cuts precisely the other way. They are arguing that the Southern District of Florida has sort of sent up a flag that these prosecutions could be undertaken elsewhere. That's true. The Southern District of Florida has argued in papers that they believed, the Southern District of Florida believed, that the nonprosecution agreement was limited to that district. They have said that out loud and in public and in their positions in filing. + +21 22 23 24 25 So certainly this investigation was not shoveled to the Southern District of New York from anywhere else, including the Department of Justice. We expect that the nonprosecution agreement will not be an impediment, in particular because the defendant certainly did not lack for sophisticated counsel in + +1 2 3 negotiating that agreement, which again did not include the Southern District of New York. We don't expect that to be any impediment at all here. + +4 THE COURT: Got it. + +5 6 7 This is a small item. In the pretrial services report which was prepared today -- how many, if more than one, passports does Mr. Epstein have? + +8 9 10 MR. WEINGARTEN: Mr. Epstein reported today one. 1. others were rescinded. As we understand it, there is one effective passport today. + +11 12 I would like to make one other point about the pretrial that is extremely important. + +13 THE COURT: Go ahead. + +14 15 MR. WEINGARTEN: The way it reads is that we have refused to provide information about income and assets. + +16 17 18 19 THE COURT: I didn't really read it that way myself. I thought it was incomplete in some places and I thought it could be beefed up, so to speak. But I imagine that in the bail application those matters may be dealt with. + +20 MR. WEINGARTEN: Exactly. + +21 22 23 24 25 THE COURT: For : In your letter you describe some obstruction or harassment, witness tampering, alleged, by Mr. Epstein. That, I take it, is going to be included in any response or any bail submission made by the government? + +1 2 3 4 5 Your Honor, I think we addressed that in our initial submission. To the extent defense counsel has a response to it, we will evaluate that response and see whether additional submission from the government is required or appropriate. + +6 7 THE COURT: I think that's it for me in terms of questions that I might have had. + +9 10 11 There is, of course, a conspiracy charge here, one of the two counts. It may be early in your investigation to know. Do you anticipate that there may be other defendants in this proceeding? + +12 13 14 Your Honor, we don't expect any imminent superseding indictments in this case. It certainly is possible down the road. + +15 16 17 18 19 20 21 22 MR. WEINGARTEN: May I make one point, your Honor? These obstruction allegations we find very nettlesome and bothering. My understanding is that the Feds and Mr. Epstein's attorneys back in the early 2000s, or 2007 and 8, when they were negotiating were looking desperately for an appropriate statute. They finally settled on a state statute that Mr. Epstein pled to. We all know how unusual that is. There was some consideration of a federal statute, including obstruction. + +23 24 25 So lawyers in good faith were having discussions back and forth whether or not they could squeeze Mr. Epstein's conduct into a particular statute, and they concluded they + +1 2 couldn't because the facts didn't fit. That is my understanding of how those obstruction discussions arose. + +3 THE COURT: Got it. + +4 5 6 7 8 9 10 In terms of bail application, it would be helpful, and maybe this is your anticipation, to file written submissions. If you could do that. What I'm getting to is Thursday afternoon is not a good time, in my opinion. I would prefer to do it, if you would go along with this, Monday morning at, say, 9:30. That would give everybody more time to make these submissions and to study them. Is that agreeable? + +11 MR. WEINGARTEN: Yes. + +12 MR. WEINBERG: Yes. + +13 14 15 THE COURT: Why don't we say Monday at 10:00. Have you arranged written submissions on any time schedule with Magistrate Judge Pitman? + +16 17 May we have just a moment, your Honor, with defense counsel? + +18 19 20 THE COURT: Yes, would you. And also determine if one party or the other is going first and that the other is responding or they are simultaneous. + +21 Yes, your Honor. Thank you. + +22 (Pause) + +23 24 25 Your Honor, the government is prepared to rely on its initial submission at least for its first argument. I expect defense counsel will respond to that 1 2 and propose a package. Then the government would like an opportunity to reply to that submission. + +3 4 5 6 7 9 The parties would be happy to make those deadlines Thursday and Saturday respectively. However, we are also happy to back that up a little bit if the Court prefers not to receive the government's submission over the weekend. We could do an earlier deadline on Thursday for defense and a late Friday deadline for the Court from the government, depending on what the Court prefers. + +10 11 THE COURT: I was going to propose defense Thursday at noon. Is that okay to get your submission in? + +12 MR. WEINBERG: We can do that, your Honor. + +13 THE COURT: Thanks. + +14 And if you could respond Friday by 5:00 p.m. + +15 We will, your Honor. Thank you. + +16 17 18 19 THE COURT: Then we can have oral presentations. I take it everybody wants to have oral presentations in addition to the written. I'll set aside as much time as we need on the 15th at 10:00. + +20 21 I ask the government if there is a speedy trial issue or application that takes us to Monday at 10:00 a.m. + +22 23 24 25 Yes, your Honor. The government asks that speedy trial time be excluded until Monday. We do expect to begin the process of working on producing discovery, to include discussions with defense counsel about a protective + +1 2 3 4 order. I think, frankly, the outcome of that will be effected by the coming week. But we do expect to have those conversations and therefore request that speedy trial time be excluded until Monday. + +5 6 7 9 THE COURT: I am going to find under 18 United States Code 3161 that the request for adjournment, joined in by both sides, to and including Monday the 15th at 10:00 a.m., is appropriate and warrants exclusion of the adjourned time from speedy trial calculations. + +10 11 12 13 14 15 16 17 I further find that the exclusion is designed to prevent any possible miscarriage of justice to facilitate these proceedings and, initially at least, so that counsel has time to prepare written bail submission and to guarantee effective representation of and preparation by counsel for both sides. Thus, the need for exclusion and the ends of justice outweigh the interests of the public and the defendant in a speedy trial pursuant to 18 U.S.C. section 3161(h) (7)(A) and (B). + +18 19 20 Does anybody want to add anything to today's session? Your Honor. May we have one more moment with defense counsel? + +21 22 THE COURT: Sure. (Pause) + +23 24 : Nothing from the government. Your + +25 THE COURT: Defense? + +2 THE COURT: Nice to see you all. See you on Monday. + +3 Thank you. + +4 (Adjourned) \ No newline at end of file diff --git a/marker2/ds9/EFTA00085745/EFTA00085745.metadata.json b/marker2/ds9/EFTA00085745/EFTA00085745.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..68fb1a5f26cf7e6999b961f12145ebccd144faf4 --- /dev/null +++ b/marker2/ds9/EFTA00085745/EFTA00085745.metadata.json @@ -0,0 +1,636 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085745.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 18, + "chars": 21803, + "elapsed_seconds": 2.83, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 113 + ], + [ + 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a/marker2/ds9/EFTA00085763/EFTA00085763.md b/marker2/ds9/EFTA00085763/EFTA00085763.md new file mode 100644 index 0000000000000000000000000000000000000000..34a8915a5f157ff3bf255979a07380037aefbcb7 --- /dev/null +++ b/marker2/ds9/EFTA00085763/EFTA00085763.md @@ -0,0 +1,35 @@ +To: (USANYS H H (USANYS)" + +Subject: FW: Jeffrey Epstein 19 cr 490 + +Date: Mon, 12 Aug 2019 18:38:01 +0000 + +Attachments: 2019 08 12 14 31 06.pdf + +From: + +Sent: Monday, August 12 2019 2:33 PM + +To: Lamine N'Diaye + +Cc + + > > < > 8/12/2019 12:47 PM >>> + +Please see attached letter from Judge Richard M. Berman. + +(See attached file: Aug 12 letter.pdf) \ No newline at end of file diff --git a/marker2/ds9/EFTA00085763/EFTA00085763.metadata.json b/marker2/ds9/EFTA00085763/EFTA00085763.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3fcd71119e0cd396f580f3ebadf8201ee516b112 --- /dev/null +++ b/marker2/ds9/EFTA00085763/EFTA00085763.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085763.pdf", + "engine": { + "marker_major": "2", + "marker_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": 0.96, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 60 + ], + [ + "Line", + 28 + ], + [ + "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/EFTA00085763" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085764/EFTA00085764.md b/marker2/ds9/EFTA00085764/EFTA00085764.md new file mode 100644 index 0000000000000000000000000000000000000000..22e85b34ed9650fe0c0c9230706cbc93686dcf64 --- /dev/null +++ b/marker2/ds9/EFTA00085764/EFTA00085764.md @@ -0,0 +1,25 @@ +![](_page_0_Picture_0.jpeg) + +August 12, 2019 + +## U.S. Department of Justice Federal Bureau of Prisons Office of the Warden + +Met lima Correctional Center New York. New York 10007 axl + +SENT VIA EMAIL The Honorable Richard M. Berman, District Judge Daniel Patrick Moynihan United tate. Courthouse + +New York, New York 10007-1312 + +Re: EPSTEIN. Jeffrey, Federal Register No. 76318-054 United States v. Jeffrey Epstein 19-er-00490-RMB + +Dear Judge Berman: + +I am writing in regards to your August 12, 2019 inquiry whether the investigations referenced in my August 10, 2019 letter will include the incident at MCC involving Mr. Epstein on or about July 23, 2019. + +I can confirm that, although an internal investigation was completed regarding the July 23, 2019 incident, the current investigations by the FBI and OIG will include this incident as well. Accordingly, I cannot divulge any information about the prior investigation at this time. + +Thank you for your time and attention to this matter. If you have any questions or concerns, please feel free to call me at + +Lamine N r iaye Warden MCC New York + +cc: Chief Judge Colleen McMahon ei' nd, District Executive U.S. Marshal Assistant U.S. Attorneys Martin Weinbe g. Counsel for Mr. Epstein \ No newline at end of file diff --git a/marker2/ds9/EFTA00085764/EFTA00085764.metadata.json b/marker2/ds9/EFTA00085764/EFTA00085764.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..de504077de6b3e90d5f39db6407c413eda65df65 --- /dev/null +++ b/marker2/ds9/EFTA00085764/EFTA00085764.metadata.json @@ -0,0 +1,88 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085764.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1234, + "elapsed_seconds": 0.77, + "image_assets": [ + "_page_0_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice \nFederal Bureau of Prisons \nOffice of the Warden", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 375.768, + 35.001999999999995 + ], + [ + 520.4243774414062, + 35.001999999999995 + ], + [ + 520.4243774414062, + 106.570556640625 + ], + [ + 375.768, + 106.570556640625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Line", + 32 + ], + [ + "Text", + 12 + ], + [ + "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/EFTA00085764" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085764/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00085764/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..8842998e437fe901bf91dd62ba4e7b69b782c5b6 --- /dev/null +++ b/marker2/ds9/EFTA00085764/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:ef512c1820301fabe79a80e3fc1d3eb464f3ad4ade15784687c61056c220cafb +size 12661 diff --git a/marker2/ds9/EFTA00085765/EFTA00085765.md b/marker2/ds9/EFTA00085765/EFTA00085765.md new file mode 100644 index 0000000000000000000000000000000000000000..e17e40916b715e8d06f8343576740d0a1064ee94 --- /dev/null +++ b/marker2/ds9/EFTA00085765/EFTA00085765.md @@ -0,0 +1,9 @@ +**To:** "Todd Wallace Blanche ([REDACTED])," "Sean S. Buckley Esq. ([REDACTED])," "John Peter Cronan Esq. ([REDACTED])," "[REDACTED]" + +**Subject:** [REDACTED] continues to kill it + +**Date:** Tue, 13 Aug 2019 01:09:59 +0000 + +--- + + \ No newline at end of file diff --git a/marker2/ds9/EFTA00085765/EFTA00085765.metadata.json b/marker2/ds9/EFTA00085765/EFTA00085765.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c208971c79b89acdac2e089f0b8fda14ccaea5a9 --- /dev/null +++ b/marker2/ds9/EFTA00085765/EFTA00085765.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085765.pdf", + "engine": { + "marker_major": "2", + "marker_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": 316, + "elapsed_seconds": 76.18, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Text", + 11 + ], + [ + "Line", + 9 + ], + [ + "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/EFTA00085765" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085766/EFTA00085766.md b/marker2/ds9/EFTA00085766/EFTA00085766.md new file mode 100644 index 0000000000000000000000000000000000000000..b0f56793539582eb3c6ecf873b8c5ba9e5c410e5 --- /dev/null +++ b/marker2/ds9/EFTA00085766/EFTA00085766.md @@ -0,0 +1,36 @@ +![](_page_0_Picture_91.jpeg) + +**To:** + +**Cc:** + +![](_page_0_Picture_94.jpeg) + +**Subject:** Epstein - Additional Requests/ Interviews + +**Date:** Tue, 13 Aug 2019 14:38:20 +0000 + +--- + +We just spoke with OCME, and they would like (i) the responding ambulance reports; and (ii) physical descriptions (height and weight) for Noel and Thomas. Could you please get us this information? + +Second, below are the people that we would like to set up voluntary interviews with in the next few days. [REDACTED] can you please reach out to [REDACTED] to set these up: + +| Name | Position | Shift | +|------------|----------|----------------| +| [REDACTED] | OPS Lt. | 8/10 from 12-8 | +| [REDACTED] | Internal | 8/10 from 12-8 | +| [REDACTED] | Internal | 8/9 from 4-12 | +| [REDACTED] | Internal | 8/9 from 4-12 | +| [REDACTED] | Control | 8/10 from 12-8 | +| [REDACTED] | Control | 8/9 from 4-12 | +| [REDACTED] | Control | 8/9 from 2-10 | + +Thanks, + +![](_page_0_Picture_101.jpeg) + +Assistant United States Attorney +Southern District of New York + +![](_page_0_Picture_103.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00085766/EFTA00085766.metadata.json b/marker2/ds9/EFTA00085766/EFTA00085766.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1c6542b42902b1ea8cb5b2770f815fe37d4b031c --- /dev/null +++ b/marker2/ds9/EFTA00085766/EFTA00085766.metadata.json @@ -0,0 +1,67 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085766.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1077, + "elapsed_seconds": 4.65, + "image_assets": [ + "_page_0_Picture_91.jpeg", + "_page_0_Picture_94.jpeg", + "_page_0_Picture_101.jpeg", + "_page_0_Picture_103.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Text", + 36 + ], + [ + "Line", + 21 + ], + [ + "Picture", + 4 + ], + [ + "PageFooter", + 2 + ], + [ + "Table", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00085766" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085766/_page_0_Picture_101.jpeg b/marker2/ds9/EFTA00085766/_page_0_Picture_101.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..86d202e128cd7b456ecae517b109d96289582164 --- /dev/null +++ b/marker2/ds9/EFTA00085766/_page_0_Picture_101.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:eef8928f5c0062e26c2f45375b4c408e1fb5e2c2f80ac65265f66fb954d3db2d +size 1586 diff --git a/marker2/ds9/EFTA00085766/_page_0_Picture_103.jpeg b/marker2/ds9/EFTA00085766/_page_0_Picture_103.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..0b94a32a613283ec16f58206a27d9d7ac7dc25b9 --- /dev/null +++ b/marker2/ds9/EFTA00085766/_page_0_Picture_103.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:b970fde78e4885637b26f2ada791e414d9bf2e98dbedbe309c8c1ccfffbad35f +size 1672 diff --git a/marker2/ds9/EFTA00085766/_page_0_Picture_91.jpeg b/marker2/ds9/EFTA00085766/_page_0_Picture_91.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..aa78ad843808d6ca5dc3528e9f6923f24c015c12 --- /dev/null +++ b/marker2/ds9/EFTA00085766/_page_0_Picture_91.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:0419a6f1d7b8804e3dc428c846e89a56574de6e3a340144bec7c9a9baea893a7 +size 7665 diff --git a/marker2/ds9/EFTA00085766/_page_0_Picture_94.jpeg b/marker2/ds9/EFTA00085766/_page_0_Picture_94.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..24d824f2ada6a034f11a53e975d7039b39b8cb56 --- /dev/null +++ b/marker2/ds9/EFTA00085766/_page_0_Picture_94.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:baf36232d5bb1d442e9d5fdff8e540386eb98881c2a792c42da1e6f243e0992b +size 989 diff --git a/marker2/ds9/EFTA00085767/EFTA00085767.md b/marker2/ds9/EFTA00085767/EFTA00085767.md new file mode 100644 index 0000000000000000000000000000000000000000..6b50958d125451ebb5273a741508b85fd9cf8871 --- /dev/null +++ b/marker2/ds9/EFTA00085767/EFTA00085767.md @@ -0,0 +1,66 @@ +**To:** [REDACTED] + +**Cc:** [REDACTED] + +**Subject:** RE: MCC + +**Date:** Tue, 13 Aug 2019 16:13:04 +0000 + +--- + +There are at least 7 officers (excluding [REDACTED] and [REDACTED]) and 2 supervisors who should have been aware that Epstein did not have a cellmate on Friday, but did not reassign him one. We reached out to 3 of those officers yesterday, but they refused to meet with us without their union rep. + +The names of the officers who worked in the SHU on 8/9, excluding [REDACTED] and [REDACTED], are: + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +The supervisors are: + +[REDACTED] +[REDACTED] +[REDACTED] + +We may be interviewing [REDACTED] today. [REDACTED] wrote a memo reporting that he told Officers [REDACTED] that Epstein would need a cellmate at 1:50 p.m. on 8/9. We may be interviewing him today as well. + +[REDACTED] + +--- + +**From:** [REDACTED] + +**Sent:** Tuesday, August 13, 2019 11:15 AM + +**To:** [REDACTED] + +**Cc:** [REDACTED] + +**Subject:** Re: MCC + +Can we confirm that one of the co's who would not meet with FBI without union rep was the co who did not assign a new cellmate to JE when the old cellmate was moved out? + +[REDACTED] + +[REDACTED] + +On Aug 13, 2019, at 10:48 AM [REDACTED] wrote: + +Yesterday 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. + +- - [REDACTED] 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, Lt. Jean arrived at 5:30 a.m. to relieve the outgoing lieutenant,. At 6:33 a.m., heard a radio call for medical staff at the SHU. responded to the SHU, where he saw Office= who said that Epstein had hung himself sent into Epstein's cell, and Epstein was on the ground, on top of two mattresses, and Office. was performing CPR. then started CPR until medical staff came. asked Office= where Epstein's cellmate was, and she said he left, and that he didn't have one overnight. old Officer= that she knew Epstein was supposed to have a cellmate, and Officer= stuttered, then said she didn't know. Officer=admitted a that they did not conduct the 3 a.m. and 5 a.m. counts; and Officersaid "we messed up" and "we didn't do the counts" and "it's not her fault: as not aware the cameras were not working in SHU. + +## Interview o + +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 caagot Epstein his pin number a few days before Epstein's death, but Epstein had not activated it. atook Epstein to the SHU showers to make the phone call. Epstein toldahe 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 — Officeand 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.. + +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. aid they were aware thaahad court, which was not out of the ordinary. No one briefed him on the fact thatapersonal property was being collected or that he was moved. did not learn that Epstein's cellmate moved until after Epstein's apparent suicide was discovered. 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. + +FBI and OIG agents also attempted to interviea and (the officers who discovered Epstein), but they did not agree to speak with agents and agents were unable to serve the subpoenas. (An individual who the agents believe was aanswered the phone but then claimed he wasn't end 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. \ No newline at end of file diff --git a/marker2/ds9/EFTA00085767/EFTA00085767.metadata.json b/marker2/ds9/EFTA00085767/EFTA00085767.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..03f3a864f1f158fad43ac1d89f2cb61754493796 --- /dev/null +++ b/marker2/ds9/EFTA00085767/EFTA00085767.metadata.json @@ -0,0 +1,143 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085767.pdf", + "engine": { + "marker_major": "2", + "marker_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": 4707, + "elapsed_seconds": 6.79, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Interview o", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 34.272, + 160.38 + ], + [ + 186.048, + 160.38 + ], + [ + 186.048, + 174.0841064453125 + ], + [ + 34.272, + 174.0841064453125 + ] + ] + }, + { + "title": "Interview of..", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 34.272, + 349.92 + ], + [ + 198.288, + 349.92 + ], + [ + 198.288, + 363.0840759277344 + ], + [ + 34.272, + 363.0840759277344 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Text", + 45 + ], + [ + "Line", + 26 + ], + [ + "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", + 80 + ], + [ + "Line", + 41 + ], + [ + "Text", + 5 + ], + [ + "ListGroup", + 3 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00085767" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085769/EFTA00085769.md b/marker2/ds9/EFTA00085769/EFTA00085769.md new file mode 100644 index 0000000000000000000000000000000000000000..b02323fd9e529ea3c99323005f26d92c7198d769 --- /dev/null +++ b/marker2/ds9/EFTA00085769/EFTA00085769.md @@ -0,0 +1,17 @@ +To: ' + +Cc: + +Subject: Trial Subpoena + +Date: Thu, 29 Jul 2021 21:46:49 +0000 + +Attachments: 2021.07.30\_Court\_Subpoenas \_Xavier\_College\_Preparatory.pdf + +Hi and M, + +We want to track down school records for Attached is a subpoena to the school. I listed the phone number I found on the website ( ). It looks like there may be a Student Records department in case that is helpful ( ). Would you please make contact and serve the subpoena? To the extent they raise confidentiality issues, you can have them contact me. Please let me know if you have any questions. + +Thanks very much, + +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/EFTA00085769/EFTA00085769.metadata.json b/marker2/ds9/EFTA00085769/EFTA00085769.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6c8556af7deef405942abb9c36ac8e051186b15c --- /dev/null +++ b/marker2/ds9/EFTA00085769/EFTA00085769.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085769.pdf", + "engine": { + "marker_major": "2", + "marker_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": 724, + "elapsed_seconds": 0.74, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Line", + 19 + ], + [ + "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/EFTA00085769" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085770/EFTA00085770.md b/marker2/ds9/EFTA00085770/EFTA00085770.md new file mode 100644 index 0000000000000000000000000000000000000000..52dc3e838ecb53d0b6267f7e1fa87061a0a84b5e --- /dev/null +++ b/marker2/ds9/EFTA00085770/EFTA00085770.md @@ -0,0 +1,101 @@ +From: + +To: + +Cc: + +Subject: RE: CBP Question + +Date: Fri, 30 Jul 2021 13:43:16 +0000 + +Thanks so much. We really appreciate you looking into this for us. To confirm, you searched the DOB and document numbers for the three individuals? Thanks again! + +From: + +Sent: urs ay, uy , : M + +To: + +Cc: + +Subject: RE: CBP Question + +Hey + +As discussed, I reviewed all the travel records you sent. Unfortunately, the outbound travel records were not recorded in CBP database during that time (between 1990-2000) as they are today. In short, the TECS travel records you have for Maxwell and Epstein are all we have in CBP holdings so there's nothing further I can provide for that date range. However, if you want travel records beyond 2000 I can certainly provide that just let me know if you have a specific date range you looking for. + +Since as two different name variations (with and without the space in her surname) you were provided two separate TECS travel records. After reviewing both records, they are accurate and include all her travel crossings recorded in CBP holdings. Attached is an excel spreadsheet that includes her full travel crossings in chronological order for you to cross reference with the TECS records provided. Hopefully it will make it easier to review her travel rather than going back and forth between the two PDFs. + +If you need any additional info (visa/passport applications, travel records, etc.) or have any questions please don't hesitate to reach out! + +Respectfully, + +U.S. Customs and Border Protection Task Force Officer - SDNY US Attorney's Office Southern District of New York + +(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. If you are not the intended recipient, please contact the sender and destroy all copies of the communication. + +DISSEMINATION INSTRUCTIONS: This document is marked Law Enforcement Sensitive/For Official Use Only and may be disseminated, with proper attribution, to Law Enforcement, DOD, or U.S. Intelligence Agencies. Further disclosure to unauthorized entities could jeopardize ongoing investigations, operations, and personal safety. This product shall not be released to the public or media. + +From: Sent: Thursda Jul 29, 2021 6:17 PM + +To: + +Cc + +Subject: RE: CBP Question + +■ + +**Thanks again for helping; we really appreciate it. Attached are the records. Please let us know if you have any questions.** + +**Thanks.** + +**From: Sent: Thursday, July 29, 2021 5:31 PM** + +**To:** + +**Cc: Su . .** + +**Hey** + +**Sorry I was on the road but I spoke with\_he filled me in on what your looking for. I'm also available for a call to further discuss.** + +**Respectfully,** + +**U.S. Customs and Border Protection Task Force Officer - SDNY US Attorney's Office Southern District of New York** + +**(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. If you are not the intended recipient, please contact the sender and destroy all copies of the communication.** + +**DISSEMINATION INSTRUCTIONS: This document is marked Law Enforcement Sensitive/For Official Use Only and may be disseminated, with proper attribution, to Law Enforcement, DOD, or U.S. Intelligence Agencies. Further disclosure to** + +unauthorized entities could jeopardize ongoing investigations, operations, and personal safety. This product shall not be released to the public or media. + +From: + +Sent: Thursday, July 29, 2021 3:56:15 PM + +To: + +Cc: + +Subject: CBP Question + +sender. 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. + +I hope you are well! I assed along your info to us. We were hoping to connect with you by phone about a question in one of our cases. Do you have time to talk today or tomorrow morning? + +Thanks so much! + +Assistant United States Attorney United States Attorney's Office rk + +New York, New York 10007 + +Tel: \ No newline at end of file diff --git a/marker2/ds9/EFTA00085770/EFTA00085770.metadata.json b/marker2/ds9/EFTA00085770/EFTA00085770.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..12abc1d546ead4e262c6924aa435a389653e5351 --- /dev/null +++ b/marker2/ds9/EFTA00085770/EFTA00085770.metadata.json @@ -0,0 +1,169 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085770.pdf", + "engine": { + "marker_major": "2", + "marker_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": 5280, + "elapsed_seconds": 1.11, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "WARNING:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 668.25 + ], + [ + 87.93122863769531, + 668.25 + ], + [ + 87.93122863769531, + 682.2140808105469 + ], + [ + 31.212, + 682.2140808105469 + ] + ] + }, + { + "title": "WARNING:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 604.26 + ], + [ + 84.93438720703125, + 604.26 + ], + [ + 84.93438720703125, + 618.1153411865234 + ], + [ + 31.212, + 618.1153411865234 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 40 + ], + [ + "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 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 37 + ], + [ + "Text", + 18 + ], + [ + "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", + 36 + ], + [ + "Line", + 18 + ], + [ + "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/EFTA00085770" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085773/EFTA00085773.md b/marker2/ds9/EFTA00085773/EFTA00085773.md new file mode 100644 index 0000000000000000000000000000000000000000..07c53c319bd0b93d0a8d9f3b3332989a7eeba364 --- /dev/null +++ b/marker2/ds9/EFTA00085773/EFTA00085773.md @@ -0,0 +1,21 @@ +From: To: Cc: + +Subject: Re: flights Date: Fri, 02 Oct 2020 17:34:16 +0000 + +Thanks— this is for the Epstein case. + +Sent from my iPhone + +On Oct 2, 2020, at 1:17 PM, wrote: + +I forgot to ask what's the case name and specific purpose of this trip? About to book both of your flight reservations now. I'll add the hotel to the trip once you make your selection. Thanks. + +From: Sent: Friday, October 2, 2020 10:24 AM To: Cc: Subject: flights > + +Hi + +Hope you're doing well and staying safe. I'm reaching out to ask if you're available today to help us make some travel reservations for an upcoming trip to London. In particular, and I are looking for a nonstop flight to London, departing 10/12 on a redeye (landing 10/13), and returning on 10/17. I think we are required to book refundable fares on U.S. carriers. + +If you're available, could you please send us some potential flights today? + +Thanks very much, \ No newline at end of file diff --git a/marker2/ds9/EFTA00085773/EFTA00085773.metadata.json b/marker2/ds9/EFTA00085773/EFTA00085773.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..72a2cd2dfb72cc7f1f0d14735c861b305cb9de93 --- /dev/null +++ b/marker2/ds9/EFTA00085773/EFTA00085773.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085773.pdf", + "engine": { + "marker_major": "2", + "marker_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": 902, + "elapsed_seconds": 0.61, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Line", + 24 + ], + [ + "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/EFTA00085773" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085774/EFTA00085774.md b/marker2/ds9/EFTA00085774/EFTA00085774.md new file mode 100644 index 0000000000000000000000000000000000000000..d3aaf00fe176521b099fb13bd7353128888898c5 --- /dev/null +++ b/marker2/ds9/EFTA00085774/EFTA00085774.md @@ -0,0 +1,57 @@ +**To:** [REDACTED] > + +**Cc:** [REDACTED] +[REDACTED] + +**Subject:** RE: The Washington Post: A sexual assault case leads to a devastating allegation against a powerful man + +**Date:** Mon, 05 Oct 2020 14:13:07 +0000 + +--- + +No problem! And thanks very much for passing that along. + +--- + +**From:** [REDACTED] + +**Sent:** Monday, October 5, 2020 10:09 AM + +**To:** [REDACTED] + +**Cc:** [REDACTED] +[REDACTED] + +**Subject:** Re: The Washington Post: A sexual assault case leads to a devastating allegation against a powerful man + +Of course, apologies for spacing on that! + +Here's something else: + +Sent from my iPad + +On Oct 4, 2020, at 9:00 PM, [REDACTED] > wrote: + +Thanks [REDACTED] FYI, [REDACTED] is now on the Maxwell team, so would be great if you could loop her in on these emails going forward. + +--- + +**From:** [REDACTED] > + +**Sent:** Sunday, October 4, 2020 5:02 PM + +**To:** [REDACTED] +[REDACTED] + +**Subject:** The Washington Post: A sexual assault case leads to a devastating allegation against a powerful man + +Not sure if you guys have seen this, just thought it was interesting. + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +Read in The Washington Post: + +Shared from [Apple News](#) \ No newline at end of file diff --git a/marker2/ds9/EFTA00085774/EFTA00085774.metadata.json b/marker2/ds9/EFTA00085774/EFTA00085774.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b5249ed9e6639229b5ce06dfa03b61c3b9c28cd3 --- /dev/null +++ b/marker2/ds9/EFTA00085774/EFTA00085774.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085774.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1323, + "elapsed_seconds": 6.54, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Text", + 50 + ], + [ + "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/EFTA00085774" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085775/EFTA00085775.md b/marker2/ds9/EFTA00085775/EFTA00085775.md new file mode 100644 index 0000000000000000000000000000000000000000..009d4debe14e56345f26b2b7d5ebd32feba635cd --- /dev/null +++ b/marker2/ds9/EFTA00085775/EFTA00085775.md @@ -0,0 +1,33 @@ +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK +UNITED STATES COURTHOUSE +500 PEARL STREET +NEW YORK, NEW YORK 10007 + +CHAMBERS OF +RICHARD M. BERMAN +UNITED STATES DISTRICT JUDGE + +August 12, 2019 + +Lamine N'Diaye, Warden +Metropolitan Correctional Center +[REDACTED] +New York, New York 10007 + +Dear Warden N'Diaye, + +Thank you for your letter of August 10, 2019 regarding the death of Jeffrey Epstein. Mr. Epstein's death is a tragedy to everyone involved in his case. + +One open question, among others, is whether the investigations referenced in your letter will include the incident at MCC involving Mr. Epstein on or about July 23, 2019. To my knowledge, it has never been definitively explained what the BOP concluded about that incident. + +Sincerely, + +![]()Richard M. Berman + +ec; Chief Judge Colleen McMahon +Edward Friedland, District Executive +[REDACTED], Supervisory Staff Attorney MCC +[REDACTED], U.S. Marshal +[REDACTED] Assistant United States Attorney +Martin Weinberg, Counsel for Mr. Epstein \ No newline at end of file diff --git a/marker2/ds9/EFTA00085775/EFTA00085775.metadata.json b/marker2/ds9/EFTA00085775/EFTA00085775.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d17e61db0f0af34fb4abfa90c9af6460650b27aa --- /dev/null +++ b/marker2/ds9/EFTA00085775/EFTA00085775.metadata.json @@ -0,0 +1,86 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085775.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1031, + "elapsed_seconds": 4.15, + "image_assets": 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+ "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 194, + "elapsed_seconds": 0.42, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 18 + ], + [ + "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/EFTA00085776" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085777/EFTA00085777.md b/marker2/ds9/EFTA00085777/EFTA00085777.md new file mode 100644 index 0000000000000000000000000000000000000000..81a36e703af493c88a60bfbadb72bac22a856626 --- /dev/null +++ b/marker2/ds9/EFTA00085777/EFTA00085777.md @@ -0,0 +1,29 @@ +**To:** [REDACTED] + +**Subject:** Fwd: Epstein + +**Date:** Tue, 13 Aug 2019 23:28:19 +0000 + +--- + +Sent from my iPhone + +Begin forwarded message: + +**From:** "[REDACTED]" > + +**Date:** August 12, 2019 at 7:14:41 PM EDT + +**To:** [REDACTED] > + +**Cc:** "[REDACTED]" >, "[REDACTED]" )" + +[REDACTED] + +[REDACTED] + +**Subject:** Epstein + +Possibly as early as tonight, the Times will report that personnel at MCC falsified records. + +Sent from my iPhone \ No newline at end of file diff --git a/marker2/ds9/EFTA00085777/EFTA00085777.metadata.json b/marker2/ds9/EFTA00085777/EFTA00085777.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2cc734813e5aee4dc963ca9c536e28ed6b0c7ab9 --- /dev/null +++ b/marker2/ds9/EFTA00085777/EFTA00085777.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085777.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": 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b/marker2/ds9/EFTA00085778/EFTA00085778.md @@ -0,0 +1,29 @@ +From: To: Cc: + +Subject: RE: + +Date: Tue, 13 Aug 2019 18:27:30 +0000 + +Understood, thanks. + +From: + +Sent: Tuesday, August 13, 2019 2:26 PM + +To + +Cc + +Subject: Re: + +Sorry I didn't read your email before my last response. I wanted to mention the on the phone but I u sweat and the issue. + +On Aug 13, 2019, at 2:23 PM wrote: + +Hi- + +We are working on the Epstein death investigation and would like to hanks. + +Assistant United States Attorney + +Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00085778/EFTA00085778.metadata.json b/marker2/ds9/EFTA00085778/EFTA00085778.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d36069e8e8ac41a1509d5a968d5fc6abda8e674b --- /dev/null +++ b/marker2/ds9/EFTA00085778/EFTA00085778.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085778.pdf", + "engine": { + "marker_major": "2", + "marker_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": 461, + "elapsed_seconds": 0.78, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 42 + ], + [ + "Line", + 21 + ], + [ + "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/EFTA00085778" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085779/EFTA00085779.md b/marker2/ds9/EFTA00085779/EFTA00085779.md new file mode 100644 index 0000000000000000000000000000000000000000..922de01d6077c774e80f954f7486c4285e929e89 --- /dev/null +++ b/marker2/ds9/EFTA00085779/EFTA00085779.md @@ -0,0 +1,23 @@ +## Epstein Investigation Brass Presentation + +August 14, 2019 + +- 1. Overview of Facts Learned in Investigation to Date (RD) + - a. Timeline of Epstein's psych history at MCC + - i. 7/6: Epstein arrested and housed at MCC + - ii. 7/8: intake screening and psych observation (explain difference between that and suicide watch) + - iii. 7/9: suicide risk assessment + - iv. 7/10: Epstein housed in SHU with Tartaglione + - b. July 23 incident + - c. Suicide watch and psychological observation + - d. Epstein's return to SHU and housing with Reyes + - e. August 9 + - i. Reyes leaves for court at 8; at least 9 officers and 3 supervisors on duty that day should have known; we are in the process of subpoenaing them. + - f. Falsification of count documents + - i. Explain count versus 30-minute check + - ii. Why we believe the 12am count was done + - g. Suicide + - i. Find Epstein at 6:33 while doing breakfast rounds (according to report) description of what happened and admissions + - iii. Attempts at resuscitation fail and Epstein is taken to hospital, declared dead at 7:26 am. +- 2. Next steps in the investigation (NR) +- 3. 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There were 9 guards and at least 3 supervisors on duty in the SHU that day who should have realized that Epstein did not have a cellmate. +- We are investigating what happened. +- At 6:45 p.m., Epstein returned from an attorney conference. +- At 7:18 p.m., he was permitted to make an unrecorded, 17-minute phone call. + +# Falsification of Counts + +![]()12 AM Count + +![]()![]()3 AM Count + +# Falsification of Counts + +Metropolitan Correctional Center +Official Count Slip + +Unit: ZA Date: 8-10-2019 +Count: 42 Time: 5:00 am + +Print Name: [Redacted] +Signature: [Redacted] +Print Name: [Redacted] +Signature: [Redacted] + +Metropolitan Correctional Center +Official Count Slip + +Unit: Z-B Date: 8-10-2019 +Count: 5 Time: 5:00 am + +Print Name: [Redacted] +Signature: [Redacted] +Print Name: [Redacted] +Signature: [Redacted] + +5 AM Count + +SECTION HOUSING UNIT +SPECIAL HOUSING UNIT +30 MINUTE CHECK SHEET +ZA +TIER-G + +DATE: 08/10/2019 + +| TIME FRAME | TIME START | TIME END | SIGNATURE | TIME FRAME | TIME START | TIME END | SIGNATURE | +|----------------|------------|----------|------------|----------------|------------|----------|-----------| +| 12:00-12:39 AM | 12:09 | 12:00 | [Redacted] | 8:00-8:30 AM | | | | +| 12:30-1:00 AM | 12:41 | 12:00 | | 8:30-9:00 AM | | | | +| 1:00-1:30 AM | 1:11 | 11:20 | | 9:00-9:30 AM | | | | +| 1:30-2:00 AM | 1:34 | 1:35 | | 9:30-10:00 AM | | | | +| 2:00-2:30 AM | 2:04 | 2:05 | | 10:00-10:30 AM | | | | +| 2:30-3:00 AM | 2:41 | 2:42 | | 10:30-11:00 AM | | | | +| 3:00-3:30 AM | 2:04 | 2:05 | | 11:00-11:30 AM | | | | +| 3:30-4:00 AM | 2:13 | 2:44 | | 11:30-12:00 AM | | | | +| 4:00-4:30 AM | 2:16 | 2:17 | | 12:00-12:30 PM | | | | +| 4:30-5:00 AM | 2:40 | 2:41 | | 12:30-1:00 PM | | | | +| 5:00-5:30 AM | 2:05 | 2:06 | | 1:00-1:30 PM | | | | +| 6:30-6:00 AM | 2:41 | 2:42 | | 1:30-2:00 PM | | | | +| 6:00-6:30 AM | 1:10 | 1:14 | | 2:00-2:30 PM | | | | +| 6:30-7:00 AM | | | | 2:30-3:00 PM | | | | +| 7:00-7:30 AM | | | | 3:00-3:30 PM | | | | +| 7:30-8:00 AM | | | | 3:30-4:00 PM | | | | + +MORNING WATCH OPERATIONS LIEUTENANT [Signature] DAY WATCH OPERATIONS LIEUTENANT [Signature] + +30-Minute Rounds + +# Next Steps/Charges? \ No newline at end of file diff --git a/marker2/ds9/EFTA00085780/EFTA00085780.metadata.json b/marker2/ds9/EFTA00085780/EFTA00085780.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7d949af8486d8731ef56cd326cc85b7cc6f79cf6 --- /dev/null +++ b/marker2/ds9/EFTA00085780/EFTA00085780.metadata.json @@ -0,0 +1,428 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085780.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3716, + "elapsed_seconds": 6.83, + "image_assets": [ + "_page_2_Picture_1.jpeg", + 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(NY) (OGA) (FBI)" Cc: ' (USANYS)" ca> + +Subject: Inmates to be interviewed + +Date: Thu, 15 Aug 2019 12:43:40 +0000 + +As discussed with= these are the inmates that were in the L-wing of the SHU with Epstein that we would like you to interview at MCC within the next few days. Please advise them this is a voluntary interview, and direct them not to discuss their ongoing criminal case, or the reason they were in the SHU. You can also make clear that they are not subjects in the investigation but are witnesses. We want to know anything they observed that night, including what said and did, whether they did checks, and any other relevant information regarding Epstein. + +- is currently charged by Indictment ii with nine counts of distribution and possession with the intent to distribute crack cocaine, in violation of Title 21, United States Code, Sections 841(a)(1)(A) and (b)(1)(C). These charges relate to nine controlled buys of crack cocaine that the NYPD executed with Fernandez between December 2018 and March 2019. A trial date has not yet been set. +- is currently charged by Indictment in with one count of assault, in violation of Title 18, United States Code, Section 111(a)(1) and (b), in connection with an incident in which he bit off part of an agent's finger during arrest. +- pled guilty to conspiring to distribute 500 grams and more of cocaine, in violation of 21 USC 841(b)(1)(8), on 5/13/19 in His guidelines are 168 to 210 months' imprisonment. His sentencing is scheduled for September 12, 2019. . + +Assistant United States Attorney + +Southern District of New York + +Tel: \ No newline at end of file diff --git a/marker2/ds9/EFTA00085787/EFTA00085787.metadata.json b/marker2/ds9/EFTA00085787/EFTA00085787.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..297eef6ae4ce3cf669ba8385a3b700853ab83555 --- /dev/null +++ b/marker2/ds9/EFTA00085787/EFTA00085787.metadata.json @@ -0,0 +1,62 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085787.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1647, + "elapsed_seconds": 0.46, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 25 + ], + [ + "Text", + 7 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00085787" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085788/EFTA00085788.md b/marker2/ds9/EFTA00085788/EFTA00085788.md new file mode 100644 index 0000000000000000000000000000000000000000..f6915c8f3f85a305da4838253d801a244e4fcc3a --- /dev/null +++ b/marker2/ds9/EFTA00085788/EFTA00085788.md @@ -0,0 +1,95 @@ +To: ' (USANYS)" + +Subject: Re: [EXTERNAL EMAIL] - RE: UK number + +Date: Wed, 07 Oct 2020 16:41:52 +0000 + +Attachments: Copy o t WITH\_BROKER\_INFO.xlsx• WORKINGTOLLS.xlsx; Copy\_ot TOLLS.XLSX; Tolls\_2323.xlsx + +Here are the spreadsheets. The individuals associated with the phone numbers are below, and we got that info from subpoena returns and whistleblower interviews. + +—=M/Morgan Stanley + +From: (USANYS) + +Sent: Wednesday, October 7, 202011:27 AM + +To: (NY) (FBI) + +Subject: RE: [EXTERNAL EMAIL] - RE: UK number + +Hey thanks — yeah if you could please send the spreadsheets that would be great. And could you please let me know who those numbers (the "other individuals") are subscribed to (or if not subscription information, how we know the numbers are associated with the relevant individuals)? Thanks again! + +From: (NY) (FBI) + +Sent: Tuesday, October 06, 2020 21:31 + +To: (USANYS) + +Subject: RE: [EXTERNAL EMAIL] - RE: UK number + +Hey, + +For the= number, here are the first contact dates with other individuals: + +— July 23, 2018 + +- June 11, 2018 + +- July 5, 2018 + +- July 27, 2018 + +For the number, here are the first contact dates with other individuals: + +—January 23, 2018 + +— February 28,2020 + +—January 24, 2018 + +From: (NY) (FBI) Sent: Friday, October 02, 2020 2:14 PM To: (USANYS) > (NY) (FBI) < &gt; Cc: (USANYS) (USANYS) < Subject: Re: [EXTERNAL EMAIL] - RE: UK number + +Hi, + +Sorry I got a little inundated, will get this to you by the end of the weekend. + +From: (USANYS) Sent: Friday, October 2, 2020 1:50 PM To: (NY) (FBI) a; Cc: (USANYS) Subject: RE: [EXTERNAL EMAIL] - RE: UK number (NY) (FBI) (USANYS) < + +Wanted to follow up on the below, and our conversation, from Wednesday — just looking for any communications between the two phone numbers and another number (or numbers) relevant to the investigation from early 2018. I think there are a handful of calls that fit that description in the spreadsheets I sent at 1:30 on Wednesday, but wanted to confirm. Basically I want to make sure it's true to say in the MLAT application that both numbers were utilized in contacts with other phone numbers relevant to the investigation in or about January 2018 (or February, or March, or whatever is accurate). + +thanks, + +From: (NY) (FBI) a> Sent: Wednesday, September 30, 2020 12:27 To: (LISANYS)< Cc: (USANYS) < (USANYS) < Subject: RE: [EXTERNAL EMAIL] - RE: UK number >; (NY) (FBI) + +It looks like that one is Vodafone too. + +I'll work on the second part. Can you give me a quick call when you get a chance + +Thanks + +From: (USANYS) [mailto. Sent: Wednesday, September 30, 2020 11:57 AM To: (NY)(Fed) ; (USANYS) > + +Cc: (USANYS) < (USANYS) < + +Subject: [EXTERNAL EMAIL] - RE: UK number + +It looks like the provider is Vodafone UK. + +Best + +On Sep 30, 2020 10:32 AM, (USANYS)" wrote: + +Could you please send the provider info for the subscriber and toll info. UK numbe ? 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[REDACTED] + +--- + +**From:** [REDACTED] (USANYS) < [REDACTED] > +**Sent:** Saturday, July 27, 2019 9:16 AM +**To:** [REDACTED] (USANYS) < [REDACTED] >; [REDACTED] (USANYS) < [REDACTED] >; [REDACTED], [REDACTED] (USANYS) < [REDACTED] > +**Cc:** [REDACTED] (USANYS) < [REDACTED] > +**Subject:** this coming week + +--- + +- [REDACTED] +- [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +[REDACTED] +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] +[REDACTED] + +[REDACTED] +[REDACTED] + +[REDACTED] +[REDACTED] + +- Pretrial conference in Epstein – 11 a.m. (PC) + +- [REDACTED] +- [REDACTED] +- [REDACTED] + +[REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] + +Friday, August 2 + +Other + +- • Epstein team is meeting on Monday afternoon with the defense attorneys, who apparently have some sort of proposal to present. (PC) +- • [REDACTED] +- [REDACTED] +- [REDACTED] +- [REDACTED] + +[REDACTED] +Chief, Criminal Division +United States Attorney's Office, SDNY +[REDACTED] +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00085791/EFTA00085791.metadata.json b/marker2/ds9/EFTA00085791/EFTA00085791.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7385b63adf1f18e3d373f6b2f2da7cf11c4419db --- /dev/null +++ b/marker2/ds9/EFTA00085791/EFTA00085791.metadata.json @@ -0,0 +1,143 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085791.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1204, + "elapsed_seconds": 4.83, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Friday, August 2", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 208.17000000000002 + ], + [ + 108.32399999999998, + 208.17000000000002 + ], + [ + 108.32399999999998, + 221.94 + ], + [ + 31.212, + 221.94 + ] + ] + }, + { + "title": "Other", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 234.89999999999998 + ], + [ + 62.424, + 234.89999999999998 + ], + [ + 62.424, + 248.67000000000002 + ], + [ + 31.212, + 248.67000000000002 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 46 + ], + [ + "Span", + 38 + ], + [ + "Line", + 16 + ], + [ + "PageFooter", + 2 + ], + [ + "ListGroup", + 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", + 17 + ], + [ + "Line", + 9 + ], + [ + "Text", + 8 + ], + [ + "ListGroup", + 5 + ], + [ + "SectionHeader", + 4 + ], + [ + "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/EFTA00085791" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085793/EFTA00085793.md b/marker2/ds9/EFTA00085793/EFTA00085793.md new file mode 100644 index 0000000000000000000000000000000000000000..ac16042b2a75320ebe9cf9e4cfed2daf7edecd42 --- /dev/null +++ b/marker2/ds9/EFTA00085793/EFTA00085793.md @@ -0,0 +1,23 @@ +From: To: Cc: "MI .L A.IlYSSItractor]" <=1=IMINE>, ' (USANYS)" + +Subject: FW: Request from NBC News + +Date: Thu, 25 Jul 2019 17:12:37 +0000 + +FYI--we declined to comment. + +Ori inal Messa e + +From: (NBCUniversal) + +Sent: Thursda Jul 25, 2019 1:09 PM + +To: (USANYS) [Contractor] (USANYS) + +Subject: Request from NBC News + +Hi there. I hope you're well. I'm working on a story about Jeffrey Epstein's ties to , who was convicted of running a massive Ponzi scheme in the 1980s/early 1990s. says he's reached out to federal authorities following Epstein's arrest (he won't elaborate other t an to say t at he called the 800 number given out at press conference) and claims he has information about Epstein's financial crimes. + +Can you let me know if you'd like to comment on this in any way? It's for a digital story, btw. + +Thanks very much, \ No newline at end of file diff --git a/marker2/ds9/EFTA00085793/EFTA00085793.metadata.json b/marker2/ds9/EFTA00085793/EFTA00085793.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b8f736298ec857bd9e590e239001e91291e41355 --- /dev/null +++ b/marker2/ds9/EFTA00085793/EFTA00085793.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085793.pdf", + "engine": { + "marker_major": "2", + "marker_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": 828, + "elapsed_seconds": 0.74, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Line", + 20 + ], + [ + "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/EFTA00085793" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085794/EFTA00085794.md b/marker2/ds9/EFTA00085794/EFTA00085794.md new file mode 100644 index 0000000000000000000000000000000000000000..9bcf633d2925173ea1623f9955ebbd08b4316400 --- /dev/null +++ b/marker2/ds9/EFTA00085794/EFTA00085794.md @@ -0,0 +1,38 @@ +## 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: | 8/27/21 | + +20-CR-330 (AJN) + +ORDER + +ALISON J. NATHAN, District Judge: + +On May 11, 2021, the Court informed the parties that it set a tentative trial date for November 29, 2021. The Court accordingly requested a jury trial for that date pursuant to the COVID rules for centralized jury trial scheduling in the district. The Clerk's Office has now confirmed that a jury trial in this case has been scheduled to commence on November 29, 2021. This is a firm trial date. When the information is available, the Court will provide courtroom location and public access information by separate order. + +Due to space limitations resulting from the SDNY COVID protocols, the Clerk's Office has also provided the following dates for administering a juror questionnaire and conducting voir dire: November 4, 5, and 12 (questionnaire), and November 16-19 (voir dire). The Court intends to use a streamlined questionnaire as much as feasible given all relevant circumstances. The parties shall bear this in mind when they discuss and jointly propose a questionnaire and voir dire on the schedule outlined below. + +In light of the firm dates discussed above, it is hereby ORDERED that the parties appear for a telephone conference to discuss jury selection matters on October 21, 2021 at 12:00 P.M. Dial-in information for the parties and for public access will be provided when it is available by separate order. + +In light of the jury selection dates provided by the Clerk's Office, the Court amends the schedule that it set on June 2, 2021 as follows. The parties shall meet and confer and submit a joint proposed juror questionnaire and joint proposed voir dire by October 11, 2021. The parties shall file a joint proposed charge and verdict sheet, with any differing proposals supported by authority or other justification, by October 27, 2021. Any motions in limine must be simultaneously filed by October 18, 2021, and any responses to motions in limine are due by October 25, 2021. Otherwise, the parties shall continue to follow the schedule that the Court set on June 2, 2021. Dkt. No. 297. + +IT IS FURTHER ORDERED that the parties appear for an in-person pretrial conference on November 1, 2021 at 11:00 A.M. Location information and public access information will be provided by separate order when available. + +SO ORDERED. + +Dated: August 27, 2021 New York, New York c)J14/1. + +ALISON J. NATHAN United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00085794/EFTA00085794.metadata.json b/marker2/ds9/EFTA00085794/EFTA00085794.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..db9c0a04657b49440d926b9ad677feae6eca8f34 --- /dev/null +++ b/marker2/ds9/EFTA00085794/EFTA00085794.metadata.json @@ -0,0 +1,128 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085794.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1.12, + "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 + ], + [ + 281.419189453125, + 72.08999999999999 + ], + [ + 281.419189453125, + 99.7330322265625 + ], + [ + 68.544, + 99.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 66 + ], + [ + "Line", + 33 + ], + [ + "Text", + 10 + ], + [ + "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": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 20 + ], + [ + "Text", + 5 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 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/EFTA00085794" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085796/EFTA00085796.md b/marker2/ds9/EFTA00085796/EFTA00085796.md new file mode 100644 index 0000000000000000000000000000000000000000..4007269a0c48cf0bf95c65ee3bd264c6a9dfccb0 --- /dev/null +++ b/marker2/ds9/EFTA00085796/EFTA00085796.md @@ -0,0 +1,38 @@ +## MARSH law firm plic + +31 Hudson Yards, Pl. II Ncw York, New York 10001 + +October 6, 2021 + +Via email — + +Honorable Alison J. Nathan United States District Court 500 Pearl Street New York, New York 10007 + +## Re: Request Regarding Victim Attendance at the Upcoming Trial in USA v. Maxwell, No. 1:20 Cr. -00330-AJN + +Dear Judge Nathan: + +We represent one of the victims of Jeffrey Epstein and his alleged lieutenant Ghislaine Maxwell, who is the defendant in the abovereferenced case. + +vas one of the Epstein victims who spoke to deliver a victim impact statement in front of Judge Berman on August 29, 2019, when Judge Berman dismissed the Epstein indictment due to Epstein's apparent suicide. + +would like to attend the upcoming trial of Ms. Maxwell scheduled for November 29, 2021. She will be coming from where she lives. + +Title 18 USC section 3771(a)(1) (the Crime Victim's Rights Act) gives victims, among other things, "The right not to be excluded from any public court proceeding, unless the Court, after receiving clear and convincing evidence, determines that testimony of the victim would be materially altered if the victim heard other testimony at that proceeding." The exception does not apply because not going to be witness at the trial. + +is not asking the government to pay for any travel expenses, but wou i e o given priority (along with other victims of course) in getting + +into the trial as a spectator. Given the keen public interest in the case, she is afraid that without priority she will not be able to get into the courtroom. + +Very truly yours, + +*Robert Y. Lewis* + +Robert Y. Lewis + +Cc: [REDACTED] +[REDACTED] l +[REDACTED] m +[REDACTED] +[REDACTED] +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00085796/EFTA00085796.metadata.json b/marker2/ds9/EFTA00085796/EFTA00085796.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f5a626fb901b492d7b7fc538a2f9f17afac11c90 --- /dev/null +++ b/marker2/ds9/EFTA00085796/EFTA00085796.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085796.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1708, + "elapsed_seconds": 2.08, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "MARSH \nlaw firm plic", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 24.5643310546875 + ], + [ + 233.39669799804688, + 24.5643310546875 + ], + [ + 233.39669799804688, + 81.32757568359375 + ], + [ + 68.544, + 81.32757568359375 + ] + ] + }, + { + "title": "Re: Request Regarding Victim Attendance at the Upcoming Trial in \nUSA v. Maxwell, No. 1:20 Cr. -00330-AJN", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 296.46 + ], + [ + 490.0352478027344, + 296.46 + ], + [ + 490.0352478027344, + 330.8809509277344 + ], + [ + 68.544, + 330.8809509277344 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 31 + ], + [ + "Text", + 10 + ], + [ + "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": "surya", + "block_counts": [ + [ + "Text", + 11 + ], + [ + "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/EFTA00085796" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085798/EFTA00085798.md b/marker2/ds9/EFTA00085798/EFTA00085798.md new file mode 100644 index 0000000000000000000000000000000000000000..fe3bcc76dfc329812358d75d470de19a36e719d6 --- /dev/null +++ b/marker2/ds9/EFTA00085798/EFTA00085798.md @@ -0,0 +1,13 @@ +From: '1 3' + +To: ' + +C • ' + +Subje + +Date: Sat, 09 Oct 2021 03:42:31 +0000 + +In our the boxes, we were reminded as the crime scene manager when Epstein reporte The document was already in 00 folder. + +ti \ No newline at end of file diff --git a/marker2/ds9/EFTA00085798/EFTA00085798.metadata.json b/marker2/ds9/EFTA00085798/EFTA00085798.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d82882147e536ebbc573ef676bc8946d7d789cca --- /dev/null +++ b/marker2/ds9/EFTA00085798/EFTA00085798.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085798.pdf", + "engine": { + "marker_major": "2", + "marker_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": 198, + "elapsed_seconds": 0.38, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "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/EFTA00085798" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085799/EFTA00085799.md b/marker2/ds9/EFTA00085799/EFTA00085799.md new file mode 100644 index 0000000000000000000000000000000000000000..91787d3ea65ff33e52d4c198c8b98a7b5f7e416e --- /dev/null +++ b/marker2/ds9/EFTA00085799/EFTA00085799.md @@ -0,0 +1,417 @@ +To: "Laura Menninger" [REDACTED], "[REDACTED]") +[REDACTED] +Cc: "[REDACTED]" <[REDACTED]> "[REDACTED]" [REDACTED] +[REDACTED] +[REDACTED] (USANYS) [Contractor] +[REDACTED], [REDACTED] SANYS) [Contractor] <[REDACTED]> + +**Subject:** RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +**Date:** Wed, 29 Sep 2021 20:04:22 +0000 + +**Importance:** Normal + +Laura, +I'm following up on my email as we intend to send the boots back this week. + +Best, +[REDACTED] + +**From:** [REDACTED] (USANYS) +**Sent:** Monday, September 27, 2021 4:37 PM + +**Subject:** RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +Laura, + +We understand you would like more time with the photos and we can leave the drives there for your review. We would like to send the boots back to New York by the end of this week as it takes some time to transport. I can reach out to the FBI agent in Colorado to help coordinate a time for you to review the boots this week if you would like to provide some times. + +Best, +[REDACTED] + +**From:** Laura Menninger [REDACTED] +**Sent:** Monday, September 27, 2021 3:27 PM + +**Subject:** [EXTERNAL] RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +Hi [REDACTED] - + +I appreciate you reaching out before you send them back. I have just concluded a multi-week trial which hampered my ability to spend as much time with the photos and boots as I need. Can you please hold off sending them back for about 2 weeks? I will reach out again to the agent here about setting up a time later this week to continue the viewing. + +Thanks, + +Laura + +**Laura A. Menninger** | Partner +**Haddon, Morgan & Foreman, P.C.** +150 E. 10th Avenue | Denver, CO 80203 + +Cc: • ; Jeff Pagliuca USANYS) + +[Contractor >; USANYS Contractor > + +Subject: RE: US v. Maxwell - [conferral re photo an of er discovery deficiencies] + +Laura, + +We intend to send the boots back to New York this week, but wanted to confirm you have finished looking at them. Please let us know. + +Best, + +From: Laura Menninger + +Sani• Thursday August 1 1 SS AM + +.JULIJCUL. nC. .../J V. IVIOAVVCII [WHICH CI IC plIVW CI ILI LAU ICI uIxuveI y ucuucnuoj + +Thank you for getting me some dates and times. Unfortunately something else has come up in the meantime that makes today unworkable. I will plan to be there at 10:30 a.m. next Wednesday and see how far I can get before requesting additional dates and times. + +In addition to my earlier questions, can you please let me know if there are Bates numbers or other production identifiers / logs for me to work off of during this review? + +Thank you, + +Laura + +From: (USANYS) •c + +A........-• x nrini nSA + +subject: RE: us v. Maxwell - Lconterral re photo and other discovery deticienciesj + +Laura, + +The items are available for review tomorrow after 11 MDT or Wednesday, September 1, after 10:30 MDT. Please let us know when you plan to do the review so I can let the FBI agent know. The review will be at 4624 Central Denver and the FBI agent isIf you need different or additional dates/times, please let us kno will get back to you on your questions about HC materials. + +Best, + +■ **From: Laura Menninger** + +**Sent: Tuesday, August 24, 2021 12:00 PM** + +**To: (USANYS) C** + +**Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies]** + +**>; Jeff Pagliuca (USANYS) [Contractor)** + +**We are available to review the hard-drives and boots this Thursday (8/26), next Tuesday (8/31) or on September 1st. Let me know which FBI office and any local officer I need to coordinate with for entry to the building.** + +**On the topic of HC materials, I don't believe I have yet received an explanation for statement below ("I have confirmed with the FBI that the larger number contained in the 302 is accurate. I have not been able to figure out where the disconnect arose between the actual number and the number that was verbally conveyed to me, which I then conveyed to you. I apologize for the mistake, which was unintentional."). Can someone please provide an explanation for** the reason those two numbers differed so dramatically? What is the current count of HC photos? Where did all of the HC photos come from? + +We may need more than one session of viewing, depending on the size of the hard drives. I also may need to re-review with an expert once I have had an opportunity to view any new materials for the first time. I also likely will need to sort out a method of viewing these with my c + +Finally, given the volume of HC materials, offered when we were in NY at some point to specify which if any HC materials the government seeks to introduce at trial. If you are able to do that now (prior to my review), it certainly will cut-down on the time needed to review and potential expert fees. Obviously if I am unable to view the materials in sufficient time, we may need to seek extra accommodations to complete the task, and a means of reviewing these new HC materials with Ms. Maxwell, as is her right. + +Let me know if those dates work and an explanation. + +Thank you, + +Laura + +Laura A. Henninger I Partner + +Haddon, Morgan & Foreman, P.C. + +150 E. 10th Avenue I Denver, CO 80203 + +From: (USANYS) + +Sent: Sunday, August 22, 2021 1:04 PM + +To: ; Laura Menninge + +Cc: ;Jeff + +Pagliuca (USANYS) + +[Contrac + +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +Counsel, + +We write to meet and confer about Judge Nathan's order (Dkt. No. 322) and some other issues. Please let us know if you are free to speak by phone tomorrow before 3 pm or Tuesday after 2:30 pm. + +Also, please let us know some dates and times that you would like to review the hard drives and boots in Colorado. + +From: + +Cant. IA/nAnnerl.ats AI ierne• A 'Alt C•]C ORA + +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +Laura, + +Thank you for your email and for your patience as I track down answers for you. + +By the end of this week, I expect to have a production ready for you, which will contain two categories of images responsive to the discussions we have been having: + +- First, the production will include several thousand images that the FBI has de-designated from Highly Confidential down to Confidential. These will be produced in a format that should provide you with all available metadata together with each image. This production is the culmination of the de-designation review process that the FBI has completed over the past few months. +- Second, the production will include all of the approximately 40,000 images previously produced to you, which were extracted from CDs seized from Epstein's New York residence. This production will be in a new format that should provide you with all available metadata together with each image. + +For this production, we will need two 500GB hard drives (one for counsel's copy and one for Ms. Maxwell's copy) on which to load the materials. + +I have also discussed your request that the FBI relocate certain items to the field office in Colorado to facilitate your review. The FBI is able to make such a transfer of two of the items you requested: + +- • The FBI will send hard drives containing the remaining highly confidential image and video files seized from Epstein's devices and CDs to Colorado, where you may review them. As was the case in New York, these will need to be reviewed on a government laptop in the presence of an FBI employee and cannot be copied, photographed, or removed from FBI property. +- • The FBI will also send the boots that were recently taken into evidence at 1B items to Colorado, where you may review them. You may examine and photograph the boots in the presence of an FBI employee, but they may not be removed from FBI property. +- • The photographs provided by [REDACTED] cannot be shipped out of the New York office because they are logged as 1A items and must remain with the case file in New York. We are happy to arrange a time for the defense to examine those photographs in person in New York. You may examine and photograph the photos in the presence of an FBI employee, with the understanding that any photographs of these materials must be treated as Confidential under the Protective Order in this case. There are relatively few photographs, so any review of these should not be time-intensive. + +Both of the case agents on our team are out of the office this week and next week, but we are working to find other agents who can help us coordinate shipping the drives and the boots to Colorado. My hope is that they will get to Colorado by next week. Please let me know what date(s) you would like to review those items later this month, and I will coordinate with the FBI to schedule your review. + +Best, + +[REDACTED] + +Assistant United States Attorney +Southern District of New York +1 St. Andrew's Plaza +New York, NY 10007 + +[REDACTED] + +[REDACTED] +From: Laura Menninger [REDACTED] +Sent: Wednesday, July 21, 2021 7:37 PM + +[REDACTED] +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +I am writing to inquire regarding the status of the HC material review and de-designation (highlighted #2 below, from May 14) and also to discuss how we may go about reviewing the additional 30,000 HC materials that we were not made available to us when we traveled to NY for that purpose. + +Do you know when the de-designation process will be complete? And when do you expect the de-designated documents will be disclosed? + +Also, regarding the remaining HC materials (highlighted #1 below), we would propose that they be made available for our review at the FBI office here in Colorado within the next 30 days. We also would like to inspect at the same time and place (a) the originals of the [REDACTED] photos that you located after our evidence review and (b) the boots that you recently took possession of. + +I am happy to schedule a time to discuss logistics if that would be easier. + +Thanks, +Laura + +**Laura A. Menninger** | Partner +**Haddon, Morgan & Foreman, P.C.** +150 E. 10th Avenue | Denver, CO 80203 + +[REDACTED] + +Sent: Thursday, May + +u•jec : v. • axwe rep o o an' o er iscovery iciencies + +Laura, + +Thank you for your email. Below please find updates regarding these outstanding issues: + +- 1. I have confirmed with the FBI that the larger number contained in the 302 is accurate. I have not been able to figure out where the disconnect arose between the actual number and the number that was verbally conveyed to me, which I then conveyed to you. I apologize for the mistake, which was unintentional. +- 2. The FBI's review of the Highly Confidential material and de-designation remains ongoing. I have reached out to the case agent for an update on timing and will let you know when I have an estimate of when that process will be complete. +- 3. My office did not create the empty Excel spreadsheet. It was included on a hard drive provided to our vendor by the FBI containing the images from CDs seized from Epstein's residence and spreadsheets created by the FBI during its review of those CDs. I do not know the origins of that third blank spreadsheet, and the FBI has informed me that it only created two spreadsheets in connection with its review of the CDs. My best guess is that the blank document was a temporary file that was automatically created when the spreadsheets were copied onto the drive, but I do not know that for certain. To the best of my knowledge, there are no blank files that my office created. +- 4. Our paralegals have been working to look into the thousands of Bates numbers you listed as unviewable at the MDC. Attached please find a spreadsheet our paralegals created providing the status of each document. You will see that the spreadsheet is divided into separate tabs for each category of problem you identified. Next to each identified Bates number, the paralegals have noted the status of each image and/or document. Below please find a key explaining each of these different status entries: +- Blanks o "Confirmed Blank" means the document has no content. o "Not Blank" means there is content to the document. For documents in this category, please let us know if you are requesting that we reproduce these documents to Ms. Maxwell at the MDC. o "No Native" means there is no corresponding native with the image. o "N/A — Not PAE Export" means the document was not produced by our vendor. +- Not Supported o "saf files " means we are unable to open these files on our system and are asking our vendor and IT for assistance. We will reach back out once we have obtained that assistance. o ".txt file (blank)" means the document has no content. +- Can't Read Won't Open o "Image Opens" means there is content to the image. Please let us know if you are requesting that we reproduce these documents to Ms. Maxwell at the MDC. o "Image Opens — Black Box(es)" means these images contained redactions of nudity. Please let us know if you are requesting that we reproduce these documents to Ms. Maxwell at the MDC. o "Native Opens" means there is content to the native. Please let us know if you are requesting that we reproduce these documents to Ms. Maxwell at the MDC. o "No native" means there is no corresponding native with the image. o "Document Produced Natively" means that a cover sheet was produced instead of an image for this document. o "Corrupt" means the document has no viewable content. o "Native Password Protected" means we are unable to open this document and are asking our vendor for assistance. We will reach back out once we have obtained that assistance. o "N/A — Not PAE Export" means the document was not produced by our vendor. +- Missing + +- ◦ "Image Opens" means there is content to the image. Please let us know if you are requesting that we reproduce these documents to Ms. Maxwell at the MDC. +- ◦ "No native" means there is no corresponding native with the image. We are conferring with our vendor regarding certain documents for which the image cover sheet indicates the document was produced natively but for which we do not have a corresponding native. We will reach back out once we have obtained that assistance. +- ◦ "Document Produced Natively" means that a cover sheet was produced instead of an image for this document. +- ◦ "Not Missing – Opens" means there is content to the native. Please let us know if you are requesting that we reproduce these documents to Ms. Maxwell at the MDC. +- ◦ "Image for this document is not exported" means that we do not have these images. We are conferring with our vendor regarding these documents and will reach back out once we have obtained assistance. +- ◦ "Blank" means the image file is blank. +- ◦ "Not Missing – Corrupt" means the document has no viewable content. +- • Corrupt + - ◦ "Document Produced Natively" means that a cover sheet was produced instead of an image for this document. + - ◦ "Not Corrupt" means there is content to the document. Please let us know if you are requesting that we reproduce these documents to Ms. Maxwell at the MDC. + - ◦ "Password Locked" means we are unable to open this document and are asking our vendor for assistance. We will reach back out once we have obtained that assistance. + - ◦ "Blank File" means the native file we have is blank. We are checking with our vendor for assistance with such files and will reach back out once we have obtained that assistance. + - ◦ "Blank" means the image file is blank. + - ◦ "Corrupt" means the document has no viewable content. + - ◦ "No Native File" means there is no corresponding native with the image. + - ◦ "N/A – Not PAE Export" means the document was not produced by our vendor. + - ◦ "Lazer Scan" means that the file is part of the 3D scan of Epstein's private island. As you may recall, there were difficulties producing the 3D scan to counsel in a viewable format, and we reproduced these documents to counsel on multiple occasions. Within the lazer scan production there are pdf files that should be viewable and should reflect the substance of the 3D scan. + +Best, + +**From:** Laura Menninger [REDACTED] +**Sent:** Tuesday, May 18, 2021 12:21 PM + +**To:** [REDACTED] < [REDACTED] > + +**Cc:** [REDACTED] (LISANYS) < [REDACTED] > [REDACTED] < [REDACTED] > [REDACTED] + +**Subject:** RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +Following up on the below, as I believe these are the outstanding issues from this email chain. + +1. 1. When do you expect to have clarification from the FBI regarding the discrepancy in highly confidential material count? +2. 2. Same for the de-designated HC materials? +3. 3. Your answer regarding Bates-stamped but content-less files only addressed those that you took off of Epstein devices. I asked about a file that your office created – an Excel spreadsheet – that did not have content yet you Bates-stamped and produced it. Are there others? +4. 4. When do you expect to have answers to the list of documents that our client is unable to view at the MDC? It is a few days shy of a month since I forwarded that list to you and I am hoping that you will have answers in the next few days. + +I will wait for answer to 1 and 2 above before I can adequately address your position on the HC materials. It may be that we need to go back to the Court to address your definition of highly confidential which is unlike I have seen on even child pornography cases. + +Laura A. Menninger I Partner + +Haddon, Morgan & Foreman, P.C. + +From: + +Sent: Tuesday, May 1 Menninger1011 + +To: Laura + +Cc: (USANYS) < ; ) >; + +u j : : v. axwe - con errs re p o o an o er iscovery e iciencies + +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. + +From: Laura Menninger + +Sent: Friday, May 7, 2021 4:43 PM + +To: ) + +Cc: (USANYS) Manufacturer's Serial No. 760750 US. Registration No. N722JE + +Pursuant to provisions of that certain Aircraft Purchase Agreement dated April , 2021 (the "Agreement") by and between HYPERION AIR, LLC, a U.S. Virgin Islands limited liability company ("Seller"), and . INDUSTRIAL INTEGRITY SOLUTIONS. LLC. a CaliforniaNew Mexico limited liability company ("Purchaser"). Purchaser hereby acknowledges the delivery and acceptance of one used 21118 Keystone (Sikorsky) model S-76C++ helicopter. bearing manufacturer's serial number 760750. and currently registered with the United States Federal Aviation Administration (the "FAA- ) as N722JE, together with said aircraft's two (2) Turbomeca S.A. model Arriel 2S2 engines bearing Manufacturer's Serial Nos. 42285TE and 42286TEC, and with all avionics, equipment systems. furnishings and accessories installed on, contained in or attached to said aircraft and engines, all as is more particularly described on Exhibit A. and also including all airframe, engine and accessory logbooks. Flight and operation manuals, maintenance and overhaul records, and all other records and paperwork relating to the above-described aircraft and engines in Seller's possession (collectively. + +the "Aircraft"). + +Purchaser accepts the Aircraft at p.m.. on 2021 in an "As Is. Where Is" condition and "With all Faults" at , Florida + +and subject to the waivers and disclaimers set forth in the Agreement. + +TOTAL TIME ON AIRFRAME AT DELIVERY: hours + +TOTAL TIME ON ENGINES AT DELIVERY: + +Engine No. I (MSN 42285TEC): hours/cycles Engine No. 2 (MSN 42286TEC): hours/cycles + +TOTAL LANDINGS AT DELIVERY: + +LLQINDUSTRIAL INTEGRITY SOLUTIONS, + +LLC + +By: Name: Title: Date: + +26 + +AIRCRAFT PURCHASE AGREEMENT + +TIIIS AIRCRAFT PURCHASE AGREEMENT (this "Agreement") is entered into as + +of April 2021, by and between HYPERION + +company, whose address is ENE + +("Seller"), and lndu trial lnte ri 1 tions L a w Me is li Ili liability company, whose + +address is ("Purchaser"). + +RECITATIONS: + +Subject to the terms and conditions set forth in this Agreement, Seller desires to sell, + +transfer, and deliver to Purchaser, and Purchaser desires to purchase from Seller, one used 2008 Keystone (Sikorsky) model S-76C++ helicopter, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration (the "FAA") as N722JE. + +together with said aircraft's two (2) Turbomeca S.A. model Arriel 2S2 engines bearing + +Manufacturer's Serial Nos. 42285TE and 42286TEC, and with all avionics, equipment systems, furnishings and accessories installed on, contained in or attached to said aircraft and engines, all as is more particularly described on Exhibit A, and also including all airframe. engine and accessory logbooks, flight and operation manuals, maintenance and overhaul records, and all other records and paperwork relating to the above-described aircraft and engines in Seller's possession (collectively, the + +"Aircraft"). + +NOW, THEREFORE, in consideration of the mutual promises and covenants herein + +contained, and other good and valuable consideration, the parties hereto agree as follows: + +. Purchase Price: Payment. Seller agrees to sell, and Purchaser agrees to + +purchase, the Aircraft for atotal purchase price of One Million Eight Hundred Thousand U.S. Dollars + +(US \$1,800,000) (the "Purchase Price"), which shall be paid by Purchaser to Seller as follows: + +(a) Purchaser shall wire transfer a deposit in the amount of One Hundred + +Thousand U.S. Dollars (US \$100,000.00) (the "Deposit") to AIC Title Service. LLC, Oklahoma City, Oklahoma, as escrow agent(the "Escrow Agent"), which Deposit shall be held in escrow and disbursed at the Closing (as hereinafter defined and described) pursuant to the conditions and + +requirements set forth in this Agreement; and + +(b) The balance of the Purchase Price in the amount of One Million Seven + +Hundred Thousand U.S. Dollars (USS1,700,000) (the "Purchase Price Balance") shall be paid at the Closing, said Purchase Price Balance to be wire transferred (as and when provided in Section 4(c) hereof) prior to the Closing into the Special Escrow Account (as defined below) of the Escrow Agent for its disbursement to Seller at the Closing upon the satisfaction of the conditions and + +requirements set forth in this Agreement. + +1.1 Establishment of Special Escrow Account. The Deposit has been wire transferred + +to the general escrow account of the Escrow Agent maintained at JP Morgan Chase Bank N.A., 100 + +N. Broadway Avenue, Suite 401, Oklahoma City. OK 73102. Upon the execution of this + +Agreement, the Escrow Agent shall promptly cause the Deposit to be transferred to, and maintained in, a special escrow account at said Bank created and maintained solely and exclusively for the + +Aircraft shall take place within the state in which the Closing Place is located. The fuel costs and the expenses of Seller's flight crew in flying the Aircraft from the Inspection Facility to the Closing Place + +shall be the sole responsibility of and paid for by Purchaser. + +(b) At least 5 days prior to Closing Escrow Agent shall search FAA records and + +verify aircraft title is free and clear of all recorded liens, claims and encumbrances. + +(c) Prior to the Closing, the following deliveries shall be made to the Escrow + +Agent by the responsible party indicated: + +(i) At least two (2) days prior to the Closing Date, Seller shall deliver the + +following to Escrow Agent: + +(A) A Warranty Bill of Sale in the form attached hereto as Exhibit E + +transferring title to the Aircraft to Purchaser duly executed by an authorized representative or the manager of Seller, with his or her title shown, but undated + +(the "Warranty Bill of Sale"); and + +(B) An FAA Form Bill of Sale AC 8050-2 in proper form for + +recordation at the FAA Civil Aircraft Registry to transfer title to the Aircraft to Purchaser duly executed by an authorized representative or the manager of + +Seller, with his or her title shown, but undated ("FAA Bill of Sale"). + +(ii) Purchaser shall: + +(A) On or before the Closing Date but prior to Closing, wire transfer + +the Purchase Price Balance into the Special Escrow Account of the Escrow + +Agent; and + +(B) At least two (2) days prior to the Closing Date, deliver to the + +Escrow Agent an Application for Aircraft Registration (AC Form 8050-1) for the Aircraft duly executed by an authorized representative or the manager of + +Purchaser, but undated (the "Application for Registration"). + +The documents described in subparagraphs (i) and (ii) of this Section 4(b) are + +hereinafter referred to collectively as the "Escrow Documents". + +(d) Prior to the Closing Date, each of Seller. Purchaser and the Escrow Agent shall + +notify each of the others in writing (either by correspondence, fax or e-mail) of the name or names and telephone number of each representative of the respective parties which is to participate in the conference call to be conducted in connection with the Closing (hereinafter the "Closing Conference Call"). The Closing Conference Call shall be originated by Purchaser on the Closing Date on or about 10:00 a.m., U.S. Central Daylight Time, so as to complete the Closing, including the filing of the Escrow Documents with the FAA Registry in Oklahoma City, Oklahoma. prior to the closing of + +that office on the Closing Date. + +agreement between Seller and said broker which governs the terms and conditions upon which any compensation may be due from Seller to said broker upon the sale of the Aircraft, and Purchaser shall + +not be responsible for any such compensation pursuant to such agreement. + +(a) Purchaser's Representations and Warranties. Purchaser hereby + +represents and warrants to Seller the following: + +(i) Purchaser is alimited liability company duly organized, validly + +existing, and in good standing under the laws of New Mexico. Purchaser has full corporate power and authority to enter into this Agreement and the documents to be delivered hereunder, to carry out its obligations hereunder, and to consummate the transaction contemplated thereby. The execution, delivery and performance by Purchaser of this Agreement and the documents to be delivered hereunder and the consummation of the transactions contemplated hereby have been duly authorized + +by all requisite corporate action on the part of Purchaser. + +(ii) No broker, finder or investment banker is entitled to any + +brokerage, finder's or other fee or commission in connection with the transactions contemplated by + +this Agreement based upon arrangements made by or on behalf of Purchaser. + +8. LIMITATION OF WARRANTIES. EXCEPT FOR THE + +REPRESENTATIONS AND WARRANTIES OF SELLER EXPRESSLY SET FORTH IN SECTION 7 HEREOF OR IN THE WARRANTY BILL OF SALE (THE "EXPRESS CONTRACT WARRANTIES"), THE AIRCRAFT AND EACH PART TIIEREOF IS BEING SOLD TO PURCHASER HEREUNDER IN ITS "AS IS, WHERE IS" CONDITION AND "WITH ALL FAULTS" EFFECTIVE AT THE CLOSING. EXCEPT FOR THE EXPRESS CONTRACT WARRANTIES, NEITHER SELLER NOR ITS AGENTS, REPRESENTATIVES OR EMPLOYEES MAKE ANY WARRANTIES, EXPRESS OR IMPLIED, OF ANY KIND OR NATURE WHATSOEVER TO PURCHASER. WITHOUT LIMITING THE GENERALITY OF THE FOREGOING DISCLAIMER OF REPRESENTATIONS AND WARRANTIES, THERE IS (I) NO WARRANTY BY SELLER, ITS AGENTS, REPRESENTATIVES OR EMPLOYEES AS TO THE AIRWORTHINESS OR PHYSICAL CONDITION OF THE AIRCRAFT; (II) NO IMPLIED WARRANTY BY SELLER, ITS AGENTS, REPRESENTATIVES OR EMPLOYEES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OF THE AIRCRAFT; (III) NO IMPLIED WARRANTY BY SELLER, ITS AGENTS, REPRESENTATIVES OR EMPLOYEES ARISING FROM COURSE OF PERFORMANCE, COURSE OF DEALING OR USAGE OF TRADE; AND (IV) NO WARRANTY BY SELLER, ITS AGENTS, REPRESENTATIVES OR EMPLOYEES AGAINST PATENT INFRINGEMENT OR THE LIKE. IN NO EVENT SHALL EITHER PARTY HERETO BE LIABLE FOR ANY SPECIAL, + +INCIDENTAL OR CONSEQUENTIAL DAMAGES OF ANY KIND. + +9. Purchaser's Breach and Remedies. + +(a) Failure by Purchaser to pay the Purchase Price at Closing in accordance with + +this Agreement, to deliver any Closing documents required by this Agreement, or any other failure or refusal by Purchaser to perform any of its obligations under this Agreement, or any material misrepresentation by Purchaser pursuant to this Agreement, shall, upon the actual or offered perfonnance by Seller of all its obligations, and the failure by Purchaser to cure such failure within seven (7) days after Seller gives Purchaser notice of such failure, constitute abreach of this Agreement + +and against any and all liability arising out of the care, custody, use and/or control of the Aircraft at all times from and after such delivery. The provisions of this Section 11(c) shall survive the Closing. + +12. Other Matters. + +(a) Each party hereto agrees to execute and deliver such additional documents and + +take such further actions as may be reasonably requested by the other party hereto to fully effectuate + +and carry out the purposes of this Agreement. + +(b) Except as expressly provided herein, the provisions of this Agreement which + +by their terms are to be performed and observed after the Closing, and the several representations, + +warranties and agreements of the parties herein contained, shall survive the Closing. + +(c) This Agreement sets forth the entire understanding of the parties hereto with + +respect to the subject matter hereof and supersedes any and all prior agreements, arrangements and understandings relating to the subject matter hereof. No representation, promise, inducement or statement of intention has been made by either party which is not embodied in this Agreement, and neither party shall be bound by, or be liable for, any alleged representation, promise, inducement, or + +statement of intention not embodied herein. + +(d) This Agreement may be executed in one or more counterparts, and all such + +counterparts shall constitute one and the same instrument. + +(e) No modification or amendment of this Agreement shall be binding unless it is + +in writing and signed by each of the parties hereto. + +(I) All notices required or permitted hereunder shall be in writing and, except as + +may otherwise be provided herein, shall be deemed to be given when delivered personally, or within three (3) business days after mailing, if mailed by registered or certified mail, return receipt requested, postage prepaid, or on the date of transmission, if sent by facsimile or e-mail (and written confirmation of transmission is provided), addressed to the other party for whom it is intended at the address, facsimile number, or email address set forth below, or to such other address as hereafter may + +be designated in writing by either party hereto to the other party hereto: + +If to Seller: + +HYPERION AIR, I.L.0 + +Fax: Email: + +If to Purchaser: + +'DU " S. LIC + +Email: + +(g) Any signatures on this Agreement may be transmitted via facsimile or e-mail + +(in pdf format), which signatures shall be deemed originals for all purposes if transmitted in + +accordance with Section 12(f) above. + +(h) Neither any failure nor any delay on the part of either party hereto in exercising + +any right hereunder shall operate as a waiver thereof, nor shall any single or partial waiver or exercise of any right hereunder preclude any other future single or partial waiver or exercise of any right hereunder. No waiver hereof shall be effective unless it is writing signed by the party hereto to be charged with the same and then it shall only be effective as to the specific matter and in the specific + +instance stated in such writing. + +(i) The descriptive headings of the several sections of this Agreement are inserted + +for convenience only and do not constitute a part of this Agreement. + +(j) This Agreement shall be construed and enforced in accordance with the laws + +of the U.S. Virgin Islands, excluding its conflicts of laws rules, and, to the extent applicable, the laws + +of the United States of America. + +(k) If any clause, provision or section of this Agreement is found by any court of + +competent jurisdiction to be invalid or unenforceable for any reason whatsoever, such invalidity or unenforceability shall not in itself affect the remaining clauses, provisions and sections hereof, so long as the rights or obligations of the parties hereto shall not be materially and adversely affected + +thereby. + +(1) All payments provided for in this Agreement are to be made in United States + +Dollars. + +(m) Purchaser and Seller (for purposes of this clause, the "Indemnifying Party") + +each agree to indemnify and hold the other harmless in respect of any claims for brokerage fees, finders fees, agent's commissions or other similar payments or forms of compensation which may be made against the other party as a result of any contracts, understandings, arrangements, agreements or other actions of the Indemnifying Party in connection with the purchase or sale of the Aircraft. + +(n) Except as otherwise expressly provided in this Agreement, each of Seller and + +Purchaser shall bear its own costs and expenses (including, but not limited to, the fees of its legal and tax advisors), incurred in the drafting and the negotiation of this Agreement and in connection with + +the Closing. + +(o) Each of the parties hereto agree that the terms and provisions of this + +Agreement, including, but not limited to, the fact that discussions and negotiations have been conducted by the parties hereto, shall be deemed to be strictly confidential and shall not be disclosed to any third parties other than the parties respective employees, attorneys, accountants, tax advisors or other representatives for the purposes of effectuating the purchase and sale of the Aircraft contemplated by this Agreement, and except as may be required in connection with any aapllicablc + +probate laws or by applicable federal, state, territorial and local laws of the United States of America + +and its territories and possessions. + +IN WITNESS WHEREOF, the parties to this Aircraft Purchase Agreement have + +caused it to be executed by their duly authorized representatives. + +SELLER: + +HYPERION AIR, I.LC + +By: + +Name: Darren K. Indyke + +Title: Authorized Representative + +PURCHASER: + +INDUSTRIAI. INTEL SOLUTIONS, + +..s + +LLC + +Name: Rich Munkvold + +Title: GOV + +CONSENT AND JOINDER: + +The undersigned. AIC Title Service, LLC. ("Escrow Agent') does hereby consent to and join in the foregoing Agreement hereby agreeing to act as Escrow Agent in accordance with the provisions of the Agreement applicable to Escrow Agent + +in exchange for an escrow fee of One thousand eight U.S. Dollars (US S 1.800-00 + +Escrow Agent confirms that the Deposit is being held and at all times shall continue to be held in escrow exclusively with respect to the sale of the Aircraft by Seller to Purchaser as contemplated by this Agreement and for no other transaction. person, entity, or purpose, including, without limitation, any planned or subsequent sale of the Aircraft by Purchaser. Escrow Agent further confirms that any funds constituting the Deposit or the Purchase Price have been or will be deposited with Escrow Agent from Purchaser's account or, if such funds originate from an account other than in the name of Purchaser, such funds have been or will be unconditionally and irrevocably assigned by the depositor for use as the + +Deposit or the Purchase Price, as applicable, solely in connection with this Agreement. + +Escrow Agent's agreement to serve as the "Escrow Agent" is conditioned on the following limitation. Notwithstanding the provisions contained in Section I2(j) this Agreement or any provision contained in any other agreement between Purchaser and Seller, the competent courts of the State of Oklahoma or the United States District Court for the Western District of Oklahoma shall have exclusive jurisdiction to hear all disputes against Escrow Agent and no other courts shall have any jurisdiction whatsoever in respcct of such disputes against Escrow Agent. Should a dispute arise between Purchaser and Seller relating to any funds or other items which are in the possession of Escrow Agent, Escrow Agent shall be entitled to interplead any funds or other items in its possession with the competent courts of the State of Oklahoma or the United Slates District Court for the Western District of Oklahoma. The foregoing shall not affect the governing law and jurisdiction provisions contained in Section 12(j) to the extent that any dispute is between only Purchaser and + +Seller and does not involve Escrow Agent in any manner. + +Escrow Agent: + +AIC Title Service, LLC + +By: + +Name: Melissa KobelIdt Title: Escrow agent + +EXHIBIT A + +TO + +AIRCRAFT PURCHASE AGREEMENT + +BY AND BETWEEN HYPERION AIR, LLC AND INDUSTRIAL INTEGRITY SOLUTIONS, LLC + +SPECIFICATIONS + +2008KEYSTONE (SIKORSKY) S-76C++ HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JE + +(See Attached) + +Weather Radar: Honeywell Primus Wu-880 Weather Radar XM Graphical Weather: Garmin Gdl-69 XM Weather Receiver + +Communications - Iridium Phone System Passenger Addressing System + +Entertainment - XM Satellite Radio + +Additional Features + +Dual Retractable Steps Pulse Light System Halogen Search Light + +Led Recognition Lights Emergency Flotation System + +Dual Crew Flashlights Manual Rotor Brake System Maintenance & Inspections Sikorsky Power Assurance Program Phone Handset In Cabin Bose Headset Jacks For Each Seat Location Nose Landing + +Gear Doors Led Landing Lights + +Upper / Lower Led Anti-Collision Lights Keith Electric Air-Conditioned + +Cockpit And Cabin First Aid Kit Heated Windshields / Windshield Wiper + +System Tinted Cabin Windows + +Maintenance Tracking By Sikorsky FleloTrac + +Inspection Status 36 Month C/W June 2019, Fresh Annual Jan 2021 + +EXHIBIT A-I + +TO + +AIRCRAFT PURCHASE AGREEMENT + +BY AND BETWEEN HYPERION AIR, LLC AND INDUSTRIAL INTEGRITY SOLUTIONS, LLC + +Purchaser will purchase the Aircraft in its as-is, where-is condition and subject to the following matters, for which Seller shall have no responsibility and which Purchaser agrees do not cause the Aircraft to violate the Delivery Condition provided for in Section 2 (a) of the + +Aircraft Purchase Agreement: + +1- Paint tailboom, remove old tail number, and install Decal N Number This also includes cleaning minor corrosion by lower antennas. + +2 - CoPilots EFIS tube needs to be exchanged. + +3- re/wire passenger headsets to communicate with Pilots. (Previous owner: Aetna Insurance did not want Pilots to hear + +Passenger conversation for some reason). + +4- clean up current minor inspections and 60 day future Maintenance. + +EXHIBIT B + +TO + +AIRCRAFT PURCHASE AGREEMENT + +BY AND BETWEEN HYPERION AIR, LLC AND INDUSTRIAL INTEGRITY SOLUTIONS, LLC + +SCOPE OF PRE-PURCIIASE INSPECTION + +2008 KEYSTONE (SIKORSKY) S-76C++ HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JE + +(See Attached) + +EXHIBIT C + +TO + +AIRCRAFT PURCHASE AGREEMENT + +BY AND BETWEEN HYPERION AIR, LLC AND INDUSTRIAL INTEGRITY SOLUTIONS, LLC + +CERTIFICATE OF TECHNICAL ACCEPTANCE + +2008 KEYSTONE (SIKORSKY) S-76C++ HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JE + +(See Attached) + +EXHIBIT C + +TO + +AIRCRAFT PURCHASE AGREEMENT + +BY AND BETWEEN IfYPERJON AIR, LLC AND INDUSTRIAL INTEGRITY SOLUTIONS, LLC + +Certificate of Technical Acceptance + +2008 KEYSTONE (SIKORSKY) 5-76C-1-1- HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JE + +Reference is made to the provisions of Sections 3(f) and (h) of the Aircraft Purchase + +Agreement dated April , 2021 (the "Agreement") by and between II YPERION AIR, LLC, a U.S. Virgin Islands limited liability company ("Seller"), and INDUSTRIAL INTEGRITY SOLUTIONS, LLC, a New Mexico limited liability company, a ("Purchaser"), relating to the purchase and sale of one used 2008 Keystone (Sikorsky) model S-76C+ helicopter, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration (the "MA") as N722JE, together with said aircraft's two (2) Turbomeca S.A. model Arriel 2S2 engines bearing Manufacturer's Serial Nos. 42285TE and 42286TEC, and with all avionics. equipment systems, furnishings and accessories installed on, contained in or attached to said aircraft and engines, all as is more particularly described on Exhibit A, and also including all airframe, engine and accessory logbooks, flight and operation manuals, maintenance and overhaul records, and all other records and paperwork relating to the above-described aircraft and engines in Seller's possession (collectively, the "Aircraft"). Capitalized terms used but not otherwise defined in this Certificate shall have the meanings + +ascribed to such terms in the Agreement. This is to Certify as follows: + +Unconditional Acceptance: + +Purchaser hereby certifies that Purchaser has completed its Pre-Purchase Inspection of the + +Aircraft in accordance with the provisions of the Agreement on the date written below, and Purchaser has Technically Accepted the Aircraft in its "as is", "where-is" and "with all faults" condition. The Deposit has become non-refundable and may be disbursed only as and when provided in the Agreement. This confirmation constitutes Purchaser's Unconditional Acceptance as provided in + +Sections 3(f) and (h) of the Agreement; + +Dated: + +INDUSTRIAL INTEGRITY SOLUTIONS. LLC + +By: + +Name: Title: + +EXHIBIT D + +TO + +AIRCRAFT PURCHASE AGREEMENT + +BY AND BETWEEN HYPERION AIR, LLC AND INDUSTRIAL INTEGRITY SOLUTIONS, LLC + +TERMINATION NOTICE + +2008 KEYSTONE (SIKORSKY) S-76C++ HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JE + +Reference is made to the provisions of Sections 3(f) and (g) of the Aircraft Purchase + +Agreement dated April , 2021 (the "Agreement") by and between IlYPERION AIR, LLC, a U.S. Virgin Islands limited liability company ("Seller"), and INDUSTRIAL INTEGRITY SOLUTIONS, LLC, a New Mexico limited liability company ("Purchaser"), relating to the purchase and sale of one used 2008 Keystone (Sikorsky) model S-76C++ helicopter, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration (the "FAA") as N722JE, together with said aircraft's two (2) Turbomeca S.A. model Arriel 2S2 engines bearing Manufacturer's Serial Nos. 42285TE and 42286TEC, and with all avionics, equipment systems, furnishings and accessories installed on, contained in or attached to said aircraft and engines, all as is more particularly described on Exhibit A, and also including all airframe, engine and accessory logbooks, flight and operation manuals, maintenance and overhaul records, and all other records and paperwork relating to the above-described aircraft and engines in Seller's possession (collectively, the "Aircraft"). Capitalized terms used but not otherwise defined in this Certificate shall have the meanings + +ascribed to such terms in the Agreement. + +Purchaser hereby confirms that Purchaser has completed its Pre-Purchase Inspection of the Aircraft in accordance with the provisions of the Agreement on the date written below, and Purchaser has rejected the Aircraft. This shall constitute Purchaser's Termination Notice in accordance with Sections 3(f) and (g) of the Agreement. The Escrow Agent is directed to return the Deposit to Purchaser, whereupon all further obligations of Seller and Purchaser pursuant to the Agreement shall cease, except those relating to expenses and confidentiality as provided in Sections 12(n) and (o) of + +the Agreement. + +Dated: + +[NAME OF PURCHASER] + +By: + +Name: Title: + +EXHIBIT E + +AIRCRAFT PURCHASE AGREEMENT + +BY AND BETWEEN HYPERION AIR, LLC AND INDUSTRIAL INTEGRITY SOLUTIONS, LLC + +WARRANTY BILL OF SALE + +2008 KEYSTONE (SIKORSKY) S-76C++ HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JE + +(See Attached) + +WARRANTY BILL OF SALE + +Pursuant to that certain Aircraft Purchase Agreement, dated April —, + +2021 (the + +"Agreement"), by and between HYPERION AIR, LLC, a U.S. Virgin Islands limited liability company ("Seller"), and INDUSTRIAL INTEGRITY SOLUTIONS, LIC, a New Mexico limited liability company ("Purchaser"), for and in consideration of the sum of Ten Dollars (\$10.00) and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged by Seller, and being the owner of the full legal and beneficial title in and to that certain used 2008 Keystone (Sikorsky) model S-76C44 helicopter, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration (the "FAA") as N722JE, together with said aircraft's two (2) Turbomeca S.A. model Arriel 252 engines bearing Manufacturer's Serial Nos. 42285TE and 42286TEC, and with all avionics, equipment systems, furnishings and accessories installed on, contained in or attached to said aircraft and engines, all as is more particularly described on Exhibit A, and also including all airframe, engine and accessory logbooks, flight and operation manuals, maintenance and overhaul records, and all other records and paperwork relating to + +the above-described aircraft and engines in Seller's possession (collectively, the "Aircraft"). + +Seller does hereby grant, bargain, sell, convey, transfer and deliver unto Purchaser, its + +successors and assigns, all of Seller's right, title and interest in and to the Aircraft. + +Seller hereby warrants to Purchaser, its successors and assigns, that Seller is the lawful + +full legal, record and beneficial owner of 100% of the Aircraft and that there is hereby conveyed to Purchaser good and marketable title to the Aircraft, free and clear of any and all leases, liens, claims, encumbrances and rights of third parties whatsoever, and Seller will warrant and defend such title + +forever, at the sole expense of Seller, against all claims and demands whatsoever. + +EXCEPT FOR THE WARRANTIES SET FORTH IN THE IMMEDIATELY + +PRECEDING PARAGRAPH (THE "EXPRESS WARRANTIES"). THE AIRCRAFT AND EACH PART THEREOF IS BEING SOLD TO PURCHASER HEREUNDER IN ITS "AS IS, WHERE IS" CONDITION AND "WITH ALL FAULTS" EFFECTIVE AT THE CLOSING. EXCEPT FOR THE EXPRESS WARRANTIES, NEITHER SELLER NOR ITS AGENTS, REPRESENTATIVES OR EMPLOYEES MAKE ANY WARRANTIES, EXPRESS OR IMPLIED, OF ANY KIND OR NATURE WHATSOEVER TO PURCHASER. WITHOUT LIMITING THE GENERALITY OF THE FOREGOING DISCLAIMER OF REPRESENTATIONS AND WARRANTIES, THERE IS (I) NO WARRANTY BY SELLER, ITS AGENTS, REPRESENTATIVES OR EMPLOYEES AS TO THE AIRWORTHINESS OR PHYSICAL CONDITION OF THE AIRCRAFT, (II) NO IMPLIED WARRANTY BY SELLER, ITS AGENTS, REPRESENTATIVES OR EMPLOYEES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OF THE AIRCRAFT, (III) NO IMPLIED WARRANTY BY SELLER, ITS AGENTS, REPRESENTATIVES OR EMPLOYEES ARISING FROM COURSE OF PERFORMANCE, COURSE OF DEALING OR USAGE OF TRADE, AND (IV) NO WARRANTY BY SELLER, ITS AGENTS, REPRESENTATIVES OR EMPLOYEES AGAINST PATENT INFRINGEMENT OR THE LIKE. + +[Signature on following page] + +IN WITNESS WHEREOF, Seller has caused this Warranty Bill of Sale to be executed + +by its duly authorized representative, this day of April, 2021. + +I IYPERION AIR, LLC + +By: Name: Title: Date: + +EXHIBIT F + +TO + +AIRCRAFT PURCHASE AGREEMENT + +BY AND BETWEEN HYPERION AIR, LLC AND INDUSTRIAL INTEGRITY SOLUTIONS, LLC + +DELIVERY RECEIPT + +2008 KEYSTONE (SIKORSKY) S-76C++ HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JE + +(See Attached) + +2008KEYSTONE (SIKORSKY) S-76C++ HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JF, + +Pursuant to provisions of that certain Aircraft Purchase Agreement dated April , 2021 (the + +"Agreement") by and between HYPERION AIR, LLC, aU.S. Virgin Islands limited liability company ("Seller"), and INDUSTRIAL INTEGRITY SOLUTIONS, LLC, aNew Mexico limited liability company ("Purchaser"), Purchaser hereby acknowledges the delivery and acceptance of one used 2008 Keystone (Sikorsky) model S-76C-,-+ helicopter, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration (the "FAA") as N722JE, together with said aircraft's two (2) Turbomeca S.A. model Arriel 2S2 engines bearing Manufacturer's Serial Nos. 42285TE and 42286TEC, and with all avionics, equipment systems, furnishings and accessories installed on, contained in or attached to said aircraft and engines, all as is more particularly described on Exhibit A. and also including all airframe, engine and accessory logbooks, flight and operation manuals, maintenance and overhaul records, and all other records and paperwork relating to the above-described aircraft and engines in Seller's possession (collectively, the + +"Aircraft'). + +Purchaser accepts the Aircraft at p.m., on , 2021 in an "As + +Is, Where Is" condition and "With all Faults" at Florida and + +subject to the waivers and disclaimers set forth in the Agreement. + +TOTAL TIME ON AIRFRAME AT DELIVERY: hours + +TOTAL TIME ON ENGINES AT DELIVERY: + +Engine No. 1 (MSN 42285TEC): hours/cycles Engine No. 2 (MSN 42286TEC): hours/cycles + +TOTAL LANDINGS AT DELIVERY: + +INDUSTRIAL. INTEGRITY SOLUTIONS, LLC + +By: Name: Title: Date: + +STATE OF + +) ss: + +COUNTY OF + +The foregoing instrument was acknowledged before me this day of 2021 + +by , as the of a + +, on behalf of said + +NOTARY PUBLIC, STATE OF + +TITLE SERVICE + +C + +INTERNATIONAL REGISTRY PROFESSIONAL ADMINISTRATION SERVICES AGREEMENT + +This agreement is between Industrial Integrity Solutions, LLC and AIC TITLE SERVICE, LLC, as Professional Administrator ("PA"). + +• TUE anticipates registering interests with the International Registry ("IR") created pursuant to the Convention on International Interests in Mobile Equipment (the "Convention"), the Protocol to the Convention on International Interests in Mobile Equipment on Matters Specific to Aircraft Equipment ("Protocol"), both signed in Cape Town, South Africa on November 16, 2001, together with the Regulations for the International Registry ("Regulations"), the International Registry Procedures ("Procedures"), the International Registry Website Terms and Conditions ("Terms and Conditions") and all other rules, amendments, supplements, and revisions (collectively the "CTT"). • PA is an approved Professional User Entity under the CTT and PA and its employees and agents providing services + +under this agreement have each been or will be approved as a Professional User of PA. + +• PA has agreed to assist TUE with establishing TUE as an approved Transacting User Entity and with registering + +interests on the IR. + +as Transacting User Entity ("TUE") + +The parties agree as follows: + +1. Services. TUE appoints PA as its agent and authorizes PA to perform the following services: a. Establish an account in the name of the TUE as a Transacting User Entity on the IR + +b. Appoint an employee or agent of PA as the TUE's Administrator to communicate with the IR on behalf of + +the TUE; + +c. Appoint or assist TUE with appointing one or more (i) Transacting Users, as may be designated from time to time by TUE, or (ii) Professional Users (which may be one or more employees or agents of TUE) to act for + +TUE when delegated authority by the Administrator; + +d. PA's employees or agents as an Administrator or Professional User for TUE, shall be authorized to perform any and all functions of an Administrator or Professional User as contemplated and authorized under the CTT, including initiating or consenting to the registration of international interests, sale or contracts of + +sale with the IR (including amending, subordinating, subrogating, discharging or assigning said registrations) or specifically delegating the authority to make such registrations with the IR to another + +Transacting User or Professional User; + +e. Obtain Priority Search Certificates, Informational Searches, or Contracting State Search Certificates from the IR as requested by the TUE or as necessary in the discretion of PA or its employees or agents acting + +reasonably; + +f. PA's employees or agents acting as Administrator or Professional User for TUE shall not take any action with respect to the IR on behalf of the TUE until TUE specifically authorized in writing (which may include + +email or fax instructions); + +g. If at any time PA's employees or agents acting as Administrator or Professional User for TUE are not certain how to proceed, for any reason, they may refuse to take any action until they receives written instructions + +from TUE in a form and with content acceptable to PA. + +2. Authority and Binding Actions. + +a. Any actions by PA's employees or agents on behalf of TUE when dealing with the IR will be subject to the + +most current Regulations, Procedures and Terms and Conditions set forth on the IR website, + +https://www.internationalregistry.aero. + +b. TUE is also bound by the Regulations, Procedures, Terms and Conditions, shall ratify any actions PA's employees or agents performance in accordance with the terms of this Agreement, and shall complete + +the TUE Information Form attached and incorporated by reference as Exhibit A. + +TITLE SERVICE C + +c. TUE shall execute and return to PA the Confirmation of Entitlement to Act ("CEA") form attached as + +Exhibit B. This form Is required by and must be submitted by PA to the IR, must be signed by an officer or senior manager of the TUE (the TUE is called the "Entity" on this form), notes the Back-Up Contact appointed by + +the TUE, and may not be altered in any way. + +d. PA's employees or agents acting as Administrator or Professional User for TUE shall, upon receipt of + +direction from the individual authorized to act on behalf of TUE as provided in Exhibit A (the "Backup Contact") + +in form acceptable to Agent, be authorized to perform any and all functions of an Administrator or + +Professional User as contemplated and authorized under the ar, + +3. Fees. PA shall charge the fees and costs as set forth below: + +Service Total Fees + +1. Assist parties with establishing a TUE and Agent acts as Administrator for a TUE. Renewal fees are the same + +price. + +\$400 (1 year) + +2. Make registrations with the IR as + +Administrator or as a designated PUE per one (1) airframe + +and two (2) associated engines Assist. + +\$300 for each registration + +3. As Administrator, specifically delegate authority to + +make registrations to another PUE or TUE. + +\$25 / aircraft object + +4. Obtain IR search certificates per aircraft and + +two associated engines. + +\$300 + +a. TUE shall pay all PA's fees and costs in advance of services rendered, by either wire transfer or credit + +ca d. + +b. PA's fees may be modified from time to time upon PA sending TUE a revised fee schedule. + +4. Limitation on PA's Liability. + +a. TUE acknowledges that PA's employees and agents acting as Administrator or Professional User for TUE + +are acting as representatives of PA and not in any individual capacity. + +b. PA and its employees and agents acting as Administrator or Professional User will not be responsible or liable for any matters relating to or arising from the failure of the IR or the failure or malfunction of any + +of the IR's or PA's computers or computer systems. + +c. PA and its employees and agents acting as Administrator or Professional User for TUE shall be entitled to rely, without investigation, upon any document, instrument, instruction, notice, consent, certificate, statement, signature or writing (collectively, a "Communication") delivered to them (whether email, facsimile or otherwise) that purports to have been signed, executed or sent by TUE or any person acting by + +or for TUE, as conclusive evidence that the person or entity signing, executing or sending any such + +Communication had full and complete authority to do so on behalf of TUE. + +d. TUE agrees to indemnify and hold PA and its employees and agents acting as Administrator or + +Professional User for TUE harmless from all losses, costs, damages, expenses and attorneys' fees suffered or incurred by them arising from their acts or omissions related to or in the good faith performance of this + +Agreement, except such acts or omissions as may be the result of their willful misconduct or gross + +negligence. + +TITLE SERVICE + +5. Term. This agreement will terminate by either party giving ten (10) days written notice to the other. Upon + +termination of this Agreement, and upon payment of all fees owed to PA, PA will promptly appoint TUE Contact (or + +such other person as designated in writing by TUE Contact) as the Administrator for TUE. + +6. Notices. Any notice or communication shall be given in writing by serving the same upon the party to whom the notice is addressed by telecopy/facsimile, email, via overnight courier service, or by certified mail, return receipt + +requested, at the following addresses: + +PA: TUE: As provided in the TUE Information form (Exhibit A) + +AIC TITLE SERVICE, LLC + +Attention: Suzanne Pruitt + +7. Governing Law Venue. This agreement shall be construed in accordance with, and all actions arising under or in connection with this agreement shall be governed by, the internal laws of the State of Oklahoma (without reference to conflict of law principles). Any suit, action or other legal proceeding arising out of or relating to this Agreement shall be brought exclusively in the United States District Court for the Western District of Oklahoma or the District Court for Oklahoma County. The parties agree to submit to personal jurisdiction in the foregoing + +courts and to venue in those courts. + +8. Fax and Email Delivery and Counterparts. This Agreement may be executed in one or more counterparts, each of which shall be deemed an original, and all of which together shall constitute one and the same instrument. The exchange of copies of this Agreement by facsimile transmission or email shall constitute effective execution and + +delivery and may be used in lieu of the original Agreement for all purposes. + +9. Assignment. This Agreement may not be assigned, transferred or otherwise disposed of by either party without + +consent of the parties. + +10. Entire Agreement. This agreement and the attached exhibits contain the entire agreement of the parties with respect to the subject matter of this agreement, and supersede all prior negotiations, agreements and understandings. This agreement may only be amended by a written document duly executed by all parties. 11. Effectiveness; Date. This agreement will become effective when all the parties have signed it. The date this agreement is signed by the last party to sign it (as indicated by the date associated with that party's signature) + +will be deemed the date of this agreement. + +TUE: Industrial Integrity Sol tions)..LC a New Mexico Limited Liability Company + +Printed Name: Richard Munk Id + +Signature: + +Title: Chief Financial Officer + +Date: 5-5-21 + +PA: AIC Title Service, LLC + +Signature: + +Title: International Registry Specialist + +Date: + +A, - ID TITLE SERVICE + +Exhibit A + +TUE INFORMATION FORM + +TUE Information: + +Company Name: Industrial Integrity Solutions, LLC a New Mexico Limited Liability Company + +Street Address: Street Address: + +P.O. Box: + +City: Ontario + +State: Ca + +Zip Coca Country: USA + +BACKUP CONTACT Information: + +Backup Contact: Rich Munkvold Title: Chief Financial Officer + +Phone: + +Fax: + +Email: + +Alternate Backup Contact: Tia Goodman + +Title: Controller + +Phone: + +Email: + +Return the following with this form and your completed CEA form (Exhibit B) to PA: + +1. If TUE is a corporation or limited liability company, a copy of a certificate of incorporation or formation, as + +applicable. + +2. If the TUE is an individual, a legible copy of your driver's license and/or passport. + +CONFIRMATION OF ENTITLEMENT TO ACT FORM + +TO: The Registrar of International Registry of International Interests in Aircraft Equipment + +AT: Email: registryofficials@aviareto.aero OR Fax no: +353 I 829 3508 + +FORM + +Administrator: Suzanne Pruitt Back-Up Contact: Rich Munkvold Entity: Industrial Integrity Solutions + +Entity Postal Address: + +Entity State of Incorporation: New Mexico + +Relation of Administrator to Entity (select one) + +O Employee of O Attorney for Cl Agent of + +O Natural person acting in own capacity + +O Other. Please describe: + +Entity Type (select one) + +OA legal entity + +OLegal entities acting jointly + +DA natural person + +EINatural persons acting jointly 1OOther. Please describe: + +DECLARATION + +I confirm that the details noted in the Form above are correct and that, when approved by the Registrar, the Administrator has authority to + +act as administrator for the Entity in accordance with the Regulations end Procedures for the International Registry and to: + +(a) effect, amend, discharge, transfer the right to discharge or consent to registrations on the International Registry in which the Entity is a + +named party or is authorized to act for a named party; and + +(b) carry out all other functions of an administrator and assume all of the powers, obligations and responsibilities of an administrator set + +out in the Regulations and Procedures for the International Registry. + +I confirm that the Back-Up Contact noted above is the "back-up contact' as described in the Regulations and Procedures for the + +International Registry. + +I confirm that I have the power to act on behalf of the Entity in confirming the above nominations, authorisations, undertakings and + +details. + +If signing electronically, please acknowledge the following: + +O I confirm that I am permitted to sign documents using an electronic signature and that I have personally attached my electronic + +signature to this document, in acoordanc • r the Entity's prevailing policies and guidance. + +Signature - r e' + +(cannot be signed by the Administrator) Name (Please Print) Richard Munkvold TITLE (Please Print) Chief Financial Officer + +Complete name of the Applicant: + +State in which LLC is organized: + +Effective date of formation of the LLC: C1°1ciber 7, 2016 + +Industrial Intregrity Solutions, LLC + +New Mexico + +Name of each member of the LLC: + +Name of Member: Type of Entity + +(ie: individual, corporation, + +partnership, etc.) + +U.S. Citizenship Verification + +James L. Previti Individual Y ❑ N ❑ + +Frontier Finance Co. Califomia Corp. y E N + +yll N 1- 1 + +(Please use additional sheets if additional space is required) + +LLC is managed by: [1 Manager(s) ember(s) + +If LLC is managed by Manager(s)/Officer(s) + +Name of Manager(s) Type of Entity + +Offica(s) (ie: individual, corporation, + +partnership, etc.) + +❑ Officer(s) + +U.S. Citizenship Verification + +N + +N + +(Please use additional sheets if additional space is required) + +Can the managers, members or officers of this LLC act independently? VIA E + +The undersigned certifies that the Applicant is a citizen of the United States since, to the best knowledge and belief of the undersigned, at least 2/3rds of the managers, officers or managing members qualify as citizens of the United States as defined in 49 U.S.C. 40101(aXI5) and at least 75% of the voting interest or units is owned or controlled by persons who qualify as citizens of the United States as defined in 49 U.S.C. 40102(aX15). + +49 U.S.C. Section (aX15): Citizen of the United States means: (1) An individual who is a citizen of the United States or one of its possessions; or (2) A partnership of which each member is such an individual; or (3) A corporation or association created or organized under the laws of the United States or of any State, Territory, or pocceccion of the United States, of which the president and 2/3 or more of the board of directors and other managing officers thereof are such individuals and in which at least 75% of the voting interest is owned or + +controlled by persons who are citizens of the United States or of one of its possessions. + +If any member, officer or manager of the LLC is not a citizen of the United States as defined in U.S.C. + +40102(aX15) please attach an additional sheet for explanation to substantiate that the LLC qualifies as a citizen + +of the United States. + +I s + +G889060 + +FILED + +in the office of the Secretary of State of the State of California + +AUG-27 2019 + +The Space •or F deg Use Only + +., State of California + +.... 01-...:", Secretary of State + +Statement of Information (Domestic Stock and Agricultural Cooperative Corporations) FEES (Filing and Disclosure): \$25.00. If this is an amendment, see instructions. IMPORTANT — READ INSTRUCTIONS BEFORE COMPLETING THIS FORM + +1. CORPORATE NAME FRONTIER FINANCE CO. + +2. CALIFORNIA CORPORATE NUMBER + +C2557295 + +No Change Statement (Not applicable if agent address of record is a P.O. Box address. See instructions.) + +3If there have been any changes to the Information contained in the last statement of Information filed with the California Secretary + +of State, or no statement of information has been previously filed, this form must be completed in its entirety. + +If there has been no change in any of the information contained in the last Statement of information filed with the California Secretary + +of State, check the box and proceed to Item 17. + +Complete Addresses for the Following (Do not abbreviate the name of the city. Items 4 and 5 cannot be P.O. Boxes.) + +4 T RE OF PR FICE CITY STATE ZIP CODE + +CITY STATE ZIP CODE + +6. WJLING ADDRESS OF CORPORATION. IF DIFFERENT THAN ITEM 4 CITY STATE ZIP CODE + +Names and Complete Addresses of the Following Officers (TM corporation must list Mese three officers. A comparable title for the specific + +officer may be added: however, the preprinted titles on this form must not be altered.) + +7. CHIEF EXECUTIVE OFFICER/ ADDRESS CITY + +JAMES L PREVITI + +ITY + +STATE ZIP CODE + +8 SECRETARY DRESS + +RICHARD MUNKVOLD + +STATE ZIP CODE + +9. CHIEF FINANCIAL OFFICER/ mn STATE ZIP CODE iiiii mi min illi ms + +RICHARD MUNKVOLD + +Names and Complete Addresses of All Directors, Including Directors Who are Also Officers (The corporation must have at least one + +director. Attach additional pages. if necessary.) + +10. NAVE + +JAMES L PREVITI ==lilliailli Mil= + +STATE ZIP CODE + +it. NAME ADDRESS CITY STATE ZIP CODE + +12. NAME ADDRESS CITY STATE ZIP CODE + +13 NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS, IF ANY: + +Agent for Service of Process if the agent is an individual, the agent must reside in California and item 15 must be completed with a California street address, a P.O. Box address is not acceptable. If the agent Is another corporation, the agent must have on file with the California Secretary of State a + +certificate pursuant to California Corporations Code section 15O5 and Item 15 must be left blank. + +14. NAME OF AGENT FOR SERVICE OF PROCESS + +PARACORP INCORPORATED + +15. STREET ADDRESS OF AGENT FOR SERVICE OF PROCESS IN CALIFORNIA. IF AN INDNIDUAL CITY STATE ZIP CODE + +Type of Business + +16. DESCRIBE THE TYPE OF BUSINESS OF THE CORPORATION + +FINANCING & REAL ESTATE + +I Z. BY SUBVITTING THIS STATEMENT OF INFORMATION TO THE CALIFORNIA SECRETARY OF STATE, THE CORPORATION CERTIFIES THE INFORMATION + +CONTAINED HEREIN. INCLUDING ANY ATTACHMENTS, IS TRUE AND CORRECT. O8/27/2O19 MICHAEL MONTGOMERY COUNSEL + +I s + +G889060 + +FILED + +in the office of the Secretary of State of the State of California + +AUG-27 2019 + +The Space •or F deg Use Only + +., State of California + +.... 01-...:", Secretary of State + +Statement of Information (Domestic Stock and Agricultural Cooperative Corporations) FEES (Filing and Disclosure): \$25.00. If this is an amendment, see instructions. IMPORTANT — READ INSTRUCTIONS BEFORE COMPLETING THIS FORM + +1. CORPORATE NAME FRONTIER FINANCE CO. + +2. CALIFORNIA CORPORATE NUMBER + +C2557295 + +No Change Statement (Not applicable if agent address of record is a P.O. Box address. See instructions.) + +3If there have been any changes to the Information contained in the last statement of Information filed with the California Secretary + +of State, or no statement of information has been previously filed, this form must be completed in its entirety. + +If there has been no change in any of the information contained in the last Statement of information filed with the California Secretary + +of State, check the box and proceed to Item 17. + +Complete Addresses for the Following (Do not abbreviate the name of the city. Items 4 and 5 cannot be P.O. Boxes.) + +4 T RE OF PR FICE CITY STATE ZIP CODE + +CITY STATE ZIP CODE + +6. WJLING ADDRESS OF CORPORATION. IF DIFFERENT THAN ITEM 4 CITY STATE ZIP CODE + +Names and Complete Addresses of the Following Officers (TM corporation must list Mese three officers. A comparable title for the specific + +officer may be added: however, the preprinted titles on this form must not be altered.) + +7. CHIEF EXECUTIVE OFFICER/ ADDRESS CITY + +JAMES L PREVITI + +ITY + +STATE ZIP CODE + +8 SECRETARY DRESS + +RICHARD MUNKVOLD + +STATE ZIP CODE + +9. CHIEF FINANCIAL OFFICER/ mn STATE ZIP CODE iiiii mi min illi ms + +RICHARD MUNKVOLD + +Names and Complete Addresses of All Directors, Including Directors Who are Also Officers (The corporation must have at least one + +director. Attach additional pages. if necessary.) + +10. NAVE + +JAMES L PREVITI ==lilliailli Mil= + +STATE ZIP CODE + +it. NAME ADDRESS CITY STATE ZIP CODE + +12. NAME ADDRESS CITY STATE ZIP CODE + +13 NUMBER OF VACANCIES ON THE BOARD OF DIRECTORS, IF ANY: + +Agent for Service of Process if the agent is an individual, the agent must reside in California and item 15 must be completed with a California street address, a P.O. Box address is not acceptable. If the agent Is another corporation, the agent must have on file with the California Secretary of State a + +certificate pursuant to California Corporations Code section 15O5 and Item 15 must be left blank. + +14. NAME OF AGENT FOR SERVICE OF PROCESS + +PARACORP INCORPORATED + +15. STREET ADDRESS OF AGENT FOR SERVICE OF PROCESS IN CALIFORNIA. IF AN INDNIDUAL CITY STATE ZIP CODE + +Type of Business + +16. DESCRIBE THE TYPE OF BUSINESS OF THE CORPORATION + +FINANCING & REAL ESTATE + +I Z. BY SUBVITTING THIS STATEMENT OF INFORMATION TO THE CALIFORNIA SECRETARY OF STATE, THE CORPORATION CERTIFIES THE INFORMATION + +CONTAINED HEREIN. INCLUDING ANY ATTACHMENTS, IS TRUE AND CORRECT. O8/27/2O19 MICHAEL MONTGOMERY COUNSEL + +IS ! DEPARTMENT Of REVENUE + +> The following Is a suggested format of an affidavit to be completed by the purchaser and furnished to the selling dealer. In order to satisfy the requirements for exemption, the affidavit must contain all of this + +information and be completed in full. + +Florida Broward + +STATE OF COUNTY OF + +[ Suggested Format for Affidavit for Exemption of Aircraft Sold for Removal from the State of Florida by aNonresident Purchaser + +07400002 N. 05102 + +\*\*\* READ CAREFULLY BEFORE SIGNING \*\*\* + +Before me this day appeared the affiant named below, who being duly sworn, states that + +1. I have read Rule 12A-1.007(10), Florida Administrative Code, and § 212.05, Florida Statutes; and + +2. I am not a resident of the State of Florida and did not make my permanent place of abode in Florida at the + +time of taking delivery of the aircraft described below; and + +-3. I am not engaged in Florida in any employment, trade, business, or profession for which the described aircraft + +will be used in Florida; and + +4. I do not represent a corporation which has any officer or director who Is a resident of Florida, or makes his + +or her permanent place of abode in Florida; and + +5. I do not represent an artificial entity other than a corporation which has any individual vested with authority to participate in the management, direction, or control of the affairs of the entity who is a resident of Florida or + +makes his or her permanent place of abode in Florida; and + +6. I agree to furnish the Florida Department of Revenue (within 30 days of the date of departure) written proof + +that this aircraft was licensed, titled, or registered outside Florida; and + +7. I agree to furnish the Florida Department of Revenue (within 10 days of the date of departure) invoices for fuel, tie-down or hangar charges, repairs, or other similar documentation issued by an out-of-state vendor or + +supplier which identifies this aircraft and its timely removal (including the FM registration number). + +PLEASE TYPE OR PRINT THE FOLLOWING INFORMATION: + +Industrial Integrity Solutions, LLC + +Name of purchaser SSN + +If purchaser is a corporation or partnership, list officers or partners + +TA + +Purchasersiont address (Street) + +(City) (State/Country) (ZIP) + +Purchaser's daytime telephone number ( 909. ) 354 - 8002 D.O.S. + +Purchaser's driver's license number and state of Issuance + +Purchaser's passport or visa number + +Name of selling dealer or broker Address of selling dealer (Street) + +(City) (State/Country) (ZIP) + +Selling dealer or broker's Florida certificate of registration number + +Selling dealer or broker's telephone number ( + +Date of sale (Month) MAY (Day) (Year) 2021 + +N/A + +(continued on reverse side) + +Description of Aircraft + +Make + +Serial number 760750 FAA registration number N722JE + +(Check one) New O Used lidi + +Purchase Net purchase price \$ 1,800,000.00 Trade-in \$ price \$ + +Primary location of aircraft while in Florida KFXE AIRPORT + +SIKORSKY Model S76C++ Year 2008 + +Iclaim exemption from Florida sales and use tax on the purchase price of the aircraft described herein under + +s. 212.05(1)(a)2, Florida Statutes, for the following reason (check one): + +OThe aircraft will be removed from Florida within 10 days of the date of purchase. + +Gil The aircraft requires repairs, additions, or alterations and it will immediately be taken to a repair facility and will be removed from Florida within 20 days (excluding tolled days) after completion of the work. + +Under penalty of perjury, I declare that I have read the foregoing and the facts alleged are true to the best of my knowledge and belief. I understand that if I fail to comply with the requirements of this affidavit, I will be liable for + +payment of the tax and a mandatory penalty equal to the tax. + +Sworn to (or affirmed) and subscribed before me this day of + +Signature of Notary + +Print, type, or stamp name of Notary + +O Personally known O Produced identification Type of Identification: + +Signa Acopy of the affidavit must be retained by the selling dealer and made a pad of the de + +The selling dealer or broker should provide the purchaser with a copy. + +Notice To Dealers + +r's records. + +Affidavits not filed within five (5) days of the date of sale may not be accepted by the Department oevenue and + +the selling dealer or broker may be billed for tax, penalty, and interest due. + +ACKNOWLEDGMENT + +Anotary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or + +validity of that document. + +State of California + +County of SAM SEILNAtZOINO + +on mim -4 t 1.02. before me aUAKii Cetet-Ot GOrrWEESeNlentl + +(insert name and title of the officer) + +personally appeared .V-1 12)0 + +who proved to me on the basis of satisfactory evidence to be the personcsi whose namejel is/w6 subscribed to the within instrument and acknowledged to me that heiskreatry executed the same in his/Peril- authorized capacity(ies'), and that by his/l)et/p4ir signaturefgon the instrument the personfg, or the entity upon behalf of which the persorpracted, executed the instrument. + +Icertify under PENALTY OF PERJURY under the laws of the State of California that the foregoing + +paragraph is true and correct. + +WITNESS my hand and official seal. + +JULIAN CARLOS GONZALES • Canis COMM. 02353114 + +Noisy Public + +\*made County •-• Ca Mt 27 2025 + +IS ! DEPARTMENT Of REVENUE + +> The following Is a suggested format of an affidavit to be completed by the purchaser and furnished to the selling dealer. In order to satisfy the requirements for exemption, the affidavit must contain all of this + +information and be completed in full. + +Florida Broward + +STATE OF COUNTY OF + +[ Suggested Format for Affidavit for Exemption of Aircraft Sold for Removal from the State of Florida by aNonresident Purchaser + +07400002 N. 05102 + +\*\*\* READ CAREFULLY BEFORE SIGNING \*\*\* + +Before me this day appeared the affiant named below, who being duly sworn, states that + +1. I have read Rule 12A-1.007(10), Florida Administrative Code, and § 212.05, Florida Statutes; and + +2. I am not a resident of the State of Florida and did not make my permanent place of abode in Florida at the + +time of taking delivery of the aircraft described below; and + +-3. I am not engaged in Florida in any employment, trade, business, or profession for which the described aircraft + +will be used in Florida; and + +4. I do not represent a corporation which has any officer or director who Is a resident of Florida, or makes his + +or her permanent place of abode in Florida; and + +5. I do not represent an artificial entity other than a corporation which has any individual vested with authority to participate in the management, direction, or control of the affairs of the entity who is a resident of Florida or + +makes his or her permanent place of abode in Florida; and + +6. I agree to furnish the Florida Department of Revenue (within 30 days of the date of departure) written proof + +that this aircraft was licensed, titled, or registered outside Florida; and + +7. I agree to furnish the Florida Department of Revenue (within 10 days of the date of departure) invoices for fuel, tie-down or hangar charges, repairs, or other similar documentation issued by an out-of-state vendor or + +supplier which identifies this aircraft and its timely removal (including the FM registration number). + +PLEASE TYPE OR PRINT THE FOLLOWING INFORMATION: + +Industrial Integrity Solutions, LLC + +Name of purchaser SSN + +If purchaser is a corporation or partnership, list officers or partners + +Purchasessint address (Street) + +(City) (State/Country) (ZIP) + +Purchaser's daytime telephone number ( 909. ) 354 - 8002 D.O.S. + +Purchaser's driver's license number and state of Issuance + +Purchaser's passport or visa number + +Name of selling dealer or broker Address of selling dealer (Street) + +(City) (State/Country) (ZIP) + +Selling dealer or broker's Florida certificate of registration number + +Selling dealer or broker's telephone number ( + +Date of sale (Month) MAY (Day) (Year) 2021 + +N/A + +(continued on reverse side) + +Description of Aircraft + +Make + +Serial number 760750 FM registration number N722JE + +(Check one) New 0 Used 51 + +Purchase Net purchase price \$ 1,800,000.00 Trade-in S price \$ + +Primary location of aircraft while in Florida KFXE AIRPORT + +SIKORSKY Model S76C++ Yew 2008 + +Iclaim exemption from Florida sales and use tax on the purchase price of the aircraft described herein under + +s. 212.05(1)(a)2, Florida Statutes, for the following reason (check one): + +OThe aircraft will be removed from Florida within 10 days of the date of purchase. + +(81 The aircraft requires repairs, additions, or alterations and it will immediately be taken to a repair facility and will be removed from Florida within 20 days (excluding tolled days) after completion of the work. + +Under penalty of perjury, I declare that f have read the foregoing and the facts alleged are true to the best of my knowledge and belief. I understand that if I fall to comply with the requirements of this affidavit, I will be liable for + +payment of the tax and a mandatory penalty equal to the tax. + +Sworn to (or affirmed) and subscribed before me this day of + +Signature of Notary + +Print, type, or stamp name of Nota + +O Personalty known O Produced identification Type of Identification: + +Signe nt/purchaser + +Distribution of Do ments + +6Vilk + +cie6 Alt" + +Theoriginal affidavit and a copy of the sales Invoice, bill of sale, or closin ocument must be sent to the Florida + +Department of Revenue, Aircraft Enforcement Unit, P.O. Box 6417, Tallahass Fl. 32314-6417 within five (5) days of the + +date of sale. + +Acopy of the affidavit must be retained by the selling dealer and made a part of the de es records. + +The selling dealer or broker should provide the purchaser with a copy. + +Notice To Dealers + +Affidavits not filed within five (5) days of the date of sale may not be accepted by the Department oevenue and + +the selling dealer or broker may be billed for tax, penalty, and interest due. + +ACKNOWLEDGMENT + +Anotary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or + +validity of that document. + +State of California + +County of SAM SEILNAtZOINO + +on mim -4 t 1.02. before me aUAKii Cetet-Ot GOrrWEESeNlentl + +(insert name and title of the officer) + +personally appeared .V-1 12)0 + +who proved to me on the basis of satisfactory evidence to be the personcsi whose namejel is/w6 subscribed to the within instrument and acknowledged to me that heiskreatry executed the same in his/Peril- authorized capacity(ies'), and that by his/l)et/p4ir signaturefgon the instrument the personfg, or the entity upon behalf of which the persorpracted, executed the instrument. + +Icertify under PENALTY OF PERJURY under the laws of the State of California that the foregoing + +paragraph is true and correct. + +WITNESS my hand and official seal. + +JULIAN CARLOS GONZALES • Canis COMM. 02353114 + +Noisy Public + +\*made County •-• Ca Mt 27 2025 + +SECOND AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT + +This SECOND AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT + +(this "Second Amendment") is made and entered into as of the r day of May, 2021 (the "Effective Date"), by and between Hyperion Air, LLC ("Seller") and Industrial Integrity Solutions, LLC ("Purchaser"), and amends that certain Aircraft Purchase Agreeement by and between Seller and Purchaser entered into as of April 16, 2021 (the "Original Agreement"), as the same was previously amended by that certain First Amendment to Aircraft Purchase Agreeement by and between Seller and Purchaser made and entered into as of April 20, 2021 (said Original Agreement, as so amended, the "Agreement"), governing the purchase and the sale of that certain 2008 Keystone Helicopter (Sikorsky) model S-76C++ aircraft, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration as N722JE. All capitalized terms used but not otherwise defined + +herein shall have the meanings ascribed to those terms in the Agreement. + +WHEREAS, Section 4(a) of the Agreement provides in relevant part that "...in no event + +shall the Closing take place later than May 7, 2021 (the "Closing Date")"; + +WHEREAS, the Parties desire to extend the May 7, 2021 Closing deadline provided for + +in Section 4(a) until May 13, 2021, so that May 13, 2021 is the absolute final and latest date + +by which Purchaser must close under the Agreement; and + +WHEREAS, Seller is willing to extend the May 7, 2021 Closing deadline until May 13, + +2021, effective when and on the condition that immediately upon execution of this Second Amendment Purchaser increases the Deposit by delivering to the Escrow Agent an additional One Hundred Thousand Dollars (\$100,000), and provided further that Purchaser agrees herein that the full amount of the Deposit, as so increased, is non-refundable and immediately, absolutely, and unconditionally due and payable to Seller regardless of whether or not the Closing occurs, and immediately instructs Escrow Agent to disburse the Deposit, as so + +increased, to Seller in accordance with Seller's disbursement instructions; + +NOW, THEREFORE, in consideration of these premises and the mutual covenants + +and agreements herein contained, the parties agree as follows: + +1. Subject to the provisions of Paragraph 2 of this Second Amendment and + +effective if and only if Purchaser fully complies with such provisions, Section 4(a) of the + +Agreement is hereby amended in its entirety to read as follows: + +(a) The closing of this transaction ("the Closing") and delivery of the + +Aircraft to Purchaser shall take place at Fort Lauderdale Executive Airport KFXE, Florida ("the Closing Place") by not later than the Closing Date (as hereinafter defined), + +unless the parties subsequently agree upon a later date in writing, in which case such agreed upon date shall be deemed the "Closing Date". The Closing shall take place promptly after: (i) Purchaser's delivery of the Certificate of Technical Acceptance indicating Purchaser's Unconditional Acceptance of the Aircraft in accordance with Sections 3(f) and (h) hereof; and (2) confirmation from the Escrow Agent that the Escrow Agent has received the Purchase Price Balance from Purchaser and all Escrow Documents (as defined below), but in no event shall the Closing take place later than May 13, 2021 (the "Closing Date"). Seller and Purchaser hereby acknowledge that the passing of title, possession and delivery of the Aircraft shall take place within the state in which the Closing Place is located. The fuel costs and the expenses of Seller's flight crew, if any, in flying the Aircraft from the Inspection Facility to the Closing Place + +shall be the sole responsibility of and paid for by Purchaser. + +2. Immediately following Purchaser's and Seller's execution of this Second + +Amendment, Purchaser shall increase the amount of the Deposit by delivering an additional One Hundred Thousand Dollars (\$100,000) to the Escrow Agent, whereupon the full amount of the Deposit, as so increased Cum Two Hundred Thousand Dollars (\$200,000), hereinafter referred to as the "Increased Deposit"), shall be non-refundable and immediately, absolutely and unconditionally due and payable to Seller, regardless of whether or not a Closing shall thereafter occur. Concurrently with Purchaser's delivery of the additional amount of the Deposit to the Escrow Agent, Purchaser shall deliver to the Escrow Agent (and send a copy of the same to Seller) a signed written instruction directing the Escrow Agent to immediately disburse the Increased Deposit to Seller in accordance with Seller's disbursement directions, without any further writing or approval from Purchaser being required and without any requirement that a Closing occur. If and only if Seller receives the full amount of the Increased Deposit in accordance with Seller's disbursement instructions, the amount of the Purchase Price Balance required to be paid by Purchaser under the Agreement shall decrease to One Million Six Hundred Thousand Dollars (\$1,600,000). The provisions of Paragraph 1 of this Second Amendment will not be effective unless and until Seller receives the full amount of + +the Deposit in accordance with Seller's disbursement instructions. + +3. In the event of any inconsistencies between the provisions of the Agreement and + +the provisions of this Second Amendment, the provisions of this Second Amendment shall control in all respects. Except as expressly amended hereby, the provisions of the Agreement + +shall remain unchanged, valid and in full force and effect + +4. This Second Amendment may be fully executed in separate counterparts by each + +of the parties hereto. Any signatures on this Second Amendment may be transmitted via facsimile or e-mail (in pdf format), which signatures shall be deemed originals for all purposes. + +[Signatures on the following page) + +IN WITNESS WHEREOF, the parties hereto have executed this SECOND + +AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT as of the day and year first + +written above. + +Seller: + +Hyperion Air, LI.0 + +By: + +Print: Darren Indyke + +Title: Authorized Representative + +Purchaser: + +Industrial Integrity Solutions, LLC + +By: + +Print: Rich Munkvold + +Title: Chief Financial Officer + +SECOND AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT + +This SECOND AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT + +(this "Second Amendment") is made and entered into as of the r day of May, 2021 (the "Effective Date"), by and between Hyperion Air, LLC ("Seller") and Industrial Integrity Solutions, LLC ("Purchaser"), and amends that certain Aircraft Purchase Agreeement by and between Seller and Purchaser entered into as of April 16, 2021 (the "Original Agreement"), as the same was previously amended by that certain First Amendment to Aircraft Purchase Agreeement by and between Seller and Purchaser made and entered into as of April 20, 2021 (said Original Agreement, as so amended, the "Agreement"), governing the purchase and the sale of that certain 2008 Keystone Helicopter (Sikorsky) model S-76C++ aircraft, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration as N722JE. All capitalized terms used but not otherwise defined + +herein shall have the meanings ascribed to those terms in the Agreement. + +WHEREAS, Section 4(a) of the Agreement provides in relevant part that "...in no event + +shall the Closing take place later than May 7, 2021 (the "Closing Date")"; + +WHEREAS, the Parties desire to extend the May 7, 2021 Closing deadline provided for + +in Section 4(a) until May 13, 2021, so that May 13, 2021 is the absolute final and latest date + +by which Purchaser must close under the Agreement; and + +WHEREAS, Seller is willing to extend the May 7, 2021 Closing deadline until May 13, + +2021, effective when and on the condition that immediately upon execution of this Second Amendment Purchaser increases the Deposit by delivering to the Escrow Agent an additional One Hundred Thousand Dollars (\$100,000), and provided further that Purchaser agrees herein that the full amount of the Deposit, as so increased, is non-refundable and immediately, absolutely, and unconditionally due and payable to Seller regardless of whether or not the Closing occurs, and immediately instructs Escrow Agent to disburse the Deposit, as so + +increased, to Seller in accordance with Seller's disbursement instructions; + +NOW, THEREFORE, in consideration of these premises and the mutual covenants + +and agreements herein contained, the parties agree as follows: + +1. Subject to the provisions of Paragraph 2 of this Second Amendment and + +effective if and only if Purchaser fully complies with such provisions, Section 4(a) of the + +Agreement is hereby amended in its entirety to read as follows: + +(a) The closing of this transaction ("the Closing") and delivery of the + +Aircraft to Purchaser shall take place at Fort Lauderdale Executive Airport KFXE, Florida ("the Closing Place") by not later than the Closing Date (as hereinafter defined), + +unless the parties subsequently agree upon a later date in writing, in which case such agreed upon date shall be deemed the "Closing Date". The Closing shall take place promptly after: (i) Purchaser's delivery of the Certificate of Technical Acceptance indicating Purchaser's Unconditional Acceptance of the Aircraft in accordance with Sections 3(f) and (h) hereof; and (2) confirmation from the Escrow Agent that the Escrow Agent has received the Purchase Price Balance from Purchaser and all Escrow Documents (as defined below), but in no event shall the Closing take place later than May 13, 2021 (the "Closing Date"). Seller and Purchaser hereby acknowledge that the passing of title, possession and delivery of the Aircraft shall take place within the state in which the Closing Place is located. The fuel costs and the expenses of Seller's flight crew, if any, in flying the Aircraft from the Inspection Facility to the Closing Place + +shall be the sole responsibility of and paid for by Purchaser. + +2. Immediately following Purchaser's and Seller's execution of this Second + +Amendment, Purchaser shall increase the amount of the Deposit by delivering an additional One Hundred Thousand Dollars (\$100,000) to the Escrow Agent, whereupon the full amount of the Deposit, as so increased Cum Two Hundred Thousand Dollars (\$200,000), hereinafter referred to as the "Increased Deposit"), shall be non-refundable and immediately, absolutely and unconditionally due and payable to Seller, regardless of whether or not a Closing shall thereafter occur. Concurrently with Purchaser's delivery of the additional amount of the Deposit to the Escrow Agent, Purchaser shall deliver to the Escrow Agent (and send a copy of the same to Seller) a signed written instruction directing the Escrow Agent to immediately disburse the Increased Deposit to Seller in accordance with Seller's disbursement directions, without any further writing or approval from Purchaser being required and without any requirement that a Closing occur. If and only if Seller receives the full amount of the Increased Deposit in accordance with Seller's disbursement instructions, the amount of the Purchase Price Balance required to be paid by Purchaser under the Agreement shall decrease to One Million Six Hundred Thousand Dollars (\$1,600,000). The provisions of Paragraph 1 of this Second Amendment will not be effective unless and until Seller receives the full amount of + +the Deposit in accordance with Seller's disbursement instructions. + +3. In the event of any inconsistencies between the provisions of the Agreement and + +the provisions of this Second Amendment, the provisions of this Second Amendment shall control in all respects. Except as expressly amended hereby, the provisions of the Agreement + +shall remain unchanged, valid and in full force and effect + +4. This Second Amendment may be fully executed in separate counterparts by each + +of the parties hereto. Any signatures on this Second Amendment may be transmitted via facsimile or e-mail (in pdf format), which signatures shall be deemed originals for all purposes. + +[Signatures on the following page) + +IN WITNESS WHEREOF, the parties hereto have executed this SECOND + +AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT as of the day and year first + +written above. + +Seller: + +Hyperion Air, LI.0 + +By: + +Print: Darren Indyke + +Title: Authorized Representative + +Purchaser: + +Industrial Integrity Solutions, LLC + +By: + +Print: Rich Munkvold + +Title: Chief Financial Officer + +SECOND AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT + +This SECOND AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT + +(this "Second Amendment") is made and entered into as of the 7th day of May, 2021 (the "Effective Date"), by and between Hyperion Air, LLC ("Seller") and Industrial Integrity Solutions, I.LC ("Purchaser"), and amends that certain Aircraft Purchase Agreeement by and between Seller and Purchaser entered into as of April 16, 2021 (the "Original Agreement"), as the same was previously amended by that certain First Amendment to Aircraft Purchase Agreeement by and between Seller and Purchaser made and entered into as of April 20, 2021 (said Original Agreement, as so amended, the "Agreement"), governing the purchase and the sale of that certain 2008 Keystone Helicopter (Sikorsky) model S-76C++ aircraft, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration as N722JE. All capitalized terms used but not otherwise defined + +herein shall have the meanings ascribed to those terms in the Agreement. + +WHEREAs, Section 4(a) of the Agreement provides in relevant part that ". . .in no event + +shall the Closing take place later than May 7, 2021 (the "Closing Date")"; + +WHEREAS, the Parties desire to extend the May 7, 2021 Closing deadline provided for + +in Section 4(a) until May 13, 2021, so that May 13, 2021 is the absolute final and latest date + +by which Purchaser must close under the Agreement; and + +WHEREAS, Seller is willing to extend the May 7, 2021 Closing deadline until May 13, + +2021, effective when and on the condition that immediately upon execution of this Second Amendment Purchaser increases the Deposit by delivering to the Escrow Agent an additional One Hundred Thousand Dollars (S100,000). and provided further that Purchaser agrees herein that the full amount of the Deposit, as so increased, is non-refundable and immediately, absolutely, and unconditionally due and payable to Seller regardless of whether or not the Closing occurs, and immediately instructs Escrow Agent to disburse the Deposit, as so + +increased, to Seller in accordance with Seller's disbursement instructions; + +NOW, THEREFORE, in consideration of these premises and the mutual covenants + +and agreements herein contained, the parties agree as follows: + +1. Subject to the provisions of Paragraph 2 of this Second Amendment and + +effective if and only if Purchaser fully complies with such provisions, Section 4(a) of the + +Agreement is hereby amended in its entirety to read as follows: + +(a) The closing of this transaction ("the Closing") and delivery of the + +Aircraft to Purchaser shall take place at Fort Lauderdale Executive Airport KFXE, Florida ("the Closing Place") by not later than the Closing Date (as hereinafter defined), + +unless the parties subsequently agree upon alater date in writing, in which case such agreed upon date shall be deemed the "Closing Date". The Closing shall take place promptly after: (i) Purchaser's delivery of the Certificate of Technical Acceptance indicating Purchaser's Unconditional Acceptance of the Aircraft in accordance with Sections 3(f) and (h) hereof; and (2) confirmation from the Escrow Agent that the Escrow Agent has received the Purchase Price Balance from Purchaser and all Escrow Documents (as defined below), but in no event shall the Closing take place later than May 13, 2021 (the "Closing Date"). Seller and Purchaser hereby acknowledge that the passing of title, possession and delivery of the Aircraft shall take place within the state in which the Closing Place is located. The fuel costs and the expenses of Seller's flight crew, if any, in flying the Aircraft from the Inspection Facility to the Closing Place + +shall be the sole responsibility of and paid for by Purchaser. + +2. Immediately following Purchaser's and Seller's execution of this Second + +Amendment, Purchaser shall increase the amount of the Deposit by delivering an additional One I lundred Thousand Dollars (\$100,000) to the Escrow Agent, whereupon the full amount of the Deposit, as so increased (is" Two Hundred Thousand Dollars (\$200,000), hereinafter referred to as the "Increased Deposit"), shall be non-refundable and immediately, absolutely and unconditionally due and payable to Seller, regardless of whether or not a Closing shall thereafter occur. Concurrently with Purchaser's delivery of the additional amount of the Deposit to the Escrow Agent, Purchaser shall deliver to the Escrow Agent (and send a copy of the same to Seller) a signed written instruction directing the Escrow Agent to immediately disburse the Increased Deposit to Seller in accordance with Seller's disbursement directions, without any further writing or approval from Purchaser being required and without any requirement that a Closing occur. If and only if Seller receives the full amount of the Increased Deposit in accordance with Seller's disbursement instructions, the amount of the Purchase Price Balance required to be paid by Purchaser under the Agreement shall decrease to One Million Six Hundred Thousand Dollars (\$1,600,000). The provisions of Paragraph 1 of this Second Amendment will t be effective unless and until Seller receives the full amount of + +the Deposit in accorsImic with Seller's disbursement instructions. + +lia-nuneas akS•n + +3. In the ev€ni of any inconsistencies between the provisions of the Agreement and + +the provisions of this Second Amendment, the provisions of this Second Amendment shall control in all respects. Except as expressly amended hereby, the provisions of the Agreement + +shall remain unchanged, valid and in full force and effect. + +4. This Second Amendment may be fully executed in separate counterparts by each + +of the parties hereto. Any signatures on this Second Amendment may be transmitted via facsimile or e-mail (in pdf format), which signatures shall be deemed originals for all purposes. + +[Signatures on the following page] + +IN WITNESS WHEREOF, the parties hereto have executed this SECOND + +AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT as of the day and year first + +written above. + +Seller: + +Hyperion Air, LLC + +BY: Jc2/41.-v, Print: Darren Indyke + +Title: Authorized Representative + +Purchaser: + +Industrial Integrity Solutions, LLC + +By: + +Print: Rich Munkvold + +Title: Chief Financial Officer + +SECOND AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT + +This SECOND AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT + +(this "Second Amendment") is made and entered into as of the 7th day of May, 2021 (the "Effective Date"), by and between Hyperion Air, LLC ("Seller") and Industrial Integrity Solutions, I.LC ("Purchaser"), and amends that certain Aircraft Purchase Agreeement by and between Seller and Purchaser entered into as of April 16, 2021 (the "Original Agreement"), as the same was previously amended by that certain First Amendment to Aircraft Purchase Agreeement by and between Seller and Purchaser made and entered into as of April 20, 2021 (said Original Agreement, as so amended, the "Agreement"), governing the purchase and the sale of that certain 2008 Keystone Helicopter (Sikorsky) model S-76C++ aircraft, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration as N722JE. All capitalized terms used but not otherwise defined + +herein shall have the meanings ascribed to those terms in the Agreement. + +WHEREAs, Section 4(a) of the Agreement provides in relevant part that ". . .in no event + +shall the Closing take place later than May 7, 2021 (the "Closing Date")"; + +WHEREAS, the Parties desire to extend the May 7, 2021 Closing deadline provided for + +in Section 4(a) until May 13, 2021, so that May 13, 2021 is the absolute final and latest date + +by which Purchaser must close under the Agreement; and + +WHEREAS, Seller is willing to extend the May 7, 2021 Closing deadline until May 13, + +2021, effective when and on the condition that immediately upon execution of this Second Amendment Purchaser increases the Deposit by delivering to the Escrow Agent an additional One Hundred Thousand Dollars (S100,000). and provided further that Purchaser agrees herein that the full amount of the Deposit, as so increased, is non-refundable and immediately, absolutely, and unconditionally due and payable to Seller regardless of whether or not the Closing occurs, and immediately instructs Escrow Agent to disburse the Deposit, as so + +increased, to Seller in accordance with Seller's disbursement instructions; + +NOW, THEREFORE, in consideration of these premises and the mutual covenants + +and agreements herein contained, the parties agree as follows: + +1. Subject to the provisions of Paragraph 2 of this Second Amendment and + +effective if and only if Purchaser fully complies with such provisions, Section 4(a) of the + +Agreement is hereby amended in its entirety to read as follows: + +(a) The closing of this transaction ("the Closing") and delivery of the + +Aircraft to Purchaser shall take place at Fort Lauderdale Executive Airport KFXE, Florida ("the Closing Place") by not later than the Closing Date (as hereinafter defined), + +unless the parties subsequently agree upon alater date in writing, in which case such agreed upon date shall be deemed the "Closing Date". The Closing shall take place promptly after: (i) Purchaser's delivery of the Certificate of Technical Acceptance indicating Purchaser's Unconditional Acceptance of the Aircraft in accordance with Sections 3(f) and (h) hereof; and (2) confirmation from the Escrow Agent that the Escrow Agent has received the Purchase Price Balance from Purchaser and all Escrow Documents (as defined below), but in no event shall the Closing take place later than May 13, 2021 (the "Closing Date"). Seller and Purchaser hereby acknowledge that the passing of title, possession and delivery of the Aircraft shall take place within the state in which the Closing Place is located. The fuel costs and the expenses of Seller's flight crew, if any, in flying the Aircraft from the Inspection Facility to the Closing Place + +shall be the sole responsibility of and paid for by Purchaser. + +2. Immediately following Purchaser's and Seller's execution of this Second + +Amendment, Purchaser shall increase the amount of the Deposit by delivering an additional One I lundred Thousand Dollars (\$100,000) to the Escrow Agent, whereupon the full amount of the Deposit, as so increased (is" Two Hundred Thousand Dollars (\$200,000), hereinafter referred to as the "Increased Deposit"), shall be non-refundable and immediately, absolutely and unconditionally due and payable to Seller, regardless of whether or not a Closing shall thereafter occur. Concurrently with Purchaser's delivery of the additional amount of the Deposit to the Escrow Agent, Purchaser shall deliver to the Escrow Agent (and send a copy of the same to Seller) a signed written instruction directing the Escrow Agent to immediately disburse the Increased Deposit to Seller in accordance with Seller's disbursement directions, without any further writing or approval from Purchaser being required and without any requirement that a Closing occur. If and only if Seller receives the full amount of the Increased Deposit in accordance with Seller's disbursement instructions, the amount of the Purchase Price Balance required to be paid by Purchaser under the Agreement shall decrease to One Million Six Hundred Thousand Dollars (\$1,600,000). The provisions of Paragraph 1 of this Second Amendment will t be effective unless and until Seller receives the full amount of + +the Deposit in accorsImic with Seller's disbursement instructions. + +lia-nuneas akS•n + +3. In the ev€ni of any inconsistencies between the provisions of the Agreement and + +the provisions of this Second Amendment, the provisions of this Second Amendment shall control in all respects. Except as expressly amended hereby, the provisions of the Agreement + +shall remain unchanged, valid and in full force and effect. + +4. This Second Amendment may be fully executed in separate counterparts by each + +of the parties hereto. Any signatures on this Second Amendment may be transmitted via facsimile or e-mail (in pdf format), which signatures shall be deemed originals for all purposes. + +[Signatures on the following page] + +IN WITNESS WHEREOF, the parties hereto have executed this SECOND + +AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT as of the day and year first + +written above. + +Seller: + +Hyperion Air, LLC + +BY: Jc2/41.-v, Print: Darren Indyke + +Title: Authorized Representative + +Purchaser: + +Industrial Integrity Solutions, LLC + +By: + +Print: Rich Munkvold + +Title: Chief Financial Officer + +SECOND AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT + +This SECOND AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT + +(this "Second Amendment") is made and entered into as of the r day of May, 2021 (the "Effective Date"), by and between Hyperion Air, LLC ("Seller") and Industrial Integrity Solutions, LLC ("Purchaser"), and amends that certain Aircraft Purchase Agreeement by and between Seller and Purchaser entered into as of April 16, 2021 (the "Original Agreement"), as the same was previously amended by that certain First Amendment to Aircraft Purchase Agreeement by and between Seller and Purchaser made and entered into as of April 20, 2021 (said Original Agreement, as so amended, the "Agreement"), governing the purchase and the sale of that certain 2008 Keystone Helicopter (Sikorsky) model S-76C++ aircraft, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration as N722JE. All capitalized terms used but not otherwise defined + +herein shall have the meanings ascribed to those terms in the Agreement. + +WHEREAS, Section 4(a) of the Agreement provides in relevant part that "...in no event + +shall the Closing take place later than May 7, 2021 (the "Closing Date")"; + +WHEREAS, the Parties desire to extend the May 7, 2021 Closing deadline provided for + +in Section 4(a) until May 13, 2021, so that May 13, 2021 is the absolute final and latest date + +by which Purchaser must close under the Agreement; and + +WHEREAS, Seller is willing to extend the May 7, 2021 Closing deadline until May 13, + +2021, effective when and on the condition that immediately upon execution of this Second Amendment Purchaser increases the Deposit by delivering to the Escrow Agent an additional One Hundred Thousand Dollars (\$100,000), and provided further that Purchaser agrees herein that the full amount of the Deposit, as so increased, is non-refundable and immediately, absolutely, and unconditionally due and payable to Seller regardless of whether or not the Closing occurs, and immediately instructs Escrow Agent to disburse the Deposit, as so + +increased, to Seller in accordance with Seller's disbursement instructions; + +NOW, THEREFORE, in consideration of these premises and the mutual covenants + +and agreements herein contained, the parties agree as follows: + +1. Subject to the provisions of Paragraph 2 of this Second Amendment and + +effective if and only if Purchaser fully complies with such provisions, Section 4(a) of the + +Agreement is hereby amended in its entirety to read as follows: + +(a) The closing of this transaction ("the Closing") and delivery of the + +Aircraft to Purchaser shall take place at Fort Lauderdale Executive Airport KFXE, Florida ("the Closing Place") by not later than the Closing Date (as hereinafter defined), + +unless the parties subsequently agree upon a later date in writing, in which case such agreed upon date shall be deemed the "Closing Date". The Closing shall take place promptly after: (i) Purchaser's delivery of the Certificate of Technical Acceptance indicating Purchaser's Unconditional Acceptance of the Aircraft in accordance with Sections 3(f) and (h) hereof; and (2) confirmation from the Escrow Agent that the Escrow Agent has received the Purchase Price Balance from Purchaser and all Escrow Documents (as defined below), but in no event shall the Closing take place later than May 13, 2021 (the "Closing Date"). Seller and Purchaser hereby acknowledge that the passing of title, possession and delivery of the Aircraft shall take place within the state in which the Closing Place is located. The fuel costs and the expenses of Seller's flight crew, if any, in flying the Aircraft from the Inspection Facility to the Closing Place + +shall be the sole responsibility of and paid for by Purchaser. + +2. Immediately following Purchaser's and Seller's execution of this Second + +Amendment, Purchaser shall increase the amount of the Deposit by delivering an additional One Hundred Thousand Dollars (\$100,000) to the Escrow Agent, whereupon the full amount of the Deposit, as so increased Cum Two Hundred Thousand Dollars (\$200,000), hereinafter referred to as the "Increased Deposit"), shall be non-refundable and immediately, absolutely and unconditionally due and payable to Seller, regardless of whether or not a Closing shall thereafter occur. Concurrently with Purchaser's delivery of the additional amount of the Deposit to the Escrow Agent, Purchaser shall deliver to the Escrow Agent (and send a copy of the same to Seller) a signed written instruction directing the Escrow Agent to immediately disburse the Increased Deposit to Seller in accordance with Seller's disbursement directions, without any further writing or approval from Purchaser being required and without any requirement that a Closing occur. If and only if Seller receives the full amount of the Increased Deposit in accordance with Seller's disbursement instructions, the amount of the Purchase Price Balance required to be paid by Purchaser under the Agreement shall decrease to One Million Six Hundred Thousand Dollars (\$1,600,000). The provisions of Paragraph 1 of this Second Amendment will not be effective unless and until Seller receives the full amount of + +the Deposit in accordance with Seller's disbursement instructions. + +3. In the event of any inconsistencies between the provisions of the Agreement and + +the provisions of this Second Amendment, the provisions of this Second Amendment shall control in all respects. Except as expressly amended hereby, the provisions of the Agreement + +shall remain unchanged, valid and in full force and effect + +4. This Second Amendment may be fully executed in separate counterparts by each + +of the parties hereto. Any signatures on this Second Amendment may be transmitted via facsimile or e-mail (in pdf format), which signatures shall be deemed originals for all purposes. + +[Signatures on the following page) + +IN WITNESS WHEREOF, the parties hereto have executed this SECOND + +AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT as of the day and year first + +written above. + +Seller: + +Hyperion Air, LI.0 + +By: + +Print: Darren Indyke + +Title: Authorized Representative + +Purchaser: + +Industrial Integrity Solutions, LLC + +By: + +Print: Rich Munkvold + +Title: Chief Financial Officer + +2008KEYSTONE (SIKORSKY) S-76C++ HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JE + +Pursuant to provisions of that certain Aircraft Purchase Agreement dated April 2021 (the + +"Agreement") by and between HYPERION AIR, LLC, aU.S. Virgin Islands limited liability company ("Seller"), and INDUSTRIAL INTEGRITY SOLUTIONS, LLC, aNew Mexico limited liability company ("Purchaser"), Purchaser hereby acknowledges the delivery and acceptance of one used 2008 Keystone (Sikorsky) model S-76C++ helicopter, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration (the "FAA") as N722JE, together with said aircraft's two (2) Turbomeca S.A. model Arriel 2S2 engines bearing Manufacturer's Serial Nos. 42285TE and 42286TEC, and with all avionics, equipment systems, furnishings and accessories installed on, contained in or attached to said aircraft and engines, all as is more particularly described on Exhibit A, and also including all airframe, engine and accessory logbooks, flight and operation manuals, maintenance and overhaul records, and all other records and paperwork relating to the above-described aircraft and engines in Seller's possession (collectively, the + +"Aircraft"). + +Purchaser accepts the Aircraft at p.m., on 2021 in an "As + +Is, Where Is" condition and "With all Faults" at Florida and + +subject to the waivers and disclaimers set forth in the Agreement. + +TOTAL TIME ON AIRFRAME AT DELIVERY: hours + +TOTAL TIME ON ENGINES AT DELIVERY: + +Engine No. 1 (MSN 42285ItC): hours/cycles Engine No. 2 (MSN 42286TEC): hours/cycles + +TOTAL LANDINGS AT DELIVERY: + +INDUSTRIAL 1NTE TIONS, LLC + +By: + +Name: tC04,fik frigev scate".4) + +Title: 0:0 + +Date: S-/ 3- Z.. + +2008KEYSTONE (SIKORSKY) S-76C++ HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JE + +Pursuant to provisions of that certain Aircraft Purchase Agreement dated April 2021 (the + +"Agreement") by and between HYPERION AIR, LLC, aU.S. Virgin Islands limited liability company ("Seller"), and INDUSTRIAL INTEGRITY SOLUTIONS, LLC, aNew Mexico limited liability company ("Purchaser"), Purchaser hereby acknowledges the delivery and acceptance of one used 2008 Keystone (Sikorsky) model S-76C-i-F helicopter, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration (the "FAA") as N722JE, together with said aircraft's two (2) Turbomeca S.A. model Arriel 2S2 engines bearing Manufacturer's Serial Nos. 42285TE and 42286TEC, and with all avionics, equipment systems, furnishings and accessories installed on, contained in or attached to said aircraft and engines, all as is more particularly described on Exhibit A, and also including all airframe, engine and accessory logbooks, flight and operation manuals, maintenance and overhaul records, and all other records and paperwork relating to the above-described aircraft and engines in Seller's possession (collectively, the + +"Aircraft"). + +Purchaser accepts the Aircraft at p.m., on 2021 in an "As + +Is, Where Is" condition and "With all Faults" at FortLauderdale Executive airport KFXE , Florida and + +subject to the waivers and disclaimers set forth in the Agreement. + +TOTAL TIME ON AIRFRAME AT DELIVERY: 2641.9 hours + +TOTAL TIME ON ENGINES AT DELIVERK;tai + +Engine No. I (MSN 42285TEC): 2641 9 Cyde: N1.3852.6 N2-3188.2 hours/cycles 2641.9 Cycles: N1.3879.7 N24197.4 Engine No. 2 (MSN 42286TEC): hours/cycles + +TOTAL LANDINGS AT DELIVERY: 5472 + +INDUSTRIAL INTE SOL tATIONS, LLC + +By: + +Name: C.04.44D frigev ornetn...0 + +Title: 0:0 Date: S- 3- Z.. + +2008KEYSTONE (SIKORSKY) S-76C++ HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JE + +Pursuant to provisions of that certain Aircraft Purchase Agreement dated April 2021 (the + +"Agreement") by and between HYPERION AIR, LLC, aU.S. Virgin Islands limited liability company ("Seller"), and INDUSTRIAL INTEGRITY SOLUTIONS, LLC, aNew Mexico limited liability company ("Purchaser"), Purchaser hereby acknowledges the delivery and acceptance of one used 2008 Keystone (Sikorsky) model S-76C-i-F helicopter, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration (the "FAA") as N722JE, together with said aircraft's two (2) Turbomeca S.A. model Arriel 2S2 engines bearing Manufacturer's Serial Nos. 42285TE and 42286TEC, and with all avionics, equipment systems, furnishings and accessories installed on, contained in or attached to said aircraft and engines, all as is more particularly described on Exhibit A, and also including all airframe, engine and accessory logbooks, flight and operation manuals, maintenance and overhaul records, and all other records and paperwork relating to the above-described aircraft and engines in Seller's possession (collectively, the + +"Aircraft"). + +Purchaser accepts the Aircraft at p.m., on 2021 in an "As + +Is, Where Is" condition and "With all Faults" at Florida and + +subject to the waivers and disclaimers set forth in the Agreement. + +TOTAL TIME ON AIRFRAME AT DELIVERY: hours + +TOTAL TIME ON ENGINES AT DELIVER a1 + +Engine No. 1 (MSN 42285TEC): 2641 9 Cycle: NI=3852.6 / N2.3188.2 hours/cycles Engine No. 2 (MSN 42286TEC): 2641.9 Cycles: N I =3879.7 / N2=3197A hours/cycles + +TOTAL LANDINGS AT DELIVERY: 5472 + +INDUSTRIAL INTE SOLjTdTIONS, LLC + +By: + +Name: C.04.44D frigev ornetn...0 + +Title: 0:0 + +Date: S- 3- Z.. I + +2008KEYSTONE (SIKORSKY) S-76C++ HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JE + +Pursuant to provisions of that certain Aircraft Purchase Agreement dated April 2021 (the + +"Agreement") by and between HYPERION AIR, LLC, aU.S. Virgin Islands limited liability company ("Seller"), and INDUSTRIAL INTEGRITY SOLUTIONS, LLC, aNew Mexico limited liability company ("Purchaser"), Purchaser hereby acknowledges the delivery and acceptance of one used 2008 Keystone (Sikorsky) model S-76C++ helicopter, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration (the "FAA") as N722JE, together with said aircraft's two (2) Turbomeca S.A. model Arriel 2S2 engines bearing Manufacturer's Serial Nos. 42285TE and 42286TEC, and with all avionics, equipment systems, furnishings and accessories installed on, contained in or attached to said aircraft and engines, all as is more particularly described on Exhibit A, and also including all airframe, engine and accessory logbooks, flight and operation manuals, maintenance and overhaul records, and all other records and paperwork relating to the above-described aircraft and engines in Seller's possession (collectively, the + +"Aircraft"). + +Purchaser accepts the Aircraft at p.m., on 2021 in an "As + +Is, Where Is" condition and "With all Faults" at Florida and + +subject to the waivers and disclaimers set forth in the Agreement. + +TOTAL TIME ON AIRFRAME AT DELIVERY: hours + +TOTAL TIME ON ENGINES AT DELIVERY: + +Engine No. 1 (MSN 42285ItC): hours/cycles Engine No. 2 (MSN 42286TEC): hours/cycles + +TOTAL LANDINGS AT DELIVERY: + +INDUSTRIAL 1NTE TIONS, LLC + +By: + +Name: tC04,fik frigev scate".4) + +Title: 0:0 + +Date: S-/ 3- Z.. \ No newline at end of file diff --git a/marker2/ds9/EFTA00085811/EFTA00085811.metadata.json b/marker2/ds9/EFTA00085811/EFTA00085811.metadata.json new file mode 100644 index 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"previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00085811" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085898/EFTA00085898.md b/marker2/ds9/EFTA00085898/EFTA00085898.md new file mode 100644 index 0000000000000000000000000000000000000000..3553017f72876da08139489519967fde01c09179 --- /dev/null +++ b/marker2/ds9/EFTA00085898/EFTA00085898.md @@ -0,0 +1,15 @@ +From: "a" , (USANYS)" + +Subject: AIC Title Service files + +Date: Mon, 11 Oct 2021 18:12:25 +0000 + +Embedded: [EXTERNAL]\_RE\_Subpoena\_to [EXTERNAL]\_RE\_Subpoena\_to [EXTERNALLRE\_Subpoena\_to [EXTERNALLRE\_Subpoena\_to [EXTERNALLRE\_Subpoena\_to [EXTERNALLRE\_Subpoena\_to \_AIC\_Title\_ Part\_ 6\_ -\_ final.msg; \_ AIC \_ Title \_ Part \_5.msg; \_ AIC \_ Title \_ Part \_4. msg; \_ AIC \_ Title \_ Part \_3. msg; \_ AIC \_ Title \_ Part \_2. msg; \_ AIC \_ Title \_ Part \_1. msg + +Hey + +When you have a minute, would you download these attachments as subpoena returns from AIC Title Service and tee them up for the next Rule 16 production (after today)? + +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/EFTA00085898/EFTA00085898.metadata.json b/marker2/ds9/EFTA00085898/EFTA00085898.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1e6761daf6a1ff4f38e0e4d377bc3347334a8f9b --- /dev/null +++ b/marker2/ds9/EFTA00085898/EFTA00085898.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085898.pdf", + "engine": { + "marker_major": "2", + "marker_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": 0.48, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Line", + 28 + ], + [ + "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/EFTA00085898" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085899/EFTA00085899.md b/marker2/ds9/EFTA00085899/EFTA00085899.md new file mode 100644 index 0000000000000000000000000000000000000000..416c7032b63a1d22ef3882d74868b3e480d6d226 --- /dev/null +++ b/marker2/ds9/EFTA00085899/EFTA00085899.md @@ -0,0 +1,169 @@ +From: Bruce Marshall ; 'Suzanne + +Pruitt. c l> + +Subject: RE: Subpoena to AIC Title Part 5 + +Bruce Marshall + +EVP & General Counsel + +AIC Title Service + +Tel: or Fax: www.aictitle.com + +From: Bruce Marshall + +Sent: Monday, October 11, 202112:55 PM + +To: 'Callie Meier' < >; + +Cc: "c >; (USANYS)' 'Suzanne + +Pruitt' c > + +Subject: RE: Subpoena to AIC Title Part 4 + +Bruce Marshall + +EVP & General Counsel + +AIC Title Service + +Tel: or Fax: www.aictitle.com + +![](_page_0_Picture_9.jpeg) + +![](_page_0_Picture_10.jpeg) + +![](_page_0_Picture_21.jpeg) + +From: Bruce Marshall + +Sent: Monday, October 11, 202112:54 PM + +To: 'Callie Meier' < >; + +Cc: (USANYS)' < >; 'Suzanne + +Pruitt' •c. > + +![](_page_0_Picture_22.jpeg) + +![](_page_0_Picture_33.jpeg) + +![](_page_0_Picture_34.jpeg) + +AIC Title Service Tel: Or Fax: www.aictitle.com + +From: Bruce Marshall + +Sent: Monday, October 11, 202112:52 PM + +To: 'Callie Meier' • + +Cc: (USANYS). c >• 'Suzanne Pruitt' 'c l> + +Subject: RE: Subpoena to AIC Title Part 2 + +Bruce Marshall EVP & General Counsel + +AIC Title Service Tel: or Fax: www.aictitle.com + +![](_page_1_Picture_2.jpeg) + +![](_page_1_Picture_3.jpeg) + +From: Bruce Marshall + +Sent: Monday, October 11, 202112:50 PM + +To: 'Callie Meier' • + +Cc: Pruitt < (USANYS)' • Suzanne + +Subject: RE: Subpoena to AIC Title Part 1 + +I am sending the response in multiple files due to size. + +Best Regards, + +Bruce Marshall EVP & General Counsel + +AIC Title Service Tel: or Fax: www.aictitle.com + +From: Callie Meier •t > + +Sent: Friday, October 8, 2021 2:15 PM + +To: + +Cc: (USANYS) + +![](_page_1_Picture_11.jpeg) + +![](_page_1_Picture_12.jpeg) + +![](_page_1_Picture_22.jpeg) + +![](_page_1_Picture_23.jpeg) + +Subject: RE: Subpoena to AIC Title + +I have completed the requested subpoena for N722JE and sent it to our general counsel for review. I should hear back from him next week and will forward directly to you. Thank you and please contact me with any questions. Have a great weekend. + +The FAA and AIC will be closed Monday, 11 September in honor of Indigenous Peoples' Day. + +Callie Meier + +Document Specialist + +AIC Title Service Tel: or Fax: www.aictitle.com + +![](_page_1_Picture_35.jpeg) + +![](_page_1_Picture_36.jpeg) + +To: + +Cc: (USANYS) < + +Subject: Subpoena to AIC Title + +Hi Callie, + +Thank you again for the call this afternoon. Attached is the subpoena we discussed. 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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: + +**All records relating to the aircraft with tail number N750A or N722JE from January 1, 2008 to the present** + +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 +September 30, 2021 + +/s + +AUDREY STRAUSS +*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 +Email: [REDACTED] +Telephone: [REDACTED] + +![]() \ No newline at end of file diff --git a/marker2/ds9/EFTA00085902/EFTA00085902.metadata.json b/marker2/ds9/EFTA00085902/EFTA00085902.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9665e416e001b63653e82ecb6a5b2081f63cd861 --- /dev/null +++ b/marker2/ds9/EFTA00085902/EFTA00085902.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085902.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1421, + "elapsed_seconds": 5.9, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "United States District Court SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 185.43599999999998, + 91.53 + ], + [ + 429.01199999999994, + 91.53 + ], + [ + 429.01199999999994, + 127.17 + ], + [ + 185.43599999999998, + 127.17 + ] + ] + }, + { + "title": "GREETINGS:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 56.304, + 223.56000000000003 + ], + [ + 129.744, + 223.56000000000003 + ], + [ + 129.744, + 236.51999999999998 + ], + [ + 56.304, + 236.51999999999998 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Text", + 33 + ], + [ + "Line", + 32 + ], + [ + "SectionHeader", + 5 + ], + [ + "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/EFTA00085902" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00085903/EFTA00085903.md b/marker2/ds9/EFTA00085903/EFTA00085903.md new file mode 100644 index 0000000000000000000000000000000000000000..3b98a27f7844cfdb80b5b62b43b594cb2a7a11ee --- /dev/null +++ b/marker2/ds9/EFTA00085903/EFTA00085903.md @@ -0,0 +1,1000 @@ +# Delaware + +### The First State + +PAGE 1 + +JEFFREY W. BULLOCK, SECRETARY OF STATE OF THE STATE OF DELAWARE, DO HEREBY CERTIFY THE ATTACHED IS A TRUE AND CORRECT COPY OF THE CERTIFICATE OF AMENDMENT OF "SHMITKA AIR, INC.", CHANGING ITS NAME FROM "SBMITKA AIR, INC." TO "FREEDOM AIR INTERNATIONAL, INC.", FILED IN THIS OFFICE ON THE SIXTH DAY OF JULY, A.D. 2010, AT 2:37 O'CLOCK P.M. + +AFILED COPY OF THIS CERTIFICATE RAS BEEN FORWARDED TO THE NEW CASTLE COUNTY RECORDER OF DEEDS. + +3143027 8100 + +100717774 + +![](_page_0_Picture_7.jpeg) + +You may verity this costliest.\* online at corp delaware. goy/suet:war. ahead + +jelfrey w Bullock. Secretary of State AUTHE ION: 8097751 + +DATE: 07-07-10 + +#### CERTIFICATE OF AMENDMENT OF CERTIFICATE OF INCORPORATION OF SHMITKA AIR, INC. + +State of Delaware Sacrdltary of State Division of Corporations Delivered 02:52 PM 07/06/2010 FILED 02:37 PM 07/06/2010 SRV 100717774 - 3143027 FILE + +SHMITKA AIR, INC., a corporation organized and existing under and by virtue of the General Corporation Law of the State of Delaware (the "Corporation"), + +DOES HEREBY CERTIFY: + +FIRST: That the sole director of the Corporation, by Written Consent of Sole Director in Lieu of Meeting, filed with the Minutes of the proceedings of the Board of Directors, adopted the following resolution proposing and declaring advisable the amendment of the Certificate of Incorporation of the Corporation to change the name of the Corporation from Shmitka Air, Inc. to Freedom Air International, Inc.: + +> RESOLVED, that the Certificate of Incorporation of Shmitka Air, Inc. be amended to change the name of the Corporation from Shmitka Air, Inc. to Freedom Air International, Inc. by changing the first Article thereof so that, as amended, said Article shall be and read as follows: + +"1. The Name of the corporation is FREEDOM AIR INTERNATIONAL, INC." + +SECOND: That in lieu of a meeting and vote of the stockholders of the Corporation, the sole stockholder of the Corporation has given written consent to said amendment in accordance with the provisions of Section 228 of the General Corporation Law of the State of Delaware. + +THIRD: That the aforesaid amendment was duly adopted in accordance with the applicable provisions of Sections 242 and 228 of the General Corporation Law of the State of Delaware. + +IN WITNESS WHEREOF, the Corporation has caused this certificate to be signed by Darren K. Indyke, its Vice President, this G1-1-4 day of July, 2010. + +arren K. Indyke, Vice President + +UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION +FEDERAL AVIATION ADMINISTRATION-MIKE MONRONEY AERONAUTICAL CENTER +AIRCRAFT REGISTRATION APPLICATION + +UNITED STATES REGISTRATION NUMBER **N 722JE** +AIRCRAFT MANUFACTURER & MODEL **Reustone Helicopter** +(Sikorsky) **S-76C++** +AIRCRAFT SERIAL No. **760750** + +FOR FAA USE ONLY + +TYPE OF REGISTRATION (Check One box) + + 1. Individual    2. Partnership    3. Corporation    4. Co-Owner    5. Government + 8. Non-Citizen Corporation    9. Non-Citizen Corporation Co-Owner + +NAME OR APPLICANT (Person(s) shown on evidence of ownership. If individual, give last name, first name, and middle initial.) + +**Freedom Air International, Inc.** + +TELEPHONE NUMBER: ( ) + +ADDRESS (Permanent mailing address for first applicant on list) (If P.O. Box is used, physical address must also be shown.) + +Number and street: [Redacted] + +Rural Route: P.O. Box: + +| CITY | STATE | ZIP CODE | +|------------|------------|------------| +| [Redacted] | [Redacted] | [Redacted] | + + **CHECK HERE IF YOU ARE ONLY REPORTING A CHANGE OF ADDRESS ATTENTION! Read the following statement before signing this application. This portion MUST be completed.** + +A false or dishonest answer to any question in this application may be grounds for punishment by fine and/or imprisonment (U.S. Code, Title 18, Sec. 1001). + +**CERTIFICATION** + +I/WE CERTIFY: + +(1) That the above aircraft is owned by the undersigned applicant, who is a citizen (including corporations) of the United States. +(For voting trust, give name of trustee: \_\_\_\_\_), or: + +CHECK ONE AS APPROPRIATE: + +- a. A resident alien, with alien registration (Form 1-151 or Form 1-551) No. \_\_\_\_\_ +- b. A non-citizen corporation organized and doing business under the laws of (state) \_\_\_\_\_ and said aircraft is based and primarily used in the United States. Records or flight hours are available for inspection at \_\_\_\_\_ + +(2) That the aircraft is not registered under the laws of any foreign country; and + +(3) That legal evidence of ownership is attached or has been filed with the Federal Aviation Administration. + +NOTE: If executed for co-ownership all applicants must sign. Use reverse side if necessary. + +TYPE OR PRINT NAME BELOW SIGNATURE + +| SIGNATURE | TITLE | DATE | | +|-------------------------------------------------------------|------------------------|-----------------------|----------------| +| EACH PART OF THIS APPLICATION MUST BE SIGNED IN INK. | Daren K. Indike | Vice President | 8/21/10 | +| SIGNATURE | TITLE | DATE | | +| | | | | +| SIGNATURE | TITLE | DATE | | +| | | | | + +NOTE Pending receipt of the Certificate of Aircraft Registration, the aircraft may be operated for a period not in excess of 90 days, during which time the PINK copy of this application must be carried in the aircraft. + +--- + +FAA REGISTRY +N-Number Inquiry Results + +--- + +N722JE is Assigned + +--- + +Aircraft Description + +| Serial Number | 760750 | Type Registration | Corporation | +|------------------------|---------------------|------------------------|-------------| +| Manufacturer Name | KEYSTONE HELICOPTER | Certificate Issue Date | 02/27/2009 | +| Model | S-76C | Status | Valid | +| Type Aircraft | Rotocraft | Type Engine | Turbo-shaft | +| Pending Number Change | None | Dealer | No | +| Date Change Authorized | None | Mode S Code | 52325707 | +| MFR Year | 2008 | Fractional Owner | NO | + +--- + +Registered Owner + +![]()![]()Airworthiness + +| Engine Manufacturer | TURBOMECA | Classification | Standard | +|---------------------|------------|----------------|------------| +| Engine Model | ARRIEL 2S2 | Category | Transport | +| | | A/W Date | 12/08/2008 | + +This is the most current Airworthiness Certificate data, however, it may not reflect the current aircraft configuration. For that information, see the aircraft record. A copy can be obtained at [Http://aircraft.faa.gov/e.gov/ND/airrecordsND.asp](http://aircraft.faa.gov/e.gov/ND/airrecordsND.asp) + +--- + +**Other Owner Names** + +#### FAA REGISTRY N-Number Inquiry Results + +N491GM is Assigned + +### Aircraft Description + +Serial Number Manufacturer Name Model Type Aircraft Pending Number Change Date Change Authorized MFR Year 1999 53375 BELL 407 Rotorcraft None None Type Registration Certificate Issue Date Status Type Engine Dealer Corporation 11/13/2002 Valid Turbo-shaft No Mode S Code 5141216! Fractional Owner NO + +Name Street SHMITKA AIR INC + +![](_page_4_Picture_9.jpeg) + +City County Country + +### Registered Owner + +State Zip Code + +![](_page_4_Picture_12.jpeg) + +Engine Manufacturer ROLLS-ROYC Engine Model 250-C47B + +#### Airworthiness + +Classification Category A/W Date Standard Normal 11/14/2002 + +This is the most current Airworthiness Certificate data, however, it may not reflect the current aircraft configuration. For that information, see the aircraft record. A copy can be obtained at + +Htto://aircraft.faa.uov/e.aoviND/airrecordsND.asn + +#### Other Owner Names + +ctoo Gm c) traa•Z-E. h O?-n-e aitV + +To: Cc: Sent: Frid 2010 3:32 PM 110Ct:LAM r 41 -31' A-fire s co + +From: Lisa Gaskin + +' arren Ind ke' Christopher R SIK Shurkus; + +Sheila Allen + +Subject: FW: name change + +Attachments: FAI.pdf + +Hi, Larry. + +I'm sorry I didn't answer sooner, but this went to my old email address & had to be routed to me. Aero Records was purchased in June by AIC Title Service LLC, and several of us are here at AIC now. My new information is below. (New email, address, phones, etc...) + +We can definitely take care of this for you. I will hold on to the name change copy that you emailed to us, and we need you to also send FAA Form 8050-1, the Application for Aircraft Registration, for each of the aircraft, showing the new company name. We will submit the name change document, with the application forms, to the FAA, and they will issue new certificates to you, under the new name, about a month following the filing of the documents. Our fees are \$79 each aircraft, plus \$5 to the FAA (total of \$84 each aircraft). You can send us a check in the amount of \$168., along with the documents, or give us a credit card to bill — whichever is easiest for you. + +If you have not received our information regarding the re-registration of all aircraft that will soon begin taking place at FAA, just let me know, and I will get that information to you, via email. Aircraft certificates will need to be renewed every three years, and our company has the ability to track these for clients. + +Just let me know if you need me to mail the Application for Registration forms to you, or answer any other questions. + +Thank you, + +Lisa + +Lisa Gaskin Special Services Administrator + +ph: + +ph: + +fax: + +AI T I ' + +Follow us on Twitter at wi.vw.twitter.com/AlCtitle + +From: Lauren Qui + +Sent: Friday, Julyc21,1111111. 1.1 + +To: Lisa Gaskin + +Subject: Fwd: name change + +This came for you in your Aero email. Thanks! + +Sincerely, + +Lauren + +----- Forwarded message ----- + +From: [REDACTED] +Date: Fri, Jul 23, 2010 at 11:22 AM +Subject: name change + +To: [REDACTED] +Cc: [REDACTED] + +Hello Lisa, + +Shmitka Air, Inc, has changed its name to "FREEDOM AIR INTERNATIONAL" at this time, can you forward me the appropriated paper work to start the process for my registration change with the FAA for our Bell 407 N491GM serial number 53375 and Sikorsky S76 N722JE serial number 750 ? + +I have attached the name change from Delaware in this email. if you have any questions please call. + +thank you, + +Larry Visoski + +Chief Pilot, Freedom Air, International + +[REDACTED] + +[REDACTED] + +[REDACTED] Cell + +Howard and Chris, + +can you notify the appropriate parties at Sikorsky of this name change in reference to our contract warrenty and AAG credit money? thanks, Larry + +-- + +Lauren Quick + +AIC Title Service, LLC + +[REDACTED] + +Follow us on Twitter at [www.twitter.com/AICtitle](http://www.twitter.com/AICtitle) + +NAME +CHG DOC ATT. + +From: Lauren Quick +Sent: Friday, July 23, 2010 11:42 AM +To: Lisa Gaskin +Subject: Fwd: name change +Attachments: FAI.pdf + +*Need answer +to this email.* + +Lisa, + +This came for you in your Aero email. Thanks! + +Sincerely, + +Lauren + +----- Forwarded message ----- + +From: [REDACTED] +Date: Fri, Jul 23, 2010 at 11:22 AM +Subject: name change +To: [REDACTED] +Cc: [REDACTED] + +*wants to r/o name +Chg ~~FOR~~ [REDACTED] 49 1 GM - 5/M 53375 (Bell) +72 2 JE - 5/M 750 (Sikorsky) +(also name change doc there)* + +*Talk to +Sheila* + +Hello Lisa, +Smitka Air, Inc. has changed its name to "FREEDOM AIR INTERNATIONAL" at this time, +can you forward me the appropriated paper work to start the process for my registration change with the FAA for our Bell +407 N491GM serial number 53375 and Sikorsky S76 N722JE serial number 750 ? + +I have attached the name change from Delaware in this email. if you have any questions please call. + +thank you, +Larry Visoski +Chief Pilot, Freedom Air, International + +*Quoted this: \$84 each a/c* + +[\$79 + \$5] + +[REDACTED] +[REDACTED] Cell + +Howard and Chris, +can you notify the appropriate parties at Sikorsky of this name change in reference to our contract warranty and AAG +credit money? thanks, Larry + +*ds K. Judyske, PLLC* + +*Charge his MCs* + +-- +Lauren Quick +AIC Title Service, LLC + +[REDACTED] + +[REDACTED] + +Follow us on Twitter at [www.twitter.com/AICtitle](http://www.twitter.com/AICtitle) + +From: Lisa Gaskin Sent: Thursda 29, 2010 9:40 AM To: Subject: RE: name change + +Hi, Larry. + +r\E ti + +We will send another Fed-Ex today. Please be sure to have the forms sent back through our office, since we have advanced money for 2 Fed-Ex transmissions. + +Thank you, + +Lisa + +Lisa Gaskin Special Services Administrator + +![](_page_8_Picture_8.jpeg) + +AIC Title Service, LLC + +![](_page_8_Picture_10.jpeg) + +Follow us on Twitter at www.twitter.comMICtitle + +From: Sent: ay, Ju y 28, 2010 4:26 P To: Lisa Gaskin Subject: Re: name change + +Hi Lisa, Yes can ou fedex to D n Indyke / Lesley Groff + +![](_page_8_Picture_14.jpeg) + +As a back up plan, Thx Larry v + +Sent from my BlackBerry® wireless han e + +From: Lisa Gaskin Date: Wed, 28 Jul 2010 15:56:45 -0500 To Subject: RE: name change + +![](_page_8_Picture_18.jpeg) + +Larry, the fed-ex has gone today. If you would like me to send out another package tomorrow, for delivery on Friday, I can. Just let me know...thanks I + +Lisa + +Lisa Gaskin Special Services Administrator + +![](_page_9_Picture_3.jpeg) + +AIC Title Service, LLC + +![](_page_9_Picture_5.jpeg) + +Follow us on Twitter at www.twitter.com/AlCtitle + +From: Sent: Wednesday, July 28, 2010 3:40 PM To: Lisa Gaskin Subject: Re: name change + +Lisa, I'm in Paris now, have you sent package yet, I may have you send to Darren Indyke in Ny to complete? Is that possible? Thx Larry + +Sent from my BlackBerry® wireless handheld + +From: Lisa Gaskin Date: Wed 28 Jul 20 14:53:47 -0500 To: Subject: RE: name change + +Hi, Larry. + +We are sending you application forms via Fed-Ex for delivery tomorrow. + +Thank you, + +Lisa + +Lisa Gaskin Special Services Administrator + +![](_page_9_Picture_16.jpeg) + +**From:** [REDACTED] +**Sent:** Wednesday, July 28, 2010 11:57 AM +**To:** Lisa Gaskin +**Subject:** Re: name change + +☆ Yes Lisa please fwd the forms needed and I'll get them filled out to you +Thx, +Larry Visoski + +*Jend 7 +A/C* + +Sent from my BlackBerry® wireless handheld + +--- + +**From:** Lisa Gaskin <[REDACTED]> +**Date:** Fri, 23 Jul 2010 15:32:06 -0500 +**To:** [REDACTED] +**Cc:** Darren Indyke <[REDACTED]>; [REDACTED]; Christopher R SIK +Shurkus <[REDACTED]>; [REDACTED]; Sheila Allen [REDACTED] +**Subject:** FW: name change + +Hi, Larry. + +I'm sorry I didn't answer sooner, but this went to my old email address & had to be routed to me. Aero Records was purchased in June by AIC Title Service LLC, and several of us are here at AIC now. My new information is below. (New email, address, phones, etc...) + +We can definitely take care of this for you. I will hold on to the name change copy that you emailed to us, and we need you to also send FAA Form 8050-1, the Application for Aircraft Registration, for each of the aircraft, showing the new company name. We will submit the name change document, with the application forms, to the FAA, and they will issue new certificates to you, under the new name, about a month following the filing of the documents. Our fees are \$79 each aircraft, plus \$5 to the FAA (total of \$84 each aircraft). You can send us a check in the amount of \$168., along with the documents, or give us a credit card to bill – whichever is easiest for you. + +If you have not received our information regarding the re-registration of all aircraft that will soon begin taking place at FAA, just let me know, and I will get that information to you, via email. Aircraft certificates will need to be renewed every three years, and our company has the ability to track these for clients. + +☆ Just let me know if you need me to mail the Application for Registration forms to you, or answer any other questions. + +Thank you, + +Lisa + +Lisa Gaskin +Special Services Administrator + +![](_page_10_Picture_148.jpeg) + +Follow us on Twitter at [www.twitter.com/AICtitle](http://www.twitter.com/AICtitle) + +--- + +**From:** Lauren Quick [REDACTED] +**Sent:** Friday, July 23, 2010 11:42 AM +**To:** Lisa Gaskin +**Subject:** Fwd: name change + +Lisa, + +This came for you in your Aero email. Thanks! + +Sincerely, + +Lauren + +----- Forwarded message ----- + +**From:** [REDACTED] +**Date:** Fri, Jul 23, 2010 at 11:22 AM +**Subject:** name change + +**To:** [REDACTED] +**Cc:** [REDACTED] + +Hello Lisa, +Shmitka Air, Inc, has changed its name to "FREEDOM AIR INTERNATIONAL" at this time, +can you forward me the appropriated paper work to start the process for my registration change with the FAA for our Bell +407 N491GM serial number 53375 and Sikorsky S76 N722JE serial number 750 ? +I have attached the name change from Delaware in this email. if you have any questions please call. +thank you, +Larry Visoski +Chief Pilot, Freedom Air, International + +[REDACTED] 4 + +[REDACTED] + +[REDACTED] Cell + +Howard and Chris, +can you notify the appropriate parties at Sikorsky of this name change in reference to our contract warrenty and AAG +credit money? thanks, Larry + +-- +Lauren Quick +AIC Title Service, LLC + +[REDACTED] + +**DECLARATION OF INTERNATIONAL OPERATIONS** + +*GAN Jise* + +THE UNDERSIGNED OWNER OF AIRCRAFT N491GM, MANUFACTURER: BELL, MODEL 407, WITH SERIAL NUMBER 53375, HEREBY DECLARES THAT THIS AIRCRAFT IS SCHEDULED TO MAKE AN INTERNATIONAL FLIGHT ON AUGUST 6, 2010, AS FLIGHT NUMBER N491GM, DEPARTING: WEST PALM BEACH, FLORIDA, WITH A DESTINATION OF: NASSAU, BAHAMAS. + +EXPEDITED REGISTRATION IN SUPPORT OF THIS INTERNATIONAL FLIGHT IS REQUESTED THIS \_\_\_\_ DAY OF AUGUST, 2010, WITH KNOWLEDGE THAT: + +Whoever, in any matter within the jurisdiction of the executive branch of the Government of the United States, knowingly and willfully makes or uses any false writing or document knowing the same to contain any materially false, fictitious or fraudulent statement of representation shall be fined under Title 18 United States Code or imprisoned not more than 5 years, or both (18 U.S.C. Sec. 1001(a)). + +NAME OF OWNER: Freedom Air International, Inc. + +TYPED NAME OF SIGNER: Darren Indyke + +SIGNATURE: *Darren Indyke* + +TITLE: Vice President, Freedom Air International, Inc. + +COMMENTS: + +Filed by: AIC TITLE SERVICE, LLC /LISA GASKIN + +TELEPHONE: [REDACTED] + +PLEASE SEND ORIGINAL TO AIC TITLE SERVICE, LLC + +![](_page_12_Picture_107.jpeg) + +# DECLARATION OF INTERNATIONAL OPERATIONS + +THE UNDERSIGNED OWNER OF AIRCRAFT N491GM, MANUFACTURER: BELL, MODEL 407, WITH SERIAL NUMBER 53375, HEREBY DECLARES THAT THIS AIRCRAFT IS SCHEDULED TO MAKE AN INTERNATIONAL FLIGHT ON AUGUST 6, 2010, AS FLIGHT NUMBER N491GM, DEPARTING: WEST PALM BEACH, FLORIDA, WITH A DESTINATION OF: NASSAU, BAHAMAS. + +EXPEDITED REGISTRATION IN SUPPORT OF THIS INTERNATIONAL FLIGHT IS REQUESTED THIS DAY OF AUGUST, 2010, WITH KNOWLEDGE THAT: + +> Whoever, in any matter within the jurisdiction of the executive branch of the Government of the United States, knowingly and willfully makes or uses any false writing or document knowing the same to contain any materially false, fictitious or fraudulent statement of representation shall be fined under Title 18 United States Code or imprisoned not more than 5 years, or both (18 U.S.C. Sec. 1001(a). + +NAME OF OWNER: Freedom Air International, Inc. TYPED NAME OF SIGNER: Darren Indyke + +SIGNATURE: + +TITLE: COMMENTS: Vice President, Freedom Air International, Inc. + +Filed by: AIC TITLE SERVICE LLC /LISA GASKIN TELEPHONE: + +PLEASE SEND ORIGINAL TO AIC TITLE SERVICE, LLC + +From: Lisa Gaskin Sent: Tuesday, August 03, 2010 9:44 AM To: 'Darren Indyke' Subject: RE: Freedom Air International + +Good morning, Darren! + +Just fill in all of the blanks on 2 of the forms, describing each of the aircraft (make, model, serial number, registration number), this time showing your new company name in the applicant block. Be sure that a physical address is shown. Also, be sure to print your name, in addition to signing the form. Your title "Vice President" should also be shown in the appropriate block. You can keep the pink copies, and send me the white & green pages of each form. + +Then, just mail or overnight the forms to me, here at AIC. + +Thanks so much, + +Lisa + +Lisa Gaskin Special Services Administrator + +![](_page_14_Picture_8.jpeg) + +![](_page_14_Picture_10.jpeg) + +Follow us on Twitter at www.twitter.com/AICtitle + +Original Message + +From: Darren Indyke [mailto + +Sent: Tuesda Au ust 03 211.P. PM IM + +To + +Subject: Freedom Air International + +Please advise how the registration forms should be filled out to reflect the name change. Thanks. + +Darren K. Indyke + +Vice President + +![](_page_15_Picture_69.jpeg) + +Date: July 29, 2010 + +To: Darren Indyke/LesleyGroff + +Re: Form 8050-1 + +Via Federal Express + +Dear Darren & Lesley: + +Enclosed please find FAA form 8050-1 (Application for Aircraft Registration), forwarded to you at the request of Larry Visoski, in connection with name changes for two aircraft. + +We look forward to helping you with this transaction. + +Thank you, + +![]()Lisa Gaskin +Special Services Administrator + +/lg + +Encl. + +![](_page_16_Picture_0.jpeg) + +Date: July 28, 2010 + +To: Larry Visoski Freedom Air International (West Palm Beach, Florida) + +Re: Form 8050-1 + +Via Federal Express + +Dear Larry: + +Enclosed please find the forms you requested, in reference to your name change. + +We look forward to helping with this process. + +Thank you, + +Joic.sc,j + +Lisa Gaskin Special Services Administrator + +fig + +End. + +1:45 + +Darin w/ freedom +Aii + +![](_page_17_Picture_13.jpeg) + +Please call + +N 491.6M + +Talk to Trap +and call him. + +Spoke +w/ Wendy. + +The Needs to give them +a few days to process +for 1982 Flight. + +se: entl flight +after name change. + +Do this a problem? + +(To fly w/ all hard card?) + +FrMt 0rigin°. JRBA + +Bala Klein + +ft3RK Associates In + +![](_page_18_Picture_4.jpeg) + +She Date: 04AUG10 + +SHP TO (800)288-2519 BILL SENDER + +Lisa Gaskin + +AIC Title Service, LLC + +![](_page_18_Picture_7.jpeg) + +Ref a + +Invoice # + +PO # + +Dept 0 + +TRK# 7937 9141 6629 + +XH OKCA + +![](_page_18_Picture_28.jpeg) + +14•ClatA140J4 + +THU - 05 AUG Al + +STANDARD OVERNIGHT + +73127 + +OK-US + +OKC + +#### After printing this label: + +- 1. Use the 'Print' button on this page to print your label to your laser or inkjet printer. +- 2. Fold the printed page along the horizontal line. +- 3. Place label in shipping pouch and affix it to your shipment so that the barcode portion of the label can be read and scanned. + +Warning. Use only the printed original label for shipping. Using a photocopy of this label for shipping purposes is fraudulent and could result in additional billing charges, along with the cancellation of your FedEx account number. + +Use of this system constitutes your agreement to the service conditions in the current FedEx Service Guide, available on fedex.com.FedEx will not be responsible for any claim in excess of \$1 00 per package, whether the result of loss, damage, delay, non-detiveryznisdelivery.or misinformation, unless you declare a higher value, pay an additional charge, document your actual loss and file a timely cialm.LImitatIons found In the current Feder Service Guide apply. Your right to recover from FedEx for any loss. including Intrinsic valueof the package. loss of sales, income interest, profit. attorneys fees, costs, and other loans of damage whether direct, Incidentalconsequential, or special is limited to the greater of \$100 or the authorized declared value. Recovery cannot exceed actual documented loss.Maximum for items of extraordinary value is \$500, e.g. jewelry, precious metres, negotiable instruments and other items listed In our ServiceGuide. Written claims must be filed within strict time limits, see current FedEx Service Guide. + +From: Darren Indyke Sent: Friday, August 13, 2010 5:15 PM To: Lisa Gaskin Subject: Re: N722JE AND N491GM + +Yes thanks. + +Darren Indyke + +Sent from my iPhone + +On Aug 13, 2010, at 6:06 PM, Lisa Gaskin wrote: + +Dear Darren: + +Please give me your authority to file with the FAA, on Monday morning, the (2) aircraft registration applications & name change document for Freedom Air International Inc. I have these ready to go. + +Also, as you instructed during our phone conversation, I will NOT submit the declaration of international operations form. + +Thanks so much, + +Lisa + +Lisa Gaskin + +Special Services Administrator + +![](_page_19_Picture_13.jpeg) + +![](_page_20_Picture_0.jpeg) + +DATE: August 16, 2010 + +FEDERAL AVIATION ADMINISTRATION AIRCRAFT REGISTRATION BRANCH OKLAHOMA CITY, OK + +RE: (1) N722JE, Keystone Helicopter S-76C, Serial No. 760750 (2) N491GM, Bell 407, Serial No. 53375 Freedom Air International Inc. + +Ladies and Gentlemen: + +We are enclosing the following document for your review and recordation: + +Bill of Sale + +X Name Change Document + +X (2) Application for Registration forms + +C." OD r.D ca + +Please process the name change documents and return Certificates of Registration to AIC Title Service in the Public Documents Room. If for any reason you find any of these documents to be unacceptable for recordation or not needed for FAA records, please return them to AIC Title Service, LLC in the Public Documents Room. + +Sincerely, + +Lisa Gaskin + +AIC Title Service, LLC Staff FAA fees: \$10.00 + +**REGISTRATION NOT TRANSFERABLE** + +UNITED STATES OF AMERICA + DEPARTMENT OF TRANSPORTATION - FEDERAL AVIATION ADMINISTRATION + CERTIFICATE OF AIRCRAFT REGISTRATION + +NATIONALITY AND REGISTRATION MARKS **N 491GM** AIRCRAFT SERIAL NO. + +MANUFACTURER AND MANUFACTURER'S DESIGNATION OF AIRCRAFT **53375** + +BELL + ICAO Aircraft Address Code: 51412161 407 + +I + S + U + E + D + T + O + +**FREEDOM AIR INTERNATIONAL INC** + 103 FOULK RD STE 202 + WILMINGTON DE 19803-3742 + +**CORPORATION** + +It is certified that the above described aircraft has been entered on the register of the Federal Aviation Administration, United States of America, in accordance with the Convention on International Civil Aviation dated December 7, 1944, and with Title 49, United States Code, and regulations issued thereunder. + +DATE OF ISSUE + +November 13, 2002 + +*[Signature]* + +ADMINISTRATOR + +Federal Aviation Administration + +![](_page_21_Picture_30.jpeg) + +This certificate is issued for registration purposes only and is not a certificate of title. The Federal Aviation Administration does not determine rights of ownership as between private persons. + +(CUT ON DOTTED LINE) + +U.S. Department of Transportation + Federal Aviation Administration + +Civil Aviation Registry + P.O. Box 25564 + Oklahoma City, OK 73125-0504 + +Official Business + Penalty for Private Use \$300 + +AC Form 8050-3 (5/2008) Supersedes previous editions + +**TO:** + +**FREEDOM AIR INTERNATIONAL INC** + +**100 FOULK RD STE 202** + +491GM + +AC Form 8050-3 (5/2008) Supersedes previous editions + +**REGISTRATION NOT TRANSFERABLE** + +UNITED STATES OF AMERICA + DEPARTMENT OF TRANSPORTATION - FEDERAL AVIATION ADMINISTRATION + CERTIFICATE OF AIRCRAFT REGISTRATION + +NATIONALITY AND REGISTRATION MARKS **N 722JE** AIRCRAFT SERIAL NO. **760750** + +MANUFACTURER AND MANUFACTURER'S DESIGNATION OF AIRCRAFT + KEYSTONE HELICOPTER S-760 + ICAO Aircraft Address Code: 52325707 + +**FREEDOM AIR INTERNATIONAL INC** + [REDACTED] +**CORPORATION** + +It is certified that the above described aircraft has been entered on the register of the Federal Aviation Administration, United States of America, in accordance with the Convention on International Civil Aviation dated December 7, 1944, and with Title 4.9, United States Code, and regulations issued thereunder. + +DATE OF ISSUE **February 27, 2009** + +![]()(CUT ON DOTTED LINE) + +U.S. Department of Transportation + Federal Aviation Administration + Civil Aviation Registry + P.O. Box 26504 + Oklahoma City, OK 73125-0504 + Official Business + Peaceful for Private Use \$300 + AC Form 8050-3 (5/2008) Supersedes previous editions **722JE** + +**TO: FREEDOM AIR INTERNATIONAL INC** + [REDACTED] + +From: Lisa Gaskin Sent: 010 2:52 PM To: Subject: Certificates o egistration + +Hi, Darren. + +I have received both of the registration certificates, for N491GM and N722JE, under the new name- Freedom Air International Inc. + +Please let me know if you would like these sent via mail or overnight courier & the best address to use. + +Thanks so much, + +Lisa + +Lisa Gaskin Special Services Administrator + +![](_page_23_Picture_8.jpeg) + +AIC Title Service, LLC + +![](_page_23_Picture_10.jpeg) + +Follow us on Twitter at www.twitter.com/AlCtitle + +![](_page_23_Picture_13.jpeg) + +From: Sent: To: Subject: nimponsio Friday, August 27, 2010 4:40 PM Lisa Gaskin Re: Fwd: Certificates of Registration + +Fedex 114420816 + +Ck\_conc + +"qLsz D-E)' + +Larry + +You are authorized to charge + +Sent from my BlackBerry® wireless handheld + +From: Lisa Gaskin + +Date: Fri 27 Au 20 + +To: Darren Indyke + +Subject: RE: Fwd: Certificates of Regis ra ion + +Larry, could you please authorize me to put the Fed-Ex fees n your mastercard that we used for the FAA transaction? (Or, if you have a fed-ex acct. number, I can use that. But, ou'll need to get it to me pretty quickly...) Thanks! + +Lisa + +Lisa Gaskin + +Special Services Administrator + +AIC Title Service, LLC + +Follow us on Twitter at www.twitter.comMICtitle + +From: + +Sent: Friday, August 27, 2010 4:00 PM + +To: Darren Indyke; + +Subject: Re: Fwd: + +Please fedex with saturday delivery to my Fla home; + +Larry Visoski + +Thank you, Larry + +Sent from my BlackBerry® wireless handheld + +From: Darren Indyke MOM + +Date: Fri, 27 Aug 2010 13:08:45 -0700 + +To: + +Subject: Fwd: Certificates of Registration + +PIs tell Lisa where you want them sent + +Sent from my iPhone + +Begin forwarded message: + +From: Lisa Gaskin + +CD + +11-101N2i3A0 AIRIORM VOE.01. AVW OL - NOW + +.1211321031.1 + +1 + +830N3s 1118 + +After printing this label: + +1. Use the 'Print' button on this page to print your label to your laser or inkjet printer. + +2. Fold the printed page along the horizontal line. + +3. Place label in shipping pouch and affix it to your shipment so that the barcode portion of the label can be read and scanned. + +Warning: Use onhjr the printed anginal label for shipping. Using a photocopy of this label for shipping purposes is fraudulent and could result in + +additional bang charges. along with the cancellation of your FedEx account number + +Use of this system constitutes your agreement to the service conditions in the current FedEx Service Guide, available on fedex.com.FedEx will not be responsible for any claim in excess of \$100 per package, whether the result of loss. damage. delay, non-deliverymisdelivery,or misinformation. unless you declare a higher value, pay an additional charge, document your actual loss and file a timely claim.Limitations found in the current FedEx Service Guide apply. Your right to recover from FedEx for any loss. including intrinsic value of the package. loss of sales. income interest. profit, attorneys fees, costs. and other forms of damage whether direct, incidentattOnSequential or special is limited to the greater of 8100 or the authorized declared value. Recovery cannot exceed actual documented loss.Maximum for items of extraordinary value is \$1000, e.g. jewelry, precious metals, negotiable instruments and other items listed in our ServiceGuide. Written claims must be filed within strict time limits. see current + +FedEx Service Guide. + +May 7, 2021 + +Melissa Koboldt + +AIC Title Service + +Re: N722JE Purchase + +Dear Melissa, + +Enclosed you will find the Exemption of Aircraft Sold for Removal based upon our potential + +acquisition of the helicopter N722JE. + +Please let me know if you have any questions. + +Sincerely, + +....ie.-ter + +Rich Munkvold + +Chief Financial Officer + +Industrial Integrity Solutions, LLC + +Of PARfmf Of MENU, Suggested Format for Affidavit for Exemption of Aircraft Sold for Removal from the State of Florida by a Nonresident Purchaser + +GT-500002 + +The following is a suggested format of an affidavit to be completed by the purchaser and furnished to the selling dealer. In order to satisfy the requirements for exemption, the affidavit must contain all of this + +information and be completed in full. + +Florida Broward STATE OF COUNTY OF + +N. 05/02 + +\*\*\* READ CAREFULLY BEFORE SIGNING ' + +Before me this day appeared the affiant named below, who being duly sworn, states that: + +1. I have read Rule 12A-1.007(10), Florida Administrative Code, and § 212.05, Florida Statutes; and + +2. I am not a resident of the State of Florida and did not make my permanent place of abode in Florida at the + +time of taking delivery of the aircraft described below; and + +3. I am not engaged in Florida in any employment, trade, business, or profession for which the described aircraft + +will be used in Florida; and + +4. I do not represent a corporation which has any officer or director who is a resident of Florida, or makes his + +or her permanent place of abode in Florida; and + +5. I do not represent an artificial entity other than a corporation which has any individual vested with authority to participate in the management, direction, or control of the affairs of the entity who is a resident of Florida or + +makes his or her permanent place of abode in Florida; and + +6. I agree to furnish the Florida Department of Revenue (within 30 days of the date of departure) written proof + +that this aircraft was licensed, titled, or registered outside Florida; and + +7. I agree to furnish the Florida Department of Revenue (within 10 days of the date of departure) invoices for fuel, tie-down or hangar charges, repairs, or other similar documentation issued by an out-of-state vendor or + +supplier which identifies this aircraft and its timely removal (including the FAA registration number). + +PLEASE TYPE OR PRINT THE FOLLOWING INFORMATION: + +Industrial Integrity Solutions, LLC + +Name of purchaser SSN + +If purchaser is a corporation or partnership, list officers or partners + +Purchaser's permanent address (Street) + +(City) + +Purchaser's daytime telephone number + +/Country) (ZIP) + +D.O.B. + +Purchaser's driver's license number and state of issuance + +Purchasers passport or visa number + +Name of selling dealer or broker Address of selling dealer (Street) + +(City) (State/Country) (ZIP) + +Selling dealer or broker's Florida certificate of registration number + +Selling dealer or broker's telephone number ( + +Date of sale (Month) MAY (Day) (Year) 2021 + +N/A + +Description of Aircraft + +Make + +Serial number 760750 FAA registration number N722JE + +(Check one) New Used CB + +Purchase Net purchase price S 1 .800,000.00 Trade-in \$ price \$ + +SIKORSKY Model S76C++ Year 2008 + +Primary location of aircraft while in Florida KFXE AIRPORT + +I claim exemption from Florida sales and use tax on the purchase price of the aircraft described herein under + +s. 212.05(1)(a)2, Florida Statutes, for the following reason (check one): + +U The aircraft will be removed from Florida within 10 days of the date of purchase. + +Ga The aircraft requires repairs, additions, or alterations and it will immediately be taken to a repair facility and will be removed from Florida within 20 days (excluding tolled days) after completion of the work. + +Under penalty of perjury, I declare that I have read the foregoing and the facts alleged are true to the best of my knowledge and belief. I understand that if I fail to comply with the requirements of this affidavit, I will be liable for + +payment of the tax and a mandatory penalty equal to the tax. + +Sworn to (or affirmed) and subscribed before me this day of + +Signature of Notary + +Print, type, or stamp name of Notary + +D Personally known U Produced identification Type of Identification: + +Signs ure of affiantipurchaser + +Distribution of Do ments + +The original affidavit and a copy of the sales invoice, bill of sale, or closing ocument must be sent to the Florida + +Department of Revenue, Aircraft Enforcement Unit, P.O. Box 6417, Tallahass FL 32314-6417 within five (5) days of the + +date of sale. + +A copy of the affidavit must be retained by the selling dealer and made a part of the de + +The selling dealer or broker should provide the purchaser with a copy. + +Notice To Dealers + +r s records. + +Affidavits not filed within five (5) days of the date of sale may not be accepted by the Department o avenue and + +the selling dealer or broker may be billed for tax, penalty, and interest due. + +ACKNOWLEDGMENT + +Anotary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or + +\_validity of that document. + +State of California + +County of AN ,gett4At2.01N-0 + +On MAC , 2-024 before me,a0Ahl. Citet.Dt G1)001AlKijklini + +(insert name and title of the officer) + +personally appeared 1;14 CAVV03 1•1 ..V OLD + +who proved to me on the basis of satisfactory evidence to be the personffil whose name,(4) is/ subscribed to the within instrument and acknowledged to me that he/sPreitPey executed the same in his/Depeir authorized capacity(jeg), and that by histetipt4ir signaturefg on the instrument the persong or the entity upon behalf of which the persoracted, executed the instrument. + +Icertify under PENALTY OF PERJURY under the laws of the State of California that the foregoing + +paragraph is true and correct. + +WITNESS my hand and official seal. + +S GONZALES + +z + +Notify Public • California g Ffreenkcle Canty ••• Gam. Mat 27.2025 + +SECOND AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT + +This SECOND AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT + +(this "Second Amendment") is made and entered into as of the 7th day of May, 2021 (the "Effective Date"), by and between Hyperion Air, LLC ("Seller") and Industrial Integrity Solution, LLC ("Purchaser"), and amends that certain Aircraft Purchase Agreeement by and between Seller and Purchaser entered into as of April 16, 2021 (the "Original Agreement"), as the same was previously amended by that certain First Amendment to Aircraft Purchase Agreeement by and between Seller and Purchaser made and entered into as of April 20, 2021 (said Original Agreement, as so amended, the "Agreement"), governing the purchase and the sale of that certain 2008 Keystone Helicopter (Sikorsky) model S-76C++ aircraft, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration as N7221E. All capitalized terms used but not otherwise defined + +herein shall have the meanings ascribed to those terms in the Agreement. + +WHEREAS, Section 4(a) of the Agreement provides in relevant part that ". . .in no event + +shall the Closing take place later than May 7, 2021 (the "Closing Date")"; + +WHEREAS, the Parties desire to extend the May 7, 2021 Closing deadline provided for + +in Section 4(a) until May 13, 2021, so that May 13, 2021 is the absolute final and latest date + +by which Purchaser must close under the Agreement; and + +WHEREAS, Seller is willing to extend the May 7, 2021 Closing deadline until May 13, + +2021, effective when and on the condition that immediately upon execution of this Second Amendment Purchaser increases the Deposit by delivering to the Escrow Agent an additional One Hundred Thousand Dollars (S100,000). and provided further that Purchaser agrees herein that the full amount of the Deposit, as so increased, is non-refundable and immediately, absolutely, and unconditionally due and payable to Seller regardless of whether or not the Closing occurs, and immediately instructs Escrow Agent to disburse the Deposit, as so + +increased, to Seller in accordance with Seller's disbursement instructions; + +NOW, THEREFORE, in consideration of these premises and the mutual covenants + +and agreements herein contained, the parties agree as follows: + +1. Subject to the provisions of Paragraph 2 of this Second Amendment and + +effective if and only if Purchaser fully complies with such provisions, Section 4(a) of the + +Agreement is hereby amended in its entirety to read as follows: + +(a) The closing of this transaction ("the Closing") and delivery of the + +Aircraft to Purchaser shall take place at Fort Lauderdale Executive Airport KFXE, Florida ("the Closing Place") by not later than the Closing Date (as hereinafter defined), + +IN WITNESS WHEREOF, the parties hereto have executed this SECOND + +AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT as of the day and year first + +written above. + +Seller: + +Hyperion Air, LLC + +By: ---1-.)(2".EA.A.\_ Print: Darren Indyke + +Title: Authorized Representative + +Purchaser: + +Industrial Integrity Solutions, LLC + +By: + +Print: Rich Munkvold + +Tide: Chief Financial Officer + +DELIVERY RECEIPT + +2008KEYSTONE (SIKORSKY) S-76C++ HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JE + +Pursuant to provisions of that certain Aircraft Purchase Agreement dated April \_, 2021 (the + +"Agreement") by and between HYPERION AIR, LLC, aU.S. Virgin Islands limited liability company ("Seller"), and INDUSTRIAL INTEGRITY SOLUTIONS, LLC, aNew Mexico limited liability company ("Purchaser"), Purchaser hereby acknowledges the delivery and acceptance of one used 2008 Keystone (Sikorsky) model S-76C++ helicopter, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration (the "FAA") as N722JE, together with said aircraft's two (2) Turbomeca S.A. model Arriel 2S2 engines bearing Manufacturer's Serial Nos. 42285TE and 42286TEC, and with all avionics, equipment systems, furnishings and accessories installed on, contained in or attached to said aircraft and engines, all as is more particularly described on Exhibit A, and also including all airframe, engine and accessory logbooks, flight and operation manuals, maintenance and overhaul records, and all other records and paperwork relating to the above-described aircraft and engines in Seller's possession (collectively, the + +"Aircraft"). + +Purchaser accepts the Aircraft at p.m., on , 2021 in an "As + +Is, Where Is" condition and "With all Faults" at , Florida and + +subject to the waivers and disclaimers set forth in the Agreement. + +TOTAL TIME ON AIRFRAME AT DELIVERY: hours + +TOTAL TIME ON ENGINES AT DELIVERY: + +Engine No. 1 (MSN 42285TEC): hours/cycles Engine No. 2 (MSN 42286TEC): hours/cycles + +TOTAL LANDINGS AT DELIVERY: + +INDUSTRIAL INTE + +By: + +Name: e'cow /1/1p.uovoCia> + +Title: C..0 + +Date: S- 3- Z. I + +TIONS, LLC + +DELIVERY RECEIPT + +2008KEYSTONE (SIKORSKY) S-76C++ HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JE + +Pursuant to provisions of that certain Aircraft Purchase Agreement dated April 2021 (the + +"Agreement") by and between HYPERION AIR, LLC, aU.S. Virgin Islands limited liability company ("Seller"), and INDUSTRIAL INTEGRITY SOLUTIONS, LLC, aNew Mexico limited liability company ("Purchaser"), Purchaser hereby acknowledges the delivery and acceptance of one used 2008 Keystone (Sikorsky) model S-76C-i-F helicopter, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration (the "FAA") as N722JE, together with said aircraft's two (2) Turbomeca S.A. model Arriel 2S2 engines bearing Manufacturer's Serial Nos. 42285TE and 42286TEC, and with all avionics, equipment systems, furnishings and accessories installed on, contained in or attached to said aircraft and engines, all as is more particularly described on Exhibit A, and also including all airframe, engine and accessory logbooks, flight and operation manuals, maintenance and overhaul records, and all other records and paperwork relating to the above-described aircraft and engines in Seller's possession (collectively, the + +"Aircraft"). + +Purchaser accepts the Aircraft at p.m., on 2021 in an "As + +Is, Where Is" condition and "With all Faults" at Florida and + +subject to the waivers and disclaimers set forth in the Agreement. + +TOTAL TIME ON AIRFRAME AT DELIVERY: hours + +TOTAL TIME ON ENGINES AT DELIVER a1 + +Engine No. 1 (MSN 42285TEC): 2641 9 Cycle: NI=3852.6 / N2.3188.2 hours/cycles Engine No. 2 (MSN 42286TEC): 2641.9 Cycles: N I =3879.7 / N2=3197A hours/cycles + +TOTAL LANDINGS AT DELIVERY: 5472 + +INDUSTRIAL INTE SOLjTdTIONS, LLC + +By: + +Name: C.04.44D frigev ornetn...0 + +Title: 0:0 + +Date: S- 3- Z.. I + +ARCOLP01 AIRCRAFT REGISTRATION SYSTEM 05/13/21 ARCOLM01 COLLATERAL INQUIRY 09:04 + +TYPE-COLL SEARCH CRITERIA + +1 + +2,3,9 + +4 + +5 + +Type-Coll : 1 (Required) + +N-Number : 722JE + +Mfr Name . • Model Name . • Serial Number: + +Air Carrier : Air Carr City: Air Carr Loc : + +Recording Nbr: + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT PREV + +ARNNIP03 AIRCRAFT REGISTRATION SYSTEM 05/13/21 ARNNIM03 MASTER N-NUMBER INQUIRY - ASSIGNED 09:04 + +AIRCRAFT DESCRIPTION DATES-STATUS + +Reg-Number : 722JE Cert Issue: 07/17/2019 Pending Chg: Act Issue : 07/17/2019 Serial Num : 760750 Last Act : 07/17/2019 Year-Make : 2008 KEYSTONE HELICOPTER Expir Date: 07/31/2022 + +Model : S-76C Type Reg : LLC Mode-S-Code: 52325707 Uniq-id: 01014797 Status : VALID + +REGISTERED OWNER INFORMATION Reason : FINST REJ + +LIMITED LIABILITY: HYPERION AIR LLC + +Street PACKET INFORMATION + +City Phase/Queue: State-Zip : ■ **Pkt Status : County Stat Date** + +**Country-Zip : VIRGIN ISLANDS USA Susp/D1r/IR: NO NO YES Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- OPT MAIN PREV IMAGE** + +ARNNIP03 + +05/13/21 + +ARNNIM03 M 1. View Airworthiness Info 09:04 + +2. View Cross-Reference + +AIRCRAFT DE 3. View Previous Registered Owners + +Reg-Number : 722JE 9 Pending Chg: 9 Serial Num : 760750 9 Year-Make : 2008 KEYST 2 + +Model : S-76C Mode-S-Code: 52325707 + +REGISTERED OWN + +LIMITED LIABILITY: HYP + +Street : 610 /NATION + +City : ST + +State-Zip : VI OPTION: + +County + +Country-Zip : VIR NO YES Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT PREV + +> N-Number Serial Num Mfr Name Model Name + +AIRCRAFT DOCUMENT CONTROL SYSTEM REGISTRATION IMAGES Page 1 of 4 + +722JE 760750 + +KEYSTONE HELICOPTER + +S-76C + +DOCUMENTS + +05/13/21 09:04 + +Document Description Status Doc ID Doc Date \*Figs + +1. APPLICATION FOR REGISTRATION ACCEPTED 8485 06/13/2019 2 2. EVIDENCE OF OWNERSHIP JD020475 8484 06/13/2019 2 3. REG RENEWAL APP (ONLINE) ACCEPTED 9377 03/28/2017 4 4. RQST DUP/EXTENSION/TEMPORARY ACCEPTED 9736 08/04/2014 2 5. TEMPORARY CERTIFICATE ACCEPTED 9084 08/04/2014 2 6. REGISTRATION RENEWAL APP ACCEPTED 4974 07/14/2014 2 + +WINDOW 1 : + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- CONT MAIN A/W +PAGE PREV +DOC + +> N-Number Serial Num Mfr Name Model Name + +AIRCRAFT DOCUMENT CONTROL SYSTEM REGISTRATION IMAGES Page 2 of 4 + +722JE 760750 + +KEYSTONE HELICOPTER + +S-76C + +DOCUMENTS + +05/13/21 09:04 + +Document Description Status Doc ID Doc Date liPgs + +1. N-NUM CHANGE CANC. NOTICE ACCEPTED 1736 12/11/2012 2 2. FORM 8050-64 ACCEPTED 5077 09/16/2011 2 3. N-NUMBER CHANGE REQUEST ACCEPTED 3932 08/26/2011 2 4. N-NUM CHANGE EXP NOTICE ACCEPTED 4012 10/12/2012 4 5. APPLICATION FOR REGISTRATION ACCEPTED 7391 07/26/2011 2 6. EVIDENCE OF OWNERSHIP DT007148 7390 07/26/2011 2 + +WINDOW 1 : + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- CONT MAIN A/W -PAGE +PAGE PREV -DOC +DOC + +> N-Number Serial Num Mfr Name Model Name + +AIRCRAFT DOCUMENT CONTROL SYSTEM REGISTRATION IMAGES Page 3 of 4 + +722JE 760750 + +KEYSTONE HELICOPTER + +S-76C + +DOCUMENTS + +05/13/21 09:04 + +Document Description Status Doc ID Doc Date #Pgs + +1. APPLICATION FOR REGISTRATION ACCEPTED 6668 08/16/2010 2 2. N-NUMBER CHANGE REQUEST ACCEPTED 0725 02/12/2010 2 3. N-NUMBER CHANGE REQUEST ACCEPTED 3902 03/16/2010 2 4. NAME CHANGE TEMPLATE ACCEPTED 4696 03/17/2010 2 5. APPLICATION FOR REGISTRATION ACCEPTED 2985 02/17/2009 2 6. EVIDENCE OF OWNERSHIP PH001657 0071 12/30/2008 2 + +WINDOW 1 : + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- CONT MAIN A/W -PAGE +PAGE PREV -DOC +DOC + +> N-Number Serial Num Mfr Name Model Name + +AIRCRAFT DOCUMENT CONTROL SYSTEM REGISTRATION IMAGES Page 4 of 4 + +722JE 760750 + +KEYSTONE HELICOPTER + +S-76C + +DOCUMENTS + +05/13/21 09:04 + +Document Description Status Doc ID Doc Date liPgs + +1. EVIDENCE OF OWNERSHIP PH001656 0069 12/30/2008 2 2. MISCELLANEOUS-SUPPORT ACCEPTED 0752 12/23/2008 2 3. ASSIGNMENT LETTER ACCEPTED 8161 09/09/2008 2 4. ASSIGNMENT OF N-NUMBER ACCEPTED 5061 09/05/2008 2 5. ASSIGNMENT OF N-NUMBER ACCEPTED 5060 09/05/2008 2 6. MEMO TO FILE ACCEPTED 8211 09/09/2008 2 + +WINDOW 1 : + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- CONT MAIN A/W -PAGE PREV -DOC +DOC + +GEGIIP02 AIRCRAFT DOCUMENT CONTROL SYSTEM 05/13/21 GFGIIM02 IMAGE INQUIRY - ADMINISTRATIVE 09:06 + +Doc Type : ASG + +Required Search Criteria + +N-Number : 722JE + +Serial Number + +Name + +Control Number : 2021 - F7 + +E-Number Date + +Billing Number • Recording Number • + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT MAIN PREV + +GEGIIP02 AIRCRAFT DOCUMENT CONTROL SYSTEM 05/13/21 GFGIIM02 IMAGE INQUIRY - ADMINISTRATIVE 09:06 + +Doc Type : NCG + +Required Search Criteria + +N-Number : 722JE + +Serial Number + +Name + +Control Number : 2021 - F7 + +E-Number Date + +Billing Number • Recording Number • + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT MAIN PREV + +GFGIIP02 AIRCRAFT DOCUMENT CONTROL SYSTEM 05/13/21 GFGIIM02 IMAGE INQUIRY - ADMINISTRATIVE 09:07 + +Doc Type : RSV + +Required Search Criteria + +N-Number : 722JE + +Serial Number + +Name + +Control Number : 2021 - F7 + +E-Number Date + +Billing Number • Recording Number • + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT MAIN PREV + +GFGIIP02 AIRCRAFT DOCUMENT CONTROL SYSTEM 05/13/21 GFGIIM02 IMAGE INQUIRY - ADMINISTRATIVE 09:07 + +Doc Type : RSV + +Required Search Criteria + +N-Number : 722JE + +Serial Number + +Name + +Control Number : 2021 - F7 + +E-Number Date + +Billing Number • Recording Number • + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT MAIN PREV + +GFGIIP07 AIRCRAFT DOCUMENT CONTROL SYSTEM 05/13/21 GFGIIM43 IMAGE INQUIRY - ADMINISTRATIVE 09:07 + +IR Authorization Code : + +OR + +Name + +OR + +N-number : 722JE + +OR + +Type + +Serial Number: + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT MAIN PREV + +GFGIINII GFGIIM36 AIRCRAFT DOCUMENT CONTROL SYSTEM IMAGE INQUIRY - ADMINISTRATIVE Page 1 of 1 + +05/13/21 09:07 + +Doc Description: INTERNATIONAL REGISTRY + +N-Number : 722JE + +IR Auth Code N-Number Date Pgs + +1. IRN20190613101517 722JE 06/14/2019 2 2. IRN20110726120229 722JE 07/27/2011 2 + +3. 4. 5. 6. 7. 8. 9. 10. + +WINDOW 1 : Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- WIN 1 FB MAIN COLL PREV +DOC + +GFGIIP07 AIRCRAFT DOCUMENT CONTROL SYSTEM 05/13/21 GFGIIM43 IMAGE INQUIRY - ADMINISTRATIVE 09:07 + +IR Authorization Code : + +OR + +Name + +OR + +N -number + +OR + +Type : 1 + +Serial Number: 760750 + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT MAIN PREV + +GFGIIN12 AIRCRAFT DOCUMENT CONTROL SYSTEM GFGIIM36 IMAGE INQUIRY - ADMINISTRATIVE + +Page 1 of 1 + +Doc Description: INTERNATIONAL REGISTRY + +05/13/21 09:07 + +Collateral : 1 760750 + +IR Auth Code Collateral Date A Pgs + +\* 1. IRN20190613101517 722JE 760750 KEYSTONE HELICOPTER S-7 06/14/2019 2 2. IRN20110726120229 722JE 760750 SIKORSKY S-76 07/27/2011 2 3. IRN20081230154204 750A 760750 SIKORSKY S-76 12/31/2008 2 + +4. 5. 6. 7. 8. 9. 10. + +WINDOW 1 : Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- WIN 1 FB MAIN COLL PREV +DOC + +ARC0LP01 AIRCRAFT REGISTRATION SYSTEM 05/13/21 ARC0LMO1 COLLATERAL INQUIRY 09:07 + +TYPE-COLL SEARCH CRITERIA + +Type-Coll : 2 (Required) + +1 N-Number + +2,3,9 Mfr Name • + +Model Name • + +Serial Number: 42285 + +4 Air Carrier + +Air Carr City: Air Carr Loc : + +5 Recording Nbr: + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT PREV + +ARCOLP01 AIRCRAFT REGISTRATION SYSTEM 05/13/21 ARCOLM01 COLLATERAL INQUIRY 09:08 + +TYPE-COLL SEARCH CRITERIA + +Type-Coll : 2 (Required) + +1 N-Number + +2,3,9 Mfr Name • + +Model Name • + +Serial Number: 42285 + +4 Air Carrier + +Air Carr City: Air Carr Loc : + +5 Recording Nbr: + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT PREV + +GFGIIP07 AIRCRAFT DOCUMENT CONTROL SYSTEM 05/13/21 GFGIIM43 IMAGE INQUIRY - ADMINISTRATIVE 09:08 + +IR Authorization Code : + +OR + +Name + +OR + +N -number + +OR + +Type : 2 + +Serial Number: 42285TE + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT MAIN PREV + +GFGIIP07 AIRCRAFT DOCUMENT CONTROL SYSTEM GFGIIM43 IMAGE INQUIRY - ADMINISTRATIVE + +05/13/21 09:08 + +IR Authorization Code : + +Name + +N -number + +OR + +OR + +OR + +Type + +Serial Number: + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT MAIN PREV + +GFGIIP07 AIRCRAFT DOCUMENT CONTROL SYSTEM 05/13/21 GFGIIM43 IMAGE INQUIRY - ADMINISTRATIVE 09:08 + +IR Authorization Code : + +OR + +Name + +OR + +N -number + +OR + +Type : 2 Serial Number: 42285 + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT MAIN PREV + +GFGIIN12 GFGIIM36 AIRCRAFT DOCUMENT CONTROL SYSTEM IMAGE INQUIRY - ADMINISTRATIVE Page 1 of 1 + +Doc Description: INTERNATIONAL REGISTRY + +05/13/21 09:08 + +Collateral : 2 42285 + +IR Auth Code Collateral Date Pgs + +1. IRN20190613101517 42285 TURBO ARRIEL 2S2 06/14/2019 2 2. IRN20110726120229 42285 TURBO ARRIEL 2S2 07/27/2011 2 + +3. 4. 5. 6. 7. 8. 9. 10. + +WINDOW 1 : Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- WIN 1 FB MAIN COLL PREV +DOC + +ARCOLP01 AIRCRAFT REGISTRATION SYSTEM 05/13/21 ARCOLM01 COLLATERAL INQUIRY 09:08 + +TYPE-COLL SEARCH CRITERIA + +Type-Coll : 2 (Required) + +1 N-Number + +2,3,9 Mfr Name • + +Model Name • + +Serial Number: 42286 + +4 Air Carrier + +Air Carr City: Air Carr Loc : + +5 Recording Nbr: + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT PREV + +GFGIIP07 AIRCRAFT DOCUMENT CONTROL SYSTEM 05/13/21 GFGIIM43 IMAGE INQUIRY - ADMINISTRATIVE 09:09 + +IR Authorization Code : + +OR + +Name + +OR + +N -number + +OR + +Type : 2 + +Serial Number: 42286TEC + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT MAIN PREV + +GFGIIP07 AIRCRAFT DOCUMENT CONTROL SYSTEM GFGIIM43 IMAGE INQUIRY - ADMINISTRATIVE + +05/13/21 09:09 + +IR Authorization Code : + +Name + +N -number + +OR + +OR + +OR + +Type + +Serial Number: + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT MAIN PREV + +GFGIIP07 AIRCRAFT DOCUMENT CONTROL SYSTEM 05/13/21 GFGIIM43 IMAGE INQUIRY - ADMINISTRATIVE 09:09 + +IR Authorization Code : + +OR + +Name + +OR + +N -number + +OR + +Type : 2 + +Serial Number: 42286TEC + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT MAIN PREV + +GFGIIP07 AIRCRAFT DOCUMENT CONTROL SYSTEM GFGIIM43 IMAGE INQUIRY - ADMINISTRATIVE + +05/13/21 09:09 + +IR Authorization Code : + +Name + +N -number + +OR + +OR + +OR + +Type + +Serial Number: + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT MAIN PREV + +GFGIIP07 AIRCRAFT DOCUMENT CONTROL SYSTEM 05/13/21 GFGIIM43 IMAGE INQUIRY - ADMINISTRATIVE 09:09 + +IR Authorization Code : + +OR + +Name + +OR + +N -number + +OR + +Type : 2 Serial Number: 42286 + +Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- + +CONT MAIN PREV + +GFGIIN12 GFGIIM36 AIRCRAFT DOCUMENT CONTROL SYSTEM IMAGE INQUIRY - ADMINISTRATIVE Page 1 of 1 + +Doc Description: INTERNATIONAL REGISTRY + +05/13/21 09:09 + +Collateral : 2 42286 + +IR Auth Code Collateral Date Pgs + +1. IRN20190613101517 42286 TURBO ARRIEL 2S2 06/14/2019 2 2. IRN20110726120229 42286 TURBO ARRIEL 2S2 07/27/2011 2 + +3. 4. 5. 6. 7. 8. 9. 10. + +WINDOW 1 : Enter-PF1---PF2---PF3---PF4---PF5---PF6---PF7---PF8---PF9---PF10--PF11--PF12--- WIN 1 FB MAIN COLL PREV +DOC + +Complete name of the Applicant: + +State in which LLC is organized: + +Industrial Intregrity Solutions. LLC + +New Mexico + +Effective date of formation of the LLC: October 7.2016 + +Name of each member of the LLC: + +Name of Member: + +James L Previti + +Frontier Finance Co + +Type of Entity + +(ie: individual, corporation, + +partnership, etc.) + +Individual + +California Corp. + +(Please use additional sheets if additional space is required) + +LLC is managed by: + +If LLC is managed by Name of Manageffs) + +Officer(s) + +0 Manager(s) ember(s) + +Manager(s)/Officer(s) + +Intairaditt + +(ie: individual, corporation, + +partnership, etc.) + +(Please use additional sheets if additional space is required) + +Can the managers, members or officers of this LLC act independently? + +Citizenship Verification + +Y + +YI:1 + +Officer(s) + +NE + +tin + +U.S. Citizenship Verification + +The undersigned certifies that the Applicant is a citizen of the United States since, to the best knowledge and belief of the undersigned, at least 2/3rds of the managers, officers or managing members qualify as citizens of the United States as defined in 49 U.S.C. 40101(aXI5) and at least 75% of the voting interest or units is owned or controlled by persons who qualify as citizens of the United States as defined in 49 U.S.C. 40102(aXI5). + +49U.S.C. Section (aXI5): Citizen of the United States means: (I) An individual who is a citizen of the United States or one of its possessions; or (2) A partnership of which each member is such an individual; or (3) A corporation or association created or organized under the laws of the United States or of any State, Territory, or possession of the United States, of which the president and 2/3 or more of the board of directors and other managing officers thereof are such individuals and in which at least 75% of the voting interest is owned or + +controlled by persons who are citizens of the United States or of one of its possessions. + +If any member, officer or manager of the LLC is not a citizen of the United States as defined in U.S.C. + +40102(aXI5) please attach an additional sheet for explanation to substantiate that the LLC qualifies as a citizen + +of the United States. + +RV COW, FMnevral- (title) Dated. 5 -(2-a• I + +IN WITNESS WHEREOF, Seller has caused this Warranty Bill of Sale to be + +executed by its duly authorized representative, this T'day of 01, 2021. + +HYPERION AIR, LLC + +!Dig by LARRY VISOSKI + +By: + +Name: Lawrence Visoski + +Title: Manager + +Date: + +.DEPA - Vv.! Al 01 Rf'fnbf + +Suggested Format for Affidavit for Exemption of Aircraft Sold for Removal from the State of Florida by a Nonresident Purchaser + +GT-500002 + +The following is a suggested format of an affidavit to be completed by the purchaser and furnished to the selling dealer. In order to satisfy the requirements for exemption, the affidavit must contain all of this + +information and be completed in full. + +Florida Broward STATE OF COUNTY OF + +N. 05/02 + +\*\*\* READ CAREFULLY BEFORE SIGNING ' + +Before me this day appeared the affiant named below, who being duly sworn, states that: + +1. I have read Rule 12A-1.007(10), Florida Administrative Code, and § 212.05, Florida Statutes; and + +2. I am not a resident of the State of Florida and did not make my permanent place of abode in Florida at the + +time of taking delivery of the aircraft described below; and + +3. I am not engaged in Florida in any employment, trade, business, or profession for which the described aircraft + +will be used in Florida; and + +4. I do not represent a corporation which has any officer or director who is a resident of Florida, or makes his + +or her permanent place of abode in Florida; and + +5. I do not represent an artificial entity other than a corporation which has any individual vested with authority to participate in the management, direction, or control of the affairs of the entity who is a resident of Florida or + +makes his or her permanent place of abode in Florida; and + +6. I agree to furnish the Florida Department of Revenue (within 30 days of the date of departure) written proof + +that this aircraft was licensed, titled, or registered outside Florida; and + +7. I agree to furnish the Florida Department of Revenue (within 10 days of the date of departure) invoices for fuel, tie-down or hangar charges, repairs, or other similar documentation issued by an out-of-state vendor or + +supplier which identifies this aircraft and its timely removal (including the FAA registration number). + +PLEASE TYPE OR PRINT THE FOLLOWING INFORMATION: + +Industrial Integrity Solutions, LLC + +Name of purchaser SSN + +If purchaser is a corporation or partnership, list officers or partners + +Purchaser's permanent address (Street) + +(City) (State/Country) (ZIP) + +Purchaser's daytime telephone number ( ) D.O.B. + +Purchaser's driver's license number and state of issuance + +Purchaser's passport or visa number + +Name of selling dealer or broker Address of selling dealer (Street) + +(City) (State/Country) (ZIP) + +Selling dealer or broker's Florida certificate of registration number + +Selling dealer or broker's telephone number ( + +Date of sale (Month) MAY (Day) 1 (Year) 2021 + +N/A + +Description of Aircraft + +Make + +Serial number 760750 FAA registration number N722JE + +(Check one) New 0 Used ill) + +Purchase Net purchase price \$ 1 .800.000.00 Trade-in \$ price \$ + +Primary location of aircraft while in Florida KFXE AIRPORT + +SIKORSKY Model S76C++ Year 2008 + +I claim exemption from Florida sales and use tax on the purchase price of the aircraft described herein under + +s. 212.05(1)(a)2, Florida Statutes. for the following reason (check one): + +U The aircraft will be removed from Florida within 10 days of the date of purchase. + +(21 The aircraft requires repairs, additions, or alterations and it will immediately be taken to a repair facility and will be removed from Florida within 20 days (excluding tolled days) after completion of the work. + +Under penalty of perjury, I declare that I have read the foregoing and the facts alleged are true to the best of my knowledge and belief. I understand that if I fail to comply with the requirements of this affidavit, I will be liable for + +payment of the tax and a mandatory penalty equal to the tax. + +Sworn to (or affirmed) and subscribed before me this day of + +Signature of Notary + +Print, type, or stamp name of Notary + +Personally known U Produced identification Type of Identification: + +Sii> laure i' of affiant/purchaser + +Distribution of Do• monts + +69 (mil' rek cec + +The original affidavit and a copy of the sales invoice, bill of sale, or closin ocument must be sent to the Florida + +Department of Revenue. Aircraft Enforcement Unit, P.O. Box 6417, Tallahass FL 32314-6417 within five (5) days of the + +date of sale. + +A copy of the affidavit must be retained by the selling dealer and made a part of the de + +The selling dealer or broker should provide the purchaser with a copy. + +Notice To Dealers + +s records. + +Affidavits not filed within five (5) days of the date of sale may not be accepted by the Department o evenue and + +the selling dealer or broker may be billed for tax, penalty, and interest due. + +DELIVERY RECEIPT + +2008KEYSTONE (SIKORSKY) S-76Ot-f HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JE + +Pursuant to provisions of that certain Aircraft Purchase Agreement dated April 11,9,2021 (the + +"Agreement") by and between HYPERION AIR, LLC, aU.S. Virgin Islands limited liability company ("Seller"), and INDUSTRIAL INTEGRITY SOLUTIONS, LLC, aNew Mexico limited liability company ("Purchaser"), Purchaser hereby acknowledges the delivery and acceptance of one used 2008 Keystone (Sikorsky) model S-76C-H- helicopter, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration (the "FAA") as N722JE, together with said aircraft's two (2) Turbomeca S.A. model Arriel 2S2 engines bearing Manufacturer's Serial Nos. 42285TE and 42286TEC, and with all avionics, equipment systems, furnishings and accessories installed on, contained in or attached to said aircraft and engines, all as is more particularly described on Exhibit A, and also including all airframe, engine and accessory logbooks, flight and operation manuals, maintenance and overhaul records, and all other records and paperwork relating to the above-described aircraft and engines in Seller's possession (collectively, the + +"Aircraft"). + +(Or + +Purchaser accepts the Aircraft at I • + +ArA + +Pa., on Int.. i3,2021in an "As + +Is, Where Is" condition and "With all Faults" at FortLauderdale Executive airport KFXE , Florida and + +subject to the waivers and disclaimers set forth in the Agreement. + +TOTAL TIME ON AIRFRAME AT DELIVERY: 2641.9 hours + +TOTAL TIME ON ENGINES AT DELIVERythal + +Engine No. 1 (MSN 42285TEC): 2641.9 Cycle N1.3652 6 / N2.3188 2hours/cycles Engine No. 2 (MSN 42286TEC): 2641.9 Cycles N I 4879 7 N2.3197 4 hours/cycles + +TOTAL LANDINGS AT DELIVERY: 5472 + +INDUSTRIAL INTE TIONS, LLC + +By: + +Name: ecia.4.5 MP. ar4412" ) + +Title: eco + +Date: 5-i 3- Z. 1 + +EFFECT OF REGISTRATION Title 49 U. S. C. 44103(cK2) provides \*A certificate of registrabon issued under this isogon is not ew0ence of ownership of aircraft in a proceeding in which ownership is or may be in Issue? THIS CERTIFICATE MUST BE SIGNED AND RETURNED BY THE REGISTERED OWNER WITHIN 21 DAYS WHEN IT IS NO LONGER IN EFFECT FOR ANY REASON UNDER 14 C.F.R. 47.41(aX1) through (7). Registration is canceled HIM request of the owner for one of the following reasons (Must check and/or compete Blocs a b c. d of e). + +a. O The aircraft is totally destroyed or scrapped. + +b. O United States citizenship has been lost. or the owners status as a resident alien has changed + +(unless changed to Mat ci a U.S. Man). + +c ❑ Thirty days have elapsed VACS the death of the registered owner (estate representative should sign) + +d. The aircraft is to be registered under the laws of a foreign country + +(NAME OF FOREIGN COUNTRY) + +(SIGNATURE) + +e. O The ownership of the aircraft is transferred to + +(NAME) + +(ADDRESS) + +(CITY. STATE. ZIP) + +(TITLE) (DATE) + +This certificate must be returned to NRORAFT REGISTRATION BRANCH. P.O. BOX 25504. OKLAHOMA CITY. OKLAHOMA 73125-0504 RETAIN THIS INFORMATION FOR FUTURE REFERENCE CHANGE OF ADDRESS + +Federal AyillbOn Regulations require that the registered owner of the aircraft shall report in writing within 30 day\* any change in permanent mailing address. A revised Certificate of Registration will be issued without charge. The APoicaten for Registration AC Form 8050-1 may + +be used to report a change of address. + +REPLACEMENT OF CERTIFICATE + +If this certificate is lost destroyed or mutilated, a replacement may be obtained al the written request of the NOlder. Send your request and 32.00 replacement fee (check or money order made payable to tbe + +Federal Aviation Administration) to + +Aircraft Registration Branch P O 8ox 25504 Oklahoma City. Oidahorne 73125-0504 + +NOTE Al correspondence should include the registration NiNumber. manufacturer, model and serial number of the aircraft To offer your feedback regarding the aircraft registration profess. please visit our websse at http /'registry faa govarcert/ + +SIKORSKY COMMERCIAL INC\* + +USA + +Invoice Number: 8117788 Invoice Date: February 04, 2021 + +Customer No. 301290 + +Sales Order Sales Order Date Customer Contract or P/O No. + +22278585 February 04, 2021 S76D12297PAP + +Remit To: SIKORSKY COMMERCIAL INC + +LOCKHEED MARTIN CORPORATION + +EFT/ACH/WIRE + +Ultimate End User: HYPERION AIR, LLC + +USA + +Ship Tu; HYPERION AIR. LLC payment alit HYPERION AIR. LLC + +Be made by: + +Amer.Virgin Is. + +Terms: Net 30 days + +Shipped from: • on: Via: CAU Bill of Lading: ITA:,eller. place + +AMER.VIRGIN IS. + +Airway Bill Number: + +Items Stock/Parts Description Condition 76C\_MAIN\_GEAR\_BOX 76C\_Main + +\_Gear Box + +Ct SN 760750 + +- + +r t. Date: December 31, 2020 + +76C\_INTER\_GEAR\_BOX 76C\_Inte + +r Gear Box + +AIRCRAFT SN 760750 + +Reporting Date: December 31. 2020 + +76C\_TAIL\_GEAR\_DOX 76C\_Tail + +Gear Box + +AIRCRAFT SN 760750 + +Reporting Date: December 31, 2020 + +sgi mitit t• Init UnitPrice0USDI NetAmountalSDI 8.30 EA 137.49 1,141.17 + +8.30 EA 9.24 76.69 + +8.30 EA 18.48 153.38 + +SUBTOTAL: 1,371.24 TAXES: 0.00 NET TOTAL: 1,371.24 TOTAL AMOUNT DUE: 1,371.24 + +'Sikorsky Commercial. Inc. is a registered trade name of Helicopter suppon. inc. (also referred to as "t St") in the Connecticut 'ovens of Shelton. North Haven. Stratford + +3. This Amendment may be fully executed in separate counterparts by each of the + +parties hereto. Any signatures on this Amendment may be transmitted via facsimile or e-mail (in + +pdf format), which signatures shall be deemed originals for all purposes. + +IN WITNESS WHEREOF, the parties hereto have executed this FIRST + +AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT as of the day and year first + +written above. + +Seller: + +Hyperion Air, LLC + +By: XILAM/.4.A... Print: Darren Indyke + +Title: Authorized Representative + +Purchaser: + +Industrial Integrity Solutions, LLC + +By: + +Print: Rick Munkvold + +Title: Chief Financial Officer + +3. This Amendment may be fully executed in separate counterparts by each of the + +parties hereto. Any signatures on this Amendment may be transmitted via facsimile or e-mail (in + +pdf format), which signatures shall be deemed originals for all purposes. + +IN WITNESS WHEREOF, the parties hereto have executed this FIRST + +AMENDMENT TO AIRCRAFT PURCHASE AGREEMENT as of the day and year first + +written above. + +Seller: + +Hyperion Air, LLC + +By: XILAM/.4.A... Print: Darren Indyke + +Title: Authorized Representative + +Purchaser: + +Industrial Integrity Solutions, LLC + +By: + +Print: Rick Munkvold + +Title: Chief Financial Officer + +ESIGN DISCLOSURES AND CONSENT + +It is required by law to provide you with certain disclosures and information about the products, services or accounts you may receive or access in connection with your relationship with us ('Required Information'). With your consent, we can deliver Required Information to you by a) displaying or delivering the Required Information electronically; and b) requesting + +that you print or download the Required Information and retain it for your records. + +This notice contains important information that you are entitled to receive before you consent to electronic delivery of Required Information. Your consent also permits the general use of electronic records and electronic signatures in connection with the Required + +Information. + +After you have read this information, if you agree to receive Required Information from us electronically, and if you agree to the general use of electronic records and electronic signatures in connection with our relationship, please click the 'ACCEPT' button. + +Statement of electronic disclosures: + +You may request to receive Required Information on paper, but if you do not consent to electronic delivery of Required Information, we cannot proceed with the acceptance and processing to create a relationship with you in connection to the products, + +services or account. + +If you consent to electronic delivery of Required Information, you may withdraw that consent at any time. However, if you withdraw your consent we will not be able to continue processing to create a relationship with you in connection to the products, + +services or account. + +If you consent to electronic disclosures, that consent applies to all Required Information we give you or receive from you in connection with our relationship and the associated + +notices, disclosures, and other documents. + +You agree to print out or download Required Information when we advise you to do so and keep it for your records. If you are unable to print or download any Required Information, you may call us and request paper copies. If you need to update your e-mail address or other contact information with us, you may do so by calling us and + +requesting the necessary updates. + +If you wish to withdraw your consent to electronic disclosures, you may do so by calling us and requesting withdrawal of consent. After consenting to receive and deliver Required Information electronically, you may request a paper copy of the Required + +Information by calling us. + +If you do not have the required software and/or hardware, or if you do not wish to use electronic records and signatures for any other reason, you can request paper copies of the + +Required Information to be sent to you by calling us. + +Your consent does not mean that we must provide the Required Information electronically. We may, at our option, deliver Required Information on paper. We may also require that + +certain communications from you be delivered to us on paper at a specified address. + +I have read the information about the use of electronic records, disclosures, notices, and e-mail, and consent to the use of electronic records for the delivery of Required Information in connection with our relationship. I have been able to view this information using my computer and software. I have an account with an internet service provider, and I am able to send e-mail and receive e-mail with hyperlinks to websites and attached files. I also consent to the use of electronic records and electronic signatures in place of written + +documents and handwritten signatures. + +ESIGN DISCLOSURES AND CONSENT + +It is required by law to provide you with certain disclosures and information about the products, services or accounts you may receive or access in connection with your relationship with us ('Required Information'). With your consent, we can deliver Required Information to you by a) displaying or delivering the Required Information electronically; and b) requesting + +that you print or download the Required Information and retain it for your records. + +This notice contains important information that you are entitled to receive before you consent to electronic delivery of Required Information. Your consent also permits the general use of electronic records and electronic signatures in connection with the Required + +Information. + +After you have read this information, if you agree to receive Required Information from us electronically, and if you agree to the general use of electronic records and electronic signatures in connection with our relationship, please click the 'ACCEPT' button. + +Statement of electronic disclosures: + +You may request to receive Required Information on paper, but if you do not consent to electronic delivery of Required Information, we cannot proceed with the acceptance and processing to create a relationship with you in connection to the products, + +services or account. + +If you consent to electronic delivery of Required Information, you may withdraw that consent at any time. However, if you withdraw your consent we will not be able to continue processing to create a relationship with you in connection to the products, + +services or account. + +If you consent to electronic disclosures, that consent applies to all Required Information we give you or receive from you in connection with our relationship and the associated + +notices, disclosures, and other documents. + +You agree to print out or download Required Information when we advise you to do so and keep it for your records. If you are unable to print or download any Required Information, you may call us and request paper copies. If you need to update your e-mail address or other contact information with us, you may do so by calling us and + +requesting the necessary updates. + +If you wish to withdraw your consent to electronic disclosures, you may do so by calling us and requesting withdrawal of consent. After consenting to receive and deliver Required Information electronically, you may request a paper copy of the Required + +Information by calling us. + +If you do not have the required software and/or hardware, or if you do not wish to use electronic records and signatures for any other reason, you can request paper copies of the + +Required Information to be sent to you by calling us. + +Your consent does not mean that we must provide the Required Information electronically. We may, at our option, deliver Required Information on paper. We may also require that + +certain communications from you be delivered to us on paper at a specified address. + +I have read the information about the use of electronic records, disclosures, notices, and e-mail, and consent to the use of electronic records for the delivery of Required Information in connection with our relationship. I have been able to view this information using my computer and software. I have an account with an internet service provider, and I am able to send e-mail and receive e-mail with hyperlinks to websites and attached files. I also consent to the use of electronic records and electronic signatures in place of written + +documents and handwritten signatures. + +WIRE INSTRUCTIONS (TOTAL BUSINESS CHECKING) + +E UUS GLOBAL AVIATION, LLC + +P MORGAN CHASE + +WIRE ACCOUNT #: + +ROUTING#: SWIFT CODE: + +OneSpan Sign Electronic Evidence Summary + +Signing Ceremony ID: + +ID: Name: Created: Completed: + +Summary document generated: + +Sender: Name: + +Documents: + +Electronic Disclosures and Signatures Consent + +N722JE N722JE BOS (FInWSCn) + +N722JE WBOS + +OneSpan Sign Electronic Evidence Summary + +Recipients: Name: Email: Role: ID: Name: Email: Role: ID: + +Electronic Disclosures and Signatures Consent + +N722JE N722JE BOS (FInWSCn) + +N722JE WBOS + +Name: Email: Role: ID: + +Audit Trail: + +fcb4Y4hMWofiPY2i5Tjg62n-P38= N722JE N722JE BOS (FInWSCn) 2021-May-0617:14:44 (GMTZ) GMT 2021-May-06 19:51:34 (GMTZ) GMT 2021-May-06 19:51:36 (GMTZ) GMT + +Melissa Koboldt + +2 pages 1 page 2 pages 2 pages + +Melissa Koboldt + +Owner + +42EC2utgPCID LARRY VISOSKI + +Larry\_Visoski Larry\_Visoski 1 accept 1 signature 1 signature + +DARREN INDYKE + +Darren\_Indyke\_FcipTcON Darren\_Indyke\_FqpRON + +2021-May-06 17:40:01 (GMTZ) GMT LARRY VISOSKI Signing Session + +For Recipient + +N/A 174.194.139.168 Signing session + +for recipient: + +LARRY VISOSKI) + +2021-May-06 17:40:11 (GMTZ) GMT LARRY VISOSKI View Electronic + +Disclosures and Signatures Consent + +174.194.139.168 + +2021-May.06 17:42:36 (GMTZ) GMT LARRY VISOSKI Accept Electronic + +Disclosures and Signatures Consent + +174.194.139.168 Approval: + +8e8k72a-d851- 47ec-bf2af81d7ac10f67 + +2021-May-06 17:42:37 (GMTZ) GMT LARRY VISOSKI Confirm Electronic + +Disclosures and Signatures Consent + +174.194.139.168 + +2021-May-0617:42:47(GMTZ)GMT LARRY VISOSKI View N722JEN722JE + +BOS (FInWSCn) + +174.194.139.168 + +2021-May-0617:44:04 (GMTZ) GMT LARRY VISOSKI Click To Sign N722JE N722JE + +BOS (FInWSCn) + +174.194.139.168 Approval: + +XiW1KrixDUP8U + +2021-May-06 19:47:50 (GMTZ) GMT LARRY VISOSKI Signing Session + +For Recipient + +N/A 174.195.144.56 Signing session + +for recipient: + +LARRY VISOSKI) + +2021-May.06 19:47:53 (GMTZ) GMT LARRY VISOSKI View N722JEN722JE + +BOS (FInWSCn) + +174.195.144.56 + +2021-May-06 19:50:49 (GMTZ) GMT LARRY VISOSKI Signing Session + +For Recipient + +N/A 64.183.118.170 Signing session + +for recipient: + +LARRY VISOSKI) + +2021-May-06 19:50:55 (GMTZ) GMT LARRY VISOSKI View N722JEN722JE + +BOS (FInWSCn) + +64.183.118.170 + +2021-May-06 19:51:17 (GMTZ) GMT LARRY VISOSKI Confirm N722JE N722JE + +BOS (FInWSCn) + +64.183.118.170 + +2021-May-0619:51:22 (GMTZ) GMT LARRY VISOSKI View N722JE WOOS 64.183.118.170 + +2021-May-0619:51:30 (GMTZ) GMT LARRY VISOSKI Click To Sign N722JE WBOS 64.183.118.170 Approval: + +vDOPyjwicisUO + +2021-May-0619:51:34 (GMTZ) GMT LARRY VISOSKI Confirm N722JE WOOS 64.183.118.170 + +EXHIBIT C + +TO + +AIRCRAFT PURCHASE AGREEMENT + +BY AND BETWEEN HYPERION AIR, LW AND INDUSTRIAL INTEGRITY SOLUTIONS, LLC + +Certificate of Technical Accentance + +2008 KEYSTONE (SIKORSKY) S-76014 HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JE + +Reference is made to the provisions of Sections 3(f) and (h) of the Aircraft Purchase + +Agreement dated April /4,, 2021 (the "Agreement") by and between HYPERION AIR, LLC, a U.S. Virgin Islands limited liability company ("Seller"), and INDUSTRIAL INTEGRITY SOLUTIONS, LLC, a New Mexico limited liability company ("Purchaser"), relating to the purchase and sale of one used 2008 Keystone (Sikorsky) model S-76C++ helicopter, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration (the "FAA') as N722JE, together with said aircraft's two (2) Turbomeca S.A. model Arriel 2S2 engines bearing Manufacturer's Serial Nos. 42285TE and 42286TEC, and with all avionics, equipment systems, furnishings and accessories installed on, contained in or attached to said aircraft and engines, all as is more particularly described on Exhibit A, and also including all airframe, engine and accessory logbooks, flight and operation manuals, maintenance and overhaul records, and all other records and paperwork relating to the above-described aircraft and engines in Seller's possession (collectively, the "Aircraft"). Capitalized terms used but not otherwise defined in this Certificate shall have the meanings + +ascribed to such terms in the Agreement. This is to Certify as follows: + +Unconditional Acceptance: + +Purchaser hereby certifies that Purchaser has completed its Pre-Purchase Inspection of the + +Aircraft in accordance with the provisions of the Agreement on the date written below, and Purchaser has Technically Accepted the Aircraft in its "as is", "where-is" and "with all faults" condition. The Deposit has become non-refundable and may be disbursed only as and when provided in the Agreement. This confirmation constitutes Purchaser's Unconditional Acceptance as provided in + +Sections 3(f) and (h) of the Agreement; + +Dated: + +INDUSTRIAL INTEG LUTIONS, LLC + +B + +Name: tomee insaglielea + +Title: ea + +EXHIBIT C + +TO + +AIRCRAFT PURCHASE AGREEMENT + +BY AND BETWEEN HYPERION AIR, LW AND INDUSTRIAL INTEGRITY SOLUTIONS, LLC + +Certificate of Technical Accentance + +2008 KEYSTONE (SIKORSKY) S-76014 HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JE + +Reference is made to the provisions of Sections 3(f) and (h) of the Aircraft Purchase + +Agreement dated April /4,, 2021 (the "Agreement") by and between HYPERION AIR, LLC, a U.S. Virgin Islands limited liability company ("Seller"), and INDUSTRIAL INTEGRITY SOLUTIONS, LLC, a New Mexico limited liability company ("Purchaser"), relating to the purchase and sale of one used 2008 Keystone (Sikorsky) model S-76C++ helicopter, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration (the "FAA') as N722JE, together with said aircraft's two (2) Turbomeca S.A. model Arriel 2S2 engines bearing Manufacturer's Serial Nos. 42285TE and 42286TEC, and with all avionics, equipment systems, furnishings and accessories installed on, contained in or attached to said aircraft and engines, all as is more particularly described on Exhibit A, and also including all airframe, engine and accessory logbooks, flight and operation manuals, maintenance and overhaul records, and all other records and paperwork relating to the above-described aircraft and engines in Seller's possession (collectively, the "Aircraft"). Capitalized terms used but not otherwise defined in this Certificate shall have the meanings + +ascribed to such terms in the Agreement. This is to Certify as follows: + +Unconditional Acceptance: + +Purchaser hereby certifies that Purchaser has completed its Pre-Purchase Inspection of the + +Aircraft in accordance with the provisions of the Agreement on the date written below, and Purchaser has Technically Accepted the Aircraft in its "as is", "where-is" and "with all faults" condition. The Deposit has become non-refundable and may be disbursed only as and when provided in the Agreement. This confirmation constitutes Purchaser's Unconditional Acceptance as provided in + +Sections 3(f) and (h) of the Agreement; + +Dated: + +INDUSTRIAL INTEG LUTIONS, LLC + +B + +Name: tomee insaglielea + +Title: ea + +EXHIBIT C + +TO + +AIRCRAFT PURCHASE AGREEMENT + +BY AND BETWEEN HYPERION AIR, LW AND INDUSTRIAL INTEGRITY SOLUTIONS, LLC + +Certificate of Technical Accentance + +2008 KEYSTONE (SIKORSKY) S-76014 HELICOPTER + +Manufacturer's Serial No. 760750 U.S. Registration No. N722JE + +Reference is made to the provisions of Sections 3(f) and (h) of the Aircraft Purchase + +Agreement dated April /4,, 2021 (the "Agreement") by and between HYPERION AIR, LLC, a U.S. Virgin Islands limited liability company ("Seller"), and INDUSTRIAL INTEGRITY SOLUTIONS, LLC, a New Mexico limited liability company ("Purchaser"), relating to the purchase and sale of one used 2008 Keystone (Sikorsky) model S-76C++ helicopter, bearing manufacturer's serial number 760750, and currently registered with the United States Federal Aviation Administration (the "FAA') as N722JE, together with said aircraft's two (2) Turbomeca S.A. model Arriel 2S2 engines bearing Manufacturer's Serial Nos. 42285TE and 42286TEC, and with all avionics, equipment systems, furnishings and accessories installed on, contained in or attached to said aircraft and engines, all as is more particularly described on Exhibit A, and also including all airframe, engine and accessory logbooks, flight and operation manuals, maintenance and overhaul records, and all other records and paperwork relating to the above-described aircraft and engines in Seller's possession (collectively, the "Aircraft"). Capitalized terms used but not otherwise defined in this Certificate shall have the meanings + +ascribed to such terms in the Agreement. This is to Certify as follows: + +Unconditional Acceptance: + +Purchaser hereby certifies that Purchaser has completed its Pre-Purchase Inspection of the + +Aircraft in accordance with the provisions of the Agreement on the date written below, and Purchaser has Technically Accepted the Aircraft in its "as is", "where-is" and "with all faults" condition. The Deposit has become non-refundable and may be disbursed only as and when provided in the Agreement. This confirmation constitutes Purchaser's Unconditional Acceptance as provided in + +Sections 3(f) and (h) of the Agreement; + +Dated: + +INDUSTRIAL INTEG LUTIONS, LLC + +B + +Name: tomee insaglielea + +Title: ea + +tYr.PARTMENT Of RIVENUf + +Suggested Format for Affidavit for Exemption of Aircraft Sold for Removal from the State of Florida by a Nonresident Purchaser + +GT500002 + +The following is a suggested format of an affidavit to be completed by the purchaser and furnished to the selling dealer. In order to satisfy the requirements for exemption, the affidavit must contain all of this + +information and be completed in full. + +Florida + +STATE OF COUNTY OF Broward + +\*\*\* READ CAREFULLY BEFORE SIGNING + +Before me this day appeared the affiant named below, who being duly sworn, states that: + +1. I have read Rule 12A-1.007(10), Florida Administrative Code, and § 212.05, Florida Statutes; and + +2. I am not a resident of the State of Florida and did not make my permanent place of abode in Florida at the + +time of taking delivery of the aircraft described below; and + +-3. I am not engaged in Florida in any employment, trade, business, or profession for which the described aircraft + +will be used in Florida; and + +4. I do not represent a corporation which has any officer or director who is a resident of Florida, or makes his + +or her permanent place of abode in Florida; and + +5. I do not represent an artificial entity other than a corporation which has any individual vested with authority to participate in the management, direction, or control of the affairs of the entity who is a resident of Florida or + +makes his or her permanent place of abode in Florida; and + +6. I agree to furnish the Florida Department of Revenue (within 30 days of the date of departure) written proof + +that this aircraft was licensed, titled, or registered outside Florida; and + +7. I agree to furnish the Florida Department of Revenue (within 10 days of the date of departure) invoices for fuel, tie-down or hangar charges, repairs, or other similar documentation issued by an out-of-state vendor or + +supplier which identifies this aircraft and its timely removal (including the FAA registration number). + +N. 05/02 + +Name of purchaser + +PLEASE TYPE OR PRINT THE FOLLOWING INFORMATION: Industrial Integrity Solutions, LLC SSN + +\*\*\* + +If purchaser is a corporation or partnership, list officers or partners + +T.I.N. + +Purchaserssint address (Street) + +(City) (State/Country) U (ZIP) + +Purchaser's daytime telephone number (W ) D.O.B. + +Purchaser's driver's license number and state of issuance + +Purchaser's passport or visa number + +Name of selling dealer or broker Address of selling dealer (Street) + +(City) (State/Country) (ZIP) + +Selling dealer or broker's Florida certificate of registration number + +Selling dealer or brokers telephone number ( + +Date of sale (Month) MAY (Day) (Year) 2021 + +N/A + +SIKORSKY S76C++ Make Model Year 2008 + +Serial number 760750 FAA registration number N722JE + +(Check one) New C:l Used 51 + +Purchase Net purchase price S 1,800,000.00 Trade-in \$ price \$ + +Primary location of aircraft while in Florida KFXE AIRPORT + +I claim exemption from Florida sales and use tax on the purchase price of the aircraft described herein under + +s. 212.05(1)(a)2, Florida Statutes, for the following reason (check one): + +O The aircraft will be removed from Florida within 10 days of the date of purchase. + +i The aircraft requires repairs, additions, or alterations and it will immediately be taken to a repair facility and will be removed from Florida within 20 days (excluding tolled days) after completion of the work. + +Under penalty of perjury, I declare that I have read the foregoing and the facts alleged are true to the best of my knowledge and belief. I understand that if I fail to comply with the requirements of this affidavit, I will be liable for + +payment of the tax and a mandatory penalty equal to the tax. + +Signature of affiant/purchaser + +Sworn to (or affirmed) and subscribed before me this day of + +Signature of Notary + +Print, type, or stamp name of Notary + +O Personally known O Produced identification Type of Identification: + +Distribution of Documents + +The original affidavit and a copy of the sales invoice, bill of sale, or closing document must be sent to the Florida + +Department of Revenue, Aircraft Enforcement Unit, P.O. Box 6417, Tallahassee FL 32314-6417 within five (5) days of the + +date of sale. + +A copy of the affidavit must be retained by the selling dealer and made a part of the dealer's records. + +The selling dealer or broker should provide the purchaser with a copy. + +Notice To Dealers + +Si. + +BANYAN WE THANK YOU FOR YOUR BUSINESS! IT HAS BEEN A PLEASURE TO SERVE YOU. + +> 34211 I HYPERION AIR + +L L T VIRGIN ISLANDS OF THE USA + +O + +BANYAN AIR SERVICES, INC. ACCOUNT SUMMARY + +PAGE NUMBER + +DATE + +05/06/21 19:05 + +Department Date I Invoice # I Aircraft I Document I Reference I Invoice Amount I Amount Paid I Balance Due 21 - FXE NORTH SIDE 3/01/21 1872671 N722JE 572704 LT 572704 2,675.00 .0D 2,675.00 21 - FXE NORTH SIDE 4/01/21 1879381 N722JE S76361 LT 576361 2,675.00 .03 2,675.00 21 - FXE NORTH SIDE 5/01/21 1886068 N722JE 579934 LT 579934 2,675.00 .0D 2,675.00 21 - FXE NORTH SIDE 5/06/21 1887298 N722JE 580645 LT 580645 2,675.00CR .03 2,675.00CR 20 - CUSTOMER SUPPORT 5/06/21 1887299 N722JE 580646 LT 580646 1,551.50 .03 1,551.50 21 - FXE NORTH SIDE 5/06/21 1887302 N722JE 580003 LT 580003 75.00 .00 75.00 + +Total: 6,976.50 + +Mail To: 5360 NW 20th Terrace • Ship To: 5323 NV,' 23th Terrace • Fort Lc:Joey:ale Execcit ve Airport • Florida 33309 • 954 4913 • 954 C281 • 'my, banyartar coo, + +8 34211 I D L L T VIRGIN ISLANDS OF THE USA + +0 + +8 34211 + +H X P T VIRGIN ISLANDS OF THE USA + +0 + +\*ilk + +BANYAN AIR SERVICES, INC. LINE SERVICE INVOICE + +BANIAIN + +EXE NORTH SIDE + +LINE TICKET: 021/576361 + +PAGE NUMBER 3. DOCUMENT NUMBER 1879381 DATE 4/01/21 + +Registration : N722JE Make : S76 Model : S-76 Serial Number : TBD Flight Recorder: .00 F.R. Changed : .00 FDESK3 + +A/C Total Time : .00 + +TERMS REF. NUMBER SHIP VIA ORDER NO. ORDERED REQUESTED SHIPPED CUSTOMER REPRESENTATIVE :MD 576361 4/01/21 4 C1/21 CS:OMER. SUPPORT' + +ITEM NUMBER ITEM DESCRIPTION ITEM REFERENCE + +B. O. TA x + +QTY PER PRKE + +PER DATE ISSUED QUANTITY PRICE UOM EXTENDED + +lonthly Charges For The Period: 04/01/21 to 04/30/21 + +HANGAR HANGAR-MONTHLY N722JE + +Amount Subject To Sales Tax 2,500.00 FLORIDA: 7.06 + +:uStOmer'S Account - 52675.00 Invoice billed to Customer's Account. Vote for Banyan in 2021 PRASE Survey! Thank you for your support. + +1 .117.C + +.:011 1.00 2,500.000 + +State Sales + +EACH Subtotal: Tax: Total: + +2,500.00 2,500.00 175.00 2,675.00 + +Mail To: 5360 NW 20m + +Terrace • Ship To: 5320 NW 20n + +Terrace • Ft. Lauderdale Executive Airport • Florida 33309 • 954.491.3170 p • 954.771.0281 f • ithvw.banyanair.com + +B 34211 I t,L L T VIRGIN ISLANDS OF THE USA + +0 + +8 34211 8 P I P T VIRGIN ISLANDS OF THE USA + +0 + +\*ilk + +BANYAN AIR SERVICES, INC. + +SERVICE INVOICE + +• + +LINE + +BAINIAIN + +FXE NORTH SIDE + +LINE TICKET: 021/572704 + +PAGE NUMBER 1 DOCUMENT NUMBER 1872671 DATE 3/01/21 + +Registration : N722JE Make : S76 Model : S-76 Serial Number : TBD Flight Recorder: .00 F.R. Changed : .00 FDESK3 + +A/C Total Time : .00 + +TERMS REF. NUMBER SHIP VIA ORDER NO. ORDERED REQUESTED SHIPPED CUSTOMER REPRESENTATIVE TOD 572704 3/07.121 3, C1/21 CTSTOREP. SUPPORT + +ITEM NUMBER ITEM DESCRIPTION ITEM REFERENCE B. O. TA x QTY PER PRKE + +PER DATE ISSUED QUANTITY PRICE UOM EXTENDED + +lonthly Charges For The Period: 03/01/21 to 03/31/21 + +HANGAR HANGAR-MONTHLY N722JE + +Amount Subject To Sales Tax 2,500.00 FLORIDA: 7.06 + +:uStOmer'S ACCOunt - 52675.00 Invoice billed to Customer's Account. Vote for Banyan in 2021 PRASE Survey! Thank you for your support. + +1 3/Ol'TCT: 1.00 2,500.030 + +State Sales + +EACH Subtotal: Tax: Total: + +2,500.00 2,500.00 175.00 2,675.00 + +Mail To: 5360 NW 20m + +Terrace • Ship To: 5320 NW 20'n + +Terrace • Ft Lauderdale Executive Airport • Florida 33309 • 954.491.3170 p • 954.771.0281 f • Ithvw.banyanair.com + +From: Darzhane Gresham < + +Sent: Thursday, May 13, 2021 9:54 AM + +To: Melissa Koboldt + +Subject: N722JE + +Amount Account + +Bank Reference Customer Reference + +Text + +50.000 00 USD + +0513236386 + +> on behalf of Darzhane Gresham + +From: Abby Jones <-> on behalf of Abby Jones + +Sent: Wednesday, August 4, 2021 11:57 AM + +To: Melissa Koboldt + +Subject: Scans + +Attachments: N4848L Temp Registration.pdf; N707GY Registration.pdf; N460CM Registration.pdf; + +N345RP Registration.pdf; N731AT Registration.pdf; N315TA Registration.pdt N722JE + +Registration.pdf; N3165T Registration.pdf; N56JP Registration.pdf; N2590U Registration.pdf; N98FP Registration.pdf; N215RP Registration.pdf; N262WH + +Registration.pdf + +Abby Jones + +Receptionist + +AIC Title Service Tel: or www.aictitle.com + +Fax: + +alp + +TITLE SERVICE + +0 0 0 + +From: Darren Indyke < + +Sent: Thursday, May 6, 2021 3:47 PM + +To: Melissa Koboldt + +Cc: Darren Indyke; Richard Kahn; + +Jonathan Williams + +Subject: Re: N7221E Escrow - AIC Title Service + +I am working to get an answer for you. + +DARREN K. INDYKE + +Telephone: Telecopier: Mobile: email: + +> on behalf of Darren Indyke + +The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail, and destroy this + +communication and all copies thereof, including all attachments. + +Copyright of Darren K. Indyke - © 2019 Darren K. Indyke — All rights reserved. + +On May 6, 2021, at 4:31 PM, Melissa Koboldt > wrote: + +Darren, can you please reply? I'm trying to get this ready for closing tomorrow for another agent. Jon + +Williams is copied here and will assist in my absence. + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: Skype + +From: Melissa Koboldt [mailto + +Sent: Thursday, May 06, 2021 1:17 PM + +To: 'Darren Indyke' Cc: 'Richard Kahn' + +Fax + +Subject: RE: N722JE Escrow - AIC Title Service + + + +'Larry Visoski' <->; 'Gary Anzalone' + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Melissa Koboldt [mailto + +Sent: Thursday, May 06, 2021 12:23 PM + +To: 'Darren Indyke' Cc: 'Richard Kahn' + +Fax: + +Subject: RE: N722JE Escrow - AIC Title Service + +'Larry Visoski' < >; 'Gary Anzalone' + +You were only on copy, they were sent to Larry for his signature. + +The PUE requests for the IR will be going out this afternoon, you'll need to advise IATS (the IR + +administrator) to approve AIC's request. + +Please send me closing/disbursement instructions. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke [mailto: + +Sent: Thursday, May 06, 2021 12:18 PM + +To: Melissa Koboldt Cc: Richard Kahn + + + +; Larry Visoski <->; Gary Anzalone + +Subject: Re: N722JE Escrow - AIC Title Service + +Larry C should sign as manager. You sent the docs to me to sign? + +Sent from my iPhone. Please excuse the typos. + +On May 6, 2021, at 1:16 PM, Darren Indyke > wrote: + +What about getting Larry closing docs? Also do we need to do anything Re the intl + +registry? + +Sent from my iPhone. Please excuse the typos. + +On May 6, 2021, at 1:12 PM, Melissa Koboldt + +posted. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke [mailto: + +Sent: Wednesday, May 05, 2021 5:50 PM + +To: Melissa Koboldt + +Cc: Richard Kahn < Larry Visoski + +< I>; Gary Anzalone + +Subject: Re: N722JE Escrow - AIC Title Service + +Fax: + + + +No to change FAA but yes to change warranty bos. Please See how + +difficult Friday would be and we can decide after you let us + +know. Thanks. + +Sent from my iPhone. Please excuse the typos. + +On May 5, 2021, at 6:41 PM, Melissa Koboldt + +wrote: + +The FAA has is registered with no comma- + + + +Do you still want it added? + +Yes I can change the WBOS. + +Everyone is booked in closings, I can see if it can be squeezed in but Monday would be preferable. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke + +Visoski < >.; Gary Anzalone + +Subject: Re: N722JE Escrow - AIC Title Service + +Thank you for the docs. A couple of revisions Can you make seller Hyperion Air, LLC on FAA bos (you forgot the comma after "Air"). Can you change date to May on warranty bos. And re moving closing, is there no one in your office who can do it on Friday? Please advise. + +Thank you again. + +Sent from my iPhone. Please excuse the typos. + +On May 5, 2021, at 5:11 PM, Melissa + +Koboldt wrote: + +Hi Darren, + +Please review the FAA BOS and WBOS and advise if everything is in order and I will have them sent to Larry for digital + +signatures. + +It is my understanding closing was targeted for 5-7-2021 however I will be out of the office, do you have any issue with closing to occur on 5-10-2021? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: + + + +From: Darren Indyke < + +Sent: Thursday, May 6, 2021 3:49 PM + +To: Melissa Koboldt + +Cc: Darren Indyke; Richard Kahn; + +Jonathan Williams + +Subject: Re: N7221E Escrow - AIC Title Service + +> on behalf of Darren Indyke + +If we want to demonstrate that the delivery was done in Florida, we will need a notarized delivery receipt, I believe. + +DARREN K. INDYKE + +Telephone: Telecopier: Mobile: email: + +The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail, and destroy this + +communication and all copies thereof, including all attachments. + +Copyright of Darren K. Indyke - © 2019 Darren K. Indyke — All rights reserved. + +On May 6, 2021, at 4:47 PM, Melissa Koboldt wrote: + +Also, is it necessary for the delivery receipt to be notarized or can you accept a digital signature? + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: + +From: Melissa Koboldt [mailto: + +Sent: Thursday, May 06, 2021 3:32 PM + +To: 'Darren Indyke' Cc: 'Richard Kahn' < + +>; Jonathan Williams < + +Subject: RE: N722JE Escrow-AIC Title Service + +>; 'Larry Visoski' < >; 'Gary Anzalone' + +Darren, can you please reply? I'm trying to get this ready for closing tomorrow for another agent. Jon + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Melissa Koboldt [mailto + +Sent: Thursday, May 06, 2021 1:17 PM + +To: 'Darren Indyke' Cc: 'Richard Kahn' + +Fax: + +'Larry Visoski' <->; 'Gary Anzalone' + +Subject: RE: N722JE Escrow-AIC Title Service + +Darren, is there anything else to pay out of escrow other than the broker fee and !/: the escrow fee? + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +Fax: + +From: Melissa Koboldt [mailto: + +Sent: Thursday, May 06, 2021 12:23 PM + +To: 'Darren Indyke' + +Cc: 'Richard Kahn' < > 'Larry Visoski' < >; 'Gary Anzalone' + +Subject: RE: N722JE Escrow - AIC Title Service + +You were only on copy, they were sent to Larry for his signature. + +The PUE requests for the IR will be going out this afternoon, you'll need to advise IATS (the IR + +administrator) to approve AIC's request. + +Please send me closing/disbursement instructions. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke [math° + +Sent: Thursday, May 06, 2021 12:18 PM + +To: Melissa Koboldt + +Fax: + +Larry C should sign as manager. You sent the docs to me to sign? + +Sent from my iPhone. Please excuse the typos. + +On May 6, 2021, at 1:16 PM, Darren Indyke > wrote: + +What about getting Larry closing docs? Also do we need to do anything Re the intl + +registry? + +Sent from my iPhone. Please excuse the typos. + +On May 6, 2021, at 1:12 PM, Melissa Koboldt + +wrote: + +< + +I haven't been able to find anyone who can take it yet, will keep you + +posted. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke [mailto: + +Sent: Wednesday, May 05, 2021 5:50 PM + +To: Melissa Koboldt Cc: Richard Kahn + +a Gary Anzalone + +Subject: Re: N722JE Escrow - AIC Title Service + + + +Fax: + +; Larry Visoski + +No to change FAA but yes to change warranty bos. Please See how + +difficult Friday would be and we can decide after you let us + +know. Thanks. + +Sent from my iPhone. Please excuse the typos. + +On May 5, 2021, at 6:41 PM, Melissa Koboldt + +wrote: + +The FAA has is registered with no comma- + + + +Everyone is booked in closings, I can see if it can be squeezed in but Monday would be preferable. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke + +[mailto: + +Sent: Wednesday, May 05, 2021 5:24 PM + +To: Melissa Koboldt + +Cc: Richard Kahn Larry + +Visoski <->; Gary Anzalone + +Fax: + +Subject: Re: N722JE Escrow - AIC Title Service + +Thank you for the docs. A couple of revisions Can you make seller Hyperion Air, LLC on FAA bos (you forgot the comma after "Air"). Can you change date to May on warranty bos. And re moving closing, is there no one in your office who can do it on Friday? Please advise. + +Thank you again. + +Sent from my iPhone. Please excuse the typos. + +On May 5, 2021, at 5:11 PM, Melissa Koboldt ca . + +wrote: + +Hi Darren, + +Please review the FAA BOS and WBOS and advise if everything is in order and I will have them sent to Larry for digital + +signatures. + +It is my understanding closing was targeted for 5-7-2021 however I will be out of the office, do you have any issue with closing to occur on 5-10-2021? + + + +AIC Title Service Tel: Or + +Skype: melissa.koboldt www.aictitle.com + + cN722JE WBOS.pdf> Fax: + +From: Darren Indyke < + +Sent: Thursday, May 6, 2021 4:06 PM + +To: Melissa Koboldt + +Cc: Darren Indyke; Richard Kahn; + +Jonathan Williams + +Subject: Re: N7221E Escrow - AIC Title Service + +> on behalf of Darren Indyke + +As long as we get a notarized fly away affidavit, then I amok with an e signature on the delivery receipt. + +We are getting figures together for additional disbursements and will finalize as soon as possible and make sure to send + +them to Jonathan. Thank you. + +DARREN K. INDYKE + +Telephon Telecopier: Mobile: email: + +The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail, and destroy this + +communication and all copies thereof, including all attachments. + +Copyright of Darren K. Indyke - © 2019 Darren K. Indyke - All rights reserved. + +On May 6, 2021, at 5:02 PM, Melissa Koboldt <.. > wrote: + +I don't believe the delivery receipt would need to be notarized since there will be a fly away affidavit. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +Fax: + +From: Darren Indyke [mailto: + +Sent: Thursday, May 06, 2021 3:49 PM + +To: Melissa Koboldt + +Cc: Darren Indyke ‹ ..>; Richard Kahn + + + +Jonathan Williams + +Sent: Thursday, May 06, 2021 1:17 PM + +To: 'Darren Indyke' Cc: 'Richard Kahn' + +Anzalone' + +Subject: RE: N722.IE Escrow - AIC Title Service + +; 'Larry Visoski' <->; 'Gary + +Darren, is there anything else to pay out of escrow other than the broker fee and !/: the + +escrow fee? + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: Skype: + +From: Melissa Koboldt [mailto: + +Sent: Thursday, May 06, 2021 12:23 PM + +To: 'Darren Indyke' Cc: 'Richard Kahn' + +Anzalone' + +Subject: RE: N7221E Escrow - AIC Title Service + + + +; 'Larry Visoski' <->; 'Gary + +You were only on copy, they were sent to Larry for his signature. + +The PUE requests for the IR will be going out this afternoon, you'll need to advise IATS + +(the IR administrator) to approve AIC's request. + +Please send me closing/disbursement instructions. + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: Skype: or + +From: Darren Indyke [mailto: + +Sent: Thursday, May 06, 2021 12:18 PM + +To: Melissa Koboldt + +Cc: Richard Kahn <1 1); Larry Visoski <->; Gary + +Anzalone < + +Subject: Re: N722JE Escrow - AIC Title Service + +Fax: + + + +Larry C should sign as manager. You sent the docs to me to sign? + +Sent from my iPhone. Please excuse the typos. + +What about getting Larry closing docs? Also do we need to do anything + +Re the intl registry? + +Sent from my iPhone. Please excuse the typos. + +On May 6, 2021, at 1:12 PM, Melissa Koboldt + +wrote: + +I haven't been able to find anyone who can take it yet, + +will keep you posted. + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: + +From: Darren Indyke + +[mailto: + +Sent: Wednesday, May 05, 2021 5:50 PM + +To: Melissa Koboldt Cc: Richard Kahn + +Visoski a; Gary Anzalone + +Subject: Re: N722JE Escrow - AIC Title Service + +; Larry + +No to change FAA but yes to change warranty + +bos. Please See how difficult Friday would be and we + +can decide after you let us know. Thanks. + +Sent from my iPhone. Please excuse the typos. + +On May 5, 2021, at 6:41 PM, Melissa + +Koboldt • wrote: + +The FAA has is registered with no + +comma- + + + +Do you still want it added? + +would be preferable. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: + +From: Darren Indyke + +[mailto: + +Sent: Wednesday, May 05, 2021 5:24 + +PM + +To: Melissa Koboldt + +Cc: Richard Kahn + +Visoski < + +; Larry >; Gary Anzalone + +Subject: Re: N722JE Escrow - AIC Title + +Service + +Thank you for the dots. A couple of revisions Can you make seller Hyperion Air, LLC on FAA bos (you forgot the comma after "Air"). Can you change date to May on warranty bos. And re moving closing, is there no one + +in your office who can do it on Friday? Please advise. Thank you + +again. + +Sent from my iPhone. Please excuse the + +typos. + +On May 5, 2021, at 5:11 PM, Melissa Koboldt + +M> wrote: + +Hi Darren, + +Please review the FAA BOS and WBOS and advise if everything is in order and I will have + + + +It is my understanding closing was targeted for 5-7-2021 however I will be out of the office, do you have any issue with closing to occur on 5- + +10-2021? + +Thanks, + +Melissa Koboldt + +Escrow agent + +M =T + +Tel: or Fax: + +Skype: + + + + + + + + on behalf of Darren Indyke + +Please see below wire transfer instructions to the Estate of Jeffrey Epstein, the sole member of Seller Hyperion Air, LLC, + +which instructions are to be used for all disbursements to Seller: + +Bank name: First Bank + +Routing number for wires + +Account name: Account address: + +Account number: + +Thank you. + +DARREN K. INDYKE + +Telephone: Telecopier: Mobile: email: + +Estate of Jeffrey Epstein + +The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail, and destroy this + +communication and all copies thereof, including all attachments. + +Copyright of Darren K. Indyke - © 2019 Darren K. Indyke - All rights reserved. + +On May 6, 2021, at 6:38 PM, Melissa Koboldt <.. > wrote: + +Please see attached draft closing statement, these are the numbers as far as I know them, if anything + +changes please advise Jon. + +Thanks, + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Melissa Koboldt [mailto: + +Sent: Thursday, May 06, 2021 1:17 PM + +To: 'Darren Indyke' Cc: 'Richard Kahn' < + +c: >; 'Gary Anzalone' + +Fax: + +Subject: RE: N722JE Escrow - AIC Title Service + +>; 'Larry Visoski' + +Darren, is there anything else to pay out of escrow other than the + +broker fee and % the escrow fee? + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: Or + +Skype: melissa.koboldt www.aictitle.com + +From: Melissa Koboldt [maiIto + +Sent: Thursday, May 06, 2021 12:23 PM + +To: 'Darren Indyke' Cc: 'Richard Kahn' < + +a 'Gary Anzalone' + +Fax: + +Subject: RE: N722JE Escrow - AIC Title Service + +>; 'Larry Visoski' + +You were only on copy, they were sent to Larry for his signature. + +The PUE requests for the IR will be going out this afternoon, you'll need + +to advise IATS (the IR administrator) to approve AIC's request. + +Please send me closing/disbursement instructions. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +Fax: + + + +< >; Gary Anzalone + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke + +[mailto: + +Sent: Wednesday, May 05, 2021 5:50 + +PM + +To: Melissa Koboldt + +Cc: Richard Kahn + +Visoski < + +; Larry >; Gary Anzalone + +Subject: Re: N722JE Escrow - AIC Title + +Service + +No to change FAA but yes to change warranty bos. Please See how difficult Friday would be and we can decide after you let us know. Thanks. + +Fax: + +On May 5, 2021, at 6:41 PM, Melissa Koboldt + +In> wrote: + +The FAA has is registered with no + +comma- + + + +Do you still want it + +added? + +Yes I can change the + +WBOS. + +Everyone is booked in closings, I can see if it can be squeezed in but Monday would be + +preferable. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke + +[mailto + +Sent: Wednesday, May 05, 2021 5:24 PM To: Melissa Koboldt + +I> + +Cc: Richard Kahn + +=>; Larry Visoski + +Gary + +Anzalone + +Fax: + + + +Hello, + +From: Darren Indyke < > on behalf of Darren Indyke + +Sent: Wednesday, May 12, 2021 5:07 PM + +To: Gary Anzalone + +Cc: Melissa Koboldt; Sherry Cannon; + +Subject: Re: N722JE Aircraft Escrow Closing Statement, AIC Title Service, LLC + +I just pre-cleared with Melissa subject to my final Re ire of of exemption affidavit and my request to deliver a signed + +delivery receipt as part of closing tomorrow. + +Sent from my iPhone. Please excuse the typos. + +On May 12, 2021, at 9:50 AM, Gary Anzalone < wrote: + +Thank you Melissa, + +Please let us know when you receive the balance of the funds today. + +We will not require a group conference closing, however Darren Indyke will require a quick run + +through between the two of you prior to closing. + +Gary Anzalone Mana in Partner + +On Tue, May 11, 2021 at 8:58 PM e > wrote: + +AIC's Automated Aircraft Escrow Services Providing the latest, most up-to-date info for our clients. + +Please click the link below to view your Aircraft Escrow Closing Statement. + +(Aircraft Escrow Closing Statement - CLICK HERE + +Note: This link will expire after 14 days. + +From: Sent: To: Cc: Subject: Darren Indyke <- + +Thursday, May 13, 2021 7:33 AM + +Darren Indyke; + +Re: N7221E Aircraft Escrow Closing Statement, AIC Title Service, LLC + +> on behalf of Darren Indyke + +OK. Thank you. Please send all docs including delivery receipt to me in one email, Thank you. + +DARREN K. INDYKE + +Telephone: Telecopier: Mobile: email: + +The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail, and destroy this + +communication and all copies thereof, including all attachments. + +Copyright of Darren K. Indyke - © 2019 Darren K. Indyke - All rights reserved. + +On May 11, 2021, at 9:58 PM, wrote: + +AIC's Automated Aircraft Escrow Services Providing the latest, most up-to-date info for our clients. + +Hello, + +Please click the link below to view your Aircraft Escrow Closing Statement. + +(Aircraft Escrow Closing Statement - CLICK HERE + +Note: This link will expire after 14 days. + +If you're unable to click the HTML formatted link above, please manually copy and paste this entire URL + +into the address bar of your web browser: + +https://www.aictitle.comiclefault.aspx?tabid=948&sqs=ER0MDmxCgw7Lbex CI-I8Yw%3d%3d + +Thank you for your business. + +AIC Title Service, LLC + +Tel: + +2 + +From: Darren Indyke < + +Sent: Wednesday, May 5, 2021 5:24 PM + +To: Melissa Koboldt + +Cc: Richard Kahn; Larry Visoski; Gary Anzalone Subject: Re: N7221E Escrow - AIC Title Service + +> on behalf of Darren Indyke + +Thank you for the docs. A couple of revisions Can you make seller Hyperion Air, LLC on FAA bos (you forgot the comma after "Air"). Can you change date to May on warranty bos. And re moving closing, is there no one in your office who can + +do it on Friday? Please advise. Thank you again. + +Sent from my iPhone. Please excuse the typos. + +On May 5, 2021, at 5:11 PM, Melissa Koboldt < wrote: + +Hi Darren, + +Please review the FAA BOS and WBOS and advise if everything is in order and I will have them sent to + +Larry for digital signatures. + +It is my understanding closing was targeted for 5-7-2021 however I will be out of the office, do you have + +any issue with closing to occur on 5-10-2021? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + + Fax: + + + +From: Darren Indyke < + +Sent: Wednesday, May 5, 2021 5:50 PM + +To: Melissa Koboldt + +Cc: Richard Kahn; Larry Visoski; Gary Anzalone Subject: Re: N7221E Escrow - AIC Title Service + +> on behalf of Darren Indyke + +No to change FAA but yes to change warranty bos. Please See how difficult Friday would be and we can decide after you + +let us know. Thanks. + +Sent from my iPhone. Please excuse the typos. + +On May 5, 2021, at 6:41 PM, Melissa Koboldt < wrote: + +The FAA has is registered with no comma- + + + +Do you still want it added? + +Yes I can change the WBOS. + +Everyone is booked in closings, I can see if it can be squeezed in but Monday would be preferable. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +Fax: + +From: Darren Indyke [mailto: + +Sent: Wednesday, May 05, 2021 5:24 PM + +To: Melissa Koboldt + +Cc: Richard Kahn ; Larry Visoski < + +Subject: Re: N722JE Escrow - AIC Title Service + + + +>; Gary Anzalone + +Thank you for the docs. A couple of revisions Can you make seller Hyperion Air, LLC on FAA bos (you forgot the comma after "Air"). Can you change date to May on warranty bos. And re moving closing, is + +there no one in your office who can do it on Friday? Please advise. Thank you again. + +Sent from my iPhone. Please excuse the typos. + +Please review the FAA BO5 and WBOS and advise if everything is in order and I will have + +them sent to Larry for digital signatures. + +It is my understanding closing was targeted for 5-7-2021 however I will be out of the + +office, do you have any issue with closing to occur on 5-10-2021? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + + Fax: + + + +From: Darren lndyke < + +Sent: Thursday, May 6, 2021 12:15 PM + +To: Melissa Koboldt + +Cc: Richard Kahn; Larry Visoski; Gary Anzalone Subject: Re: N7221E Escrow - AIC Title Service + +Please update us Re closing docs and closing. + +Sent from my iPhone. Please excuse the typos. + +> on behalf of Darren Indyke + +On May 5, 2021, at 6:50 PM, Darren Indyke > wrote: + +No to change FAA but yes to change warranty bos. Please See how difficult Friday would be and we can + +decide after you let us know. Thanks. + +Sent from my iPhone. Please excuse the typos. + +On May 5, 2021, at 6:41 PM, Melissa Koboldt < wrote: + +The FAA has is registered with no comma- + + + +Do you still want it added? + +Yes I can change the WBOS. + +Everyone is booked in closings, I can see if it can be squeezed in but Monday would be + +preferable. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +Fax: + +From: Darren Indyke [mailto: + +Sent: Wednesday, May 05, 2021 5:24 PM + +To: Melissa Koboldt + +Cc: Richard Kahn + +>; Gary + +Thank you for the docs. A couple of revisions Can you make seller Hyperion Air, LLC on FAA bos (you forgot the comma after "Air"). Can you change date to May on warranty + +bos. And re moving closing, is there no one in your office who can do it on + +Friday? Please advise. Thank you again. + +Sent from my iPhone. Please excuse the typos. + +On May 5, 2021, at 5:11 PM, Melissa Koboldt + +wrote: + +Hi Darren, + +< + +Please review the FAA BOS and WBOS and advise if everything is in order and I will have them sent to Larry for digital signatures. + +It is my understanding closing was targeted for 5-7-2021 however I will be out of the office, do you have any issue with closing to occur on 5-10- + +2021? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + + Fax: + + + +From: Darren Indyke < + +Sent: Thursday, May 6, 2021 12:16 PM + +To: Melissa Koboldt + +Cc: Richard Kahn; Larry Visoski; Gary Anzalone Subject: Re: N7221E Escrow - AIC Title Service + +> on behalf of Darren Indyke + +What about getting Larry closing docs? Also do we need to do anything Re the intl registry? + +Sent from my iPhone. Please excuse the typos. + +On May 6, 2021, at 1:12 PM, Melissa Koboldt < > wrote: + +I haven't been able to find anyone who can take it yet, will keep you posted. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke [mailto + +Sent: Wednesday, May 05, 2021 5:50 PM + +To: Melissa Koboldt Cc: Richard Kahn + +Fax: + +Subject: Re: N722JE Escrow - AIC Title Service + +; Larry Visoski <->; Gary Anzalone + +No to change FAA but yes to change warranty bos. Please See how difficult Friday would be and we can + +decide after you let us know. Thanks. + +Sent from my iPhone. Please excuse the typos. + +On May 5, 2021, at 6:41 PM, Melissa Koboldt < wrote: + +The FAA has is registered with no comma- + + + +Do you still want it added? + +Yes I can change the WBOS. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke [mailto: + +Sent: Wednesday, May 05, 2021 5:24 PM + +To: Melissa Koboldt Cc: Richard Kahn + +Anzalone + +Subject: Re: N722JE Escrow - AIC Title Service + +Fax: + + + +; Larry Visoski <->; Gary + +Thank you for the dots. A couple of revisions Can you make seller Hyperion Air, LLC on FAA bos (you forgot the comma after "Air"). Can you change date to May on warranty + +bos. And re moving closing, is there no one in your office who can do it on + +Friday? Please advise. Thank you again. + +Sent from my iPhone. Please excuse the typos. + +On May 5, 2021, at 5:11 PM, Melissa Koboldt + +wrote: + +Hi Darren, + +Please review the FAA BOS and WBOS and advise if everything is in order and I will have them sent to Larry for digital signatures. + +It is my understanding closing was targeted for 5-7-2021 however I will be out of the office, do you have any issue with closing to occur on 5-10- + +2021? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + + Fax: + + + +From: Darren Indyke < + +Sent: Thursday, May 6, 2021 12:18 PM + +To: Melissa Koboldt + +Cc: Richard Kahn; Larry Visoski; Gary Anzalone Subject: Re: N7221E Escrow - AIC Title Service + +Larry C should sign as manager. You sent the docs to me to sign? + +Sent from my iPhone. Please excuse the typos. + +> on behalf of Darren Indyke + +On May 6, 2021, at 1:16 PM, Darren Indyke c > wrote: + +What about getting Larry closing docs? Also do we need to do anything Re the intl registry? + +Sent from my iPhone. Please excuse the typos. + +On May 6, 2021, at 1:12 PM, Melissa Koboldt < wrote: + +I haven't been able to find anyone who can take it yet, will keep you posted. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke [mailto: + +Sent: Wednesday, May 05, 2021 5:50 PM + +To: Melissa Koboldt Cc: Richard Kahn < + +Anzalone < + +Subject: Re: N7221E Escrow - AIC Title Service + +Fax: + +>; Larry Visoski >; Gary + +No to change FAA but yes to change warranty bos. Please See how difficult Friday + +would be and we can decide after you let us know. Thanks. + +Sent from my iPhone. Please excuse the typos. + +On May 5, 2021, at 6:41 PM, Melissa Koboldt + +wrote: + +Do you still want it added? + +Yes I can change the WBOS. + +Everyone is booked in closings, I can see if it can be squeezed in but + +Monday would be preferable. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke [mailto: + +Sent: Wednesday, May 05, 2021 5:24 PM + +To: Melissa Koboldt Cc: Richard Kahn + +<- 1>: Gary Anzalone + +Subject: Re: N722JE Escrow - AIC Title Service + + + +Fax: + +; Larry Visoski + +Thank you for the dots. A couple of revisions Can you make seller Hyperion Air, LLC on FAA bos (you forgot the comma after "Air"). Can you change date to May on warranty bos. And re moving closing, is there no one in your office who can do it on Friday? Please advise. + +Thank you again. + +Sent from my iPhone. Please excuse the typos. + +On May 5, 2021, at 5:11 PM, Melissa Koboldt + +wrote: + +Hi Darren, + +Please review the FAA BOS and WBOS and advise if everything is in order and I will have them sent to Larry + +for digital signatures. + +It is my understanding closing was targeted for 5-7-2021 however I will be out of the office, do you have any + +issue with closing to occur on 5-10-2021? + +Thanks, + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + + Fax: + +From: Rich Munkvold < > on behalf of Rich Munkvold + +Sent: Thursda Ma 6, 2021 9:48 AM + +To: + +Cc: • Tia Goodman + +Subject: RE: Please respond as the listed back-up contact on behalf of Industrial Integrity + +Solutions, LLC + +Becky, + +I have not received any contact form the IR which is odd. Can you reach out to them? + +Thanks! + +From: + +Sent: Wednesday, May 5, 2021 3:09 PM + +To: Rich Munkvold < + +Cc: ; Tia Goodman + +Subject: Please respond as the listed back-up contact on behalf of Industrial Integrity Solutions, LLC + +Rich, + +Suzanne Pruitt of AIC Title Service, LLC, has made application to become the Administrator of Industrial Integrity + +Solutions, LLC on the International Registry (the "IR"). As part of the application process, the IR will be contacting you to respond as the backup contact listed for Industrial Integrity Solutions, LLC, to which your response is required. Please respond from the email that they will send you with the following information that I have already given them -- PLEASE NOTE THAT YOUR RESPONSE MUST BE TO THE EMAIL FROM THE IR (NOT TO THIS EMAIL) THAT YOU RECEIVE (your reply + +to the IR's email will automatically re-direct to the proper email address at the IR): + +Name: Rich Monkvold Title: Chief Financial Officer + +Number: + +It is very important that you provide them with the exact details above. If something is incorrect with the information above, please advise and I will amend the certificate after we are approved. Once you have responded with this information, the IR will begin to work the documents that I have already sent them. Please cc me on your response so that I will know when you responded in case I need to call the IR concerning your certificate. I will let you know once we + +have received your certificate. + +Please let me know if there is anything else that I can do for you. If you have not received an email from the IR here in + +the next couple of minutes, please look in your junk mail or quarantine for an email from + +(NOTE: this email address is an "auto-generated email", and any + +responses sent to that email address are not proper, as the email address is not monitored). Please let me know if you + +look and still cannot find it, and we will ask the IR to re-send the email. + +If you have questions or need further information, please do not hesitate to contact us. Thank you. + +USA + +Tel: or Fax: + +From: Rich Munkvold < > on behalf of Rich Munkvold + +Sent: Thursday, May 6, 2021 10:23 AM + +To: Becky Carmichael + +Cc: Tonya Campbell; Melissa Koboldt; Tia Goodman + +Subject: RE: Please respond as the listed back-up contact on behalf of Industrial Integrity + +Solutions, LLC + +I was actually keeping an eye out for it in my junk/spam folders and I have not received anything. And I did re-verify the + +spelling on the document that I sent over just in case I typed something incorrectly. + +Can you please have them re-send? + +Thanks! + +From: Becky Carmichael ca + +Sent: Thursday, May 6, 20218:15 AM + +To: Rich Munkvold < + +Cc: Tonya Campbell : Melissa Koboldt Tia Goodman + +Subject: RE: Please respond as the listed back-up contact on behalf of Industrial Integrity Solutions, LLC + +Hi Rich, + +Have you checked both your spam and/or junk folders to see if the email was misdirected there? You should have received the email from the IR yesterday afternoon (Wednesday, May 5, 2021) at or about 5:12 pm CDT. Please check in your junk and/or spam folders for an email from — if you still cannot + +find it, let me know and I will contact the IR to have them re-send it. + +Kind regards, + +Becky Carmichael + +International Registry Specialist + +AIC Title Service + +Tel: + +www.aictitle.com + +or Fax: + +etl + +TITLE SERVICE + +From: Rich Munkvold + +Sent: Thursday, May 6, 2021 9:48 AM + +To: + +Cc: • Tia Goodman + +Subject: RE: Please respond as the listed back-up contact on behalf of Industrial Integrity Solutions, LLC + +0 0 0 + +Thanks! + +From: + +Sent: Wednesday, May 5, 2021 3:09 PM + +To: Rich Munkvold < + +Cc: Tia Goodman < + +> + +Subject: Please respond as the listed back-up contact on behalf of Industrial Integrity Solutions, LLC + +Rich, + +> + +Suzanne Pruitt of AIC Title Service, LLC, has made application to become the Administrator of Industrial Integrity + +Solutions, LLC on the International Registry (the "IR"). As part of the application process, the IR will be contacting you to respond as the backup contact listed for Industrial Integrity Solutions, LLC, to which your response is required. Please respond from the email that they will send you with the following information that I have already given them -- PLEASE NOTE THAT YOUR RESPONSE MUST BE TO THE EMAIL FROM THE IR (NOT TO THIS EMAIL) THAT YOU RECEIVE (your reply + +to the IR's email will automatically re-direct to the proper email address at the IR): + +Name: Rich Monkvold Title: Chief Financial Officer + +Number: + +It is very important that you provide them with the exact details above. If something is incorrect with the information above, please advise and I will amend the certificate after we are approved. Once you have responded with this information, the IR will begin to work the documents that I have already sent them. Please cc me on your response so that I will know when you responded in case I need to call the IR concerning your certificate. I will let you know once we + +have received your certificate. + +Please let me know if there is anything else that I can do for you. If you have not received an email from the IR here in + +the next couple of minutes, please look in your junk mail or quarantine for an email from + +(NOTE: this email address is an "auto-generated email", and any + +responses sent to that email address are not proper, as the email address is not monitored). Please let me know if you + +look and still cannot find it, and we will ask the IR to re-send the email. + +If you have questions or need further information, please do not hesitate to contact us. Thank you. + +Becky Carmichael + +AIC Title Service, LLC + +USA + +Tel: or Fax: + +From: Rich Munkvold < + +Sent: Thursday, May 6, 2021 2:04 PM + +To: Melissa Koboldt Cc: Kamran Ali Subject: RE: New Escrow Attachments: 0701\_001.pdf + +Melissa, + +Here you go. + +Thanks! + +From: Melissa Koboldt + +Sent: Thursday, May 6, 2021 10:29 AM + +To: Rich Munkvold Subject: RE: New Escrow > on behalf of Rich Munkvold + +I need to know how the LLC is set up so I can see who needs to sign the app and the appropriate title. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: Or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold + +Sent: Wednesday, May 05, 2021 3:06 PM + +To: Melissa Koboldt + +Cc: Gary Anzalone < MI) + +Subject: RE: New Escrow + +Fax: + +TITLE SERVICE + +000 + +Do we have to file with the IR to purchase or finance the airplane? If not, then let's not bother. + +Thanks! + +From: Melissa Koboldt + +Sent: Wednesday, May 5, 2021 12:47 PM + +Hi Rich, + +What address and phone number do you want to use for registration purposes? I need to get FAA docs prepared and + +sent for digital signatures. + +Are we filing this transaction with the IR? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold 1mailto: + +Sent: Wednesday, April 21, 2021 9:51AM + +To: Melissa Koboldt < Cc: Gary Anzalone + +Subject: RE: New Escrow + +Melissa, + +Attached is an amendment to the APA which is signed. I don't have the APA signed by the seller. I did attach the APA + +signed by me. + +Thanks! + +Fax: + +aA t i C + +TITLE SERVICE + +0 O O + +From: Melissa Koboldt + +Sent: Tuesday, April 20, 2021 8:14 PM + +To: Rich Munkvold Subject: RE: New Escrow + +You have any agreement on this? just a straight sale from seller to buyer? + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: i or + +Skype: melissa.koboldt www.aictitle.com + +S `~ + +TITLE SERVICE + +000 + +Melissa, + +We are going to be wiring a deposit to you for a helicopter. I want to confirm that the proper wiring instructions should + +be into the -= account. + +The helicopter is a 2008 Sikorsky S/N 760750 with a tail number of N722JE. + +Please let me know. + +Thanks! + +From: Rich Munkvold < + +Sent: Thursday, May 6, 2021 3:06 PM + +To: Melissa Koboldt Cc: Kamran Ali Subject: RE: New Escrow Attachments: 0702\_001.pdf + +yes + +From: Melissa Koboldt + +Sent: Thursday, May 6, 2021 12:15 PM + +To: Rich Munkvold Subject: RE: New Escrow + +Are you CFO of Frontier Finance Co.? + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Thursday, May 06, 2021 2:04 PM + +To: Melissa Koboldt < Cc: Kamran Ali < + +Subject: RE: New Escrow + +Melissa, + +Here you go. + +Thanks! + +From: Melissa Koboldt + +Sent: Thursday, May 6, 2021 10:29 AM + +To: Rich Munkvold Subject: RE: New Escrow Fax: + +> on behalf of Rich Munkvold + +aA t i C + +TITLE SERVICE + +000 + +I need to know how the LLC is set up so I can see who needs to sign the app and the appropriate title. + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Wednesday, May 05, 2021 3:06 PM + +To: Melissa Koboldt Cc: Gary Anzalone + +Subject: RE: New Escrow + +Fax: + +RA J C TITLE SERVICE + +0 O O + +Do we have to file with the IR to purchase or finance the airplane? If not, then let's not bother. + +Thanks! + +From: Melissa Koboldt + +Sent: Wednesday, May 5, 2021 12:47 PM + +To: Rich Munkvold Cc: Gary Anzalone + +Subject: RE: New Escrow + +Hi Rich, + +What address and phone number do you want to use for registration purposes? I need to get FAA docs prepared and + +sent for digital signatures. + +Are we filing this transaction with the IR? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Wednesday, April 21, 2021 9:51 AM + +To: Melissa Koboldt Cc: Gary Anzalone + +Fax: + +aA t i C + +TITLE SERVICE + +0 O O + +Attached is an amendment to the APA which is signed. I don't have the APA signed by the seller. I did attach the APA + +signed by me. + +Thanks! + +From: Melissa Koboldt + +Sent: Tuesday, April 20, 2021 8:14 PM + +To: Rich Munkvold Subject: RE: New Escrow + +< + +You have any agreement on this? just a straight sale from seller to buyer? + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Thursday, April 15, 2021 2:26 PM + +To: Melissa Koboldt Subject: New Escrow Fax: + +Melissa, + +ArA t IC + +TITLE SERVICE + +0 0 0 + +We are going to be wiring a deposit to you for a helicopter. I want to confirm that the proper wiring instructions should + +be into the -= account. + +The helicopter is a 2008 Sikorsky S/N 760750 with a tail number of N722JE. + +Please let me know. + +Thanks! + +From: Rich Munkvold < + +Sent: Friday, May 7, 2021 12:45 PM + +To: Melissa Koboldt + +Cc: Gary Anzalone; Tia Goodman; Sherry Cannon + +Subject: N722JE Escrow + +> on behalf of Rich Munkvold + +Melissa, + +We will not be closing escrow on N722JE today. We are extending the closing until next Wednesday (5/12). + +We have also wired in an additional \$100,000 as good faith. This can be released to the sellers upon you having a + +mutually executed extension to 5/12/21. + +Thanks! + +From: Rich Munkvold < + +Sent: Thursday, April 15, 2021 2:26 PM + +To: Melissa Koboldt Subject: New Escrow + +Melissa, + +> on behalf of Rich Munkvold + +We are going to be wiring a deposit to you for a helicopter. I want to confirm that the proper wiring instructions should + +be into the account. + +The helicopter is a 2008 Sikorsky S/N 760750 with a tail number of N722.IE. + +Please let me know. + +Thanks! + +From: Rich Munkvold < > on behalf of Rich Munkvold + +Sent: Wednesday, April 21, 2021 9:51 AM + +To: Melissa Koboldt Cc: Gary Anzalone Subject: RE: New Escrow + +Attachments: N722JE Signed Amendment.pdf; N7221E APA Signed by Buyer.pdf + +Melissa, + +Attached is an amendment to the APA which is signed. I don't have the APA signed by the seller. I did attach the APA + +signed by me. + +Thanks! + +From: Melissa Koboldt + +Sent: Tuesday, April 20, 2021 8:14 PM + +To: Rich Munkvold Subject: RE: New Escrow + +You have any agreement on this? just a straight sale from seller to buyer? + +Melissa Koboldt + +R C + +Escrow agent AJ + +TITLE SERVICE + +< + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Thursday, April 15, 2021 2:26 PM + +To: Melissa Koboldt Subject: New Escrow + +Melissa, + +We are going to be wiring a deposit to you for a helicopter. I want to confirm that the proper wiring instructions should + +be into the -= account. + +The helicopter is a 2008 Sikorsky S/N 760750 with a tail number of N722JE. + +Please let me know. + +Thanks! + +Fax: + +0 0 0 + +From: Rich Munkvold + +Sent: Wednesday, May 5, 2021 3:06 PM + +To: Melissa Koboldt Cc: Gary Anzalone Subject: RE: New Escrow + +C + +• + +> on behalf of Rich Munkvold + +Do we have to file with the IR to purchase or finance the airplane? If not, then let's not bother. + +Thanks! + +From: Melissa Koboldt + +Sent: Wednesday, May 5, 2021 12:47 PM + +To: Rich Munkvold < Cc: Gary Anzalone < Subject: RE: New Escrow + +Hi Rich, + +What address and phone number do you want to use for registration purposes? I need to get FAA docs prepared and + +sent for digital signatures. + +Are we filing this transaction with the IR? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Wednesday, April 21, 2021 9:51 AM + +To: Melissa Koboldt Cc: Gary Anzalone + +Subject: RE: New Escrow + +Melissa, + +Fax: + +TITLE SERVICE + +©00 + +Attached is an amendment to the APA which is signed. I don't have the APA signed by the seller. I did attach the APA + +From: Melissa Koboldt + +Sent: Tuesday, April 20, 2021 8:14 PM + +To: Rich Munkvold Subject: RE: New Escrow + +You have any agreement on this? just a straight sale from seller to buyer? + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Thursday, April 15, 2021 2:26 PM + +To: Melissa Koboldt Subject: New Escrow + +Melissa, + +We are going to be wiring a deposit to you for a helicopter. I want to confirm that the proper wiring instructions should + +be into the a account. + +The helicopter is a 2008 Sikorsky S/N 760750 with a tail number of N722JE. + +Please let me know. + +Thanks! + +Fax: + +SA t i C + +TITLE SERVICE + +00 + +From: Rich Munkvold + +Sent: Wednesday, May 5, 2021 3:47 PM + +To: Melissa Koboldt Cc: Gary Anzalone Subject: RE: New Escrow + +> on behalf of Rich Munkvold + +I guess that we should do it now since I will be putting a loan on it within the next 30 days. + +Thanks! + +From: Melissa Koboldt + +Sent: Wednesday, May 5, 2021 1:37 PM + +To: Rich Munkvold < Cc: Gary Anzalone + +Subject: RE: New Escrow + +Not to purchase but if there is going to be a lender they will likely require it. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Wednesday, May 05, 2021 3:06 PM + +To: Melissa Koboldt Cc: Gary Anzalone Subject: RE: New Escrow + +Do we have to file with the IR to purchase or finance the airplane? If not, then let's not bother. + +Fax: + +SAM + +TITLE SERVICE + +©00 + +Thanks! + +From: Melissa Koboldt + +Sent: Wednesday, May 5, 2021 12:47 PM + +To: Rich Munkvold < Cc: Gary Anzalone Subject: RE: New Escrow + +What address and phone number do you want to use for registration purposes? I need to get FAA docs prepared and + +sent for digital signatures. + +Are we filing this transaction with the IR? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Wednesday, April 21, 2021 9:51 AM + +To: Melissa Koboldt Cc: Gary Anzalone + +Subject: RE: New Escrow + +Fax: + +Melissa, + +tic + +TITLE SERVICE + +000 + +Attached is an amendment to the APA which is signed. I don't have the APA signed by the seller. I did attach the APA + +signed by me. + +Thanks! + +From: Melissa Koboldt + +Sent: Tuesday, April 20, 2021 8:14 PM + +To: Rich Munkvold Subject: RE: New Escrow + +You have any agreement on this? just a straight sale from seller to buyer? + +Melissa Koboldt + +Escrow agent + +< + +AIC Title Service + +Tel: + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Thursday, April 15, 2021 2:26 PM + +To: Melissa Koboldt Subject: New Escrow SA t i C + +TITLE SERVICE + +0 O 0 + +We are going to be wiring a deposit to you for a helicopter. I want to confirm that the proper wiring instructions should + +be into the account. + +The helicopter is a 2008 Sikorsky S/N 760750 with a tail number of N722JE. + +Please let me know. + +Thanks! + +From: Rich Munkvold < + +Sent: Wednesda , Ma 5, 2021 4:01 PM + +To: + +Subject: RE: Title Insurance Quote + +Melissa, + +> on behalf of Rich Munkvold + +I went back and checked to see if we were charged a title fee on the G550 and we were not. We were only charged 50% + +of the escrow fee. + +Please let me know what this fee is for. + +Thanks! + +From: < M> + +Sent: Wednesday, May 5, 2021 12:50 PM + +To: Rich Munkvold < + +Subject: Title Insurance Quote + +AvSure, Inc. + +To reach a licensed agent contact AIC Title Service, LLC at + +Telephone + +TITLE INSURANCE QUOTE AIRCRAFT OWNER'S POLICY + +N722JE, KEYSTONE HELICOPTER S-76C, SN: 760750 + +This Title Insurance Quote is provided as of May 05, 2021 02:49 PM and remains at all times subject + +to the Notes provided below. + +Quote requested by and for the benefit of: + +Rich Munkvold + +Amount of Title Insurance: \$1,800,000.00 + +Premium: \$4,268.00 + +Note 1: Issuance of Title Insurance subject to the terms and conditions disclosed herein and + +Note 3: Insurance coverage on applicable International Registry (I.R.) remains subject to the + +registration of I.R. interests or insured waiver thereof. + +From: Rich Munkvold + +Sent: Wednesday, May 5, 2021 4:11 PM + +To: Melissa Koboldt Cc: Tia Goodman Subject: RE: New Escrow Attachments: 0694\_001.pdf + +Here you go + +From: Melissa Koboldt + +Sent: Wednesday, May 5, 2021 1:57 PM + +To: Rich Munkvold Cc: Gary Anzalone + +Subject: RE: New Escrow + +> + +> on behalf of Rich Munkvold + +Ok, it appears the entity is not signed up on the IR so we will need to do that, paperwork attached. Also, will need LLC + +statement completed, signed and returned to me as there is nothing on file with the FAA for the LLC. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold imailto + +Sent: Wednesday, May 05, 2021 3:47 PM + +To: Melissa Koboldt Cc: Gary Anzalone + +Subject: RE: New Escrow + +I guess that we should do it now since I will be putting a loan on it within the next 30 days. + +Thanks! + +Fax: + +Ain + +Arts + +TITLE SERVICE + +OOO + +From: Melissa Koboldt < + +Sent: Wednesday, May 5, 2021 1:37 PM + +To: Rich Munkvold Cc: Gary Anzalone + +Subject: RE: New Escrow + +Not to purchase but if there is going to be a lender they will likely require it. + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Wednesday, May 05, 2021 3:06 PM + +To: Melissa Koboldt Cc: Gary Anzalone + +Subject: RE: New Escrow + +Fax: + +RA J C TITLE SERVICE + +0 O O + +Do we have to file with the IR to purchase or finance the airplane? If not, then let's not bother. + +Thanks! + +From: Melissa Koboldt + +Sent: Wednesday, May 5, 2021 12:47 PM + +To: Rich Munkvold Cc: Gary Anzalone + +Subject: RE: New Escrow + +Hi Rich, + +What address and phone number do you want to use for registration purposes? I need to get FAA docs prepared and + +sent for digital signatures. + +Are we filing this transaction with the IR? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Wednesday, April 21, 2021 9:51 AM + +To: Melissa Koboldt Cc: Gary Anzalone + +Fax: + +aA t i C + +TITLE SERVICE + +0 O O + +Attached is an amendment to the APA which is signed. I don't have the APA signed by the seller. I did attach the APA + +signed by me. + +Thanks! + +From: Melissa Koboldt + +Sent: Tuesday, April 20, 2021 8:14 PM + +To: Rich Munkvold Subject: RE: New Escrow + +< + +You have any agreement on this? just a straight sale from seller to buyer? + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Thursday, April 15, 2021 2:26 PM + +To: Melissa Koboldt Subject: New Escrow Fax: + +Melissa, + +ArA t IC + +TITLE SERVICE + +0 0 0 + +We are going to be wiring a deposit to you for a helicopter. I want to confirm that the proper wiring instructions should + +be into the -= account. + +The helicopter is a 2008 Sikorsky S/N 760750 with a tail number of N722JE. + +Please let me know. + +Thanks! + +From: Rich Munkvold + +Sent: Wednesday, May 5, 2021 4:39 PM + +To: Melissa Koboldt + +Subject: RE: Title Insurance Quote + +C + +If it is not normal and customary, then let's not + +From: Melissa Koboldt + +Sent: Wednesday, May 5, 2021 2:35 PM + +To: Rich Munkvold + +Subject: RE: Title Insurance Quote + +> on behalf of Rich Munkvold + +It's if you want title insurance, I don't think you guys normally purchase it but I always have to send out quotes. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: Or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Wednesday, May 05, 2021 4:01PM + +To: + +Subject: RE: Title Insurance Quote + +Melissa, + +Fax: + +aA t iC + +TITLE SERVICE + +0 0 0 + +I went back and checked to see if we were charged a title fee on the G550 and we were not. We were only charged 50% + +of the escrow fee. + +Please let me know what this fee is for. + +Thanks! + +From: + +Sent: Wednesday, May 5, 2021 12:50 PM + +To: Rich Munkvold + +Subject: Title Insurance Quote + +AvSure, Inc. + +Telephone + +TITLE INSURANCE QUOTE AIRCRAFT OWNER'S POLICY + +N722JE, KEYSTONE HELICOPTER S-76C, SN: 760750 + +This Title Insurance Quote is provided as of May 05, 2021 02:49 PM and remains at all times subject + +to the Notes provided below. + +Quote requested by and for the benefit of: + +Rich Munkvold + +Amount of Title Insurance: \$1,800,000.00 + +Premium: \$4,268.00 + +Note 1: Issuance of Title Insurance subject to the terms and conditions disclosed herein and + +contained in any policy issued in furtherance hereof. + +Note 2: Premium given is based on a clean title search. If encumbrances or FAA remarks are found, + +additional fees may apply. + +Note 3: Insurance coverage on applicable International Registry (I.R.) remains subject to the + +registration of I.R. interests or insured waiver thereof. + +From: Rich Munkvold < > on behalf of Rich Munkvold + +Sent: Friday, May 7, 2021 5:31 PM + +To: Melissa Koboldt + +Cc: Gary Anzalone; Sherry Cannon; Larry Visoski; Tia Goodman + +Subject: N722JE Attachments: 0716\_001.pdf + +Melissa, + +Attached is a copy of the completed exemption per your request. You should have the original on Monday. + +Thanks! + +From: Sent: To: Cc: Subject: + +Thank you! + +Sincerely, + +Gary Anzalone Mana>in> Partner Gary Anzalone < > on behalf of Gary Anzalone + +Wednesday, April 21, 2021 10:32 AM + +Melissa Koboldt Sherry Cannon + +Re: AK Title Report — Aircraft: N7221E, KEYSTONE HELICOPTER, S-76C SN: 760750 + +Prder#152973.841) + +On Wed, Apr 21, 2021 at 10:21 AM < > wrote: + +AIC Title Report Delivery. + +• tIRCRAFT CLOSING + +For the convenience of our Aircraft Closing Room Tm clients, we're providing you a personalized copy of the Report(s) for Aircraft: N722JE, KEYSTONE HELICOPTER, + +S-76C SN: 760750. + +Please click CONTINUE to view your Report(s). + +REPORTS PERTAIN TO THE FOLLOWING AIRCRAFT OBJECTS: + +Engine: TURBOMECA S.A. SN:42285TE Engine: TURBOMECA S.A. SN:42286TEC Airframe: N722JE + +Note: This link will expire after fourteen (14) days. + +Please download or print all Report(s) to retain for your records. After the link has expired, reports may + +be re-sent for an additional fee. Please contact us for assistance. + +For added convenience, a PDF copy of the Report(s) is attached. You may also find a copy stored in + +your AIRCRAFT CLOSING ROOM'" transaction. + +If the button link above does not work, please click the URL below, or copy and paste it into your browser + +address bar. + +https://reports.aictitle.com/?r=2cg980YxbIWIxaja%2bzQ%2bbA%3d%3d + +RcLel A152913 ,"-1495 + +sA t IC + +TITLE SERVICE + +ai + +AIE Title Service, LLC m + +From: Rich Munkvold < > on behalf of Rich Munkvold + +Sent: Wednesday, May 12, 2021 4:59 PM + +To: Melissa Koboldt + +Cc: Gary Anzalone; Tie Goodman; Sherry Cannon; Larry Visoski + +Subject: RE: N722JE Escrow + +We can close when you are position to do so. + +Thanks! + +From: Melissa Koboldt < + +Sent: Wednesday, May 12, 2021 2:44 PM + +To: Rich Munkvold < + +Cc: Gary Anzalone >; Tia Goodman < Sherry + +Cannon + +Subject: RE: N722JE Escrow + +Hi Rich, + +We have received the balance of funds into escrow, please let me know when you are ready to proceed with closing. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold [mak() + +Sent: Tuesday, May 11, 2021 1:23 PM + +To: Melissa Koboldt + +Cc: Gary Anzalone >; Tia Goodman < >; Sherry + +Cannon + +Subject: RE: N722JE Escrow + +Fax: + +;cad C + +TITLE SERVICE + +000 + +Melissa, + +Can you please send over a revised closing statement reflecting the additional deposit? + +Thanks! + +From: Melissa Koboldt < + +Subject: RE: N722JE Escrow + +I have received the mutually executed extension and will now wire the \$200k to seller. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold [mailto: + +Sent: Friday, May 07, 202112:45 PM + +To: Melissa Koboldt Cc: Gary Anzalone < + +Cannon < + +Subject: N722JE Escrow + +Melissa, + +We will not be closing escrow on N722JE today. We are extending the closing until next Wednesday (5/12). + +We have also wired in an additional \$100,000 as good faith. This can be released to the sellers upon you having a + +mutually executed extension to 5/12/21. + +Thanks! + +Fax: + +C + +TITLE SERVICE + +; Tia Goodman + +0 0 0 + +Sherry + +From: Gary Anzalone < + +Sent: Wednesday, April 21, 2021 9:50 AM + +To: Melissa Koboldt Cc: Sherry Cannon + +Subject: Re: N722JE - Sikorsky 576C++ sn 760750 + +> on behalf of Gary Anzalone + +Hi Melissa + +Thank you for getting this back to us! + +Actually, both parties are EQUUS's clients, but on this one we will be paid by the Seller! + +Sincerel x + +Gary Anzalone Managing Partner + +On Tue, Apr 20, 2021 at 11:02 PM Melissa Koboldt + +Hi again, signed and attached. + +I assume you are representing the seller? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +Fax: + +wrote: + +tic + +TITLE SERVICE + +0 0 0 + +Sent: Monday, April 19, 2021 1:39 PM + +To: Melissa Koboldt < >; Sherry Cannon + +Subject: N722JE - Sikorsky S76C++ sn 760750 + +Hi Melissa + +Attached you will find the executed and counter executed APA between Hyperion Air LLC and Industrial + +Integrity Solutions LLC for Sikorsky S76C++ sn 76075o, N722JE. + +Additionally, I have attached the Exhibit C Technical acceptance making the deposit hereby non refundable. + +At your convenience, can you please return a copy of the APA with your executed Consent and Joinder? + +I expect you have already spoken with Rich Munkvold of Industrial Integrity Solutions with respect to lien + +searches, IR etc, but I will differ to him with respect to the timing of the closing. + +I am fairly certain there are no plans to close this week. Let me know what he tells you in this respect. + +Sincerely, + +L + +Gary Anzalone + +Managing Partner + +• + +From: Rich Munkvold + +Sent: Tuesday, May 11, 2021 1:23 PM + +To: Melissa Koboldt + +Cc: Gary Anzalone; Tia Goodman; Sherry Cannon + +Subject: RE: N722JE Escrow + +Melissa, + +Can you please send over a revised closing statement reflecting the additional deposit? + +Thanks! + +From: Melissa Koboldt + +Sent: Tuesday, May 11, 2021 11:15 AM + +To: Rich Munkvold Cc: Gary Anzalone + +Cannon + +Subject: RE: N722JE Escrow + +> on behalf of Rich Munkvold + +; Tia Goodman < Sherry + +I have received the mutually executed extension and will now wire the \$200k to seller. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold [mak() + +Sent: Friday, May 07, 2021 12:45 PM + +To: Melissa Koboldt Cc: Gary Anzalone + +Cannon + +Subject: N722JE Escrow + +Melissa, + +We will not be closing escrow on N722JE today. We are extending the closing until next Wednesday (5/12). + +Fax: + +c + +TITLE SERVICE + +OOO + +Tia Goodman < > Sherry + +We have also wired in an additional \$100,000 as good faith. This can be released to the sellers upon you having a + +mutually executed extension to 5/12/21. + +Thanks! + +From: Gary Anzalone < > on behalf of Gary Anzalone + +Sent: Wednesday, April 21, 2021 9:56 AM + +To: Rich Munkvold Cc: Melissa Koboldt Subject: Re: New Escrow + +Attachments: Seller Countersigned Signature page from APA dated April 16, 2021.pdf; consent & + +joinder.pdf + +Rich, + +Here is a copy of the Seller signature page as well as one with Melissa's consent & joinder + +Sincerel x + +Gary Anzalone Mana ' Partner + +On Wed, Apr 21, 2O21 at 9:51 AM Rich Munkvold < > wrote: + +Melissa, + +Attached is an amendment to the APA which is signed. I don't have the APA signed by the seller. I did attach the APA + +signed by me. + +Thanks! + +From: Melissa Koboldt + +Sent: Tuesday, April 20, 2021 8:14 PM + +To: Rich Munkvold Subject: RE: New Escrow + +You have any agreement on this? just a straight sale from seller to buyer? + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold [mailto:l + +Sent: Thursday, April 15, 2021 2:26 PM + +To: Melissa Koboldt < Subject: New Escrow + +Melissa, + +ArAsti C + +TITLE SERVICE + +0 0 0 + +We are going to be wiring a deposit to you for a helicopter. I want to confirm that the proper wiring instructions should + +be into the =account. + +The helicopter is a 2008 Sikorsky S/N 760750 with a tail number of N722JE. + +Please let me know. + +Thanks! + +From: Gary Anzalone < > on behalf of Gary Anzalone + +Sent: Monday, April 19, 2021 1:39 PM To: Melissa Koboldt Sherry Cannon Subject: N722JE - Sikorsky 576C++ sn 760750 + +Attachments: Seller Countersigned Signature page from APA dated April 16, 2021.pdf; signed by + +purchaser.pdf; Exhibit C acceptance.pdf + +Hi Melissa + +Attached you will find the executed and counter executed APA between Hyperion Air LLC and Industrial + +Integrity Solutions LLC for Sikorsky 576C++ sn 760750, N722JE. + +Additionally, I have attached the Exhibit C Technical acceptance making the deposit hereby non refundable. + +At your convenience, can you please return a copy of the APA with your executed Consent and Joinder? + +I expect you have already spoken with Rich Munkvold of Industrial Integrity Solutions with respect to lien + +searches, IR etc, but I will differ to him with respect to the timing of the closing. + +I am fairly certain there are no plans to close this week Let me know what he tells you in this respect. + +Gary Anzalone Man 'n• Partner + +From: Rich Munkvold < + +Sent: Saturday, May 8, 2021 12:34 PM + +To: Melissa Koboldt + +Cc: Gary Anzalone; Sherry Cannon + +Subject: N722JE Extension Attachments: 0723\_001.pdf + +Melissa, + +Attached is our signature on the extension of escrow until 5/13/21. + +Thanks! + +> on behalf of Rich Munkvold + +From: Rich Munkvold < + +Sent: Wednesday, May 12, 2021 7:29 PM + +To: Larry Visoski + +Cc: Melissa Koboldt; Gary Anzalone; Tia Goodman + +Subject: N722JE Attachments: 0769\_001.pdf > on behalf of Rich Munkvold + +Larry, + +Attached is the delivery certificate. Can you tell us the hours and landings so that Melissa can put in that information? + +Thanks! + +From: Gary Anzalone < + +Sent: Tuesday, April 20, 2021 7:33 PM + +To: Melissa Koboldt Cc: Sherry Cannon + +Subject: Re: N722JE - Sikorsky S76C++ sn 760750 Attachments: Amendment to the APA fully executed.pdf > on behalf of Gary Anzalone + +Hi Melissa + +Attached is a fully executed amendment to the APA extending the closing date to no later than May 7, 2021 + +I would appreciate you getting the consent and joinder back to us tomorrow. + +Sincerely, + +Gary Anzalone Mana ,in y Partner + +On Tue, Apr 20, 2021 at 11:28 AM Melissa Koboldt > wrote: + +Haha sorry! been buried in closings. Rich hasn't sent me anything so I don't know what's happening on this deal yet, I'll + +look at your dots and revert back this afternoon. + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Gary Anzalone [mailto: + +Sent: Tuesday, April 20, 2021 11:12 AM + +To: Melissa Koboldt c >; Sherry Cannon + +sA t i C + +TITLE SERVICE + +0 0 0 + +Melissa + +Talk to me sister! + +Sincerely, + +Gary Anzalone + +Managing Partner + +L + +On Mon, Apr 19, 2021 at 1:38 PM Gary Anzalone wrote: + +Hi Melissa + +Attached you will find the executed and counter executed APA between Hyperion Air LLC and Industrial + +Integrity Solutions LLC for Sikorsky 576C++ sn 760750, N722JE. + +Additionally, I have attached the Exhibit C Technical acceptance making the deposit hereby non refundable. + +At your convenience, can you please return a copy of the APA with your executed Consent and Joinder? + +I expect you have already spoken with Rich Munkvold of Industrial Integrity Solutions with respect to lien + +searches, IR etc, but I will differ to him with respect to the timing of the closing. + +I am fairly certain there are no plans to close this week. Let me know what he tells you in this respect. + +Sincerely, + +Gary Anzalone + +Managing Partner + +From: Gary Anzalone < + +Sent: Friday, April 16, 2021 1:39 PM To: Melissa Koboldt; Sherry Cannon + +Subject: Deposit + +Did you get a deposit from Rich Munkvold for Sikorsky 760750? + +Gary Anzalone Equus Aviation > on behalf of Gary Anzalone + +From: Sent: To: Subject: + +Melissa + +Talk to me sister! + +Sin cerel + +Gary Anzalone Mana•'n Partner Gary Anzalone < + +Tuesday, April 20, 2021 11:12 AM Melissa Koboldt; Sherry Cannon + +Re: N722JE - Sikorsky S76C++ sn 760750 + +> on behalf of Gary Anzalone + +On Mon, Apr 19, 2021 at 1:38 PM Gary Anzalone wrote: + +Hi Melissa + +Attached you will find the executed and counter executed APA between Hyperion Air LLC and Industrial + +Integrity Solutions LLC for Sikorsky S76C++ sn 760750, N722JE. + +Additionally, I have attached the Exhibit C Technical acceptance making the deposit hereby non refundable. + +At your convenience, can you please return a copy of the APA with your executed Consent and Joinder? + +I expect you have already spoken with Rich Munkvold of Industrial Integrity Solutions with respect to lien + +searches, IR etc, but I will differ to him with respect to the timing of the closing. + +I am fairly certain there are no plans to close this week. Let me know what he tells you in this respect. + +Gary Anzalone Mana • • Partner + +From: Sent: To: Cc: Subject: Gary Anzalone < + +Wednesday, May 5, 2021 2:39 PM + +Melissa Koboldt + +Sherry Cannon + +Re: N722JE - Sikorsky S76C++ sn 760750 + +> on behalf of Gary Anzalone + +Honestly it may make Buyer happy so please test the water with Darren and let me know. + +Sincerely, + +Gary Anzalone Mana ,in y Partner + +On Wed, May 5, 2021 at 2:35 PM Melissa Koboldt < wrote: + +Well ya know no one ever closes on the date it says lol. + +Will do. + +I can always hand to another agent to close if it's going to cause heartburn with either party. + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Gary Anzalone [mailto: + +TITLE SERVICE + +000 + +ruh roh...I am guessing you did not catch the date on the amendment we sent you on the zoth. + +I am certain that Monday would be ok with the Purchaser. + +I suggest you send the draft BOS and WBOS to Darren Indyke (seller) and just let him know you have a + +conflict and ask him if Monday is ok with him. I am sure we will be ok. + +Sincerely, + +Gary Anzalone + +Managing Partner + +On Wed, May 5, 2021 at 2:06 PM Melissa Koboldt wrote: + +Hi Gary, + +This Friday (7'")? I'm out of office. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Gary Anzalone [mailto + +Sent: Wednesday, May 05, 2021 1:57 PM + +To: Melissa Koboldt Cc: Sherry Cannon + +Subject: Re: N722JE - Sikorsky S76C++ sn 760750 + +Hi Melissa, + +We are getting our ducks in a row to dose the S76 on Friday. + +.A.IC + +TITLE SERVICE + +0 O O + +Just as we did on the G550, can you please email a copy of the proposed WBOS and FAA BOS to Sellers attorney Darren Indyke to approve the form, prior to sending them to Captain Larry Visosky to docusign? + +Darren Indyke + +• Work + +Sincerely, + +Gary Anzalone + +On Wed, Apr 21, 2021 at 9:54 AM Melissa Koboldt < wrote: + +Roger. + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Gary Anzalone mailto: + +Sent: Wednesday, April 21, 2021 9:50 AM + +To: Melissa Koboldt Cc: Sherry Cannon + +Subject: Re: N722JE - Sikorsky 576C++ sn 760750 + +Hi Melissa + +Thank you for getting this back to us! + +C + +TITLE SERVICE + +0 0 0 + +Actually, both parties are EQUUS's clients, but on this one we will be paid by the Seller! + +Sincerely, + +Gary Anzalone + +Managing Partner + +On Tue, Apr 20, 2021 at 11:02 PM Melissa Koboldt < wrote: + +Hi again, signed and attached. + +I assume you are representing the seller? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Gary Anzalone [mailto: + +Sent: Monday, April 19, 2021 1:39 PM + +To: Melissa Koboldt < >; Sherry Cannon + +Subject: N722JE - Sikorsky 576C++ sn 760750 + +CA + +TITLE SERVICE + +• C + +©OO + +Attached you will find the executed and counter executed APA between Hyperion Air LLC and Industrial + +Integrity Solutions LLC for Sikorsky S76C++ sn 76075o, N722JE. + +Additionally, I have attached the Exhibit C Technical acceptance making the deposit hereby non + +refundable. + +At your convenience, can you please return a copy of the APA with your executed Consent and Joinder? + +I expect you have already spoken with Rich Munkvold of Industrial Integrity Solutions with respect to lien + +searches, IR etc, but I will differ to him with respect to the timing of the closing. + +I am fairly certain there are no plans to close this week. Let me know what he tells you in this respect. + +Sincerely, + +Gary Anzalone + +Managing Partner + +• + +From: Sent: To: Cc: Subject: Attachments: + +here you go! + +sincerely, + +Gary Anzalone Mana =in = Partner Gary Anzalone < > on behalf of Gary Anzalone + +Wednesday, May 5, 2021 2:51 PM + +Melissa Koboldt + +Sherry Cannon + +Re: N722JE - Sikorsky S76C++ sn 760750 + +4-14-21 Revised Aircraft Purchase Agreement (PREVITI - HYPERION) Rev.1 Redline.docx + +On Wed, May 5, 2021 at 2:48 PM Melissa Koboldt < > wrote: + +Will do. + +Do you have the APA in word version by chance? I need to pull the WBOS out of it. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Gary Anzalone [mailto: + +Sent: Wednesday, May 05, 20212:39 PM + +To: Melissa Koboldt + +Cc: Sherry Cannon + +Fax: + +al + +TITLE SERVICE + +0 0 to + +Honestly it may make Buyer happy so please test the water with Darren and let me know. + +Sincerely, + +Gary Anzalone + +Managing Partner + +On Wed, May 5, 2021 at 2:35 PM Melissa Koboldt wrote: + +Well ya know no one ever closes on the date it says lol. + +Will do. + +I can always hand to another agent to close if it's going to cause heartburn with either party. + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: Or Fax: + +Skype: melissa.koboldt www.aictitle.com + +aA t i C + +TITLE SERVICE + +0 O O + +Sent: Wednesday, May 05, 2021 2:11 PM To: Melissa Koboldt > + +Cc: -;Sherry Cannon wrote: + +Hi Gary, + +This Friday (r)? I'm out of office. + +Escrow agent + +AIC Title Service + +Tel: Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Gary Anzalone [mailto + +Sent: Wednesday, May 05, 2021 1:57 PM + +To: Melissa Koboldt < Cc: Sherry Cannon + +Subject: Re: N722.IE - Sikorsky S76C++ sn 760750 + +Hi Melissa, + +•= > + +We are getting our ducks in a row to close the S76 on Friday. + +K s - C + +TITLE SERVICE + +©00 + +Just as we did on the G5,5o, can you please email a copy of the proposed WBOS and FAA BOS to Sellers attorney Darren lndyke to approve the form, prior to sending them to Captain Larry Visosky to docusign? + +Darren Indyke + +• Work + +Sincerely, + +Gary Anzalone + +On Wed, Apr 21, 2021 at 9:54 AM Melissa Koboldt .ic= > wrote: + +Roger. + +Melissa Koboldt + +Escrow agent + +NC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aiclitle.com + +From: Gary Anzalone [mailto: + +Sent: Wednesday, April 21, 2021 9:50 AM + +To: Melissa Koboldt Cc: Sherry Cannon + +Subject: Re: N722JE - Sikorsky 576C++ sn 760750 + +Hi Melissa + +Thank you for getting this back to us! + +SAC + +TITLE SERVICE + +0 0 0 + +Actually, both parties are EQUUS's clients, but on this one we will be paid by the Seller! + +Sincerely, + +Gary Anzalone + +Managing Partner + +1 + +On Tue, Apr 20, 2021 at 11:02 PM Melissa Koboldt < + +Hi again, signed and attached. + +I assume you are representing the seller? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +> wrote: + +ArA t i C + +TITLE SERVICE + +©00 + +From: Gary Anzalone [mailto: + +Sent: Monday, April 19, 2021 1:39 PM + +To: Melissa Koboldt < >; Sherry Cannon \*c > + +Subject: N722JE - Sikorsky S76C++ sn 760750 + +Attached you will find the executed and counter executed APA between Hyperion Air LLC and Industrial + +Integrity Solutions LLC for Sikorsky 576C++ sn 760750, N722JE. + +Additionally, I have attached the Exhibit C Technical acceptance making the deposit hereby non + +refundable. + +At your convenience, can you please return a copy of the APA with your executed Consent and Joinder? + +I expect you have already spoken with Rich Munkvold of Industrial Integrity Solutions with respect to lien + +searches, IR etc, but I will differ to him with respect to the timing of the closing. + +I am fairly certain there are no plans to close this week Let me know what he tells you in this respect. + +Sincerely, + +Gary Anzalone + +Managing Partner + +• + +• + +• + +• + +From: Sent: To: Cc: Subject: Gary Anzalone < + +Thursday, May 6, 2021 3:35 PM + +Melissa Koboldt Rich Munkvold + +Re: N722JE delivery receipt + +> on behalf of Gary Anzalone + +Melissa + +You will have to ask Darren I ndyke for that authorization. I am ok to waive notary if it is docusigned but it is up + +to him + +Gary Anzalone Mana in Partner + +On Thu, May 6, 2O21 at 3:28 PM Melissa Koboldt > wrote: + +Does the delivery receipt need to be notarized or can I send to Rich for digital signature? + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +ArA t i C + +TITLE SERVICE + +0 CD + +Sent: Thursday, May 06, 2021 3:32 PM + +To: 'Darren Indyke' + +Cc: 'Richard Kahn' ; 'Gary Anzalone' ); Jonathan Williams + +Subject: RE: N722JE Escrow - AIC Title Service + +Darren, can you please reply? I'm trying to get this ready for closing tomorrow for another agent. Jon + +Williams is copied here and will assist in my absence. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Melissa Koboldt frnailto + +Sent: Thursday, May 06, 2021 1:17 PM + +To: 'Darren Indyke' + +Cc: 'Richard Kahn' c: >; 'Larry Visoski' a; 'Gary Anzalone' + +Fax: + + + +Subject: RE: N722JE Escrow - AIC Title Service + +Darren, is there anything else to pay out of escrow other than the broker fee and /2 the escrow fee? + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Melissa Koboldt [mak° + +Sent: Thursday, May 06, 2021 12:23 PM + +To: 'Darren Indyke' Cc: 'Richard Kahn' + +C + +Subject: RE: N722JE Escrow - AIC Title Service + +Fax: + +; 'Larry Visoski' a; 'Gary Anzalone' + +You were only on copy, they were sent to Larry for his signature. + +The PUE requests for the IR will be going out this afternoon, you'll need to advise IATS (the IR + +administrator) to approve AIC's request. + +Please send me closing/disbursement instructions. + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke [mailto + +Sent: Thursday, May 06, 2021 12:18 PM + +To: Melissa Koboldt + +Cc: Richard Kahn < Larry Visoski a; Gary Anzalone + +Fax: + +Subject: Re: N722JE Escrow-AIC Title Service + +Larry C should sign as manager. You sent the docs to me to sign? + +Sent from my iPhone. Please excuse the typos. + +On May 6, 2021, at 1:16 PM, Darren Indyke < wrote: + +What about getting Larry closing docs? Also do we need to do anything Re the Intl + +registry? + +Sent from my iPhone. Please excuse the typos. + +On May 6, 2021, at 1:12 PM, Melissa Koboldt + + wrote: + +I haven't been able to find anyone who can take it yet, will keep you + +posted. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke Imailto + +Sent: Wednesday, May 05, 2021 5:50 PM + +To: Melissa Koboldt + +Cc: Richard Kahn < Larry Visoski + +< >; Gary Anzalone + +Fax: + +> + +Subject: Re: N722JE Escrow-AIC Title Service + +No to change FAA but yes to change warranty bos. Please See how + +difficult Friday would be and we can decide after you let us + +On May 5, 2021, at 6:41 PM, Melissa Koboldt + +wrote: + +The FAA has is registered with no comma- + + + +Do you still want it added? + +Yes I can change the WBOS. + +Everyone is booked in closings, I can see if it can be squeezed in but Monday would be preferable. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke + +[mailto: + +Sent: Wednesday, May 05, 20215:24 PM + +To: Melissa Koboldt < Cc: Richard Kahn < + +Visoski < M>; Gary Anzalone + +< + +Fax: + +Subject: Re: N722JE Escrow - AIC Title Service + +>; Larry + +Thank you for the dots. A couple of revisions Can you make seller Hyperion Air, LLC on FAA bos (you forgot the comma after "Air"). Can you change date to May on warranty bos. And re moving closing, is there no one in your office who can do it on Friday? Please + +advise. Thank you again. + +Sent from my iPhone. Please excuse the typos. + +On May 5, 2021, at 5:11 PM, Melissa + +Koboldt wrote: + + + +Please review the FAA BOS and WBOS and advise if everything is in order and I will have them sent to Larry for digital + +signatures. + +It is my understanding closing was targeted for 5-7-2021 however I will be out of the office, do you have any issue with closing to occur on 5-10-2021? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: Or + +Skype: melissa.koboldt www.aictitle.com + + Fax: + + + +From: Sent: To: Subject: + +please add to closing statement + +Sincerely, + +Gary Anzalone Mana Partner Gary Anzalone < > on behalf of Gary Anzalone + +Thursday, May 6, 2021 3:58 PM + +Melissa Koboldt + +Fwd: EXTERNAL: Re: Sikorsky Statement- Hyperion Air + +Forwarded message + +From: Larry Visoski < + +Date: Thu, May 6, 2021 at 2:32 PM + +Subject: Fwd: EXTERNAL: Re: Sikorsky Statement- Hyperion Air + +To: Darren Indyke >, Rich Kahn , Gary Anzalone + +Sorry I've been off the grid had technical issues with my email address, is it possible to add this payment to Sikorsky + +from escrow funds? Reference PAP power assurance program for the gearboxes + +This payment was from the previous buyer from India from our flight January and February + +Sent from my iPhone + +Begin forwarded message: + +From: "Stablein, Nancy M" .cz > + +Date: May 5, 2021 at 7:12:16 AM PDT + +To: Larry + +Subject: RE: EXTERNAL: Re: Sikorsky Statement- Hyperion Air + +Good morning Larry, + +Just wanted to follow up on the status of payment as we have not received it yet. + +Company + +Code Payer Payer Name2 Reference Document # Document + +Amount + +Document Date + +Best Regards, + +Nancy Stablein + +Global Financial Services/Commercial Collections + +Sikorsky Commercial Inc., A Lockheed Martin Company + +Email: Office: + +SIKORSKY + +A LOCKHEED MARTIN COMPANY + +From: Larry < + +Sent: Tuesday, April 20, 2021 9:02 AM + +To: Stablein, Nancy M (US) < + +Subject: Re: EXTERNAL: Re: Sikorsky Statement- Hyperion Air + +Hi Nancy, I'm sorry to bother you with this" + +Yes, I have another contact for sure, + +I'll get payment processed and update asap + +Thx + +Larry + +Sent from my iPad + +Good morning Larry, + +I am in the collections department and I do not handling invoicing flight hours. Do you have another contact within Sikorsky that you have been sending these hours to bill? + +Best Regards, + +Nancy Stablein + +Global Financial Services/Commercial Collections + +Sikorsky Commercial Inc., A Lockheed Martin Company + +Email: I Office: + + + +From: Larry < + +Sent: Monday, April 19, 2021 4:15 PM + +To: Stablein, Nancy M (US) + +Subject: EXTERNAL: Re: Sikorsky Statement- Hyperion Air + +Hi Nancy + +We finally have a buyer for 760750 N722JE, we should close in 2 weeks, + +Can I ask for your assistance, I've attached a copy of the current total time for the 576. + +Could you add this to my invoice, we have barley flown the helicopter, just monthly + +engine runs, + +Can you send me a total invoice to pay up in full, so we can deduct this from the Closing + +of the helcopter, + +Larry Visoski + +Manager + +Hyperion Air, LLC + +N722JE + + + +Sent from my iPad + +On Apr 6, 2021, at 6:16 AM, Stablein, Nancy M + +wrote: + +Good morning Larry, + +Please see below your current statement. The invoice is now 31 days past due. Please let me know when we should be expecting payment. + +Company Account Reference Document Document Net due date Arrears Code Number Date net due + +6120 17382 0008117788 6000005896 2/4/2021 3/6/2021 + +Best Regards, + +From: Gary Anzalone < > on behalf of Gary Anzalone + +Sent: Thursday, May 6, 2021 4:02 PM + +To: Melissa Koboldt; + +Subject: Fwd: EXTERNAL: Re: Sikorsky Statement- Hyperion Air + +Dear Nancy, + +We will get this balance funded out of escrow tomorrow or Monday when the helicopter sells. + +Can you please provide the applicable wiring instruction to Melissa Kobaldt of AIC Title, as she is copied herein + +and her contact information is as follows; + +Melissa Koboldt Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +Gary Anzalone Mana in Partner Fax: + +From: \*Stablein. Nancy M" + +Date: May 5. 2021 at 7:12:16 AM PDT + +To: Larry la> + +Subject: RE: EXTERNAL: Re: Sikorsky Statement- Hyperion Air + +Good morning Larry, + +Just wanted to follow up on the status of payment as we have not + +received it yet. + +Company + +Code Payer Payer Name2 Reference Document # Documen + +Amount + +6120 17382 Hyperion Air, LLC + +Hyperion Air, LLC Total + +0008117788 6000005896 1,371 + +1,371 + +Global Financial Services/Commercial Collections Sikorsky Commercial Inc., A Lockheed Martin Company + +Email: + + + +Sent: Tuesday, April 20, 2021 9:02 AM + +To: Stablein, Nancy M (US) < + +Subject: Re: EXTERNAL: Re: Sikorsky Statement- Hyperion Air + +Hi Nancy, I'm sorry to bother you with this" + +Yes, I have another contact for sure, + +I'll get payment processed and update asap + +Thx Larry + +Sent from my iPad + +On Apr 20, 2021, at 4:54 AM, Stablein, Nancy M + +wrote: + +Good morning Larry, + +I am in the collections department and I do not handling invoicing flight hours. Do you have another contact within Sikorsky that you have been sending + +these hours to bill? + +Best Regards, + +Nancy Stablein + +Global Financial Services/Commercial Collections Sikorsky Commercial Inc., A Lockheed Martin Company + +Email: + +cimage003.png> + +I Office: + +From: Larry < > + +Sent: Monday, April 19, 2021 4:15 PM + +To: Stablein, Nancy M (US) + +Subject: EXTERNAL: Re: Sikorsky Statement- Hyperion + +Air + +Can I ask for your assistance, I've attached a copy of + +the current total time for the S76. + +Could you add this to my invoice, we have barley flown + +the helicopter, just monthly engine runs, + +Can you send me a total invoice to pay up in full, so we can deduct this from the Closing of the helcopter, The new owner will certainly continue with PAP + +program with you, Thanks in Advance Larry Visoski Manager + +Hyperion Air, LLC + +N722JE + + + +Sent from my iPad + +On Apr 6, 2021, at 6:16 AM, Stablein, + +Nancy M + +wrote: + +Good morning Larry, + +Please see below your current + +statement. The invoice is now 31 days past due. Please let me know when we + +should be expecting payment. + +Company Account Reference Document Document Net du + +Code Number Date + +6120 17382 0008117788 6000005896 2/4/2021 3 + +Best Regards, + +Nancy Stablein + +Global Financial Services/Commercial + +Collections + +Sikorsky Commercial Inc., A Lockheed + +Martin Company + +From: Gary Anzalone < + +Sent: Thursday, May 6, 2021 5:41 PM + +To: Melissa Koboldt + +Cc: Darren Indyke; Richard Kahn; + +Subject: Re: N722JE Escrow - AIC Title Service + +> on behalf of Gary Anzalone + +Jonathan Williams + +Melissa, + +We are waiting on an invoice from Banyan for any applicable hangar balances due. They told Larry we will have + +it in minutes + +Sincerely, + +Gary Anzalone Mana Partner + +On Thu, May 6, 2O21 at 5:38 PM Melissa Koboldt t > wrote: + +Please see attached draft closing statement, these are the numbers as far as I know them, if anything changes please + +advise Jon. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke (math° + +Sent: Thursday, May 06, 2021 4:06 PM + +To: Melissa Koboldt < Cc: Darren Indyke < + +TITLE SERVICE + +000 + +>; Richard Kahn < >; + +As long as we get a notarized fly away affidavit, then I am ok with an e signature on the delivery receipt. + +We are getting figures together for additional disbursements and will finalize as soon as possible and make sure to send + +them to Jonathan. Thank you. + +DARREN K. INDYKE + +Telephone: Telecopier: Mobile: email: + +The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail, and destroy this + +communication and all copies thereof, including all attachments. + +Copyright of Darren K. Indyke - 2019 Darren K. Indyke - All rights reserved. + +On May 6, 2021, at 5:02 PM, Melissa Koboldt wrote: + +I don't believe the delivery receipt would need to be notarized since there will be a fly away affidavit. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +Fax: + + + +Sent: Thursday, May 06, 2021 3:49 PM + +To: Melissa Koboldt Cc: Darren Indyke + +>; + +Subject: Re: N722JE Escrow - AIC Title Service + +Richard Kahn + +Jonathan Williams + +If we want to demonstrate that the delivery was done in Florida, we will need a notarized delivery + +receipt, I believe. + +DARREN K. INDYKE + +Telephone: Telecopier. Mobile: email: + +it\* • .\*\*\*\*\*\*\*\*.\*\*\*1111.\*\*\*111.\*\*.\*\*.\*\*\*\*\*\*1001.1.11\* \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* • It 1St. \*\*\*\*\*\*\*\*\*\* Fat • I • HI • Fit ttf • \*it The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail, and destroy this + +communication and all copies thereof, including all attachments. + +Copyright of Darren K. Indyke - O 2019 Darren K. Indyke - All rights reserved. + +................ ................ ..................... + +On May 6, 2021, at 4:47 PM, Melissa Koboldt > wrote: + +Also, is it necessary for the delivery receipt to be notarized or can you accept a digital + +signature? + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +From: Melissa Koboldt fmailto: + +Sent: Thursday, May 06, 2021 3:32 PM + +To: 'Darren Indyke' + +Cc: 'Richard Kahn' >; 'Larry Visoski' c ; 'Gary + +Anzalone' Jonathan Williams + +Subject: RE: N722JE Escrow-AIC Title Service + +Darren, can you please reply? I'm trying to get this ready for closing tomorrow for + +another agent. Jon Williams is copied here and will assist in my absence. + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Melissa Koboldt Irnailto: + +Sent: Thursday, May 06, 2021 1:17 PM + +To: 'Darren Indyke' Cc: 'Richard Kahn' + +Anzalone' + +Subject: RE: N722JE Escrow - AIC Title Service + +; 'Larry Visoski' < >; 'Gary + +Darren, is there anything else to pay out of escrow other than the broker fee and /2 the + +escrow fee? + +Melissa Koboldt + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Melissa Koboldt (matIto: + +Sent: Thursday, May 06, 2021 12:23 PM + +To: 'Darren Indyke' Cc: 'Richard Kahn' + +Anzalone' + +Subject: RE: N722JE Escrow - AIC Title Service + +; 'Larry Visoski' < >; 'Gary + +You were only on copy, they were sent to Larry for his signature. + +The PUE requests for the IR will be going out this afternoon, you'll need to advise IATS + +(the IR administrator) to approve AIC's request. + +Please send me closing/disbursement instructions. + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: Fax: + +Skype: melissa.koboldt www.aictitle.com + +Anzalone + +Subject: Re: N722JE Escrow - AIC Title Service + +Larry C should sign as manager. You sent the docs to me to sign? + +Sent from my iPhone. Please excuse the typos. + +On May 6, 2021, at 1:16 PM, Darren Indyke C wrote: + +What about getting Larry closing docs? Also do we need to do + +anything Re the intl registry? + +Sent from my iPhone. Please excuse the typos. + +On May 6, 2021, at 1:12 PM, Melissa Koboldt + +wrote: + +I haven't been able to find anyone who can take it yet, + +will keep you posted. + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke + +Subject: Re: N722JE Escrow - AIC Title Service + +No to change FAA but yes to change warranty + +bos. Please See how difficult Friday would be and we + +can decide after you let us know. Thanks. + +Sent from my iPhone. Please excuse the typos. + +On May 5, 2021, at 6:41 PM, Melissa + +Koboldt < wrote: + +The FAA has is registered with no + +comma- + + + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke + +[mailto: + +Sent: Wednesday, May 05, 2021 5:24 + +PM + +To: Melissa Koboldt + +Cc: Richard Kahn + +ca; Larry Visoski < I>; Gary + +Anzalone + +< + +Subject: Re: N722JE Escrow - AIC Title + +Service + +Thank you for the docs. A couple of revisions Can you make seller Hyperion Air, LLC on FAA bos (you forgot the comma after "Air"). Can you change date to May on warranty bos. And re moving closing, is there no one in your office who can do it on Friday? Please advise. Thank you + +again. + +Sent from my iPhone. Please excuse + +the typos. + +On May 5, 2021, at 5:11 PM, Melissa + +Koboldt + +M> wrote: + +Hi Darren, + +Please review the FAA BO5 and WBOS and advise if everything is in order and I will have them sent to Larry for digital signatures. + +It is my understanding closing was targeted for 5-7-2021 however I will be out of the office, do you have any issue with closing to occur on 5-10- + +2021? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + + + + + + + + on behalf of Gary Anzalone + +Sent: Monday, May 10, 2021 8:18 AM + +To: Rich Munkvold + +Cc: Melissa Koboldt; Sherry Cannon + +Subject: Re: N7221E Extension + +Attachments: Second Amendment to Aircraft Purchase Agreement with revision to page 2 signed by + +both but initialed by DKI only.pdf + +Rich, + +Attached is the counter execution from the Seller with noted typo which has been corrected and initialled. When you have a moment to please initial the correction and return it, it would be greatly appreciated. + +Gary Anzalone Mana•in Partner + +On Sat, May 8, 2021 at 12:33 PM Rich Munkvold wrote: + +Melissa, + +Attached is our signature on the extension of escrow until 5/13/21. + +Thanks! + +From: Gary Anzalone < + +Sent: Monday, May 10, 2021 5:07 PM + +To: Melissa Koboldt + +Cc: Darren Indyke; Richard Kahn; + +Subject: Re: N722JE Escrow - AIC Title Service + +Attachments: 0730\_001.pdf; Untitled attachment 00039.html + +Melissa, + +> on behalf of Gary Anzalone + +Attached is the fully executed 2nd amendment. + +As per Rich Munkvold's authorization you can now release the 200,000 dollar non refundable deposit to the Seller. + +Gary Anzalone Equus Aviation + +From: Gary Anzalone < > on behalf of Gary Anzalone + +Sent: Wednesday, May 12, 2021 8:51 AM To: Melissa Koboldt; Sherry Cannon + +Cc: Darren Indyke; + +Subject: Re: N722JE Aircraft Escrow Closing Statement, AIC Title Service, LLC + +'Thank you Melissa, + +Please let us know when you receive the balance of the funds today. + +We will not require a group conference closing, however Darren Indyke will require a quick run through + +between the two of you prior to closing. + +Gary Anzalone Mana ' Partner + +On Tue, May 11, 2021 at 8:58 PM < > wrote: + +AIC's Automated Aircraft Escrow Services Providing the latest, most up-to-date info for our clients. + +Hello, + +Please click the link below to view your Aircraft Escrow Closing Statement. + +Aircraft Escrow Closing Statement - CLICK HERE + +Note: This link will expire after 14 days. + +Ni + +If you're unable to click the HTML formatted link above, please manually copy and paste this entire URL into the + +address bar of your web browser: + +https://www.aictitle.com/clefault.aspx?tabid=948&sus=ER0MDmxCgw7LbexcliCH8Yw963d%3d + +Thank you for your business. + +AIC Title Service, LLC + +Tel: + +From: Gary Anzalone < + +Sent: Wednesday, May 12, 2021 3:58 PM + +To: Melissa Koboldt + +Subject: N722JE + +Have you heard from Rich Munkvold and or received the balance of funds? + +Gary Anzalone Mana int Partner > on behalf of Gary Anzalone + +From: Gary Anzalone < + +Sent: Wednesday, May 5, 2021 1:57 PM + +To: Melissa Koboldt; Cc: Sherry Cannon + +Subject: Re: N722JE - Sikorsky S76C++ sn 760750 + +> on behalf of Gary Anzalone + +Hi Melissa, + +We are getting our ducks in a row to close the S76 on Friday. + +Just as we did on the G55o, can you please email a copy of the proposed WBOS and FAA BOS to Sellers attorney Darren Indyke to approve the form, prior to sending them to Captain Larry Visosky to docusign? + +Darren Indyke + +• Work + +Gary Anzalone Mana in Partner + +On Wed, Apr 21, 2021 at 9:54 AM Melissa Koboldt wrote: + +Roger. + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +TITLE SERVICE + +0 0 0 + +Subject: Re: N7221E - Sikorsky 576C++ sn 760750 + +Hi Melissa + +Thank you for getting this back to us! + +Actually, both parties are EQUUS's clients, but on this one we will be paid by the Seller! + +Sincerely, + +Gary Anzalone + +Managing Partner + +On Tue, Apr 20, 2021 at 11:02 PM Melissa Koboldt + +Hi again, signed and attached. + +I assume you are representing the seller? + +Thanks, + +wrote: + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Gary Anzalone [mailto + +Sent: Monday, April 19, 2021 1:39 PM + +To: Melissa Koboldt + +Subject: N722JE - Sikorsky 576C++ sn 760750 + +Hi Melissa + +All - 1 • TITLE SERVICE + +0 O O + +; Sherry Cannon .ct > + +Attached you will find the executed and counter executed APA between Hyperion Air LLC and Industrial + +Integrity Solutions LLC for Sikorsky S76C++ an 760750, N722JE. + +Additionally, I have attached the Exhibit C Technical acceptance making the deposit hereby non refundable. + +At your convenience, can you please return a copy of the APA with your executed Consent and Joinder? + +I expect you have already spoken with Rich Munkvold of Industrial Integrity Solutions with respect to lien + +searches, IR etc, but I will differ to him with respect to the timing of the closing. + +I am fairly certain there are no plans to close this week. Let me know what he tells you in this respect. + +Gary Anzalone + +Managing Partner + +a + +From: Gary Anzalone < + +Sent: Wednesday, May 5, 2021 2:11 PM + +To: Melissa Koboldt + +Cc: Sherry Cannon + +Subject: Re: N722JE - Sikorsky S76C+ + sn 760750 + +> on behalf of Gary Anzalone + +ruh roh...I am guessing you did not catch the date on the amendment we sent you on the zoth. + +I am certain that Monday would be ok with the Purchaser. + +I suggest you send the draft BOS and WBOS to Darren Indyke (seller) and just let him know you have a conflict + +and ask him if Monday is ok with him. I am sure we will be ok. + +Gary Anzalone Mana in Partner + +On Wed, May 5, 2021 at 2:06 PM Melissa Koboldt < wrote: + +Hi Gary, + +This Friday (71? I'm out of office. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +aA t i C + +TITLE SERVICE + +0 0 0 + +Sent: Wednesday, May 05, 2021 1:57 PM To: Melissa Koboldt ttj >; + +Cc: Sherry Cannon ••: + +Subject: Re: N722JE - Sikorsky 576C++ sn 760750 + +> + +Hi Melissa, + +We are getting our ducks in a row to close the 576 on Friday. + +Just as we did on the G55o, can you please email a copy of the proposed WBOS and FAA BOS to Sellers attorney Darren Indyke to approve the form, prior to sending them to Captain Larry Visosky to docusign? + +Darren Indyke + +• Work + +Sincerely, + +Gary Anzalone + +Managing Partner + +On Wed, Apr 21, 2021 at 9:54 AM Melissa Koboldt ca wrote: + +Roger. + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Gary Anzalone [mailto + +Sent: Wednesday, April 21, 2021 9:50 AM + +To: Melissa Koboldt Cc: Sherry Cannon + +Subject: Re: N722JE - Sikorsky S76C++ sn 760750 + +Hi Melissa + +Thank you for getting this back to us! + +ArA t + +TITLE SERVICE + +©OO + +Actually, both parties are EQUUS's clients, but on this one we will be paid by the Seller! + +Sincerely, + +Gary Anzalone + +Managing Partner + +I assume you are representing the seller? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Gary Anzalone [mailto: + +Sent: Monday, April 19, 2021 1:39 PM + +To: Melissa Koboldt + +Subject: N722JE - Sikorsky 576C++ sn 760750 + +Hi Melissa + +; Sherry Cannon + +al C TITLE SERVICE + +0 0 0 + +Attached you will find the executed and counter executed APA between Hyperion Air LLC and Industrial + +Integrity Solutions LLC for Sikorsky S76C++ sn 76075o, N722JE. + +Additionally, I have attached the Exhibit C Technical acceptance making the deposit hereby non refundable. + +At your convenience, can you please return a copy of the APA with your executed Consent and Joinder? + +I am fairly certain there are no plans to close this week. Let me know what he tells you in this respect. + +Sincerely, + +Gary Anzalone + +Managing Partner + +• + +From: Gary Anzalone < + +Sent: Wednesday, May 12, 2021 4:58 PM + +To: Melissa Koboldt Subject: Re: N7221E + +> on behalf of Gary Anzalone + +neat - I 'ust spoke with Darren Indyke and he is ready to have an authorization call with you on his cell + +after you speak with Rich of course + +Gary Anzalone Mana in Partner + +On Wed, May 12, 2021 at 4:44 PM Melissa Koboldt wrote: + +Already sent him an email. + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Gary Anzalone [mailto: + +Sent: Wednesday, May 12, 2021 4:44 PM + +To: Melissa Koboldt < Subject: Re: N722JE + +TITLE SERVICE + +0 0 0 + +CAN YOU CALL RICH AND ASK FOR AUTHORIZATION TO CLOSE? + +Gary Anzalone + +Managing Partner + +On Wed, May 12, 2021 at 4:33 PM Melissa Koboldt c > wrote: + +Ok sure as soon as I say no then the wire shows up, I now have funds. + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Gary Anzalone [mailto + +Sent: Wednesday, May 12, 2021 3:58 PM + +To: Melissa Koboldt Subject: N722JE + +Have you heard from Rich Munkvold and or received the balance of funds? + +Sincerely, + +a I 4t . + +TITLE SERVICE + +0 O O + +Managing Partner + +From: Gary Anzalone < > on behalf of Gary Anzalone + +Sent: Thursday, May 13, 2021 9:52 AM + +To: Melissa Koboldt + +Cc: Rich Munkvold; Tia Goodman; Sherry Cannon; Larry Visoski + +Subject: Re: N722JE Escrow + +Thank you + +Sincerely, + +Gary Anzalone Mana Yin T Partner + +On Thu, May 13, 2021 at 9:43 AM Melissa Koboldt • wrote: + +Funds have been released and dots submitted to the FAA for filing at 9:40 CDT. I will get closing statements and doc + +sent out later today. + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold [mailto: + +Sent: Wednesday, May 12, 2021 4:59 PM + +To: Melissa Koboldt < + +Cc: Gary Anzalone < >; Tia Goodman c + +Sherry Cannon < + +Subject: RE: N722JE Escrow + +C + +TITLE SERVICE + +0 0 0 + +>; Larry Visoski < + +Thanks! + +From: Melissa Koboldt + +Sent: Wednesday, May 12, 2021 2:44 PM + +To: Rich Munkvold Cc: Gary Anzalone < Sherry Cannon < + +Subject: RE: N722JE Escrow + +Hi Rich, + +>; Tia Goodman + +We have received the balance of funds into escrow, please let me know when you are ready to proceed with closing. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold [mailto: + +Sent: Tuesday, May 11, 20211:23 PM + +To: Melissa Koboldt Cc: Gary Anzalone Sherry Cannon + +Subject: RE: N722JE Escrow + +TITLE SERVICE + +Tia Goodman + +OOO + +Can you please send over a revised closing statement reflecting the additional deposit? + +Thanks! + +From: Melissa Koboldt + +Sent: Tuesday, May 11, 2021 11:15 AM + +To: Rich Munkvold < + +Cc: Gary Anzalone < I>; Tia Goodman + +Sherry Cannon < + +Subject: RE: N722JE Escrow + +I have received the mutually executed extension and will now wire the \$200k to seller. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold [mailto: + +Sent: Friday, May 07, 2021 12:45 PM + +To: Melissa Koboldt Cc: Gary Anzalone Sherry Cannon + +Subject: N722JE Escrow + +al + +TITLE SERVICE + +Tia Goodman + +000 + +We will not be closing escrow on N722JE today. We are extending the closing until next Wednesday (5/12). + +We have also wired in an additional \$100,000 as good faith. This can be released to the sellers upon you having a + +mutually executed extension to 5/12/21. + +Thanks! + +From: Molli King < + +Sent: Thursday, May 13, 2021 9:40 AM + +To: Melissa Koboldt + +Cc: PDR + +Subject: Re: N722HE hold folder + +9:40 + +Molli King + +FAA Specialist + +On Thu, May 13, 2021 at 9:39 AM Melissa Koboldt < + +Ready! Let me know drop time. + +Melissa Koboldt + +Escrow agent + +on behalf of Molli King + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Molli King (mailto + +Sent: Thursday, May 13, 2021 9:37 AM + +To: Melissa Koboldt + +Cc: PDR Subject: Re: N722HE hold folder + +> wrote: + +&A t! C TITLE SERVICE + +©OO + +Molli King + +FAA Specialist + +On Thu, May 13, 2021 at 9:35 AM Melissa Koboldt < wrote: + +Change please + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Molli King [mailto: + +Sent: Thursday, May 13, 2021 9:28 AM + +To: Melissa Koboldt + +Cc: PDR Subject: Re: N722HE hold folder aA t i C + +TITLE SERVICE + +©OO + +Cover Letter is dated May 7th... do you want me to change it or leave as is? + +On Thu, May 13, 2021 at 9:26 AM Melissa Koboldt < I> wrote: + +Please date docs today and get money ready and put back on hold, will be filing momentarily + +FAA letters + +BOS + +ARA + +LLC already dated, will leave as is + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +al C + +TITLE SERVICE + +000 + +From: Larry Visoski <-> on behalf of Larry Visoski + +Sent: Thursday, May 13, 2021 10:20 AM + +To: Melissa Koboldt + +Cc: Rich Munkvold; Gary Anzalone; Tia Goodman + +Subject: Re: N722JE + +Attachments: 0769\_001.pdf; Untitled attachment 00293.htm + +I'm sorry Melissa + +here is the updated sheet, only thing needs to be plugged in is the delivery time + +Thx Larry + +From: Gary Anzalone < + +Sent: Wednesday, May 12, 2021 4:44 PM + +To: Melissa Koboldt Subject: Re: N7221E + +CAN YOU CALL RICH AND ASK FOR AUTHORIZATION TO CLOSE? + +Sincerely, + +Gary Anzalone Manayin Partner + +On Wed, May 12, 2021 at 4:33 PM Melissa Koboldt I> wrote: + +Ok sure as soon as I say no then the wire shows up, I now have funds. + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Gary Anzalone [mailto: + +Sent: Wednesday, May 12, 2021 3:58 PM + +To: Melissa Koboldt Subject: N722JE + +> on behalf of Gary Anzalone + +sA t l C + +TITLE SERVICE + +0 0 0 + +Have you heard from Rich Munkvold and or received the balance of funds? + +Gary Anzalone + +Managing Partner + +From: Sent: To: Subject: + +> Amount Account + +Bank Reference: Customer Referenn- + +Texl + +Amount Account + +Bank Reference Customer Referencr + +rem + +Amount Account + +Bank Reference Customer Reference + +rexi + +Darzhane Gresham < + +Thursday, May 13, 2021 9:53 AM + +Melissa Koboldt + +N722JE + +50.000 00 USD + +210513238387 0513238387 + +> on behalf of Darzhane Gresham + +6.976 50 USO + +210513238383 0513238383 + +1.490.75226 USD + +210513238388 0513238388 + +From: Darzhane Gresham < + +Sent: Thursday, May 13, 2021 9:53 AM + +To: Melissa Koboldt + +Subject: N722JE + +> on behalf of Darzhane Gresham + +The foitowing rf.gn Value Payment Outgoing transactions tor tne current t>ustness day were reported at 09 46 AM CDT on + +05113/2021. + +Amount Account + +Bank Reference Customer Referee + +Text + +1.371 24 USD + +210513238384 0513238384 + +From: Larry <-> on behalf of Larry Sent: Wednesday, May 12, 2021 8:00 PM + +To: Rich Munkvold + +Cc: Melissa Koboldt; Gary Anzalone; Tia Goodman + +Subject: Re: N7221E + +Attachments: 0769\_001.pdf; Untitled attachment 00052.htm + +Rich, + +Here you go, + +Thx, LarryV + +From: Rich Munkvold < + +Sent: Wednesday, May 12, 2021 7:29 PM + +To: Larry Visoski + +Cc: Melissa Koboldt; Gary Anzalone; Tia Goodman + +Subject: N722JE Attachments: 0769\_001.pdf > on behalf of Rich Munkvold + +Larry, + +Attached is the delivery certificate. Can you tell us the hours and landings so that Melissa can put in that information? + +Thanks! + +From: Darzhane Gresham < + +Sent: Thursday, May 13, 2021 9:53 AM + +To: Melissa Koboldt + +Subject: N722JE + +Amount. Account + +Bank Reference: Customer nerecenrp + +Text + +50.000 00 USD + +210513238387 0513238387 + +> on behalf of Darzhane Gresham + +Amount 6.976 50 USD + +Account + +Bank Reference 210513238383 Customer Reference 0513238383 + +rexl + +Amount 1.490.752 26 USD + +Account + +Bank Reference 210513238388 Customer Reference 0513238388 + +rext + +From: Rich Munkvold < + +Sent: Friday, May 7, 2021 12:45 PM + +To: Melissa Koboldt + +Cc: Gary Anzalone; Tia Goodman; Sherry Cannon + +Subject: N722JE Escrow + +> on behalf of Rich Munkvold + +Melissa, + +We will not be closing escrow on N722JE today. We are extending the closing until next Wednesday (5/12). + +We have also wired in an additional \$100,000 as good faith. This can be released to the sellers upon you having a + +mutually executed extension to 5/12/21. + +Thanks! + +From: Gary Anzalone < + +Sent: Monday, May 10, 2021 5:07 PM + +To: Melissa Koboldt + +Cc: Darren Indyke; Richard Kahn; + +Subject: Re: N722JE Escrow - AIC Title Service + +Attachments: 0730\_001.pdf; Untitled attachment 00039.html + +Melissa, + +> on behalf of Gary Anzalone + +Attached is the fully executed 2nd amendment. + +As per Rich Munkvold's authorization you can now release the 200,000 dollar non refundable deposit to the Seller. + +Gary Anzalone Equus Aviation + +From: Darren Indyke < + +Sent: Monday, May 10, 2021 10:53 AM + +To: Melissa Koboldt + +Cc: Darren Indyke; Richard Kahn; + +Jonathan Williams + +Subject: Re: N7221E Escrow - AIC Title Service + +Melissa, + +> on behalf of Darren Indyke + +Please see below wire transfer instructions to the Estate of Jeffrey Epstein, the sole member of Seller Hyperion Air, LLC, + +which instructions are to be used for all disbursements to Seller: + +Bank name: First Bank + +Routing number for wires + +Account name: Account address: + +Account number: + +Thank you. + +DARREN K. INDYKE + +Telephone: Telecopier: Mobile: email: + +Estate of Jeffrey Epstein + +The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail, and destroy this + +communication and all copies thereof, including all attachments. + +Copyright of Darren K. Indyke - © 2019 Darren K. Indyke - All rights reserved. + +On May 6, 2021, at 6:38 PM, Melissa Koboldt <.. > wrote: + +Please see attached draft closing statement, these are the numbers as far as I know them, if anything + +changes please advise Jon. + +Thanks, + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Melissa Koboldt [mailto: + +Sent: Thursday, May 06, 2021 1:17 PM + +To: 'Darren Indyke' Cc: 'Richard Kahn' < + +c: >; 'Gary Anzalone' + +Fax: + +Subject: RE: N722JE Escrow - AIC Title Service + +>; 'Larry Visoski' + +Darren, is there anything else to pay out of escrow other than the + +broker fee and % the escrow fee? + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: Or + +Skype: melissa.koboldt www.aictitle.com + +From: Melissa Koboldt [maiIto + +Sent: Thursday, May 06, 2021 12:23 PM + +To: 'Darren Indyke' Cc: 'Richard Kahn' < + +a 'Gary Anzalone' + +Fax: + +Subject: RE: N722JE Escrow - AIC Title Service + +>; 'Larry Visoski' + +You were only on copy, they were sent to Larry for his signature. + +The PUE requests for the IR will be going out this afternoon, you'll need + +to advise IATS (the IR administrator) to approve AIC's request. + +Please send me closing/disbursement instructions. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +Fax: + + + +< >; Gary Anzalone + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke + +[mailto: + +Sent: Wednesday, May 05, 2021 5:50 + +PM + +To: Melissa Koboldt + +Cc: Richard Kahn + +Visoski < + +; Larry >; Gary Anzalone + +Subject: Re: N722JE Escrow - AIC Title + +Service + +No to change FAA but yes to change warranty bos. Please See how difficult Friday would be and we can decide after you let us know. Thanks. + +Fax: + +On May 5, 2021, at 6:41 PM, Melissa Koboldt + +In> wrote: + +The FAA has is registered with no + +comma- + + + +Do you still want it + +added? + +Yes I can change the + +WBOS. + +Everyone is booked in closings, I can see if it can be squeezed in but Monday would be + +preferable. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Darren Indyke [mailto:dki.birchtreebr + +pgmail.comj + +Sent: Wednesday, May 05, 2021 5:24 PM To: Melissa Koboldt + +Cc: Richard Kahn + +=>; Larry Visoski + +Gary + +Anzalone + +Fax: + + wrote: + +Hi Darren, + +Please review the FAA BOS and WBOS and advise if everyth ing is in order and I will 7 + + + +From: Gary Anzalone < > on behalf of Gary Anzalone + +Sent: Monday, May 10, 2021 8:18 AM + +To: Rich Munkvold + +Cc: Melissa Koboldt; Sherry Cannon + +Subject: Re: N7221E Extension + +Attachments: Second Amendment to Aircraft Purchase Agreement with revision to page 2 signed by + +both but initialed by DKI only.pdf + +Rich, + +Attached is the counter execution from the Seller with noted typo which has been corrected and initialled. When you have a moment to please initial the correction and return it, it would be greatly appreciated. + +Gary Anzalone Mana•in Partner + +On Sat, May 8, 2021 at 12:33 PM Rich Munkvold wrote: + +Melissa, + +Attached is our signature on the extension of escrow until 5/13/21. + +Thanks! + +From: Rich Munkvold < + +Sent: Saturday, May 8, 2021 12:34 PM + +To: Melissa Koboldt + +Cc: Gary Anzalone; Sherry Cannon + +Subject: N722JE Extension Attachments: 0723\_001.pdf + +Melissa, + +Attached is our signature on the extension of escrow until 5/13/21. + +Thanks! + +> on behalf of Rich Munkvold + +From: Darzhane Gresham < + +Sent: Wednesday, May 12, 2021 4:03 PM + +To: Melissa Koboldt + +Subject: N722JE + +> on behalf of Darzhane Gresham + +Tne following Wire-High Value Payment Incoming transaaons Ice the current business day were reported at 16'01 PM CDT on + +05(12)2021 + +AmoUril Account + +Bank Reference Customer Reference' + +Text + +1 601.300 00 OW + +From: Rich Munkvold < > on behalf of Rich Munkvold + +Sent: Wednesday, May 12, 2021 4:59 PM + +To: Melissa Koboldt + +Cc: Gary Anzalone; Tie Goodman; Sherry Cannon; Larry Visoski + +Subject: RE: N722JE Escrow + +We can close when you are position to do so. + +Thanks! + +From: Melissa Koboldt < + +Sent: Wednesday, May 12, 2021 2:44 PM + +To: Rich Munkvold < + +Cc: Gary Anzalone >; Tia Goodman < Sherry + +Cannon + +Subject: RE: N722JE Escrow + +Hi Rich, + +We have received the balance of funds into escrow, please let me know when you are ready to proceed with closing. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold [mak() + +Sent: Tuesday, May 11, 2021 1:23 PM + +To: Melissa Koboldt + +Cc: Gary Anzalone >; Tia Goodman < >; Sherry + +Cannon + +Subject: RE: N722JE Escrow + +Fax: + +;cad C + +TITLE SERVICE + +000 + +Melissa, + +Can you please send over a revised closing statement reflecting the additional deposit? + +Thanks! + +From: Melissa Koboldt < + +Subject: RE: N722JE Escrow + +I have received the mutually executed extension and will now wire the \$200k to seller. + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold [mailto: + +Sent: Friday, May 07, 202112:45 PM + +To: Melissa Koboldt Cc: Gary Anzalone < + +Cannon < + +Subject: N722JE Escrow + +Melissa, + +We will not be closing escrow on N722JE today. We are extending the closing until next Wednesday (5/12). + +We have also wired in an additional \$100,000 as good faith. This can be released to the sellers upon you having a + +mutually executed extension to 5/12/21. + +Thanks! + +Fax: + +C + +TITLE SERVICE + +; Tia Goodman + +0 0 0 + +Sherry + +From: Darzhane Gresham < + +Sent: Tuesday, May 11, 2021 2:05 PM + +To: Melissa Koboldt + +Subject: N722JE + +> on behalf of Darzhane Gresham + +I ne toire.i.mg 1-1.gri Value Payment Outgomg transactions for the current business day were reported at 13 36 PM CDT on + +05/11/2021 + +Amount 200.000 00 USD + +Account + +Bank Reference 210511385377 Customer Reference 0511385377 + +Tex' + +From: Darzhane Gresham < + +Sent: Friday, May 7, 2021 12:10 PM + +To: Jonathan Williams + +Subject: N722JE + +> on behalf of Darzhane Gresham + +The tosoviiing Woolf irp Vaitre Payment incoming transactions tor the current business day were reported at 1206 PM CDT on + +05107/2021 + +Amount. 100,000 00 USD + +Account + +Bank Reference 210507367040 Cuslother Referencu 0507367040 + +Text + +From: Stablein, Nancy M < > on behalf of Stablein, Nancy M + +Sent: Thursday, May 6, 2021 4:47 PM To: Gary Anzalone; Melissa Koboldt; + +Subject: RE: EXTERNAL: Re: Sikorsky Statement- Hyperion Air + +Attachments: 0008117788.pdf + +Please see wire instructions under remit to section on the attached invoice. If you have any questions please let me + +know! + +Best Regards, + +Nancy Stablein + +Global Financial Services/Commercial Collections Sikorsky Commercial Inc., A Lockheed Martin Company + +Email: Office: + +SIKORSKY + +A LOCKHEED MARTIN COMPANY + +From: Gary Anzalone + +Sent: Thursday, May 6, 2021 5:02 PM + +To: Stablein, Nancy M (US) cza ; Melissa Koboldt + +Subject: Fwd: EXTERNAL: Re: Sikorsky Statement- Hyperion Air + +Dear Nancy, + +We will get this balance funded out of escrow tomorrow or Monday when the helicopter sells. + +Can you please provide the applicable wiring instruction to Melissa Kobaldt of AIC Title, as she is copied herein + +and her contact information is as follows; + +Melissa Koboldt Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +Fax: + +From: "Stablein. Nancy M" + +Date: May 5. 2021 at 7:12:16 AM PDT + +To: Larry + +Subject: RE: EXTERNAL: Re: Sikorsky Statement- Hyperion Air + +Good morning Larry, + +Just wanted to follow up on the status of payment as we have not + +received it yet. + +Company + +Code Payer Payer Name2 Reference Document # Documen + +Amount + +6120 17382 Hyperion Air, LLC + +Hyperion Air, LLC Total + +Best Regards, + +Nancy Stablein + +Global Financial Services/Commercial Collections Sikorsky Commercial Inc., A Lockheed Martin Company + +Email: + + + +Sent: Tuesday, April 20, 2021 9:02 AM + +To: Stablein, Nancy M (US) < + +Subject: Re: EXTERNAL: Re: Sikorsky Statement- Hyperion Air + +Hi Nancy, I'm sorry to bother you with this" + +Yes, I have another contact for sure, + +I'll get payment processed and update asap + +Thx Larry + +Sent from my iPad + +On Apr 20, 2021, at 4:54 AM, Stablein, Nancy M + +C + +wrote: + +1,371 1,371 + +I am in the collections department and I do not handling invoicing flight hours. Do you have another contact within Sikorsky that you have been sending + +these hours to bill? + +Best Regards, + +Nancy Stablein + +Global Financial Services/Commercial Collections Sikorsky Commercial Inc., A Lockheed Martin Company + +Email: + + + +I Office: + +From: Larry <.. > + +Sent: Monday, April 19, 2021 4:15 PM + +To: Stablein, Nancy M (US) + +Subject: EXTERNAL: Re: Sikorsky Statement- Hyperion + +Air + +Hi Nancy + +We finally have a buyer for 760750 N722JE, we should + +close in 2 weeks, + +Can I ask for your assistance, I've attached a copy of + +the current total time for the 576. + +Could you add this to my invoice, we have barley flown + +the helicopter, just monthly engine runs, + +Can you send me a total invoice to pay up in full, so we can deduct this from the Closing of the helcopter, The new owner will certainly continue with PAP + +program with you, Thanks in Advance Larry Visoski Manager + +Hyperion Air, LLC + +N722JE + + + +Sent from my iPad + +On Apr 6, 2021, at 6:16 AM, Stablein, + +Nancy M + +wrote: + +statement. The invoice is now 31 days past due. Please let me know when we + +should be expecting payment. + +Company Account Reference Document Document Net du + +Code Number Date + +6120 17382 0008117788 6000005896 2/4/2021 3 + +Best Regards, + +Nancy Stablein + +Global Financial Services/Commercial + +Collections + +Sikorsky Commercial Inc., A Lockheed + +Martin Company + +Email: Office: + + on behalf of Gary Anzalone + +Thursday, May 6, 2021 3:58 PM + +Melissa Koboldt + +Fwd: EXTERNAL: Re: Sikorsky Statement- Hyperion Air + +Forwarded message + +From: Larry Visoski < + +Date: Thu, May 6, 2021 at 2:32 PM + +Subject: Fwd: EXTERNAL: Re: Sikorsky Statement- Hyperion Air + +To: Darren Indyke >, Rich Kahn , Gary Anzalone + +Sorry I've been off the grid had technical issues with my email address, is it possible to add this payment to Sikorsky + +from escrow funds? Reference PAP power assurance program for the gearboxes + +This payment was from the previous buyer from India from our flight January and February + +Sent from my iPhone + +Begin forwarded message: + +From: "Stablein, Nancy M" .cz > + +Date: May 5, 2021 at 7:12:16 AM PDT + +To: Larry + +Subject: RE: EXTERNAL: Re: Sikorsky Statement- Hyperion Air + +Good morning Larry, + +Just wanted to follow up on the status of payment as we have not received it yet. + +Company + +Code Payer Payer Name2 Reference Document # Document + +Amount + +Document Date + +Best Regards, + +Nancy Stablein + +Global Financial Services/Commercial Collections + +Sikorsky Commercial Inc., A Lockheed Martin Company + +Email: Office: + +SIKORSKY + +A LOCKHEED MARTIN COMPANY + +From: Larry < + +Sent: Tuesday, April 20, 2021 9:02 AM + +To: Stablein, Nancy M (US) < + +Subject: Re: EXTERNAL: Re: Sikorsky Statement- Hyperion Air + +Hi Nancy, I'm sorry to bother you with this" + +Yes, I have another contact for sure, + +I'll get payment processed and update asap + +Thx + +Larry + +Sent from my iPad + +Good morning Larry, + +I am in the collections department and I do not handling invoicing flight hours. Do you have another contact within Sikorsky that you have been sending these hours to bill? + +Best Regards, + +Nancy Stablein + +Global Financial Services/Commercial Collections + +Sikorsky Commercial Inc., A Lockheed Martin Company + +Email: I Office: + + + +From: Larry < + +Sent: Monday, April 19, 2021 4:15 PM + +To: Stablein, Nancy M (US) + +Subject: EXTERNAL: Re: Sikorsky Statement- Hyperion Air + +Hi Nancy + +We finally have a buyer for 760750 N722JE, we should close in 2 weeks, + +Can I ask for your assistance, I've attached a copy of the current total time for the 576. + +Could you add this to my invoice, we have barley flown the helicopter, just monthly + +engine runs, + +Can you send me a total invoice to pay up in full, so we can deduct this from the Closing + +of the helcopter, + +Larry Visoski + +Manager + +Hyperion Air, LLC + +N722JE + + + +Sent from my iPad + +On Apr 6, 2021, at 6:16 AM, Stablein, Nancy M + +wrote: + +Good morning Larry, + +Please see below your current statement. The invoice is now 31 days past due. Please let me know when we should be expecting payment. + +Company Account Reference Document Document Net due date Arrears Code Number Date net due + +6120 17382 0008117788 6000005896 2/4/2021 3/6/2021 + +Best Regards, + +From: Sent: To: Cc: Subject: + +Thursday, May 6, 2021 3:23 PM + +You have been added to a Digital Signature Transaction. (P06A) + +AIC Digital Signature Transaction + +From: AIC Title < on behalf of AIC Title + +Sent: Thursday, May 6, 2021 2:52 PM + +To: LARRY VISOSKI Cc: Melissa Koboldt + +Subject: e-SignLive - the documents from "N7221E N722JE BOS (FInWSCn)" are available for + +download. + +Attachments: N722JE WBOS.pdf, - Electronic Disclosures and Signatures Consent.pdf; N722JE N7221E + +BOS (FInWSCn).pdf + +Hi LARRY VISOSKI, + +Signing is completed for e-SignPackage "N722JE N7223E BOS (FInWSCn)". + +You can securely download your signed documents here: + +Go to Documents + +Please make sure you download and safe keep the documents right now for your records. These documents will no longer be accessible when Melissa Koboldt archives the e-SignPackage "N722JE + +N722JE BOS (FInWSCn)". + +Thank you for using e-SignLiveTM! + +Your e-Si nLiveTM Team + +From: Rich Munkvold < + +Sent: Thursday, May 6, 2021 3:06 PM + +To: Melissa Koboldt Cc: Kamran Ali Subject: RE: New Escrow Attachments: 0702\_001.pdf + +yes + +From: Melissa Koboldt + +Sent: Thursday, May 6, 2021 12:15 PM + +To: Rich Munkvold Subject: RE: New Escrow + +Are you CFO of Frontier Finance Co.? + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Thursday, May 06, 2021 2:04 PM + +To: Melissa Koboldt < Cc: Kamran Ali < + +Subject: RE: New Escrow + +Melissa, + +Here you go. + +Thanks! + +From: Melissa Koboldt + +Sent: Thursday, May 6, 2021 10:29 AM + +To: Rich Munkvold Subject: RE: New Escrow Fax: + +> on behalf of Rich Munkvold + +aA t i C + +TITLE SERVICE + +000 + +I need to know how the LLC is set up so I can see who needs to sign the app and the appropriate title. + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Wednesday, May 05, 2021 3:06 PM + +To: Melissa Koboldt Cc: Gary Anzalone + +Subject: RE: New Escrow + +Fax: + +RA J C TITLE SERVICE + +0 O O + +Do we have to file with the IR to purchase or finance the airplane? If not, then let's not bother. + +Thanks! + +From: Melissa Koboldt + +Sent: Wednesday, May 5, 2021 12:47 PM + +To: Rich Munkvold Cc: Gary Anzalone + +Subject: RE: New Escrow + +Hi Rich, + +What address and phone number do you want to use for registration purposes? I need to get FAA docs prepared and + +sent for digital signatures. + +Are we filing this transaction with the IR? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Wednesday, April 21, 2021 9:51 AM + +To: Melissa Koboldt Cc: Gary Anzalone + +Fax: + +aA t i C + +TITLE SERVICE + +0 O O + +Attached is an amendment to the APA which is signed. I don't have the APA signed by the seller. I did attach the APA + +signed by me. + +Thanks! + +From: Melissa Koboldt + +Sent: Tuesday, April 20, 2021 8:14 PM + +To: Rich Munkvold Subject: RE: New Escrow + +< + +You have any agreement on this? just a straight sale from seller to buyer? + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Thursday, April 15, 2021 2:26 PM + +To: Melissa Koboldt Subject: New Escrow Fax: + +Melissa, + +ArA t IC + +TITLE SERVICE + +0 0 0 + +We are going to be wiring a deposit to you for a helicopter. I want to confirm that the proper wiring instructions should + +be into the -= account. + +The helicopter is a 2008 Sikorsky S/N 760750 with a tail number of N722JE. + +Please let me know. + +Thanks! + +From: Rich Munkvold < + +Sent: Saturday, May 8, 2021 12:34 PM + +To: Melissa Koboldt + +Cc: Gary Anzalone; Sherry Cannon + +Subject: N722JE Extension Attachments: 0723\_001.pdf + +Melissa, + +Attached is our signature on the extension of escrow until 5/13/21. + +Thanks! + +> on behalf of Rich Munkvold + +From: Rich Munkvold < > on behalf of Rich Munkvold + +Sent: Friday, May 7, 2021 5:31 PM + +To: Melissa Koboldt + +Cc: Gary Anzalone; Sherry Cannon; Larry Visoski; Tia Goodman + +Subject: N722JE Attachments: 0716\_001.pdf + +Melissa, + +Attached is a copy of the completed exemption per your request. You should have the original on Monday. + +Thanks! + +From: Larry Visoski <-> on behalf of Larry Visoski + +Sent: Friday, May 7, 2021 1:21 PM + +To: Melissa Koboldt + +Cc: Darren Indyke; Rich Kahn; Bella Klein; Gary Anzalone; Sherry Cannon + +Subject: N722JE + +Attachments: Untitled attachment 00119.pdf; Untitled attachment 00122.txt; LP525693.pdf; Untitled + +attachment 00125.txt; LT#\_2021-05-06-19.03.43.287078.pdf; Untitled attachment 00128.txt; LT#\_2021-05-06-19.04.14.675880.pdf; Untitled attachment 00131.txt; LT#\_ + +2021-05-06-19.04.17.892104.pde Untitled attachment 00134.txt + +Hello Melissa, + +Ref: + +Closing N722JE Hyperion Air, LLC + +Pls Find attached wiring instructions and backup receipts for S76 Hanger rent. + +To be paid from closing funds. + +Total 6,976.50 + +Thank you, Larry Visoski Manager + +Hyperion Air, LLC + +From: Gary Anzalone < + +Sent: Tuesday, April 20, 2021 7:33 PM + +To: Melissa Koboldt Cc: Sherry Cannon + +Subject: Re: N722JE - Sikorsky S76C++ sn 760750 Attachments: Amendment to the APA fully executed.pdf > on behalf of Gary Anzalone + +Hi Melissa + +Attached is a fully executed amendment to the APA extending the closing date to no later than May 7, 2021 + +I would appreciate you getting the consent and joinder back to us tomorrow. + +Sincerely, + +Gary Anzalone Mana ,in y Partner + +On Tue, Apr 20, 2021 at 11:28 AM Melissa Koboldt > wrote: + +Haha sorry! been buried in closings. Rich hasn't sent me anything so I don't know what's happening on this deal yet, I'll + +look at your dots and revert back this afternoon. + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Gary Anzalone [mailto: + +Sent: Tuesday, April 20, 2021 11:12 AM + +To: Melissa Koboldt c >; Sherry Cannon + +sA t i C + +TITLE SERVICE + +0 0 0 + +Melissa + +Talk to me sister! + +Sincerely, + +Gary Anzalone + +Managing Partner + +L + +On Mon, Apr 19, 2021 at 1:38 PM Gary Anzalone wrote: + +Hi Melissa + +Attached you will find the executed and counter executed APA between Hyperion Air LLC and Industrial + +Integrity Solutions LLC for Sikorsky 576C++ sn 760750, N722JE. + +Additionally, I have attached the Exhibit C Technical acceptance making the deposit hereby non refundable. + +At your convenience, can you please return a copy of the APA with your executed Consent and Joinder? + +I expect you have already spoken with Rich Munkvold of Industrial Integrity Solutions with respect to lien + +searches, IR etc, but I will differ to him with respect to the timing of the closing. + +I am fairly certain there are no plans to close this week. Let me know what he tells you in this respect. + +Sincerely, + +Gary Anzalone + +Managing Partner + +From: Gary Anzalone < > on behalf of Gary Anzalone + +Sent: Monday, April 19, 2021 1:39 PM To: Melissa Koboldt Sherry Cannon Subject: N722JE - Sikorsky 576C++ sn 760750 + +Attachments: Seller Countersigned Signature page from APA dated April 16, 2021.pdf; signed by + +purchaser.pdf; Exhibit C acceptance.pdf + +Hi Melissa + +Attached you will find the executed and counter executed APA between Hyperion Air LLC and Industrial + +Integrity Solutions LLC for Sikorsky 576C++ sn 760750, N722JE. + +Additionally, I have attached the Exhibit C Technical acceptance making the deposit hereby non refundable. + +At your convenience, can you please return a copy of the APA with your executed Consent and Joinder? + +I expect you have already spoken with Rich Munkvold of Industrial Integrity Solutions with respect to lien + +searches, IR etc, but I will differ to him with respect to the timing of the closing. + +I am fairly certain there are no plans to close this week Let me know what he tells you in this respect. + +Gary Anzalone Man 'n• Partner + +From: Melissa Koboldt + +Sent: Tuesday, April 20, 2021 11:02 PM To: 'Gary Anzalone'; 'Sherry Cannon' + +Subject: RE: N722JE - Sikorsky S76C++ sn 760750 + +Attachments: N722JE APA.PDF + +Hi again, signed and attached. + +I assume you are representing the seller? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +Fax: + +From: Gary Anzalone [mailto + +Sent: Monday, April 19, 2021 1:39 PM + +To: Melissa Koboldt + +Subject: N722JE - Sikorsky 576C++ sn 760750 + +Hi Melissa + +CA I C • TITLE SERVICE + +0 0 0 + +; Sherry Cannon .cz , + +Attached you will find the executed and counter executed APA between Hyperion Air LLC + +and Industrial Integrity Solutions LLC for Sikorsky S76C++ sn 76075o, N722JE. + +Additionally, I have attached the Exhibit C Technical acceptance making the deposit hereby non + +refundable. + +At your convenience, can you please return a copy of the APA with your executed Consent and + +Joinder? + +I expect you have already spoken with Rich Munkvold of Industrial Integrity Solutions with respect to + +lien searches, IR etc, but I will differ to him with respect to the timing of the closing. + +I am fairly certain there are no plans to dose this week. Let me know what he tells you in this respect. + +Sincerely, + +2 + +From: AIC Title < on behalf of AIC Title + +Sent: Thursday, May 6, 2021 2:52 PM + +To: LARRY VISOSKI Cc: Melissa Koboldt + +Subject: e-SignLive - the documents from "N7221E N722JE BOS (FInWSCn)" are available for + +download. + +Attachments: N722JE WBOS.pdf, - Electronic Disclosures and Signatures Consent.pdf; N722JE N7221E + +BOS (FInWSCn).pdf + +Hi LARRY VISOSKI, + +Signing is completed for e-SignPackage "N722JE N7223E BOS (FInWSCn)". + +You can securely download your signed documents here: + +Go to Documents + +Please make sure you download and safe keep the documents right now for your records. These documents will no longer be accessible when Melissa Koboldt archives the e-SignPackage "N722JE + +N722JE BOS (FInWSCn)". + +Thank you for using e-SignLiveTM! + +Your e-Si nLiveTM Team + +From: AIC Title < on behalf of AIC Title + +Sent: Thursday, May 6, 2021 2:52 PM + +To: Melissa Koboldt Cc: Melissa Koboldt + +Subject: eSignLive Electronic Evidence Summary + +Attachments: Documents for N722JE N722JE BOS (FInWSCn).zip; evidence-summary.pdf + +Hi Melissa Koboldt, + +Signing is completed for eSignPackage "N722JE N722JE BOS (FInWSCn)". + +Please find your Electronic Evidence Summary attached to this email. + +Thank you for using eSignLiveni! + +Your eSi nLiven, Team + +From: Sherry Cannon < > on behalf of Sherry Cannon + +Sent: Thursday, May 6, 2021 12:40 PM + +To: Melissa Koboldt Cc: Gary Anzalone + +Subject: Re: N722JE - Sikorsky S76C++ sn 760750 + +Attachments: EQUUS WIRE INSTRUCTIONS (TOTAL BUS CHECKING) 12-2020.pdf; Visoski Wire + +Info.pdf + +Dear Melissa, + +The Fee to EQUUS on the Closing Statement is \$100K. + +The distribution of that Fee upon Closing will be \$50K to EQUUS and \$50K to Larry Visoski but + +we do not want the split to be accounted for on the Closing Statement. + +Please see attached our wire instructions and those for Larry Visoski. + +With Best Regards, + +Sherry Cannon, Managing Member + +E uus Global Aviation, LLC + +www.eauusglobalaviation.com + +On Thu, May 6, 2021 at 1:30 PM Melissa Koboldt > wrote: + +How much is your fee and can you send wiring instructions? + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Gary Anzalone [mailto: + +Sent: Wednesday, April 21, 2021 9:50AM + +To: Melissa Koboldt < Cc: Sherry Cannon < + +Subject: Re: N722JE - Sikorsky 576C++ sn 760750 + +Hi Melissa + +Thank you for getting this back to us! + +ArA;IC TITLE SERVICE + +0 0 0 + +Actually, both parties are EQULTS's clients, but on this one we will be paid by the Seller! + +Sincerely, + +Gary Anzalone + +Managing Partner + +I assume you are representing the seller? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service + +Tel: or Fax: + +Skype: melissa.koboldt www.aictitle.com + +From: Gary Anzalone [mailto + +Sent: Monday, April 19, 2021 1:39 PM + +To: Melissa Koboldt + +Subject: N722JE - Sikorsky S76C++ sn 760750 + +Hi Melissa + +; Sherry Cannon + +aA t i C + +TITLE SERVICE + +0 0 0 + +Attached you will find the executed and counter executed APA between Hyperion Air LLC and Industrial + +Integrity Solutions LLC for Sikorsky S76C++ sn 760750, N722JE. + +Additionally, I have attached the Exhibit C Technical acceptance making the deposit hereby non refundable. + +At your convenience, can you please return a copy of the APA with your executed Consent and Joinder? + +I am fairly certain there are no plans to close this week. Let me know what he tells you in this respect. + +Sincerely, + +Gary Anzalone + +Managing Partner + +• + +• + +From: Rich Munkvold < + +Sent: Thursday, May 6, 2021 2:04 PM + +To: Melissa Koboldt Cc: Kamran Ali Subject: RE: New Escrow Attachments: 0701\_001.pdf + +Melissa, + +Here you go. + +Thanks! + +From: Melissa Koboldt + +Sent: Thursday, May 6, 2021 10:29 AM + +To: Rich Munkvold Subject: RE: New Escrow > on behalf of Rich Munkvold + +I need to know how the LLC is set up so I can see who needs to sign the app and the appropriate title. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: Or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold + +Sent: Wednesday, May 05, 2021 3:06 PM + +To: Melissa Koboldt + +Cc: Gary Anzalone < MI) + +Subject: RE: New Escrow + +Fax: + +TITLE SERVICE + +000 + +Do we have to file with the IR to purchase or finance the airplane? If not, then let's not bother. + +Thanks! + +From: Melissa Koboldt + +Sent: Wednesday, May 5, 2021 12:47 PM + +Hi Rich, + +What address and phone number do you want to use for registration purposes? I need to get FAA docs prepared and + +sent for digital signatures. + +Are we filing this transaction with the IR? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold 1mailto: + +Sent: Wednesday, April 21, 2021 9:51AM + +To: Melissa Koboldt < Cc: Gary Anzalone + +Subject: RE: New Escrow + +Melissa, + +Attached is an amendment to the APA which is signed. I don't have the APA signed by the seller. I did attach the APA + +signed by me. + +Thanks! + +Fax: + +aA t i C + +TITLE SERVICE + +0 O O + +From: Melissa Koboldt + +Sent: Tuesday, April 20, 2021 8:14 PM + +To: Rich Munkvold Subject: RE: New Escrow + +You have any agreement on this? just a straight sale from seller to buyer? + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: i or + +Skype: melissa.koboldt www.aictitle.com + +S `~ + +TITLE SERVICE + +000 + +Melissa, + +We are going to be wiring a deposit to you for a helicopter. I want to confirm that the proper wiring instructions should + +be into the -= account. + +The helicopter is a 2008 Sikorsky S/N 760750 with a tail number of N722JE. + +Please let me know. + +Thanks! + +From: Rich Munkvold + +Sent: Wednesday, May 5, 2021 3:06 PM + +To: Melissa Koboldt Cc: Gary Anzalone Subject: RE: New Escrow + +C + +• + +> on behalf of Rich Munkvold + +Do we have to file with the IR to purchase or finance the airplane? If not, then let's not bother. + +Thanks! + +From: Melissa Koboldt + +Sent: Wednesday, May 5, 2021 12:47 PM + +To: Rich Munkvold < Cc: Gary Anzalone < Subject: RE: New Escrow + +Hi Rich, + +What address and phone number do you want to use for registration purposes? I need to get FAA docs prepared and + +sent for digital signatures. + +Are we filing this transaction with the IR? + +Thanks, + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Wednesday, April 21, 2021 9:51 AM + +To: Melissa Koboldt Cc: Gary Anzalone + +Subject: RE: New Escrow + +Melissa, + +Fax: + +TITLE SERVICE + +©00 + +Attached is an amendment to the APA which is signed. I don't have the APA signed by the seller. I did attach the APA + +From: Melissa Koboldt + +Sent: Tuesday, April 20, 2021 8:14 PM + +To: Rich Munkvold Subject: RE: New Escrow + +You have any agreement on this? just a straight sale from seller to buyer? + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Thursday, April 15, 2021 2:26 PM + +To: Melissa Koboldt Subject: New Escrow + +Melissa, + +We are going to be wiring a deposit to you for a helicopter. I want to confirm that the proper wiring instructions should + +be into the a account. + +The helicopter is a 2008 Sikorsky S/N 760750 with a tail number of N722JE. + +Please let me know. + +Thanks! + +Fax: + +SA t i C + +TITLE SERVICE + +00 + +From: Rich Munkvold + +Sent: Wednesday, May 5, 2021 4:39 PM + +To: Melissa Koboldt + +Subject: RE: Title Insurance Quote + +C + +If it is not normal and customary, then let's not + +From: Melissa Koboldt + +Sent: Wednesday, May 5, 2021 2:35 PM + +To: Rich Munkvold + +Subject: RE: Title Insurance Quote + +> on behalf of Rich Munkvold + +It's if you want title insurance, I don't think you guys normally purchase it but I always have to send out quotes. + +Melissa Koboldt + +Escrow agent + +AIC Title Service Tel: Or + +Skype: melissa.koboldt www.aictitle.com + +From: Rich Munkvold fmailto: + +Sent: Wednesday, May 05, 2021 4:01PM + +To: + +Subject: RE: Title Insurance Quote + +Melissa, + +Fax: + +aA t iC + +TITLE SERVICE + +0 0 0 + +I went back and checked to see if we were charged a title fee on the G550 and we were not. We were only charged 50% + +of the escrow fee. + +Please let me know what this fee is for. + +Thanks! + +From: + +Sent: Wednesday, May 5, 2021 12:50 PM + +To: Rich Munkvold + +Subject: Title Insurance Quote + +AvSure, Inc. + +Telephone + +TITLE INSURANCE QUOTE AIRCRAFT OWNER'S POLICY + +N722JE, KEYSTONE HELICOPTER S-76C, SN: 760750 + +This Title Insurance Quote is provided as of May 05, 2021 02:49 PM and remains at all times subject + +to the Notes provided below. + +Quote requested by and for the benefit of: + +Rich Munkvold + +Amount of Title Insurance: \$1,800,000.00 + +Premium: \$4,268.00 + +Note 1: Issuance of Title Insurance subject to the terms and conditions disclosed herein and + +contained in any policy issued in furtherance hereof. + +Note 2: Premium given is based on a clean title search. If encumbrances or FAA remarks are found, + +additional fees may apply. + +Note 3: Insurance coverage on applicable International Registry (I.R.) remains subject to the + +registration of I.R. interests or insured waiver thereof. \ No newline at end of file diff --git a/marker2/ds9/EFTA00085930/EFTA00085930.metadata.json b/marker2/ds9/EFTA00085930/EFTA00085930.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..65dfa43b1e61465f6781c0ce033c820a0d33f3ec --- /dev/null +++ b/marker2/ds9/EFTA00085930/EFTA00085930.metadata.json @@ -0,0 +1,6927 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00085930.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 276, + "chars": 203763, + "elapsed_seconds": 183.28, + "image_assets": 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"text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Text", + 17 + ], + [ + "Line", + 17 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00085930" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086206/EFTA00086206.md b/marker2/ds9/EFTA00086206/EFTA00086206.md new file mode 100644 index 0000000000000000000000000000000000000000..c25ac5989f6934a71291bf670ecdf365369f8115 --- /dev/null +++ b/marker2/ds9/EFTA00086206/EFTA00086206.md @@ -0,0 +1,17 @@ +From: + +To: + +Subject: 404(b) notice and CC identities notice + +Date: Mon, 11 Oct 2021 22:56:29 +0000 + +Attachments: 2021.10.11\_Maxwell\_Rule\_404(b) letter (final).pdf; + +2021.10.11\_Maxwell\_Discovery\_LetteriCC\_identitiesUfinal).pdf + +Hey Team, + +Attached are the final 404(b) notice and CC identities notice, in case you want to look at them one more time. Whenever we tell the defense that the 3500 is ready for them, I'll also send these out. + +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/EFTA00086206/EFTA00086206.metadata.json b/marker2/ds9/EFTA00086206/EFTA00086206.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a57ddbccc4bc8a1fcddeaead42983936a3f7519c --- /dev/null +++ b/marker2/ds9/EFTA00086206/EFTA00086206.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086206.pdf", + "engine": { + "marker_major": "2", + "marker_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": 554, + "elapsed_seconds": 0.62, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Line", + 14 + ], + [ + "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/EFTA00086206" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086207/EFTA00086207.md b/marker2/ds9/EFTA00086207/EFTA00086207.md new file mode 100644 index 0000000000000000000000000000000000000000..05f908e9242a008b11795eafb62947c882ef6cad --- /dev/null +++ b/marker2/ds9/EFTA00086207/EFTA00086207.md @@ -0,0 +1,33 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +Plaintiff, -against-GHISLAINE MAXWELL, Defendant. + +No. 15 Civ. 7433 (LAP) + +## MEMORANDUM & ORDER + +LORETTA A. PRESKA, Senior United States District Judge: + +The Court has reviewed Defendant Ghislaine Maxwell's letter requesting reconsideration of the Court's July 23, 2020, decision to unseal (1) the transcripts of Ms. Maxwell's and Doe 1's depositions, and (2) court submissions excerpting from, quoting from, or summarizing the contents of the transcripts. (See dkt. no. 1078.) + +Ms. Maxwell's eleventh-hour request for reconsideration is denied. As Ms. Maxwell acknowledges in her letter, reconsideration is an "extraordinary remedy." In re Beacon Assocs. Litig., 818 F. Supp. 2d 697, 701 (S.D.N.Y. 2011) (quoting In re Health Mgmt. Sys. Inc. Sec. Litig., 113 F. Supp. 2d 613, 614 (S.D.N.Y. 2000)). Such motions "are properly granted only if there is a showing of: (1) an intervening change in controlling law; (2) the availability of new evidence; or (3) a need to correct a clear error or prevent manifest injustice." Drapkin v. Mafco Consol. Grp., Inc., 818 F. Supp. 2d 678, 696 (S.D.N.Y. 2011). "A motion for reconsideration + +may not be used to advance new facts, issues or arguments not previously presented to the Court, nor may it be used as a vehicle for relitigating issues already decided by the Court." Bennett v. Watson Wyatt & Co., 156 F. Supp.2d 270, 271 (S.D.N.Y. 2001). + +Here, Ms. Maxwell's request for reconsideration hinges on her assertion that new developments, i.e., her indictment and arrest, provide compelling reasons for keeping the deposition transcripts sealed. (See dkt. no. 1078 at 5.) But, despite Ms. Maxwell's contention that she could not address the effect of those events in her objections because they occurred after the close of briefing, (id.), 1 this is plowed ground. Indeed, in her original objection to unsealing, Ms. Maxwell argued that the specter of ongoing criminal investigations into unknown individuals associated with Jeffrey Epstein--a group that, of course, includes Ms. Maxwell--loomed large over the Court-ordered unsealing + +1 The Court notes as a practical matter that Ms. Maxwell was arrested on July 2, 2020--that is, three weeks prior to the Court's July 23 decision to unseal the materials at issue. To the extent that they relate to the to the Court's balancing of interests in the unsealing process, the issues that Ms. Maxwell raises in her request were surely plain the day that Ms. Maxwell was apprehended. Ms. Maxwell, however, did not seek to supplement her objections to unsealing despite ample time to do so. In fact, the Court notified the parties on July 21, 2020, that it would announce the unsealing decision with respect to Ms. Maxwell's deposition, together with other documents, on July 23. (See dkt. no. 1076.) Even then, Ms. Maxwell made no request for delay or to supplement her papers. Ms. Maxwell did not raise her "vastly different position," (Transcript of July 23 Ruling at 16:2-3), until moments after the Court had made its decision to unseal the relevant documents. + +process. (See dkt. no. 1057 at 5.) This argument, specifically Ms. Maxwell's concern that unsealing would "inappropriately influence potential witnesses or alleged victims," (id.), and her reference to "publicly reported statements by Plaintiff, Plaintiff's counsel, the United States Attorney for the Southern District of New York, and the Attorney General for the U.S. Virgin Islands" about those investigations, (id.), carried with it the clear implication that Ms. Maxwell could find herself subject to investigation and, eventually, indictment. The Court understood that implication as applying to Ms. Maxwell and thus has already considered any role that criminal charges against Ms. Maxwell might play in rebutting the presumption of public access to the sealed materials. Ms. Maxwell's request for reconsideration of the Court's July 23 ruling is accordingly denied. + +Given the Court's denial of Ms. Maxwell's request for reconsideration, the Court will stay the unsealing of Ms. Maxwell's and Doe l's deposition transcripts and any sealed or redacted order or paper that quotes from or discloses information from those deposition transcripts for two business days, i.e., through Friday, July 31, 2020, so that Ms. Maxwell may seek relief from the Court of Appeals. Any sealed materials that do not quote from or disclose information from those deposition transcripts shall be unsealed on July 30, 2020, in the manner described by the Court's Order dated July 28, 2020. (See dkt. no. 1077.) Ms. Maxwell's and + +Doe l's deposition transcripts and any sealed materials that quote or disclose information from them shall be unsealed in the manner prescribed by the July 28 Order on Monday, August 3, 2020, subject to any further stay ordered by the Court of Appeals. + +SO ORDERED. + +Dated: New York, New York July 29, 2020 + +diateef a 42AI + +LORETTA A. PRESKA Senior United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00086207/EFTA00086207.metadata.json b/marker2/ds9/EFTA00086207/EFTA00086207.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c1d3eca6c0e64511545484d789812f47efbd04e6 --- /dev/null +++ b/marker2/ds9/EFTA00086207/EFTA00086207.metadata.json @@ -0,0 +1,196 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086207.pdf", + "engine": { + "marker_major": "2", + "marker_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": 5020, + "elapsed_seconds": 0.74, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "MEMORANDUM & ORDER", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 356.18399999999997, + 174.14999999999998 + ], + [ + 496.96795654296875, + 174.14999999999998 + ], + [ + 496.96795654296875, + 187.213134765625 + ], + [ + 356.18399999999997, + 187.213134765625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 60 + ], + [ + "Line", + 28 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 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", + 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", + 53 + ], + [ + "Line", + 27 + ], + [ + "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 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 26 + ], + [ + "Line", + 13 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 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/EFTA00086207" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086211/EFTA00086211.md b/marker2/ds9/EFTA00086211/EFTA00086211.md new file mode 100644 index 0000000000000000000000000000000000000000..e2d56e0f294e8a75781699730c3eba18202c391a --- /dev/null +++ b/marker2/ds9/EFTA00086211/EFTA00086211.md @@ -0,0 +1,131 @@ +From: To: Gary Bloxsome Cc: , "Jennifer Richardson" + +Subject: RE: U.S. Department of Justice investigation + +Date: Thu, 09 Jan 2020 21:53:04 +0000 + +Inline-Images: image001.jpg; image002.jpg + +Gary, + +You can reach us at my office line, at or if you prefer we can give you a call at any number that would be convenient, if you prefer to have a conference line. We look forward to speaking with you tomorrow. thank you, + +From: Gary Bloxsome + +Sent: Wednesday, January 08, 2020 07:38 + +To: Cc: Daniel Cundy ; Jennifer Richardson + +Subject: Re: U.S. Department of Justice investigation + +Thank you for your email. + +Friday 10th January at 1400(LDN) time is fine. + +Please forward dial in details. + +Kind regards + +Gary + +Gary Bloxsome I Partner + +Blackfords I 15 Old Bailey I London I EC4M LLP 7EF + +DX 161400 Old Bailey 5 I www.blackfords.com + +![](_page_0_Picture_18.jpeg) + +![](_page_0_Picture_19.jpeg) + +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 oar Privacy Statement + +Authorised and regulated by the Solicitors Regulation Authority under number 462078. + +On 7 Jan 2020, at 18:56, wrote: + +External email: is it safe to open attachments and links? + +We are available for a preliminary call this Friday, January 10. If it would be convenient for you, we are available at 9:00 local time for us (which I believe would be 14:00 your time). If that works, we can plan to call you at your office line unless you'd prefer we use another number or a conference line. + +Sou, + +From: Gary Bloxsome Sent: Tuesday, January , : + +To: Cc: ;Jennifer Richardson Daniel Cundy + +Subject: Re: U.S. Department of Justice investigation Thank you for your email. + +Please confirm whether you would be available for a preliminary telephone call on Friday 10th January 2020. + +Kind regards. + +Gary + +Gary Bloxsome I Partner + +Blackfords UPI 15 Old Bailey I London I EC4M 7EF DX 161400 Old Bailey 5 I www.blackfords.com + +Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk, Croydon, CR0 lEA. A list of members\* names is available at this address. + +GDPR: details of how we handle personal data can be found in ourPrhecyStatement + +Authorised and regulated by the Solicitors Regulation Authority under number 462078. + +On 4 Jan 2020, at 01:38, wrote: + +External email: is it sale to open attachments and links? + +Mr. Bloxsome, + +Thank you for your response and for confirming your representation. To respond to your question generally, in connection with our investigation of conduct relating to Jeffrey Epstein and certain of his associates, we wish to request a consensual, voluntary law enforcement interview with your client. Generally, we would expect to inquire about his relationship and communications with Jeffrey Epstein and his associates, as well as certain allegations that have arisen publicly and in our investigation to date. + +Although we recognize we separately have the ability to convey such a request through diplomatic and law enforcement channels, we understand we may also alternatively inquire directly with counsel, when an individual has legal representation. Given your representation, we are inquiring directly with counsel in the first instance. Certainly we can discuss our request in more detail, but we hope this will provide the information you were seeking as a threshold matter, and we look forward to being in touch. + +Regards, + +To: + +Cc: Daniel Cundy + +ci >; Jennifer Richardson + +Subject: Re: U.S. Department of Justice investigation + +Dear Sirs, + +Thank you for your email dated 2 January 2020. + +I confirm that we do represent HRH the Duke of York. + +I would be grateful if you could please clarify what specifically you invite us to contact you about. + +Kind regards + +Gary Bloxsome + +Gary Bloxsome l Partner + +Blackfords LIP 15 Old Bailey I London I EC4M 7EF + +DX 161400 Old Bailey S I I www.blackfords.com + +Blac + +Your BFF •is on Part I all of next week... + +From: Sent: Wednesday, January 29, 2020 3:56 PM To: (USANYS) < Cc: ) c s; Subject: RE: Epstein Sharing Order Part II >; (USANYS) + +is it the intent to share those? If so, I'll just add it to every mention of each document, but if not then it's unnecessary. I don't think those are substantive dots but I defer. + +From: (USANYS) Sent: Wednesday, January 29, 2020 15:55 To: Cc: Subject: RE: Epstein Sharing Order Part II (USANYS) + +Please add it in the right place and send me the order. Remember, I'm not a T&E lawyer. But you are getting to be + +From: Sent: Wednesday, January 29, 2020 3:22 PM To: (USANYS) Cc: ) Subject: RE: Epstein Sharing Order Part II (USANYS) < + +Yes, I think this document accurately describes the materials we've received, with just a note that it doesn't appear to include revocations, so to the extent those are intended to be shared, I think that word may need to be added. + +thanks, + +From: (USANYS) < Sent: Wednesday, January 29, 2020 10:40 To: (USANYS) < Subject: Epstein Sharing Order Part II >; + +=— I've updated the sharing order application to be one to share the additional trust and will documents we have now received. Would you take a look when you can? + +I've tried to describe the various materials we have gotten from the estate attorneys over the last two weeks. Would you mind taking a look (or asking a paralegal to take a look) to make sure I've accurately described/characterized the new stuff we're looking to share? + +Thanks, + +![](_page_1_Picture_1.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00086215/EFTA00086215.metadata.json b/marker2/ds9/EFTA00086215/EFTA00086215.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8ac69121562c554dc946adf6463ce6f18eebaef5 --- /dev/null +++ b/marker2/ds9/EFTA00086215/EFTA00086215.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086215.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1644, + "elapsed_seconds": 0.69, + "image_assets": [ + "_page_1_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 89 + ], + [ + "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", + 5 + ], + [ + "Line", + 3 + ], + [ + "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/EFTA00086215" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086215/_page_1_Picture_1.jpeg b/marker2/ds9/EFTA00086215/_page_1_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..19f7270fe55f134b7f8e977c8a3fe75b7f9589f9 --- /dev/null +++ b/marker2/ds9/EFTA00086215/_page_1_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:ce242ff0f73077c3e200b4e1ac00ee2b4d571dbae63fd9edcf04919f60764379 +size 948 diff --git a/marker2/ds9/EFTA00086217/EFTA00086217.md b/marker2/ds9/EFTA00086217/EFTA00086217.md new file mode 100644 index 0000000000000000000000000000000000000000..0cbda7530b719bde87703cb65e9f3442c6abc5bc --- /dev/null +++ b/marker2/ds9/EFTA00086217/EFTA00086217.md @@ -0,0 +1,35 @@ +To: (USANYS)" + +Subject: FW: time to chat tomorrow? + +Date: Fri, 31 Jan 2020 00:27:57 +0000 + +Embedded: RE:lemsg + +I asked . See attached. Odd that they didn't reach out to us about this. + +From: + +Sent: Thursday, January 30, 2020 7:26 PM + +To: (USANYS) 4 + +Subject: RE: time to chat tomorrow? + +I unfortunately am running out to a dinner right now — want to do 9:30 tomorrow so we have a little buffer time? And as a little background on our thinking in advance, see attached. + +From: (USANYS) 4 + +Sent: Thursday, January 30, 2020 19:25 + +To: + +Subject: Re: time to chat tomorrow? + +Could we do 10? Meeting is at 10:30. Or we can talk tonight. Thanks. + +On Jan 30, 2020, at 7:23 PM, > wrote: + +Hey wanted me to reach out to give you a rundown before you talk with tomorrow (just called you but your vm is full). Is there a good time? I should be generally free after 10, until about 3:00. Thanks! + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00086217/EFTA00086217.metadata.json b/marker2/ds9/EFTA00086217/EFTA00086217.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bbf2f402b07913b5e61f97c9c96e1aa55cbeca11 --- /dev/null +++ b/marker2/ds9/EFTA00086217/EFTA00086217.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086217.pdf", + "engine": { + "marker_major": "2", + "marker_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": 936, + "elapsed_seconds": 0.9, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "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/EFTA00086217" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086218/EFTA00086218.md b/marker2/ds9/EFTA00086218/EFTA00086218.md new file mode 100644 index 0000000000000000000000000000000000000000..14e3679a5f0862490bf3f058aa67029758b20418 --- /dev/null +++ b/marker2/ds9/EFTA00086218/EFTA00086218.md @@ -0,0 +1,25 @@ +From: ' )11 To: (USANYS)" <1 Cc: 1 + +Subject: Re: Epstein 6(e) Order Signed and Ready to Pick Up + +Date: Mon, 03 Feb 2020 16:34:13 +0000 + +We can pick up ... only thing is, did this not need to go to Part 1? would know better than I whether a mag court order is sufficient, I just ask because I think the prior order was a district judge. + +Sent from my iPhone + +On Feb 3, 2020, at 11:25, (USANYS) < > wrote: + +Were you guys able to pick this up? If not, can you send a paralegal over to do so today? Thanks. + +From: McEnany,= (USANYS) •= > + +Sent: Friday, January 31, 2020 5:23 PM + +To: / (USANYS) + +Cc: + +Subject: Epstein 6(e) Order Signed and Ready to Pick Up + +I just got a call from Judge Nathan's clerk that she signed the order and it's ready to be picked up from her chambers, if one of you want to engineer that right now. \ No newline at end of file diff --git a/marker2/ds9/EFTA00086218/EFTA00086218.metadata.json b/marker2/ds9/EFTA00086218/EFTA00086218.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..220cad95334dd0e40e9aba1ebd70d0d36222cff2 --- /dev/null +++ b/marker2/ds9/EFTA00086218/EFTA00086218.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086218.pdf", + "engine": { + "marker_major": "2", + "marker_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": 819, + "elapsed_seconds": 0.65, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Line", + 19 + ], + [ + "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/EFTA00086218" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086219/EFTA00086219.md b/marker2/ds9/EFTA00086219/EFTA00086219.md new file mode 100644 index 0000000000000000000000000000000000000000..edd4c57e83bbbaba328c897904064f47ca2f6aa3 --- /dev/null +++ b/marker2/ds9/EFTA00086219/EFTA00086219.md @@ -0,0 +1,24 @@ +**To:** [REDACTED] + +[REDACTED] + +**Subject:** RE: Epstein 6(e) Order + +**Date:** Mon, 03 Feb 2020 21:58:32 +0000 + +**Attachments:** 2020-02-03, JE, 6e disclosure, signed\_order.pdf; 2020-02-03, JE, 6e disclosure, application and order.pdf + +--- + +[REDACTED], + +Following up on discussion this afternoon, attached please find the 6(e) disclosure materials—one file is the full application and order, and the other is just the order itself. + +thanks, + +[REDACTED]. + +[REDACTED] +Assistant U.S. Attorney +Southern District of New York +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00086219/EFTA00086219.metadata.json b/marker2/ds9/EFTA00086219/EFTA00086219.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8d5917171e265cb81695030f31f14c63b819500b --- /dev/null +++ b/marker2/ds9/EFTA00086219/EFTA00086219.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086219.pdf", + "engine": { + "marker_major": "2", + "marker_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": 537, + "elapsed_seconds": 2.97, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Text", + 24 + ], + [ + "Line", + 12 + ], + [ + "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/EFTA00086219" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086220/EFTA00086220.md b/marker2/ds9/EFTA00086220/EFTA00086220.md new file mode 100644 index 0000000000000000000000000000000000000000..ccdd5c794bdfbd64688f7d54d963c9fcda9b3090 --- /dev/null +++ b/marker2/ds9/EFTA00086220/EFTA00086220.md @@ -0,0 +1,149 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +In re Application of the United States for a Disclosure Order in connection with Grand Jury Investigation USAO Ref No. 2018R01618 in the United States District Court for the Southern District of New York + +## Ex Parte Sealed Application for Grand Jury Disclosure Order + +19 Misc. 0586 + +The United States of America (the "Government"), by its attorney, Geoffrey S. Berman, United States Attorney for the Southern District of New York, Associate United States Attorney, of counsel, respectfully moves this Court pursuant to Federal Rule of Criminal Procedure 6(c)(3)(E)(i) & 6(e)(3)(F) for an order authorizing disclosure of certain grand jury matters in aid of a continuing investigation into conduct by associates of Jeffrey Epstein relating to alleged sex trafficking of minors by Jeffrey Epstein, and other offenses, and possible forfeitures or injunctive relief. This application relates specifically to a series of wills and trusts created by Jeffrey Epstein over the period of approximately 2001 to 2018 that were intended to receive most (if not all) of Jeffrey Epstein's assets, including potentially forfeitable assets, and pursuant to which substantial payments would be made over time to individual beneficiaries, including individuals who may be of interest in the ongoing investigation. By this application we request authorization to disclose certain trust agreements and related documents to a trusts and estates expert we have retained to advise us in this area of law, and to attorneys in our Civil Division who would represent the Government in any litigation that may appear advisable to assert Government interests concerning these matters. As discussed more fully below, on December 20, 2019, the Honorable Denise Cote entered a disclosure order, similar in form to the order requested herein, relating to an earlier set of trust and estate documents which we had received in this + +investigation; this application relates to an additional set of trusts and estate documents that we have subsequently received. + +I. The Criminal Investigation. In November 2018, this Office, in conjunction with the Federal Bureau of Investigation and the New York City Police Department, commenced an investigation into conduct by Jeffrey Epstein and possible co-conspirators involving, among other things, alleged sex trafficking of minors during the period from (at least) the mid-1990s through the summer of 2019. On July 2, 2019, a federal grand jury in this district returned an indictment charging Jeffrey Epstein with sex trafficking of minors and conspiracy to commit sex trafficking of minors in United Stales v. Epstein, 19 Cr. 490 (RMB). On August 10, 2019, Jeffrey Epstein died by suicide while incarcerated at the Manhattan Correctional Center awaiting trial on those charges. But despite Epstein's death this Office has continued its criminal investigation into the conduct of other individuals, including possible co-conspirators, as well as possible obstructive conduct by co-conspirators or associates of Epstein. + +2. As alleged in the indictment against Epstein and in filings in that case, Epstein and others engaged in a years-long scheme to sexually abuse underage girls. In particular, Epstein enticed and recruited dozens of minor girls to engage in sex acts with him, for which he typically paid the victims hundreds of dollars in cash. He undertook this activity in several locations, including his mansion in Manhattan, New York; his estate in Palm Beach, Florida; and his private island located in the U.S. Virgin Islands. The defendant typically paid his victims hundreds of dollars in cash for each separate encounter. Epstein worked with others, including employees and associates, to facilitate this exploitation by, among other things, contacting victims and scheduling their sexual encounters with the defendant in New York and in Florida. + +3. Additionally, in connection with a prior investigation of Epstein's conduct in Florida, there were credible allegations that Epstein engaged in witness tampering, harassment, or other obstructive behaviors. Extensive allegations of obstruction and tampering by Epstein were also made in connection with civil lawsuits brought against Epstein. See Doe v. United States, 08 Civ. 80736 (S.D. Fla.), Dkt. 291-15 at 21-23, 31. More recent instances of potential obstruction surfaced following the publication, commencing November 28, 2018, of a series of articles in the Miami Herald regarding Epstein and the circumstances of his prior conviction for solicitation of a minor. Records obtained by the Government show that two days later, on or about November 30, 2018, Epstein wired \$100,000 from a trust account he controlled to an individual previously identified as a possible co-conspirator, and that just three days after that, on or about December 3, 2018, Epstein wired 5250,000 from the same trust account to another individual previously identified as a possible co-conspirator and who was identified as one of Epstein's employees in the Indictment. 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 more recently re-emerging allegations. + +4. Epstein's Will and the 1953 Trust Agreement. As part of the Government's continuing investigation, the Government obtained, via grand jury subpoena, the Will that Epstein executed on April 8, 2019, shortly before his death; and the Trust Agreement of The 1953' Trust, also executed on April 8, 2019. The Government also obtained, via grand jury subpoena, two prior trust agreements referenced in The 1953 Trust Agreement. The Will has been publicly filed in probate proceedings that are taking place in the U.S. Virgin Islands, but the various trust documents + +1 "1953" may be a reference to the year of Epstein's birth. + +are not public. (We have been advised that in normal circumstances, trust agreements set up in connection with estate planning are not generally made public.) + +5. Epstein's Will directs that, after certain payments of fees and distributions, all property be provided to the Trustees of The 1953 Trust. Property whose disposition is covered by the Trust includes Epstein's New York City residence, which was identified as subject to criminal forfeiture in the Epstein indictment and which may continue to be subject to civil or criminal forfeiture. Other potentially forfeitable property, including Epstein's other residences, is also purportedly covered by the Trust. + +6. The Additional Epstein Wills and Trust Agreements. As part of the Government's continuing investigation, the Government has further obtained, via grand jury subpoena, eight prior wills and related codicils executed by Epstein between approximately 2001-2018, as well as numerous prior trust agreements and related amendments and revocations, most of which are expressly referenced in those prior wills (collectively the Additional Trust and Estate Documents).2 The Additional Trust and Estate Documents reflect Epstein's intended beneficiaries over the roughly 18-year period preceding his suicide—Le., a time period which includes both the criminal + +2 Specifically, the Additional Trust and Estate Documents consist of: (i) a December 11, 2001 Will of Jeffrey Epstein and any related codicils, the Jeffrey Epstein 2001 Trust One and any related amendments and revocations, and the Jeffrey E. Epstein 2001 Trust Two and any related amendments and revocations; (ii) a January 27, 2012 Will and any related codicils; (iii) an October 24, 2012 Will of Jeffrey Epstein and any related codicils, and The Jeffrey E. Epstein 2012 Trust and any related amendments and revocations; (iv) a September 16, 2013 Will of Jeffrey Epstein and any related codicils, and The Jeffrey E. Epstein 2013 Trust and any related amendments; (v) a November 18, 2014 Will of Jeffrey Epstein and any related codicils, and The Jeffrey E. Epstein 2014 Trust and any related amendments and revocations; (vi) a June 29, 2017 Will of Jeffrey Epstein and any related codicils, and The Jeffrey E. Epstein 2017 Trust and any related amendments; (vii) a May 8, 2018 Will of Jeffrey Epstein and any related codicils, and the Jeffrey E. Epstein 2018 Trust and any related amendments, and (vii) a January 18, 2019 Will of Jeffrey Epstein and any related codicils, and The Jeffrey E. Epstein 2019 Trust and any related amendments and revocations. + +conduct charged in the indictment described in paragraph I above, and much of the obstructive conduct described in paragraph 3 above. + +7. Potential Proceedings Concerning Epstein's Will and The 1953 Trust. To assist the Government in evaluating its need or ability to become involved in Epstein-related trust and estate proceedings, our Office has retained Yak Law School Professor a noted expert in the field of trusts and estates, to advise us concerning, among other things, any interests the Government may have in the Epstein probate proceedings in the U.S. Virgin Islands, and any actions the Government might take, including potential injunctive relief the Government might seek to, for example, preserve its interests in potentially forfeitable property, or to void appropriate provisions of The 1953 Trust Agreement as contrary to public policy. If it appears necessary and appropriate to initiate proceedings in probate or another court to vindicate the Government's interests in this area, we anticipate that the litigation would be handled by attorneys in our Civil Division. + +8. By prior application, the Government requested authorization to disclose the Epstein Will, The 1953 Trust Agreement, and related trust documents, to Professor and to the Civil Division attorneys assigned to this matter; so that they may provide informed advice and consideration regarding judicial proceedings that may be appropriate for the Government to initiate relating to the dispositions Jeffrey Epstein made relating to his property. That application was approved by the Hon. Denise L. Cote on December 20, 2019. That Order and the application upon which it was granted are attached hereto as Exhibit A. See In re Application of the United States + +3 The Civil Division attorneys assi ed to this matter are + +under the general supervision of + +for a Disclosure Order in connection with Grand Jury Investigation USAO Ref No. 2018R01618 in the United States District Court for the Southern District of New York, Docket No. 19 Misc. 0586. + +9. By this application, the Government requests authorization to disclose the Additional Trust and Estate Documents to Professor and to the Civil Division attorneys assigned to this matter so that they may continue to provide informed advice and consideration regarding judicial proceedings that may be appropriate for the Government to initiate relating to the dispositions Jeffrey Epstein made relating to his property. + +10. Standard for Disclosure. The Supreme Court has interpreted Rule 6(3)(e)(E)(i) "to require a strong showing of particularized need for grand jury materials before any disclosure will be permitted." United States v. Sells Engineering, Inc., 463 U.S. 418, 443 (1983). Although this standard applies to requests for disclosure to government attorneys, the Supreme Court has "made it clear that the concerns that underlie the policy of grand jury secrecy are implicated to a much lesser extent when the disclosure merely involves Government attorneys." United States v. John Doe, Inc. 1, 481 U.S. 102, 112 (1987). Thus, + +a district court might reasonably consider that disclosure to Justice Department attorneys poses less risk of further leakage or improper use than would disclosure to private parties or the general public. Similarly, we are informed that it is the usual policy of the Justice Department not to seek civil use of grand jury materials until the criminal aspect of the matter is closed. And "under the particularized need standard, the district court may weigh the public interest, if any, served by disclosure to a governmental body . . . ." On the other hand, for example, in weighing the need for disclosure, the court could take into account any alternative discovery tools available by statute or regulation to the agency seeking disclosure. + +United States v. Sells Engineering, Inc., 463 U.S. at 445 (citations omitted) (quoting United States v. Abbott, 460 U.S. 557, 567 n.15 (1983)). llere, the requested disclosure is for a narrow scope of materials, to limited individuals, for the narrow purpose of identifying proceedings the Government may need to initiate in order to avoid interference with its ongoing criminal + +investigation, potential forfeiture interests, and related matters. Indeed, one of the major purposes of this disclosure is to identify and address any issues that might affect the continuing criminal grand jury investigation into Epstein-related conduct. + +11. Authorization Requested. The Government accordingly requests that the Court enter an Order, in the form attached, authorizing the Government to disclose to Professorand to the Civil Division attorneys (and their successors, if any) the Additional Trust and Estate Documents for the purpose of obtaining advice and consideration of proceedings that may be appropriate for the Government to initiate to protect its interests in the ongoing criminal investigation; potential forfeiture matters; and asserting public policy considerations that may be implicated by dispositions Jeffrey Epstein made for distribution of his property. + +12. Scaling. Because this relates to grand jury matters and concerns documents that are not otherwise already public, the Government respectfully requests that the Court order this Application be filed under seal pursuant to Fed. R. Crim. P. 6(e)(6); and that the Court's Order also be filed under seal, except that the Government may disclose the Order to persons to whom the information at issue herein is disclosed. + +13. Prior Requests. Except as otherwise noted above, no prior request for the relief sought herein has been made. + +WHEREFORE, I respectfully request that the Court issue a Disclosure Order in the form submitted herewith. + +Dated: New York, New York +January 31, 2020 + +GEOFFREY S. BERMAN +United States Attorney +Southern District of New York + +By: + +![]()Associate United States Attorney +Southern District of New York + +![]() + +# Exhibit A + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +In re Application of the United States for a Disclosure Order in connection with Grand Jury Investigation USAO Ref No. 20I8R01618 in the United States District Court for the Southern District of New York + +### Grand Jury Disclosure Order Under Seal + +19 Misc. C• 511 + +Upon the Application of the United States of America, by Geoffrey S. Berman, United States Attorney for the Southern District of New York, , Associate United States Attorney, of counsel, it is hereby ORDERED that: + +1. Jeffrey Epstein's Will, dated August 8, 2019; The 1953 Trust Agreement, dated August 8, 2019; and earlier Jeffrey Epstein trust agreements referenced in The 1953 Trust Agreement, may be disclosed to Professor of Yale Law School and to the Assistant U.S. Attorneys for the Southern District of New York designated below for the purpose of advising and considering potential judicial proceedings that may be appropriate for the Government to initiate to protect its interests in its ongoing investigation of persons involved in alleged misconduct of Jeffrey Epstein; the Government's interests in potentially forfeitable property; and to vindicate any public policy interests that may be implicated by dispositions Jeffrey Epstein made in the foregoing documents for distribution of his property. The Assistant U.S. Attorneys who may receive this information arel and such other Assistant U.S. Attorneys who may in the future be assigned responsibility for this matter. + +2. It is further Ordered that the foregoing persons shall make no further disclosure of the documents that are the subject of this Order absent further order of the Court. + +3. It is further Ordered that this Order, and the Application upon which it was made, be filed under seal, except that a copy of this Order shall be provided to the persons identified above who are authorized to receive the documents that are the subject of this Order. + +Dated: New York, New York December 20, 2019 + +![](_page_10_Picture_2.jpeg) + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +In re Application of the United States for a Disclosure Order in connection with Grand Jury Investigation USAO Ref No. 2018R01618 in the United States District Court for the Southern District of New York + +#### Ex Parte Sealed Application for Grand Jury Disclosure Order + +19 Misc. + +The United States of America (the "Government"), by its attorney, Geoffrey S. Berman, United States Attorney for the Southern District of New York, Associate United States Attorney, of counsel, respectfully moves this Court pursuant to Federal Rule of Criminal Procedure 6(e)(3)(EXi) & 6(e)(3XF) for an order authorizing disclosure of certain grand jury matters in aid of a continuing investigation into conduct by associates of Jeffrey Epstein relating to alleged sex trafficking of minors by Jeffrey Epstein, and other offenses, and possible forfeitures or injunctive relief. This application relates specifically to a trust created by Jeffrey Epstein that would receive most (if not all) of Jeffrey Epstein's assets, including potentially forfeitable assets, and pursuant to which substantial payments would be made over time to individual beneficiaries, including individuals who may be of interest in the ongoing investigation. By this application we request authorization to disclose the trust agreement and related documents to a trusts and estates expert we have retained to advise us in this area of law, and to attorneys in our Civil Division who would represent the Government in any litigation that may appear advisable to assert Government interests concerning these matters. + +1. The Criminal Investigation. In November 2018, this Office, in conjunction with the Federal Bureau of Investigation and the New York City Police Department, commenced an investigation into conduct by Jeffrey Epstein and possible co-conspirators involving, among other things, alleged sex trafficking of minors during the period from (at least) the mid-1990s through the summer of 2019. On July 2, 2019, afederal grand jury in this district returned an indictment charging Jeffrey Epstein with sex trafficking of minors and conspiracy to commit sex trafficking of minors in United States v. Epstein, 19 Cr. 490 (RMB). On August 10, 2019, Jeffrey Epstein died by suicide while incarcerated at the Manhattan Correctional Center awaiting trial on those charges. But despite Epstein's death this Office has continued its criminal investigation into the conduct of other individuals, including possible co-conspirators, as well as possible obstructive conduct by co-conspirators or associates of Epstein. + +2. As alleged in the indictment against Epstein and in filings in that case, Epstein and others engaged in a years-long scheme to sexually abuse underage girls. In particular, Epstein enticed and recruited dozens of minor girls to engage in sex acts with him, for which he typically paid the victims hundreds of dollars in cash. He undertook this activity in several locations, including his mansion in Manhattan, New York; his estate in Palm Beach, Florida; and his private island located in the U.S. Virgin Islands. The defendant typically paid his victims hundreds of dollars in cash for each separate encounter. Epstein worked with others, including employees and associates, to facilitate this exploitation by, among other things, contacting victims and scheduling their sexual encounters with the defendant in New York and in Florida. + +3. Additionally, in connection with a prior investigation of Epstein's conduct in Florida, there were credible allegations that Epstein engaged in witness tampering, harassment, or other obstructive behaviors. Extensive allegations of obstruction and tampering by Epstein were also made in connection with civil lawsuits brought against Epstein. See Doe v. United States, 08 Civ. 80736(S.D. Fla.), Dkt. 291-15 at 21-23, 31. More recent instances of potential obstruction surfaced following the publication, commencing November 28, 2018, of aseries of articles in the Miami Herald regarding Epstein and the circumstances of his prior conviction for solicitation of aminor. Records obtained by the Government show that two days later, on or about November 30, 2018, Epstein wired \$100,000 from atrust account he controlled to an individual previously identified as apossible co-conspirator, and that just three days after that, on or about December 3, 2018, Epstein wired \$250,000 from the same trust account to another individual previously identified as apossible co-conspirator and who was identified as one of Epstein's employees in the Indictment. 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 more recently re-emerging allegations. + +4. Epstein's Will and Trust Agreements. As part of the Government's continuing investigation, the Government obtained, via grand jury subpoena, the Will that Epstein executed on April 8, 2019, shortly before his death; and the Trust Agreement of The 1953 I Trust, also executed on April 8, 2019. The Government also obtained, via grand jury subpoena, two prior trust agreements referenced in The 1953 Trust Agreement. The Will has been publicly filed in probate proceedings that are taking place in the U.S. Virgin Islands, but the various trust documents are not public. (We have been advised that in normal circumstances, trust agreements set up in connection with estate planning are not generally made public.) + +5. Epstein's Will directs that, after certain payments of fees and distributions, all property be provided to the Trustees of The 1953 Trust. Property whose disposition is covered by the Trust includes Epstein's New York City residence which was identified as subject to criminal forfeiture in the Epstein indictment and which may continue to be subject to civil or criminal forfeiture. + +&quot;1953" may be areference to the year of Epstein's birth. + +Other potentially forfeitable property, including Epstein's other residences, is also purportedly covered by the Trust. + +6. Potential Proceedings Concerning Epstein's Will and The 1953 Trust. To assist the Government in evaluating its need or ability to become involved in trust and estate proceedings, our Office has retained Yale Law School Professor, a noted expert in the field of trusts and estates, to advise us concerning, among other things, any interests the Government may have in the Epstein probate proceedings in the U.S. Virgin Islands, and any actions it might take, including potential injunctive relief the Government might seek to, for example, preserve its interests in potentially forfeitable property, or to void appropriate provisions of The 1953 Trust Agreement as contrary to public policy. If it appears necessary and appropriate to initiate proceedings in probate or another court to vindicate the Government's interests in this area, we anticipate that the litigation would be handled by the attorneys in our Civil Division. + +7. By this application, the Government requests authorization to disclose the Epstein Will, The 1953 Trust Agreement, and related trust documents, to Professor and to the Civil Division attorneys assigned to this matter' so that they may provide informed advice and consideration regarding judicial proceedings that may be appropriate for the Government to initiate relating to the dispositions Jeffrey Epstein made relating to his property. + +8. Standard for Disclosure. The Supreme Court has interpreted Rule 6(3XeXE)(i) "to require a strong showing of particularized need for grand jury materials before any disclosure will be permitted." United States v. Sells Engineering, Inc., 463 U.S. 418, 443 (1983). Although this + +2 The Civil Division attorn ssi tied tot is matt . + +standard applies to requests for disclosure to government attorneys, the Supreme Court has "made it clear that the concerns that underlie the policy of grand jury secrecy are implicated to a much lesser extent when the disclosure merely involves Government attorneys." United States v. John Doe, Inc. 1, 481 U.S. 102, 112 (1987). Thus, + +a district court might reasonably consider that disclosure to Justice Department attorneys poses less risk of further leakage or improper use than would disclosure to private parties or the general public. Similarly, we are informed that it is the usual policy of the Justice Department not to seek civil use of grand jury materials until the criminal aspect of the matter is closed. And "under the particularized need standard, the district court may weigh the public interest, if any, served by disclosure to a governmental body . . . ." On the other hand, for example, in weighing the need for disclosure, the court could take into account any alternative discovery tools available by statute or regulation to the agency seeking disclosure. + +United States v. Sells Engineering, Inc., 463 U.S. at 445 (citations omitted) (quoting United States v. Abbott, 460 U.S. 557, 567 n.15 (1983)). Here, the requested disclosure is for a narrow scope of materials, to limited individuals, for the narrow purpose of identifying proceedings the Government may need to initiate in order to avoid interference with its ongoing criminal investigation, potential forfeiture interests, and related matters. Indeed, one of the major purposes of this disclosure is to identify and address any issues that might affect the continuing criminal grand jury investigation into Epstein-related conduct. + +9. Authorization Requested. The Government accordingly requests that the Court enter an Order, in the form attached, authorizing the Government to disclose to Professor and to the Civil Division attorneys (and their successors, if any) the Epstein Will; The 1953 Trust Agreement; and earlier related trust agreements, for the purpose of obtaining advice and consideration of proceedings that may be appropriate for the Government to initiate to protect its interests in the ongoing criminal investigation; potential forfeiture matters; and asserting public policy considerations that may be raised by The 1953 Trust Agreement. + +10. Sealing. Because this relates to grand jury matters and concerns documents that are not otherwise already public, the Government respectfully requests that the Court order this Application be filed under seal pursuant to Fed. R. Crim. P. 6(e)(6); and that the Court's Order also be filed under seal, except that the Government may disclose the Order to persons to whom the information at issue herein is disclosed. + +11. Prior Requests. No prior request for the relief sought herein has been made. + +WHEREFORE, I respectfully request that the Court issue a Disclosure Order in the form submitted herewith. + +Dated: New York, New York December 19, 2019 + +> GEOFFREY S. BERMAN United States Attorney Southern District of New York + +By: + +Associate United States Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00086220/EFTA00086220.metadata.json b/marker2/ds9/EFTA00086220/EFTA00086220.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..648f19bd91f9ee9b68d62cc5735ee80a6bfcf155 --- /dev/null +++ b/marker2/ds9/EFTA00086220/EFTA00086220.metadata.json @@ -0,0 +1,738 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086220.pdf", + "engine": { + "marker_major": "2", + "marker_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": 27620, + "elapsed_seconds": 4.83, + "image_assets": [ + "_page_10_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": 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a/marker2/ds9/EFTA00086237/EFTA00086237.md b/marker2/ds9/EFTA00086237/EFTA00086237.md new file mode 100644 index 0000000000000000000000000000000000000000..ab3078c8717b18509b208a208a35599331015830 --- /dev/null +++ b/marker2/ds9/EFTA00086237/EFTA00086237.md @@ -0,0 +1,41 @@ +To: + +Subject: Re: DAILY BEAST: Prince Andrew: I'm Ready to Talk. The FBI Never Asked. Feds: Oh Yes, We Did + +Date: Wed, 05 Feb 2020 19:04:39 +0000 + +Agree, I couldn't quite remember the exact quote. + +Sent from my iPhone + +On Feb 5, 2020, at 1:53 PM, + +It didn't quite accuse me of doing it for the exposure. + +Subject: DAILY BEAST: Prince Andrew: I'm Ready to Talk. The FBI Never Asked. Feds: Oh Yes, We Did + +Prince Andrew and the FBI were involved in a furious war of words Tuesday, after he denied claims made by the U.S. attorney for Manhattan, he has refused to cooperate with American authorities investigating Jeffrey Epstein's alleged sexual abuse. that + +> Andrew said no request had been received, and he was ready to talk. + +However a spokesperson for office told The Daily Beast they stood by the prosecutor's comments, specifically the claim that they had "made several attempts to contact" Andrew's representatives. + +Andrew, 59, however, was said to be "angry and bewildered," according to The DailyTelegraph, at allegations made byBerman. + +On Monday, called out Andrew for giving "zero co-operation" to the investigation into Epstein at a press conference held outside Epstein's infamous front door. + +"Nothing could be further from the truth," a source described as "close to" Andrew told The Telegraph, "The Duke is more than happy to talk to the FBI but he hasn't been approached by them yet. + +"He is angry about the way this is being portrayed and bewildered as to why this was said in New York. It seems certain people are jumping the gun." + +However law-enforcement sources were adamant that they "stood by" remarks. + +said he was taking the rare step of calling Andrew out by name because Andrew himself, in his disastrous Newsnight interview, had said: "I am willing to help any appropriate law-enforcement agency with their investigations, if required." + +While many observers saw remarks as a desperate (and likely unsuccessful) attempt to shame Prince Andrew into living up to his earlier vow, + +Duncan Levin, a former federal and New York state prosecutor in the Manhattan DA's office, saw something else: evidence of the authorities' determination to leave no stone unturned as they go after the rich and powerful global network which Epstein cultivated. + +Levin, who is now a managing partner at Tucker Levin, PLLC, told The Daily Beast that while it was "highly unusual for a prosecutor to make a public statement about a witness's reluctance to cooperate with law enforcement" there is "nothing usual about this case, in any way. Prince Andrew is not your typical witness, by any stretch of the imagination." + +![](_page_4_Picture_2.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00086237/EFTA00086237.metadata.json b/marker2/ds9/EFTA00086237/EFTA00086237.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c9da7c5972671054b94868ca4a9f38dd6cbbde85 --- /dev/null +++ b/marker2/ds9/EFTA00086237/EFTA00086237.metadata.json @@ -0,0 +1,180 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086237.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2654, + "elapsed_seconds": 0.82, + "image_assets": [ + "_page_4_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Line", + 18 + ], + [ + "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", + 23 + ], + [ + "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 + } + }, + { + "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 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Line", + 11 + ], + [ + "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": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 14 + ], + [ + "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/EFTA00086237" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086237/_page_4_Picture_2.jpeg b/marker2/ds9/EFTA00086237/_page_4_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..ce4236e46926104ab71a0035c78201e7227ede61 --- /dev/null +++ b/marker2/ds9/EFTA00086237/_page_4_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:b6088f2f5d08f48483a80cbb01156cd7eed2f2fd18889e4a9a12d01146a76760 +size 9621 diff --git a/marker2/ds9/EFTA00086242/EFTA00086242.md b/marker2/ds9/EFTA00086242/EFTA00086242.md new file mode 100644 index 0000000000000000000000000000000000000000..b2a820072af807f42546e20ba81a3267a16c85dd --- /dev/null +++ b/marker2/ds9/EFTA00086242/EFTA00086242.md @@ -0,0 +1,109 @@ +From: (USANYS)" I + +To: (USANYS)" + +Subject: RE: Noel Status + +Date: Mon, 26 Apr 2021 18:32:06 +0000 + +Nope, not yet. + +From: (USANYS) + +Sent: Monday, April 26, 2021 2:29 PM + +To: (USANYS) + +Subject: RE: Noel Status + +Has IM or spoken to you yet? sent them with a followup question/action item I think on Friday. + +From: (USANYS) + +Sent: Monday, April 26, 2021 2:28 PM + +To: (USANYS) < + +Subject: RE: Noel Status + +10, but an update would be nice \*&,) + +From: (USANYS) + +Sent: Monday, April 26, 2021 2:27 PM + +To: (USANYS) + +Subject: RE: Noel Status + +Just + +From: (USANYS) + +Sent: Monday, April 26, 2021 2:27 PM + +To: (USANYS) < + +Subject: RE: Noel Status + +Is this just for or for all of us? + +From: (USANYS) < + +Sent: Monday, April 26, 2021 2:26 PM + +To: (USANYS) (USANYS) < >; + +(USANYS) + +Cc: (USANYS) (USANYS) + +Subject: RE: Noel Status + +Give me a ring. + +From: (USANYS) + +Sent: Monday, April 26, 2021 1:16 PM + +To: (USANYS) < (USANYS) (USANYS) < >; + +Hi all, + +Sorry to bug on this, but I think we'll need to provide an update and/or seek more time from the Court by Wednesday at latest in the Epstein FOIA if we do not think there will be a determination on the Noel DP today or tomorrow, and I'll have to check in with the Times in some form before we do that. Is it possible to provide any sense of the timing, or an update on where things stand in Noel? + +Thanks, + +From: (USANYS) + +Sent: Thursday, April 22, 2021 10:44 AM + +To:IIIIIIII (USANYS) (USANYS) (USANYS) + +Subject: RE: Noel Status + +Probably - but I will have a better sense tomorrow and will get back you you. + +From: (USANYS) + +Sent: Thursday, April 22, 2021 10:36 AM + +To: (USANYS) (USANYS) + +Cc: (USANYS) + +Subject: Noel Status + +Hi all, + +Would it be possible to provide an update on the status of the deferred prosecution agreements in Noel? Do we anticipate having a determination on those in the next few days? We may need to update the Court and/or check in with the Times about timing in the Epstein FOIA depending on where things stand on the DP front. + +Thanks, + +Assistant United States Attorney + +300 Quarropas Street + +White Plains, NY 10601 + +Telephone: \ No newline at end of file diff --git a/marker2/ds9/EFTA00086242/EFTA00086242.metadata.json b/marker2/ds9/EFTA00086242/EFTA00086242.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..064b139c9a5d6088ff105706201458990f2a9a21 --- /dev/null +++ b/marker2/ds9/EFTA00086242/EFTA00086242.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086242.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2094, + "elapsed_seconds": 1.55, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 80 + ], + [ + "Line", + 39 + ], + [ + "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 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 32 + ], + [ + "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/EFTA00086242" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086244/EFTA00086244.md b/marker2/ds9/EFTA00086244/EFTA00086244.md new file mode 100644 index 0000000000000000000000000000000000000000..f49bf68eb2e77fd0f06ab8653ec808217f221487 --- /dev/null +++ b/marker2/ds9/EFTA00086244/EFTA00086244.md @@ -0,0 +1,19 @@ +BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 + +Main + +••Covid-19 Notice: The \Vest 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. \ No newline at end of file diff --git a/marker2/ds9/EFTA00086244/EFTA00086244.metadata.json b/marker2/ds9/EFTA00086244/EFTA00086244.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..761b583a58a25b1c36e2c3c796bde617f3518461 --- /dev/null +++ b/marker2/ds9/EFTA00086244/EFTA00086244.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086244.pdf", + "engine": { + "marker_major": "2", + "marker_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": 863, + "elapsed_seconds": 0.54, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "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/EFTA00086244" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086245/EFTA00086245.md b/marker2/ds9/EFTA00086245/EFTA00086245.md new file mode 100644 index 0000000000000000000000000000000000000000..733dd92438c74514a81d8df2384ad1b3484eec8d --- /dev/null +++ b/marker2/ds9/EFTA00086245/EFTA00086245.md @@ -0,0 +1,13 @@ +From: Nathan NYSD Chambers To Cc: (USANYS It -41 • Laura Mennin er !men:mile hmflaw.com>, ' , Jeff Pal liuca C + +Subject: Memorandum Endorsement in 20-cr-330, US v Maxwell + +Date: The, 27 Apr 2021 14:50:24 +0000 + +Attachments: 20cr330\_Memo\_Endorsement\_4.27.21.pdf + +Good morning, + +Please find attached a memorandum endorsement signed by Judge Nathan, which will be filed on the public docket shortly. Please confirm receipt. + +Respectfully, The Chambers of the Hon. Alison J. Nathan \ No newline at end of file diff --git a/marker2/ds9/EFTA00086245/EFTA00086245.metadata.json b/marker2/ds9/EFTA00086245/EFTA00086245.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..82838e1c637631dfa4dbe7cb4860da16cec26ecb --- /dev/null +++ b/marker2/ds9/EFTA00086245/EFTA00086245.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086245.pdf", + "engine": { + "marker_major": "2", + "marker_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": 480, + "elapsed_seconds": 0.42, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 34 + ], + [ + "Line", + 17 + ], + [ + "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/EFTA00086245" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086246/EFTA00086246.md b/marker2/ds9/EFTA00086246/EFTA00086246.md new file mode 100644 index 0000000000000000000000000000000000000000..686f875a8173e9f1695614405b8f6ef6478639fc --- /dev/null +++ b/marker2/ds9/EFTA00086246/EFTA00086246.md @@ -0,0 +1,214 @@ +212-243-1100 • Mole 917-306-6666 • Cell 888-587-4737 • Fax + +Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 + +![](_page_0_Picture_7.jpeg) + +Dear Judge Nathan: + +33 West 19th Stre New York, N, bC@Sli + +April 26, 2021 + +Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) + +| USDC SDNY | +|----------------------------| +| DOCUMENT | +| ELECTRONICALLY FILED | +| DOC #: _____ | +| DATE FILED: 4/27/21 | + +MDC legal counsel is hereby ORDERED to show cause by April 28, 2021 why an order directing the MDC to provide the information requested in this letter to the Defendant's counsel ought not issue. MDC legal counsel shall either docket it on ECF or email the letter to the Court so that the Court can docket it on ECF. Chambers will email a copy of this Order directly to legal counsel for the MDC. SO ORDERED. + +I write to report an incident stemming from an attorney-client conference with Ghislaine Maxwell: Guards on Ms. Maxwell's security detail wrongfully seized and reviewed her confidential legal documents and then intimidated Ms. Maxwell by standing over her as she used the bathroom after threatening her with a disciplinary infraction. This incident has further compromised Ms. Maxwell's ability to prepare for trial, to confer with counsel, and to retain confidential legal documents. In addition, intimidation and humiliation by guards has further exacerbated Ms. Maxwell's feelings of insecurity due to officious power exerted upon her by guards. + +On Saturday, April 24, 2021, Leah Saffian, Esq. and I attended a pre-scheduled in-person legal conference with Ms. Maxwell in the MDC. The entire 2.5-hour conference was conducted under the constant watch of four to five guards, including a lieutenant, with a camera on a tripod focused on Ms. Maxwell and counsel while recording audio and video, and captured on surveillance cameras affixed within the visiting room. After counsel left the facility, Ms. Maxwell called me to report that her legal papers were confiscated. + +stated: Later that day, I received an email from MDC legal counsel, which + +It has been brought to my attention by the staff of MDC Brooklyn that Ms. Maxwell received paperwork that was not in her possession upon entering the legal visiting area. As you are aware, the policies setforth for MDC Brooklyn legal visits do not allow for passing of any material during a legal visit. Due to our policy and procedures, the additional documents that were provided to Ms. Maxwell were confiscated. Those materials were put in an envelope and will be returned to you tomorrow upon your arrival to the institution. Please note, that you may put these documents in the legal mailbox in the lobby of the east building. + +See Exhibit A. + +I emailed the following response to + +Your accusation is inaccurate as is the information reported to you by your staff Nothing in Ms. Maxwell 's legal papers was given to her by me or by Leah Saffian, Esq. Both Ms. Swan and I dispute these allegations in the strongest terms. Today, Ms. Wiwi and I met with Ghislaine Maxwell for a scheduled legal visit- under the gaze of S guards and a portable camera recording audio and video. + +After the legal visit concluded and Ms. Saffian and I left the visiting area, guards accused Ms. Maxwell of possessing documents obtained from counsel. The guards seized confidential documents ftom her, including documents she had previously received in legal mail delivered to the MDC and given to her by MDC staff After seizing "highly confidential" documents (subject to a protective order that your staff is not authorized to review) and work product, the guards began reading the documents and have not returned them to Ms. Maxwell. + +At no time did the guards, who were assiduously watching and filming the legal conference, bring any concern to my attention, so it is quite telling that you have been contacted when counsel are told that legal staff are unavailable during the weekend. + +No documents were given to Ms. Maxwell for her retention. Demand is hereby made for an immediate identification of the documents you claim were not in Ms. Maxwell's possession upon entering the legal visiting area in advance of the arrival of counsel, a list of all guards present during the visit, and a copy of the video recording. + +Please immediately return the confiscated legal documents to Ms. Maxwell. They are her documents, not mine. The confiscation of these documents has deprived Ms. Maxwell of her time and seriously impaired her ability to review legal documents and prepare for an upcoming trial, adding to an already difficult situation. + +This matter is being reported to the Court and legal action will be initiated. + +See Exhibit B. + +A notice and demand to preserve items of evidence has been send to Exhibit C. See + +## Confiscation and Review of Confidential Legal Documents + +in advance of previous in-person legal visits, guards have gone through Ms. Maxwell's legal papers. in a break from such protocol, the guards did not do so prior to commencement of the legal visit on Saturday. + +After the legal conference and departure of counsel, the guards seized all of Ms. Maxwell's legal papers, consisting of multiple letter-sized manilla folders containing documents and a composition notebook within a Redweld folder. The guards told Ms. Maxwell they believed she improperly retained documents given to her by her attorneys and that this was a + +very serious offense. Ms. Maxwell observed three guards going through the Redweld, reading papers and pages of the notebook, dividing papers into two stacks, and leaving the room with the papers. The lieutenant took the papers out of Ms. Maxwell's sight. Ms. Maxwell asked the guards what documents were being taken; the guards refused to respond. While Ms. Maxwell could not see with specificity which documents were seized and removed to another room, she does know that documents contained in the folders and reviewed by the guards were subject to the protective order, attorney-client privileged communication, and defense work-product. + +Guards confronted Ms. Maxwell and stated in sum and substance: + +We want you to know that what you did was a very serious infraction. It was so serious that it is worthy of an incident report and a disciplinary. It has been decided this time you will receive a caution. + +### Intimidation and Humiliation Off-Camera + +After the confiscation of her papers, Ms. Maxwell requested and was given permission to use the bathroom. But unlike any other occasion, the guard team leader stood knee to knee with Ms. Maxwell while Ms. Maxwell sat on the commode in the small area containing one toilet and a sink. In addition to denying Ms. Maxwell any privacy, the guard confronted her in a confined space off-camera. + +Although Ms. Maxwell was ultimately informed that she would not receive a disciplinary infraction for the incident, being falsely accused of "a very serious offense" and having a guard standing over her while she used the commode caused Ms. Maxwell to feel intimidated and humiliated. + +#### A Further Chill on Attorney-Client Communication, Confidentiality, And Capacity to Prepare for Trial + +Being falsely accused of an infraction, being threatened with discipline, and having her legal papers confiscated has caused Ms. Maxwell to feel heightened insecurity under the control of her officious handlers. Further, this incident has put a chill on attorney-client communication because Ms. Maxwell no longer feels that she can bring legal materials to legal conferences. At the in-person legal conference on Sunday, Ms. Maxwell specifically chose not to bring documents that if confiscated and reviewed by MDC staff would compromise her defense. Documents seized on Saturday were given to Ms. Saffian, but it is unknown whether any seized documents were retained or copied by the MDC. The documents returned to Ms. Saffian had been sent as "legal mail" to Ms. Maxwell by other counsel sometime prior to the Saturday visit and had never been possessed by me or Ms. Saffian. + +Ms. Maxwell's reaction and concerns are well-founded. The guards took undue advantage of her. If they believed that counsel had given documents to Ms. Maxwell for her retention, they should have addressed the issue in the presence of counsel. The conduct of which both Ms. Maxwell and counsel have been accused did not happen; and the conduct on the part of the guards was reprehensible. + +Ms. Maxwell no longer feels that her legal papers are safe and believes that the confidentiality required to prepare her defense for trial has been irreparably breached. She is justifiably concerned that her defense documents and their contents have been improperly reviewed and disseminated. The fact that the guards did not confront counsel but chose to confiscate legal documents after Ms. Maxwell's lawyers left the visiting area further validates her suspicion and that of her counsel. In addition, Ms. Maxwell is fearful that she will be subject to retaliation, baseless allegations, and unwarranted and unprovoked discipline. + +Ms. Maxwell is an indicted pit-trial detainee who has asserted her right to counsel. Once the right to counsel has attached and is asserted, as is the case here, the government must honor it. This means more than that the government "cannot prevent the accused from obtaining the assistance of counsel. The Sixth Amendment also imposes on the government an affirmative obligation to respect and preserve the accused's choice to seek this assistance." Maine v. Moulton, 474 U.S. 159, 170-71 (1985). + +The actions by the MDC guards violated Ms. Maxwell's Sixth Amendment right to effective assistance of counsel. Without any justifiable cause they seized and inspected legal materials, failed to identify the materials seized, and withheld the materials for improper purposes. Ms. Maxwell does not know if the materials were duplicated in some fashion, i.e., photocopied, scanned, or photographed. She does not know whether the MDC plans to give any of these privileged and confidential materials or the information contained therein to the prosecution or leak them to the press. And, given the prior treatment of Ms. Maxwell's HIPPAprotected medical information, these concerns are warranted. + +Ms. Maxwell requests that the Court enter an order directing that the MDC, through its legal counsel and/or warden, to provide to Ms. Maxwell's attorneys, only, the following information: + +- the identity of the person or persons who seized the legal material; +- an inventory of the items seized; +- a statement, subject to penalty of perjury, regarding whether the materials were duplicated in any fashion; and +- whether any disciplinary or corrective action was taken against any of the offending guards. + +Very truly yours, + +BOBBI C. STERNHEIM + +Encs. + +cc: All counsel of record + +From: Subject: Legal Visit 04.24.21 Date: April 24.2021 at 4:07 PM To: bcslernheim@mac.com Cc: + +![](_page_4_Picture_2.jpeg) + +Good afternoon Bobbi: + +It had been brought to my attention by the staff of MDC Brooklyn that Ms. Maxwell received paperwork that was not in her possession upon entering the legal visiting area. As you are aware, the policies set forth for MDC Brooklyn legal visits do not allow for passing of any material during a legal visit. Due to our policy and procedures, the additional documents that were provided to Ms. Maxwell were confiscated. Those materials were put in an envelope and will be returned to you tomorrow upon your arrival to the institution. Please note, that you may put these documents in the legal mail box in the lobby of the east building. + +Thank you for understanding. + +Best. + +![](_page_4_Picture_7.jpeg) + +From: BOBBI C STERNHEIM bcslernheim@mac.com + +Subject: Ghislaine Maxwell 02879-509 Legal Visit 04.24.21 + +Date: April 24.2021 at 5:37 PM + +To: + +Cc: Leah Safflan leahsaffian@hoslednet.net. Christian Everdell CEverdellecohengresser.com, Laura Menninger Imenninger@hmflaw.com. Jeff Pagliuca jpagliuca@hmflaw.com + +Your accusation is inaccurate as is the information reported to you by your staff. Nothing in Ms. Maxwell's legal papers was given to her by me or by Leah Saffian. Esq. Both Ms. Saffian and I dispute these allegations in the strongest terms. + +Today. Ms. Saffian and I met with Ghislaine Maxwell for a scheduled legal visit• under the gaze of 5 guards and a portable camera recording audio and video. + +After the legal visit concluded and Ms. Saffian and I left the visiting area, guards accused Ms. Maxwell of possessing documents obtained from counsel. The guards seized confidential documents from her. including documents she had previously received in legal mail delivered to the MDC and given to her by MDC staff. After seizing 'highly confidential' documents (subject to a protective order that your staff is not authorized to review) and work product. the guards began reading the documents and have not returned them to Ms. Maxwell. + +At no time did the guards. who were assiduously watching and filming the legal conference, bring any concern to my attention. so it is quite telling that you have been contacted when counsel are told that legal staff are unavailable during the weekend. + +No documents were given to Ms. + +Maxwell for her retention. Demand is hereby made for an immediate identification of the documents you claim were not in Ms. + +Maxwell's possession upon entering the legal visiting area in advance of the arrival of counsel. a list of all guards present during the visit, and a copy of the video recording. + +Please immediately return the confiscated legal documents to Ms. Maxwell. They are her documents, not mine. The confiscation of these documents has deprived Ms. Maxwell of her time and seriously impaired her ability to review legal documents and prepare for an upcoming trial, adding to an already difficult situation. + +This matter is being reported to the Court and legal action will be initiated. + +Regarding tomorrow• I have recieved 15 different confirmations and cancellations regarding the scheduled visit for tomorrow. which will be attended by Ms. Saffian alone. + +I am sorting through these entails to determine what time period is permitted for tomorrow's visit. + +Bobbi + +BOBBI C. STERNHEIM, ESO. Law Offices of Bobbl C. Stemhelm 33 West 19th Street • 4th Floor New York, NY 10011 + +Main + +Cell: + +Fax: + +bcsternhelm@mac.com + +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•mall and then delete this message. + +Thank you. + +On Apr 24. 2021. at 4:07 PM. wrote: + +Good afternoon Bobbi: + +It had been brought to my attention by the staff of MDC Brooklyn that Ms. Maxwell received paperwork that was not in her possession upon entering the legal visiting area. As you are aware, the policies set forth for MDC Brooklyn legal visits do not allow for passing of any material during a legal visit. Due to our policy and procedures, the additional documents that were provided to Ms. Maxwell were confiscated. Those materials were put in an envelope and will be returned to you tomorrow upon your arrival to + +Thank you for understanding. + +Best, + +![]()212-243-1100 • Mole 917-306-6666 • Cell IM -587-4737 • Fax + +#### VIA EMAIL AND U.S. MAIL + +Sophia Papapetru, Esq. Legal Counsel Metropolitan Detention Center 80 29'h Street Brooklyn, NY 11232 + +33 West 19th Street - 4th Floor New York, New York 10011 bc@sternheknlow.com + +April 26, 2021 + +### NOTICE AND DEMAND TO PRESERVE ITEMS OF EVIDENCE + +Re: Ghislaine Maxwell 02879-509 + +Dear Ms. Papapetru: + +As counsel for Ghislaine Maxwell, 02879-054, I am notifying you, as legal counsel for the Metropolitan Detention Center, of the MDC's obligation to preserve documents and evidence related to (i) allegations made against Ms. Maxwell and her counsel regarding legal paperwork allegedly passed to Ms. Maxwell during an attorney-client conference on April 24, 2021 and (ii) the confiscation and review of Ms. Maxwell's documents by MDC staff. + +As stated in my April 24th email, material relevant to this dispute includes, but is not limited to: + +- Any images, data files, or video recordings of the legal conference as captured on the hand-held camera focused on Ms. Maxwell and counsel during the entirety of the legal conference. +- Any images, data files, or video recordings of the legal conference as captured on surveillance cameras focused on Ms. Maxwell and counsel during the entirety of the legal conference. +- The full names of all guards, including the lieutenant, present in the visiting room during the legal conference. +- Any written or recorded communications, whether stored in electronic, digital or paper format, obtained in connection with the incident identified above. +- A list of all documents claimed to be in Ms. Maxwell's possession upon entering the visiting room. This request includes copies of any such documents or notes regarding same. + +- A list of all documents claimed have been given to Ms. Maxwell by counsel for her retention during the legal conference. +- Any written correspondence, or recorded communications, whether stored in electronic, digital or paper format, created by the guards, staff and other employees of the MDC and BOP. + +Please take adequate steps to preserve all documents and data compilations, including electronically stored information ("ESP"), copies and backups, along with any paper files maintained by the MDC relevant to this dispute. ESI should be stored and maintained in its native format. + +Counsel for Ms. Maxwell will be seeking electronic data in the custody and control of the individuals and entities identified in demand letter that is relevant to this incident, including without limitation, emails and other information contained on computer systems and any electronic storage systems. + +Counsel for Ms. Maxwell consider the electronic data and paper files and video recordings to be valuable and irreplaceable sources of discoverable information in this matter. + +Please take all necessary steps to prevent the deletion or destruction of any electronic communications, such as emails, voice mails, or electronic files relating to the above items. + +Very truly yours, + +gag C. 510144:41. + +BOBBI C. 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b/marker2/ds9/EFTA00086246/_page_4_Picture_7.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:bc643b42dd88685ced683f6246e90f038df5bc1d83a5acfcc435084c6eaaf973 +size 929 diff --git a/marker2/ds9/EFTA00086255/EFTA00086255.md b/marker2/ds9/EFTA00086255/EFTA00086255.md new file mode 100644 index 0000000000000000000000000000000000000000..f90c60a008492227976789301486be77e5b53f9d --- /dev/null +++ b/marker2/ds9/EFTA00086255/EFTA00086255.md @@ -0,0 +1,29 @@ +To: + +Subject: 21-58 United States of America v. Maxwell "Attorney TERMINATED" + +Date: Tue, 27 Apr 2021 15:27:37 +0000 + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. + +## Court of Appeals, 2nd Circuit + +## Notice of Docket Activity + +The following transaction was filed on 04/27/2021 + +Case Name: United States of America v. Maxwell + +Case Number: 21-58 + +## Docket Text: + +ATTORNEY, Christian R. Everdell, for Ghislaine Maxwell, TERMINATED.[3087477] [21-58, 21-770] + +Notice will be electronically mailed to: + +Ms. Bobbi C. Stemheim, Deputy C + +Notice will be stored in the notice cart for: + +Deputy Clerk Quality Control 1 \ No newline at end of file diff --git a/marker2/ds9/EFTA00086255/EFTA00086255.metadata.json b/marker2/ds9/EFTA00086255/EFTA00086255.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6c9456e1939684ef68dc64bd8228a662d4a2022f --- /dev/null +++ b/marker2/ds9/EFTA00086255/EFTA00086255.metadata.json @@ -0,0 +1,128 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086255.pdf", + "engine": { + "marker_major": "2", + "marker_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": 991, + "elapsed_seconds": 0.79, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Court of Appeals, 2nd Circuit", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 226.44, + 215.46000000000004 + ], + [ + 385.02130126953125, + 215.46000000000004 + ], + [ + 385.02130126953125, + 230.103515625 + ], + [ + 226.44, + 230.103515625 + ] + ] + }, + { + "title": "Notice of Docket Activity", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 240.57 + ], + [ + 164.67819213867188, + 240.57 + ], + [ + 164.67819213867188, + 255.603515625 + ], + [ + 30.6, + 255.603515625 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 342.63 + ], + [ + 101.65031433105469, + 342.63 + ], + [ + 101.65031433105469, + 358.3535461425781 + ], + [ + 30.6, + 358.3535461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 23 + ], + [ + "Text", + 13 + ], + [ + "SectionHeader", + 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/EFTA00086255" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086256/EFTA00086256.md b/marker2/ds9/EFTA00086256/EFTA00086256.md new file mode 100644 index 0000000000000000000000000000000000000000..32ccf0a9b78a16a4dde0cc7936d60193d01c49a1 --- /dev/null +++ b/marker2/ds9/EFTA00086256/EFTA00086256.md @@ -0,0 +1,24 @@ +**To:** [REDACTED] + +[REDACTED] + +[REDACTED] + +**Subject:** 3500 + +**Date:** Tue, 27 Apr 2021 21:02:56 +0000 + +**Attachments:** CONFIDENTIAL\_1\_-\_Facts.pdf; CONFIDENTIAL\_2\_-\_Facts\_on\_2017\_Declaration.pdf + +--- + +Hi [REDACTED] + +Could you please add the attached materials to the next production of NTW 3500 for [REDACTED]? Thanks! + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00086256/EFTA00086256.metadata.json b/marker2/ds9/EFTA00086256/EFTA00086256.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f37da8fe58f53e49737ea1e081349611ad94e676 --- /dev/null +++ b/marker2/ds9/EFTA00086256/EFTA00086256.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086256.pdf", + "engine": { + "marker_major": "2", + "marker_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": 407, + "elapsed_seconds": 2.48, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 19 + ], + [ + "Span", + 15 + ], + [ + "Line", + 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/EFTA00086256" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086257/EFTA00086257.md b/marker2/ds9/EFTA00086257/EFTA00086257.md new file mode 100644 index 0000000000000000000000000000000000000000..0811b5ab219f6f917a45ed7462060723dc5d17b1 --- /dev/null +++ b/marker2/ds9/EFTA00086257/EFTA00086257.md @@ -0,0 +1,13 @@ +From: " ME IMIIM> + +To: ' + +Cc: + +Subject: Epstein FOIA - Noel Team + +Date: Wed, 28 Apr 2021 02:28:35 +0000 + +Importance: Normal + +Attachments: unnamed \ No newline at end of file diff --git a/marker2/ds9/EFTA00086257/EFTA00086257.metadata.json b/marker2/ds9/EFTA00086257/EFTA00086257.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4cbec5ef066d73db1c4c48fcffbdda5f966a012c --- /dev/null +++ b/marker2/ds9/EFTA00086257/EFTA00086257.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086257.pdf", + "engine": { + "marker_major": "2", + "marker_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": 145, + "elapsed_seconds": 0.5, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Text", + 9 + ], + [ + "Line", + 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/EFTA00086257" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086258/EFTA00086258.md b/marker2/ds9/EFTA00086258/EFTA00086258.md new file mode 100644 index 0000000000000000000000000000000000000000..22e54e2b63fd7d274918c07e6624924ec9822302 --- /dev/null +++ b/marker2/ds9/EFTA00086258/EFTA00086258.md @@ -0,0 +1,21 @@ +Start Date: 2021-04-28 16:30:00 +0000 + +End Date: 2021-04-28 17:00:00 +0000 + +Organizer: + +Class: X-PERSONAL + +Date Created: 2021-04-28 05:17:38 +0000 + +Date Modified: 2021-04-28 05:17:38 +0000 + +Priority: 5 + +DTSTAMP: 2021-04-28 02:28:32 +0000 + +Attendee: + +Alarm: Display the following message 15m before start + +Reminder \ No newline at end of file diff --git a/marker2/ds9/EFTA00086258/EFTA00086258.metadata.json b/marker2/ds9/EFTA00086258/EFTA00086258.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..dbc4c944100f354350da6b6abbbb9ed003597a37 --- /dev/null +++ b/marker2/ds9/EFTA00086258/EFTA00086258.metadata.json @@ -0,0 +1,82 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086258.pdf", + "engine": { + "marker_major": "2", + "marker_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": 313, + "elapsed_seconds": 0.56, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Event: Epstein FOIA - 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Could you please help us create some review batches for this database? In particular, if you could please create batches of all materials designated responsive in the search warrant database that hit on the following terms, that would be very helpful: + +> -gmax + +> -gmaxl + +> If the batches could be approximately 500 documents each, that would be great. 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[REDACTED] | Totagline | 2A | 13. | | | +| 2. | | | 14. | | | +| 3. | | | 15. | | | +| 4. | | | 16. | | | +| 5. | | | 17. | | | +| 6. | | | 18. | | | +| 7. | | | 19. | | | +| 8. | | | 20. | | | +| 9. | | | 21. | | | +| 10. | | | 22. | | | +| 11. | | | 23. | | | +| 12. | | | 24. | | | + +| | | OUT-COUNT BY UNIT | | | | +|-----|-----|-------------------|-----|---|-----| +| | | E-N | G-N | | | +| B-A | C-A | E-S | Z-A | I | Z-B | +| I-N | K-N | K-S | | | | + +1 + +Total Out-Counted: 1 + +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected counts. Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an Out-Count. No other form will be accepted in lieu of the Out-Count Form. + +NYMBH 530\*05 \* +PAGE 001 OF 001 + +CATEGORY: OCT +ASSIGNMENT: ATTY +OPER CATG ASSIGNMENT OPER CATG ASSIGNMENT + +GROUP CODE: +FACILITY: NYM +OPER CATG ASSIGNMENT + +NUM ASSIGNMENT REG NO NAME +0001 ATTY TARTAGLIONE + +OCT DATE QTR WRK +08-11-2019 205-124LAD UNASSG + +G0000 + +TRANSACTION SUCCESSFULLY COMPLETED + +DATE: F- 6 - + +FROM: (Staff Member Pre pad g Out Count) + +APPROVED 5 0peraticifattatemoro— + +# OFFICIAL OUT COUNT + +COUNT TIME: goo pfri + +LOCATION: cap2 + +| | | NAME | UNI | REG # NAME UNIT 13 14. | +|----|-----|------|------|------------------------| +| | | | vn 0 | 15 | +| | Tar | Lone | Z14" | 16 | +| 6 | | | | 18 | +| 7 | | | | 19 | +| 8 | | | | 20 | +| 9 | | | | 21 | +| 10 | | | | 22 | +| 11 | | | | 23 | +| 12 | | | | 24 | + +,a + +### OUT-COUNT BY UNIT + +B-A C-A E-N E-S G-N -S C I-N i K-N I K-S Ft-A 7,-A 7\_ 2,-B H-A + +Total Out-Counted: + +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. Prepare this form in Ink. Group the inmates according to their respective housing units. This form is to be used only as an Out-Count. No other form will be accepted in lieu of the Out-Count Form. + +NYMAQ 530.05 \* INMATE ROSTER • 08-06-2019 PAGE 001 OF 001 15:41:08 + +CATEGORY: OCT GROUP CODE: ASSIGNMENT: ATTY FACILITY: FYN OPER CATG ASSIGNMENT OPER CATG ASSIGNMENT OPER CATG ASSIGNMENT + +NUM ASSIGNMENT REG NO NAME OCT DATE QTR WRK 0001 ATTY ARAUJO 08-06-2019 I04-930U UNASSG 0002 EPSTEIN 08-06-2019 204-206LAD UNASSG 0003 MOORE 08-06-2019 K06-145U UNASSG 0004 TARTAGLIONE 08-06-2019 206-215UAD UNASSG + +G0000 TRANSACTION SUCCESSFULLY COMPLETED + +DATE: + +FROM: + +APPROVED: + +### OFFICIAL OUT COUNT + +COUNT TIME: + +LOCATION: hit/ oti + +| REG It 2 | NAME UNIT REG # NAME UNIT 13 E/04g Lk/ ga t 14 gte4G e it,k7 74 1 | +|----------|-------------------------------------------------------------------| +| 3 | 15 | +| 4 | 16 | +| 5 | 17 | +| 6 | 18 | +| 7 | 19 | +| 8 | 20 | +| 9 | 21 | +| 10 | 22 | +| 11 | 23 | +| 12 | 24 | + +### OUT-COUNT BY UNIT + +D-A C-A E-N E-S G-N G-S I-N K-N K-S R-A Z-A J Z-13 H-A + +Total Out-Counted: + +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE. MINUTES PRIOR to the affected count. Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an Out-Count. No other form will be accepted in lieu of the Out-Count Form. + +NYMAQ 530.05 • INMATE ROSTER 07-24-2019 PAGE 001 OF 001 15:37:50 + +CATEGORY; OCT GROUP CODE: ASSIGNMENT; ATTY FACILITY: NYM OPER CATG ASSIGNMENT OPER CATO ASSIGNMENT OPER CATO ASSIGNMENT + +NUM ASSIGNMENT REG NO NAME OCT DATE QTR WRK 0001 ATTY ' 1 EPSTEIN O7-24-2019 U01-OO1L UNASSG 0002 1 TARTAGLIONE 07-24-2019 7.06-215UAD UNASSO + +G0000 TRANSACTION SUCCESSFULLY COMPLRTRD + +OFFICIAL OUT COUNT + +DATE: 7-25-19 + +COUNT TIME: 400 m + +FROM: [REDACTED] + +LOCATION: Atty + +(Staff Member Preparing Out Count) + +APPROVED: [REDACTED] +(Operations Lieutenant) + +| REG # | NAME | UNIT | REG # | NAME | UNIT | +|-------|------------|----------------|-------|------|------| +| 1 | [REDACTED] | EPSTEIN H-A | 13. | | | +| 2 | [REDACTED] | ELANSKY G-N | 14. | | | +| 3 | [REDACTED] | TARTASHONE Z-A | 15. | | | +| 4. | | | 16. | | | +| 5. | | | 17. | | | +| 6. | | | 18. | | | +| 7. | | | 19. | | | +| 8. | | | 20. | | | +| 9. | | | 21. | | | +| 10. | | | 22. | | | +| 11. | | | 23. | | | +| 12. | | | 24. | | | + +OUT-COUNT BY UNIT + +| B-A | C-A | E-N | E-S | G-N | I | G-S | H-A | I | +|-----|-----|-----|-----|-----|---|-----|-----|---| +| I-N | K-N | K-S | R-A | Z-A | I | Z-B | | | + +Total Out-Counted: 3 + +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. Prepare this form in lock. Group the inmates according to their respective housing units. This form is to be used only as an Out-Count. No other form will be accepted in lieu of the Out-Count Form. + +NYMDK 530'05 • PAGE 001 OF 001 INMATE ROSTER • 07-25-2019 1S:36:23 + +CATEGORY: OCT CROUP CODE: ASSIGNMENT: ATTY FACILITY: NYM OPER CATG ASSIGNMENT OPER CATG ASSIGNMENT OPER CATG ASSIGNMENT + +NUM ASSIGNMENT RF.0 NO NAME. OCT DATE QTR WRK 0001 ATTY ELANSKY 07-25-2019 G01-703L UNASSG 0002 EPSTEIN 07-25-2019 M01-001L UNASSG 0003 TARTAGLIONE 07-25-2019 E06-215UAD UNASSG + +C0000 TRANSACTION SUCCESSFULLY COMPLETED + +DATE: + +FROM: + +APPROVED: + +7- - l el I 0 o o fro- t COUNT TIME: + +# OFFICIAL, OUT COUNT + +LOCATION: + +| REG 1. E 2. | NAME UNIT IIEG NAME UNIT IL ((t)a4e X A 14. | +|-------------|---------------------------------------------| +| 3. | 15. | +| 4. | 16. | +| 6. | 18. | +| 7. | 19. | +| 8. | 20. | +| 9. | 21. | +| 10. | 22. | +| 11. | 23. S. | +| 12. | 24. | + +## OUT-COUNT BY UNIT + +B-A C-A E-N E-8 G-N C-S I-N K-N K-S R-A Z-A i Z-B \_\_\_\_ B-A + +Total Out-Counted: + +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIORto the affected count. Prepare this form In ink. Group the inmates according to their respective housing units. This form is to be used only as an Out-Count. No other form will be accepted In lieu of the Out-Count Form. + +\* 07-27-2019 +09:35:37 + +| CATEGORY: OCT | | GROUP CODE: | | | | +|------------------|------|---------------|------|------|------------| +| ASSIGNMENT: ATTY | | FACILITY: NYM | | | | +| OPER | CATG | ASSIGNMENT | OPER | CATG | ASSIGNMENT | + +| NUM | ASSIGNMENT | REG NO | NAME | OCT DATE | QTR | WRK | +|------|------------|------------|-------------|------------|------------|--------| +| 0001 | ATTY | ██████████ | EPSTEIN | 07-27-2019 | H01-001L | UNASSG | +| 0002 | | ██████████ | TARTAGLIONE | 07-27-2019 | Z06-215UAD | UNASSG | + +G0000 + +TRANSACTION SUCCESSFULLY COMPLETED + +# METROPOLITAN CORRECTIONAL CENTER NEW YORK, NY OFFICIAL OUT COUNT + +DATE: + +COUNT TIME: r iat--- + +FROM: (S ff Wernher Preparing Out Count) LOCATION: + +APPROVED: (Operations Lieutenant) + +| APPROVED: _____
(Operations Lieutenant) | | REG # | NAME | UNIT | REG # | NAME | UNIT | +|--------------------------------------------|------------|-------|-------------|------|-------|------|------| +| 1. | [REDACTED] | | ARANTO | IN | 13. | | | +| 2. | [REDACTED] | | MYRIE | IN | 14. | | | +| 3. | [REDACTED] | | EPSTEIN | ZA | 15. | | | +| 4. | [REDACTED] | | TARTAG-HOWE | ZA | 16. | | | +| 5. | [REDACTED] | | | | 17. | | | +| 6. | | | | | 18. | | | +| 7. | | | | | 19. | | | +| 8. | | | | | 20. | | | +| 9. | | | | | 21. | | | +| 10. | | | | | 22. | | | +| 11. | | | | | 23. | | | +| 12. | | | | | 24. | | | + +OUT-COUNT BY UNIT B-A • C-A E-N E-S C-N G-S I-N 2.. K-N KS R-A Z-A + +Total Out-Counted: This form must be submitted to the Counts sod Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. + +Prepare this form in ink. Group the inmates according to their respective housing units. 'lids form is to be used only as an Oat-Count. No other form will be accepted in lieu of the Out-Count Form. + +NYMOK b30.05 • INMATE ROSTER • 08-01-2019 PAGR 001 OP 001 1S:50:29 + +CATEGORY: OCT GROUP CODE: ASSIGNMENT: ATTY FACILITY: NYM OPER CATC ASSIGNMENT OPER CATC ASSIGNMENT OPER CAW ASSIGNMENT + +NUM ASSIGNMENT REC NO NAME OCT DATE OTR WRK 0001 ATTY ARAUJO 08-01-2019 I04-206L UNASSG 0002 EPSTEIN 08-01-2019 Z04-206LAD UNASSG 0003 MYRIE 08-01-2019 TO3-922U UNASSG 0004 TARTAGLIONE 08-01-2019 706-21SUAD UNASSG + +G0000 TRANSACTION SUCCESSFULLY COMPLETED + +**OFFICIAL OUT COUNT** + +DATE: 8/04/19 + +COUNT TIME: 10:00 AM + +FROM: [REDACTED] + +LOCATION: Affy Count + +APPROVED: [REDACTED] + +[REDACTED] (Operations Lieutenant) + +| REG # | NAME | UNIT | REG # | NAME | UNIT | +|-------|------------|----------------|-------|------|------| +| 1. | [REDACTED] | MACK GN | 13. | | | +| 2. | [REDACTED] | TARTAGLIONE ZA | 14. | | | +| 3. | [REDACTED] | BOSTON ZA | 15. | | | +| 4. | [REDACTED] | | 16. | | | +| 5. | | | 17. | | | +| 6. | | | 18. | | | +| 7. | | | 19. | | | +| 8. | | | 20. | | | +| 9. | | | 21. | | | +| 10. | | | 22. | | | +| 11. | | | 23. | | | +| 12. | | | 24. | | | + +| OUT-COUNT BY UNIT | | | | | | +|-------------------|-----|-----|-----|-----|-----| +| B-A | C-A | E-N | E-S | G-N | I | +| I-N | K-N | K-S | R-A | Z-A | Z-B | + +Total Out-Counted: 3 + +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an Out-Count. No other form will be accepted in lieu of the Out-Count Form. + +NYMBI! 530'05 • INMATE ROSTER • 08-04-2019 PAGE 001 OP 001 09:57:51 + +CATEGORY: OCT GROUP CODE: ASSIGNMENT: ATTY FACILITY: NYM OPER CATG ASSIGNMENT OPER CATG ASSIGNMENT OPER CATG ASSIGNMENT + +NUM ASSIGNMENT REG NO NAME. OCT DATE QTR WRK 0001 ATTY EPSTETN 08-04-2019 Z04-206LAD UNASSG 0002 MACK 08-04-2019 GOS-737t) UNASSG 0003 TARTAGLTONE 08-04-2019 Z06-21bUAD UNASSG + +G0000 TRANSACTION SUCCESSFULLY COMPLETED + +**OFFICIAL OUT COUNT** + +DATE: 8-6-19 + +COUNT TIME: 400 PM + +FROM: [REDACTED] + +LOCATION: Att conf + +(Staff Member Preparing Out Count) + +APPROVED: [REDACTED] + +(Operations Lieutenant) + +| REG # | NAME | UNIT | REG # | NAME | UNIT | +|---------------|-------------|------|-------|------|------| +| 1. [REDACTED] | ARAUJO | IN | 13. | | | +| 2. [REDACTED] | ERSTEN | ZA | 14. | | | +| 3. [REDACTED] | MOORE | KN | 15. | | | +| 4. [REDACTED] | Tarfaglione | ZA | 16. | | | +| 5. [REDACTED] | | | 17. | ✓ | | +| 6. | | | 18. | | | +| 7. | | | 19. | | | +| 8. | | | 20. | | | +| 9. | | | 21. | | | +| 10. | | | 22. | | | +| 11. | | | 23. | | | +| 12. | | | 24. | | | + +**OUT-COUNT BY UNIT** + +| B-A | C-A | E-N | E-S | G-N | G-S | H-A | +|-----|-----|-----|-----|-----|-----|-----| +| I-N | I | K-N | K-S | Z-A | Z-B | | + +Total Out-Counted: \_\_\_\_\_ + +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count. Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as an Out-Count. No other form will be accepted in lieu of the Out-Count Form. + +.EYMAO 530+05 + INMATE ROSTER • 08-06-2019 + +PAGE 001 OF 001 15:41:08 + +CATEGORY: OCT GROUP CODE: ASSIGNMENT: ATTY FACILITY: NYM OPER CATG ASSIGNMENT OPER CATG ASSIGNMENT OPER CATG ASSIGNMENT + +NUM ASSIGNMENT REG NO NAME OCT DATE QTR WRK 0001 ATTY ARAUJO 08-06-2019 704-930U UNASSG 0002 EPSTEIN 08-06-2019 704-206LJU1 UNASSG 0003 MOORE 08-06-2019 KOS-145U UNASSG 0004 TARTAGLIONE 08-06-2019 7.06-215UAD UNASSG + +C0000 TRANSACTION SUCCESSFULLY COMPLETED \ No newline at end of file diff --git a/marker2/ds9/EFTA00086261/EFTA00086261.metadata.json b/marker2/ds9/EFTA00086261/EFTA00086261.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..357ae5d28f1b06c0ba6af4ea310baf828498cd30 --- /dev/null +++ b/marker2/ds9/EFTA00086261/EFTA00086261.metadata.json @@ -0,0 +1,1080 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086261.pdf", + "engine": { + "marker_major": "2", + 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P.0 Laura A. Menninger + +ISO East 10th Avenue Denver. Colorado 80203 rti 303.831.7364 rx 303.832.2628 www.hmflaw.com Imenningerehmflaw.com + +September 4, 2020 + +VIA ECF + +Hon. Debra Freeman United States Magistrate Judge Daniel Patrick Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 + +> Re: Reply in Support of Letter Motion to Stay Proceedings 20-cv-484 (JGK-DCF), Jane Doe v. Darren K. Indyke, et at + +Dear Judge Freeman: + +On behalf of defendant Ghislaine Maxwell, I write in further support of a Motion to Stay Proceedings in this matter until the conclusion of the criminal trial in United States v. Maxwell, 20 Cr. 330 (AJN) ("Criminal Case"). + +Plaintiff apparently concedes, by failing to respond, that (a) she is one of the three accusers mentioned in the Indictment in the Criminal Case, (b) substantial overlap, if not complete identity, therefore exists between the issues, witnesses and facts in the Criminal Case and her request for tens of millions of dollars from Ms. Maxwell in this case, (c) an indictment is legally "the most important factor" in a motion to stay parallel civil proceedings, (d) judicial economy will best be served by allowing the Criminal Case to proceed first, and (e) absent a stay, Ms. Maxwell will be forced to choose between her constitutional right to remain silent and her active and vigorous participation in defending against and refuting plaintiff's false claims in this case. + +Instead, Plaintiff argues that a stay would harm her (unspecified) interests and that litigating from inside the MDC under COVID-lockdown is "not [a] great" burden. Both arguments are borderline frivolous. + +No articulated harm to Plaintiff's interests: Despite proclaiming a stay will "harm plaintiff's interests," she fails to explain why. Ipse dixit aside, Plaintiff correctly explains that she can participate in the Epstein claims program while simultaneously pursuing this civil action and (apparently) advancing her interests through the Criminal Case. But she does not explain why the parties should be forced + +Page 2 + +to expend Estate and Ms. Maxwell's resources litigating this civil case during the pendency of both the Epstein Claims Program and the criminal trial. If it is money she seeks, she can pursue it in the Claims Program during the stay or, barring successful participation, in a civil case to resume in August 2021, after Ms. Maxwell is at liberty to refute Plaintiff's claims. If it is "justice" she seeks, the Criminal Case will resolve those issues one way or the other. Plaintiff does not articulate a basis for her desire to pursue all three avenues simultaneously nor why such multiple paths are necessary to achieve her "interests." Perhaps not surprisingly, she also cites no legal authority to bolster her argument that she be permitted to do so. + +Burden of Covid-lockdown in-custody litigation substantial: Plaintiff also contends that Ms. Maxwell's expressed concerns regarding the burden of litigating from detention in the MDC under Covid-restrictions are somehow overblown. As support, Plaintiff points out that that counsel on behalf of Ms. Maxwell filed an answer denying all of Plaintiff's allegations and served discovery requests on Plaintiff. Respectfully, it appears Plaintiff's counsel has not thought through, or is ignorant of, the current situation in detention in New York and the demands on a party in a civil litigation: + +First, Ms. Maxwell cannot be deposed based on the current limitations put in place in the MDC by the Bureau of Prisons. + +Second, Ms. Maxwell cannot participate in any other party or witness deposition. + +Third, Ms. Maxwell cannot receive, review, edit or comment on pleadings, except via U.S. Mail in both directions. All such mail is taking over a week to get to her in one direction. + +Fourth, Ms. Maxwell cannot go through her records, her computers, her photos, her documents, or any other file from the time period 1994-1999 to prepare her defense to Plaintiff's claims. + +Fifth, even phone contact with Ms. Maxwell is limited, difficult and unpredictable. Legal calls are not always granted; many have been denied even as deadlines in the civil and criminal case are looming. On the best of days, these discretionary phone conferences must be scheduled at least three days in advance and are limited in duration, many times to 15 minutes. + +Undersigned counsel has represented incarcerated individuals in other civil and criminal litigation. While it is possible to do so under normal conditions, the COVID ban on in-person visits, inability to bring documents into and out of the facility, and the age of the claims in this case renders the burden far more than Plaintiff apparently appreciates. That counsel for Ms. Maxwell was able to orally + +Page 3 + +confer with her to prepare a complete denial Answer, or to draft discovery requests to Plaintiff based on her claims and damages, speaks to none of these actual, real and substantial practical difficulties to be anticipated in any future litigation in this matter. + +By contrast, Plaintiff, who is not in custody and who launched her anonymous lawsuit nine months ago, inexplicably has been unable to produce during that time any documents corroborating her allegations. She filed a claim for \$75 million (at last count), yet has failed to verify either her complaint or her interrogatory responses, has disclosed not a single treatment provider or expert who can support her supposed trauma, has not produced any documents that corroborate her alleged abuse, and has not provided a single basis for her multi-million-dollars of purported damages. If it is so difficult for a party who is out of custody to find support for her claims or to swear to their veracity, the burden on a presumptively innocent pre-trial detainee to ferret out 26-year old documents to disprove those same claims should be obvious. + +Contrary to Plaintiff's assertion, Ms. Maxwell has not suggested there is an "absolute right to stay this case simply because she has been indicted." Resp. at 6. The Second Circuit has a litany of factors, articulated in Louis Vuitton Malletier S.A. v. LY USA, Inc., 676 F.3d 83, 96 (2d Cir. 2012), and applied numerous times since. Plaintiff has not identified any case applying the Louis Vuitton factors in which an indicted civil defendant has been denied a stay when the plaintiff is actively participating in the criminal prosecution and has an alternative forum for seeking a financial remedy. Plaintiff articulates no good basis for refusing such a stay here. + +It is obvious that Plaintiff seeks to improperly exploit Ms. Maxwell's custodial status for her tactical advantage. Plaintiff knows that her best chance to capitalize on these false allegations is to keep Ms. Maxwell, and the truth, from participating. With Mr. Epstein dead and Ms. Maxwell, literally, handcuffed, the Plaintiff attempts to seize this opportunity and advance her charges with little or no opposition. Justice, here, would not be served by permitting these dubious claims to go forward unchallenged. Ms. Maxwell simply requests a brief stay so that she may defend herself. + +Respectfully Submitted, + +C. Laura A. 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The version from ECF is attached. + +From: + +Sent: ri a e tem er • + +To: + +Cc: + +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: Frida Se tember 11 2020 3:06 PM + +To: + +Su ecu ors in us acne axwe ase s or a o ivi roceec + +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 + +(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 b a victim of Epstein's, in the decision over whether to unseal "sensitive" evidence. + +-0- Sep/11/2020 18:16 GMT + +To view this story in Bloomberg click here: + +https:/Thlinks.bloomberg.corn/news/stories/QGIAR93HBS3K + +<2020.09.04 Government letter in support of stay.pdf> \ No newline at end of file diff --git a/marker2/ds9/EFTA00086280/EFTA00086280.metadata.json b/marker2/ds9/EFTA00086280/EFTA00086280.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..986f73b2ebef96d4244c5a9f22b0d7a74e208132 --- /dev/null +++ b/marker2/ds9/EFTA00086280/EFTA00086280.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086280.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3879, + "elapsed_seconds": 1.13, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "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 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 42 + ], + [ + "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": 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/EFTA00086280" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086283/EFTA00086283.md b/marker2/ds9/EFTA00086283/EFTA00086283.md new file mode 100644 index 0000000000000000000000000000000000000000..1d6973e365e66de9714fed1a583bbf1d94834e6a --- /dev/null +++ b/marker2/ds9/EFTA00086283/EFTA00086283.md @@ -0,0 +1,77 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +THE NEW YORK TIMES COMPANY. + +Plaintiff, + +No. 20-CV-833(PAE) + +v. + +FEDERAL BUREAU OF PRISONS, + +Defendant. + +### SUPPLEMENTAL DECLARATION OF + +hereby 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? 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 seat a fair and impartial jury. + +### Segregability + +17. The 7(A) Returned Records withheld in full are exempt from disclosure in their entirety under Exemption 7(A). To the extent the records contain any non-exempt information, such information is inextricably intertwined with information that could reasonably be expected to interfere with the *Noel* prosecution for the reasons discussed above. As noted in my previous declaration, the media coverage of speculation and theories about Epstein's death makes the segregation of any possibly non-exempt information particularly difficult because providing information pertaining to Epstein without complete context risks contributing to the dissemination of speculation and theories about his death. This, in turn, could reasonably be expected to interfere with the district court's ability to seat a fair and impartial jury in *Noel*, for the reasons discussed above. + +Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief. + +Executed this 15 day of January 2021. + +![]()Counsel to the Acting United States Attorney +United States Attorney's Office for the +Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00086283/EFTA00086283.metadata.json b/marker2/ds9/EFTA00086283/EFTA00086283.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ba50d22f4df40eb1637d9d7a97fc1808c9db1007 --- /dev/null +++ b/marker2/ds9/EFTA00086283/EFTA00086283.metadata.json @@ -0,0 +1,374 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086283.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": 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estate + +Date: Sat, 16 Jan 2021 02:44:49 +0000 + +Embedded: RE:\_Epstein\_estate\_subpoena.msg + +Hey , + +While I'm traveling next week, would you be willing to please contact Epstein's estate to follow up provide us with photos? Attached is the email setting out the most recent status. on their agreement to + +Also, I think we agreed a while ago to subpoena the estate for passenger manifests from Epstein's great if you could flag for them that we plan to serve a subpoena for those. planes, so would be + +Very sorry I haven't gotten to this yet, but with everything going on next week, I'd be very grateful take the lead. if you would please + +Thanks, \ No newline at end of file diff --git a/marker2/ds9/EFTA00086290/EFTA00086290.metadata.json b/marker2/ds9/EFTA00086290/EFTA00086290.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9e912e18cf2f15418da6edb274d351d8456c81fc --- /dev/null +++ b/marker2/ds9/EFTA00086290/EFTA00086290.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086290.pdf", + "engine": { + "marker_major": "2", + "marker_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": 697, + "elapsed_seconds": 0.63, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "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/EFTA00086290" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086291/EFTA00086291.md b/marker2/ds9/EFTA00086291/EFTA00086291.md new file mode 100644 index 0000000000000000000000000000000000000000..009159ed38b4dc0e7b2c26c3897c672dc42a8dfb --- /dev/null +++ b/marker2/ds9/EFTA00086291/EFTA00086291.md @@ -0,0 +1,1699 @@ +To + +![](_page_0_Picture_2.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Date: Mon, 18 Jan 2021 19:03:21 +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 + +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/DoJ "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_1_Picture_4.jpeg) + +# P 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 DO (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_1_Picture_19.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. + +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/DoJ 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/DoJ 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/Dal 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 + +Sent: Monday, January 18, 2021 8:08 AM + +![](_page_2_Picture_10.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Honorable SONY 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) + +![](_page_3_Picture_3.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 + +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:lcahn/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 + +MORE frauds on the SDNY courts made possible by the grossly corrupt SEC and DoJ. + +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_4_Picture_13.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +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] + +![](_page_6_Picture_0.jpeg) + +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. (88H) 58 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 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 July after more than 38 years of invaluable contributions. + +vAyw.sec.gov + +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 g ov + +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 e > + +Sent: Monday. November 30. 2020 7:13 AM + +![](_page_8_Picture_10.jpeg) + +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: + +The Fraud eco system template. To continue on our Net Element (also AQR) example + +"Payment processing": transaction laundering. Like WireCard: AlliedWallet: NY Office: Rovt. + +FCC???? IT'S MONEY LAUNDERING STUPID!! + +Still MORE record Janey: + +Bravatek: also Fife and NITE trading billions of shares: MY F'N 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. + +www.whoisraisingmoney.com + +#### Payments Infrastructure i Payrix Payments Technology I United States + +# 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.piyrix.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_10_Picture_11.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_11_Picture_0.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 ... + +www.wsj.com + +Will DB buy Net Element/Pay Online as part of their EU/Russia expansion in "payment processing"??? + +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. + +www. 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 + +![](_page_11_Picture_17.jpeg) + +From: Chris Dilorio Sent: Wednesday, November 25, 2020 6:29 AM + +![](_page_12_Picture_1.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_12_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 + +![](_page_13_Picture_2.jpeg) + +#### 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 + +![](_page_13_Picture_13.jpeg) + +Subject: Fw: Formal appeal for 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? + +1 1/2 years prior to the SEC/BX/JEF/Handler/Stifel/JPM/GS/Sandler et al "glitch" + +Russia's Otkritie lures team from Knight Capital i Reuters + +Otkritie wins \$150m fraud judgment I Financial Times (ft.com) + +![](_page_14_Picture_8.jpeg) + +# 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 ... + +vo.vw.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_15_Picture_0.jpeg) + +# ;t' 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 (sec.gov) + +### EDGAR Filing Documents for 0001193125-18-050585 + +Horton Capital Partners, LLC (Filed by) UK: 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 g ov + +Joey Manko Jr + +Swiss Private Bank. Deutsche Bank. Horton. Blink + +Team The Horton Fund + +![](_page_15_Picture_14.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 + +#### 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_16_Picture_11.jpeg) + +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_18_Picture_2.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 Dilorio + +Whistleblower Extraordinaire + +![](_page_18_Picture_12.jpeg) + +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 + +Sent: Thursday, September 17, 2020 9:17 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +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.' 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.' Dilorio + +Whistleblower + +![]()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 + +--- + +**From:** Chris Dilorio <[REDACTED]> + +**Sent:** Monday, September 14, 2020 9:22 AM + +**To:** [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 + +--- + +**From:** Chris Dilorio <[REDACTED]> + +**Sent:** Monday, September 14, 2020 6:02 AM + +![]()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 + +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/detail.aspx?g=9e2b4e49-5ee2-48f6-b8c7-03d39d02b5ca + +![](_page_28_Picture_16.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 c > 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: 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. 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. + +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 <[REDACTED]> + +![](_page_30_Picture_158.jpeg) + +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 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. + +vei.vw.sec.g ov + +SeeThroughEquity was engaged in a Pump and Dump promotion of NETE in April and August 2018 + +https://www.netelementcom/press-releases/release-content/1062906#.XwRXEOWSnIV + +![](_page_32_Picture_11.jpeg) + +# 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 + +https://www.netelement.com/press-releaseth-elease-content/10734671/1.XwRXGuWSnIV + +![](_page_32_Picture_16.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 + +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_33_Picture_11.jpeg) + +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 ‹ > + +Sent: Tuesday, June 30, 2020 7:36 AM + +![](_page_34_Picture_7.jpeg) + +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 + +www.finra.org + +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 ... + +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.vw.secgov + +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-lawm1 + +![](_page_36_Picture_16.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. + +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) + +Army sec g ov + +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.' 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 1O2014 and 2O2014 that were expunged from KCG 10Q SEC filings. Not 2O2014 and 3O2014 SEC reviewed 10O's as I previously stated + +corrected below + +Chris + +![](_page_38_Picture_1.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 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. AIsoIMDS (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/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,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 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. 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 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 + +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 + +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: 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. + +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 + +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 10Q + +[https://www.sec.gov/Archives/edgar/data/1344394/000135448814000425/cgfi\\_10q.htm](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](http://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 J Dilorio + +Whistleblower + +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. + +https://www.sec.gov/Archives/edgar/data/1322587/000114420413065095/v361773 sc I3g.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? + +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 + +![](_page_49_Picture_1.jpeg) + +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 --0-- Gibraltar Global Securities is now offering offshore brokerage accounts in addition to their broad array of financial services.Gibraltar Global ... + +www.prcom + +https://www.prcom/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.' 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-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 + +%%rimy. 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/ + +# 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" + +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 OCIE 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 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 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&CI K=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 ... + +https://www.sec.gov/news/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 + +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? + +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. + +viww 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 off". FINRA bar meant nothing the last 7 years. EXCEPT JMJ/Keener/NITE ripping off more investors. + +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 \$1477779 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 + +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 I 7a 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. 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We respectfully request that the letter be filed under seal. + +Thank you, + +![](_page_0_Picture_59.jpeg) + +--- + +**From:** + +![](_page_0_Picture_61.jpeg) + +**Sent:** Monday, July 27, 2020 9:54 PM + +![](_page_0_Picture_63.jpeg) + +**Subject:** Re: In Re: Grand Jury Subpoena\_19-mc-00179 + +Good evening, + +Attached is an endorsed Order that will be filed under seal in this case. + +Thank you, + +![](_page_0_Picture_68.jpeg) + +[Redacted] + +To the Chambers of Judge Netburn: + +Please see the attached letter in connection with the order referenced below, in the above-captioned case. + +thank you, + +[Redacted] + +[Redacted] + +[Redacted] + +**Sent:** Wednesday, July 15, 2020 09:09 + +[Redacted] + +**Subject:** In Re: Grand Jury Subpoena\_19-mc-00179 + +[Redacted] + +Please see the attached PDF for an Order that was filed under seal today in 19-mc-179. + +Thank you, + +[Redacted] + +Courtroom Deputy to the Hon. Sarah Netburn +United States District Court +Southern District of New York + +[Redacted] + +[Redacted] \ No newline at end of file diff --git a/marker2/ds9/EFTA00086350/EFTA00086350.metadata.json b/marker2/ds9/EFTA00086350/EFTA00086350.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..959067765dde7f520659e1239a087c49e0d0c0f7 --- /dev/null +++ b/marker2/ds9/EFTA00086350/EFTA00086350.metadata.json @@ -0,0 +1,96 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086350.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1251, + "elapsed_seconds": 3.53, + "image_assets": [ + "_page_0_Picture_51.jpeg", + "_page_0_Picture_55.jpeg", + "_page_0_Picture_56.jpeg", + "_page_0_Picture_59.jpeg", + 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sha256:8b6c5cc402383b1e46343bcd906c224cfb2629f9ddc3001165ea3f23c76e8bac +size 9482 diff --git a/marker2/ds9/EFTA00086352/EFTA00086352.md b/marker2/ds9/EFTA00086352/EFTA00086352.md new file mode 100644 index 0000000000000000000000000000000000000000..676f5631d88eed360840e707b684e6dfe3a9be30 --- /dev/null +++ b/marker2/ds9/EFTA00086352/EFTA00086352.md @@ -0,0 +1,33 @@ +Subject: RE: Chris R. Rodgers shared the folder Documents" with you. + +Date: Wed, 20 Jan 2021 15:20:58 +0000 + +Inline-Images: image001.png; image002.png; image003.png; image007.png; image008.png; image009.jpg + +These documents have been downloaded and saved to the below shared. + +From: Chris R. Rodgers + +Sent: Tuesday, January 19, 2021 3:23 PM + +To: Jack Scarola Mary McCan Wend P. Calvet + +Subject: Chris R. Rodgers shared the folder Documents" with you. + +![](_page_0_Picture_9.jpeg) + +Chris R. Rodgers shared a folder with you + +Please click on the below link to access documents (depositions, medical records, expert reports, etc.) from civil matter against Epstein. Please let me know if you have any issues downloading these documents. Thank you. Chris Rodgers + +![](_page_1_Picture_1.jpeg) + +This link will O work for anyone. + +![](_page_1_Picture_3.jpeg) + +![](_page_1_Picture_4.jpeg) + +O Microsoft Privacy Statement + +I Privileged and Confidential I Electronic communication is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510- 2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud. Admin. 2.420 and information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this communication is strictly prohibited. Personal messages express views solely of the sender and shall not be attributed to the law firm. If you received this communication in error, please notify the sender immediately by e-mail or by telephone at (800) 780-8607 and destroy all copies of the original message. 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There were a few typos, but I gather from the email chain that multiple proofreads are ongoing, so don't want to clutter your inbox with track changes on those. Agree, there is no need to redact this filing and agree with your proposed approach to the exhibits. + +**From:** [REDACTED] +**Sent:** Monday, November 8, 2021 7:02 PM +**To:** [REDACTED] +**Cc:** [REDACTED] (USANYS) [REDACTED] +**Subject:** FW: Daubert motion + +Hi [REDACTED] + +This is the version ready for you, and specifically, Part I.C.4-6. + +Also, team, I don't think we need to redact this filing, but we definitely want to redact the defense expert notice and the attached defense list of material, so I'm inclined to just file these temporarily under seal again. Let me know your thoughts, and I'll add our customary sealing footnote. + +**From:** [REDACTED] +**Sent:** Monday, November 8, 2021 6:57 PM +**To:** [REDACTED] +**Cc:** [REDACTED] +**Subject:** Daubert motion + +Hey [REDACTED] + +Passing the pen back to you while I'm joining the Rocchio witness prep. + +I've inputted the chiefs' comments, [REDACTED]'s comments, and the citecheck from [REDACTED]. I'll be done with the webex at 10 and will finalize the exhibit attachments then. So that leaves inputting the intern citecheck from [REDACTED] which I've also attached, making sure those two articles don't contain any bombs before we file them, and anything else you have the time or inclination to do. + +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/EFTA00086354/EFTA00086354.metadata.json b/marker2/ds9/EFTA00086354/EFTA00086354.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..48dd2d02e805cb7d2cc4247f4f6e05cf94019229 --- /dev/null +++ b/marker2/ds9/EFTA00086354/EFTA00086354.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086354.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2004, + "elapsed_seconds": 7.17, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Text", + 44 + ], + [ + "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", + 9 + ], + [ + "Line", + 5 + ], + [ + "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/EFTA00086354" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086356/EFTA00086356.md b/marker2/ds9/EFTA00086356/EFTA00086356.md new file mode 100644 index 0000000000000000000000000000000000000000..819d550df9065c5591665c25c0923b1bc217e652 --- /dev/null +++ b/marker2/ds9/EFTA00086356/EFTA00086356.md @@ -0,0 +1,27 @@ +![](_page_0_Picture_0.jpeg) + +United States Attorney Southern District of New York + +The Silvio!. Mollo Building One Saint Andrew's Plaza New York, New York 10007 + +November 22, 2021 + +## BY E-MAIL + +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 (MN) + +Dear Judge Nathan: + +The Government respectfully requests permission to file the attached reply brief in support of the Government's motion to preclude the testimony of Dr. Ryan Hall. Among other issues, the defendant's opposition brief raises new arguments about hearsay exceptions that the defendant argues apply to information contained in Dr. Hall's report and further elaborates on the defendant's theory of the report's relevance. + +Respectfully submitted, + +United States Attorney + +By: s/ + +Assistant United States Attorneys Southern District of New York + +Cc: Defense Counsel (By E-Mail) \ No newline at end of file diff --git a/marker2/ds9/EFTA00086356/EFTA00086356.metadata.json b/marker2/ds9/EFTA00086356/EFTA00086356.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ea52467668f7ca154273380c639067e34dacde64 --- /dev/null +++ b/marker2/ds9/EFTA00086356/EFTA00086356.metadata.json @@ -0,0 +1,111 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086356.pdf", + "engine": { + "marker_major": "2", + "marker_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": 999, + "elapsed_seconds": 0.78, + "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 + ], + [ + 463.70361328125, + 25.11 + ], + [ + 463.70361328125, + 40.353515625 + ], + [ + 319.464, + 40.353515625 + ] + ] + }, + { + "title": "BY E-MAIL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 168.48 + ], + [ + 139.0744171142578, + 168.48 + ], + [ + 139.0744171142578, + 182.853515625 + ], + [ + 68.544, + 182.853515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 28 + ], + [ + "Text", + 13 + ], + [ + "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/EFTA00086356" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086356/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00086356/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..68a648b76680730ecee77b51e67256744f32604d --- /dev/null +++ b/marker2/ds9/EFTA00086356/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:918728f50c85a01903663cd07d912a8e18a042a6910a1788509ccc4ca2c9706a +size 3485 diff --git a/marker2/ds9/EFTA00086357/EFTA00086357.md b/marker2/ds9/EFTA00086357/EFTA00086357.md new file mode 100644 index 0000000000000000000000000000000000000000..cf824f8127d306d8116fcb403597555f1606669a --- /dev/null +++ b/marker2/ds9/EFTA00086357/EFTA00086357.md @@ -0,0 +1,127 @@ +To: + +Subject: [EXTERNAL] RE: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion + +Date: Mon, 22 Nov 2021 20:35:36 +0000 + +Yes, we'll take care of the Witness-3 response now. I assume the Court will take care of its own order. + +From: + +Sent: Monday, November 22, 2021 3:30 PM + +To: Christian Everdell + +Subject: RE: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion + +Hey Chris, + +I think all that's left is your response on Witness-3, and then the Court's order. + +We'll circulate our proposed redactions to the Dietz/Loftus briefing tomorrow after the conference. + +Thanks, + +From: Christian Everdell + +Sent: Monday, November 22, 2021 2:47 PM + +To: + +Subject: [EXTERNAL] RE: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion + +Will do. Taking care of it now. + +From: + +Sent: on ay, ovem er , : + +To: Christian Everdell + +Subject: RE: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion + +Hey Chris — yes, and you can also file your response on GX-52. (Our original letter is already on the docket at 457.) + +From: Christian Everdell + +Sent: Monda November 22 2021 2:40 PM + +To: + +Subject: (EXTERNAL] FW: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion + +We now file our response to the birth certificate motion, right? + +From: NYSD ECF Pool@nysd.uscourts.gov + +Sent: Monday, November 22, 2021 2:03 PM + +To: CourtMail@nysd.uscourts.gov + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this email because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +## U.S. District Court + +## Southern District of New York + +## Notice of Electronic Filing + +The following transaction was entered bJ on 11/22/2021 at 2:03 PM EST and filed on 11/22/2021 + +Case Name: USA v. Maxwell + +Case Number: 1:20-cr-00330-AJN + +Filer: USA + +Document Number:488 + +## Docket Text: + +LETTER MOTION addressed to Judge Alison J. Nathan from dated November 18, 2021 re: Authenticate birth certificates . Document filed by USA as to Ghislaine Maxwell. + +1:20-cr-00330-AJN-1 Notice has been electronically mailed to: + +CaseView.ECF@usdoj,gov, USANYS.ECF@USD0J.G0V + +CaseView.ECF@usdoj,gca,/ USANYS.ECF@USD0J.G0V + +caseview.ecf@usdoj.gov usanys.ecf@usdoj.gov + +Bobbi C Sternheim pcf@sternheimlaw.com + +Christian R. Everdell autodocket@cohengressercom + +David Boies , II YC Managing Clerk@bsfIlp.com + +Jeffrey S. Pagliuca + +Katielynn Boyd Townsend + +aseView.ECF@usdoj.gov USANYS.ECF@USD0J.G0V + +Laura A. Menninger + +Mark Stewart Cohen + +CaseView.ECF@usdoj.gov, USANYS.ECF@USD0J.G0V + +Si rid S. McCawle + +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 filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_ID=1008691343 [Date=11/22/2021] [FileNumber=26830188 + +-0] [26e81b320da409ccaa60e71b81a05379e51c46a710a011ba995781c0d3c0abeba + +0a1da8490aab1fc7e38aa207ba0ed993f8354ef9d3709c07cd9dfef69a38454]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00086357/EFTA00086357.metadata.json b/marker2/ds9/EFTA00086357/EFTA00086357.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..dceb90a95232b9daaf42662c773b6bcdd543b058 --- /dev/null +++ b/marker2/ds9/EFTA00086357/EFTA00086357.metadata.json @@ -0,0 +1,211 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086357.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3499, + "elapsed_seconds": 1.56, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. District Court", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 258.264, + 144.4202880859375 + ], + [ + 353.3366394042969, + 144.4202880859375 + ], + [ + 353.3366394042969, + 157.8170166015625 + ], + [ + 258.264, + 157.8170166015625 + ] + ] + }, + { + "title": "Southern District of New York", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 229.5, + 171.4202880859375 + ], + [ + 382.2889099121094, + 171.4202880859375 + ], + [ + 382.2889099121094, + 184.8170166015625 + ], + [ + 229.5, + 184.8170166015625 + ] + ] + }, + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 197.64 + ], + [ + 185.4475860595703, + 197.64 + ], + [ + 185.4475860595703, + 211.8170166015625 + ], + [ + 31.212, + 211.8170166015625 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 312.4202880859375 + ], + [ + 98.01220703125, + 312.4202880859375 + ], + [ + 98.01220703125, + 325.8170471191406 + ], + [ + 31.212, + 325.8170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Text", + 33 + ], + [ + "Line", + 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", + 86 + ], + [ + "Line", + 37 + ], + [ + "Text", + 21 + ], + [ + "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 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Line", + 11 + ], + [ + "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/EFTA00086357" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086360/EFTA00086360.md b/marker2/ds9/EFTA00086360/EFTA00086360.md new file mode 100644 index 0000000000000000000000000000000000000000..bf85ebf6184cd04027df9d43807e7fc590824e86 --- /dev/null +++ b/marker2/ds9/EFTA00086360/EFTA00086360.md @@ -0,0 +1,25 @@ +From: "a" alMIE> + +To: (USANYS)" + +Subject: FW: JOINT Proposed Voir Dire Sent\_(Reponse to Defense v1) (002).docx + +Date: Sun, 10 Oct 2021 19:23:00 +0000 + +Attachments: JOINT\_Proposed\_Voir Dire\_SentiReponse\_to\_Defense\_v1)\_(002).docx + +Hey! I got the download from Give me a call when you get to the office and I'll fill you in. + +From: (USANYS) + +Sent: Sunday, October 10, 2021 3:08 PM + +To: (USANYS) + +4c > + +Cc: (USANYS) + +Subject: JOINT Proposed Voir Dire Sent\_(Reponse to Defense v1) (002).docx + +This looks good. A few additions in comment bubbles. M, I'm going to call you now. \ No newline at end of file diff --git a/marker2/ds9/EFTA00086360/EFTA00086360.metadata.json b/marker2/ds9/EFTA00086360/EFTA00086360.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..79df7897b4d6bf776a1b9c585097542d589b4c90 --- /dev/null +++ b/marker2/ds9/EFTA00086360/EFTA00086360.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086360.pdf", + "engine": { + "marker_major": "2", + "marker_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": 0.65, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "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/EFTA00086360" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086361/EFTA00086361.md b/marker2/ds9/EFTA00086361/EFTA00086361.md new file mode 100644 index 0000000000000000000000000000000000000000..218277edea72d8ba1b72019b0a40320172c84497 --- /dev/null +++ b/marker2/ds9/EFTA00086361/EFTA00086361.md @@ -0,0 +1,91 @@ +To: + +Cc: + +Subject: Re: SDNY visit next + +Date: Tue, 08 Oct 2019 16:16:16 +0000 + +Thanks very much. + +Sent from my iPhone + +On Oct 8, 2019, at 12:05 PM, (USANYS) < > wrote: + +Seth, attached is the additional information you requested. Our agenda remains the same: + +9:00-10:00 am: Epstein death/MCC investigation + +10:00-10:15 am + +10:15-10:30 am + +10:30-11:00 am: Meeting between AG and Geoff + +Let me know if you need anything else. Geoff + +From: + +Sent: Tuesday, October 8, 2019 10:41 AM + +To: + +Cc: (OAG) >; + +Subject: RE: SDNY visit next + +Geoff, thanks again for this. We are finalizing the trip book now. I saw the head shots/summaries that you sent, they look great - can someone in SDNY please send us any additional information that would be good for the AG to review, e.g. final proposed agenda (as below), any relevant statistics relating to the office's prosecutions, some background info from your office website? + +Shouldn't be a heavy lift, just a few pages he can flip to for a primer for the visit. + +(cc'd) is putting together the binder for him today, we hope to have it to him by early afternoon, so if the items could be sent as clean PDFs, she can just print and drop in the book. + +I look forward to seeing everyone Thursday. + +Thanks, + +Subject: RE: SDNY visit next + +Hi We suggest briefing the AG on the following matters next Thursday: + +9:00-10:00 am: Epstein death/MCC investigation + +10:00-10:15 am + +10:15-10:30 am + +10:30-11:00 am: Meeting between AG and Geoff + +Let me know if this looks good. Geoff + +From: + +Sent: Monday, September 30, 2019 6:11 PM + +To: + +Cc: Subject: RE: SONY visit next + +Thanks for the response, happy to talk more tomorrow. + +Best, + +From: + +Sent: Monday, September 30, 2019 6:09 PM + +To: + +Cc: + +Subject: Re: SDNY visit next + +Hi Sorry I did not get back to you sooner but I was out for the Jewish holiday. Actually, next Wednesday is not a great day for the AG to visit our office because it is Yom Kippur. I will be out, as wil A good portion of our unit chiefs will also be observing. Let's touch base tomorrow. Regards, + +On Sep 30, 2019, at 2:11 PM, > wrote: + +we're planning an AG visit to NY next week and would like to come by SDNY in the morning on Wednesday. I know you're out today, but maybe we can talk tomorrow about an agenda. + +Thanks, + +U.S. Department of Justice \ No newline at end of file diff --git a/marker2/ds9/EFTA00086361/EFTA00086361.metadata.json b/marker2/ds9/EFTA00086361/EFTA00086361.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8fba2472c6e3953fac26fd11e353e056e38b3786 --- /dev/null +++ b/marker2/ds9/EFTA00086361/EFTA00086361.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086361.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2294, + "elapsed_seconds": 1.36, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "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", + 63 + ], + [ + "Line", + 32 + ], + [ + "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/EFTA00086361" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086363/EFTA00086363.md b/marker2/ds9/EFTA00086363/EFTA00086363.md new file mode 100644 index 0000000000000000000000000000000000000000..1c175821cf01382c50e77e8830b3a035684858d3 --- /dev/null +++ b/marker2/ds9/EFTA00086363/EFTA00086363.md @@ -0,0 +1,73 @@ +To: + +Subject: Epstein and + +Date: Tue, 16 Jul 2019 15:45:40 +0000 + +7115/19 + +Geoffrey Berman + +https://www.nytimes.corn/2019/07/09/business/dealbook/jeffrey-epstein-indictment.amp.html + +A spokesman for Bill Clinton said that the former president traveled with Mr. Epstein on the financier's private jet four times, but knew nothing about the "terrible crimes." + +THAT'S NOT TRUE. + +Take into consideration Clinton's past history with his White House sex crimes. + +How could Clinton fly to Epstein's private island and see all these young girls and NOT KNOW that something wrong was going on? + +There are stories on the intemet about Hillary accompanying Bill on some of these trips to Epstein's island and having their own individual sexual experiences with Epstein's underage sex-slaves. + +For the Clintons to get away with this horrendous crime against young girls would be yet another traumatizing memory for these girls to endure for the rest of their lives. + +Talk to these girls and ask them about Bill and Hillary Clinton. + +Taking it a step further....has anyone looked into the real possibility of Epstein murdering some of these girls and burying their bodies somewhere on his island? + +Because out of all these young girls there must have been some who were difficult, threatening to expose Epstein by going to the police, crying or hysterical and wanting to contact their relatives or trying to escape or find a place to hide. + +What did Epstein do with "those" girls? What did John Wayne Gacy do with the young boys he had sex with when he was done with them? + +Epstein must have used drugs on these poor girls. To calm them down and put them into a stupor. I'm sure he used Spanish Fly. + +Another possibility...did any of these girls have parents, adoptive parents, relatives or caretakers that gave these girls to Epstein in exchange for cash? + +Were any of these young girls fixed so that they couldn't get pregnant? Did any of these girls become sick and die? Were they exposed to AIDS and other sexually transmitted diseases? + +Worst case scenario...were babies aborted, born and sold? Killed or left to die? And buried somewhere on Epstein's island? + +Please investigate into these possible crimes that I've brought to your attention. Because there's much more to this story. + +Epstein was not only a molester, pervert and child molester, he was also a rapist, pimp, panderer, torturer and maybe a murderer of his captives and their babies!!!!!! + +What a nightmare feeding dead bodies of girls and their babies to the sharks that swim around his island. + +Make sure you grill Epstein's staff, past and present. + +What could be buried on that island? Drugs, money, young girls, babies, staff that intended to reveal Epstein's secrets? + +\_\_\_\_\_ + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +\_\_\_\_\_ + +Service, Drug Enforcement Administration, the Federal Bureau of Investigation, U.S. Immigration and Customs Enforcement's Homeland Security Investigations, the Naval Criminal Investigative Service, and U.S. Southern Command's Joint Interagency Task Force South. + +I hope my thoughts help. + +Mrs. Kendra Levine + +\_\_\_\_\_ \ No newline at end of file diff --git a/marker2/ds9/EFTA00086363/EFTA00086363.metadata.json b/marker2/ds9/EFTA00086363/EFTA00086363.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6395f71a155c4ca71cde662788a7a48fe95a3bc4 --- /dev/null +++ b/marker2/ds9/EFTA00086363/EFTA00086363.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086363.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3148, + "elapsed_seconds": 4.68, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "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": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 33 + ], + [ + "Span", + 27 + ], + [ + "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/EFTA00086363" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086365/EFTA00086365.md b/marker2/ds9/EFTA00086365/EFTA00086365.md new file mode 100644 index 0000000000000000000000000000000000000000..4b987c47a78ada0043de2b7f46c8bffc72cecccc --- /dev/null +++ b/marker2/ds9/EFTA00086365/EFTA00086365.md @@ -0,0 +1,46 @@ +From: ' (USANYS)" ci + +To: "Berman Geoff re SANYS USANIYI + +(USANYS)" (USANYS)" + +Cc: ' (USANYS)" •cl + +Subject: Epstein interview updates + +Date: Mon, 22 Jul 2019 21:10:17 +0000 + +All — we wanted to give you a rundown of (i) all the interviews we have done in the last two weeks; and (ii) where we stand with some of the employees / potential co-conspirators. Descriptions are below: + +## Employees/Associates + +- (Employee-1 in Indictment): We gave a reverse proffer toast week and she is weighing whether to come in. +- (Employee-2 in Indictment): We will receive an attorney proffer from attorneys next week. +- (Employee-3 in indictment): We interviewed her in Florida and learned the following: met Epstein around 2004, while in her early 20s, through the modelling community. Around December 2004, Epstein offered a job working as an assistant, which she accepted and maintained until early 2006. Her responsibilities included running errands and scheduling massages and other appointments. According to.. Epstein expected to have two massages every day: one in the morning and one in the afternoon. IM and were responsible for coordinating the Palm Beach massages, and was responsible for coordinating the New York massages. At some point, Epstein and began having sexual encounters, but IM was very distressed when discussing these incidents and was not prepared to describe them in detail during our first meeting. The team believes these encounters may have been coercive and/or nonconsensual. At least some of these encounters involved I= herself providing Epstein with his massages when they were in the Virgin Islands. As a result, was aware that his massages were sexual. I= described how Epstein had two groups of girls who provided massages in his homes: one group was of professional masseuses who gave actual massages to Epstein's friends, and the second group consisted of young girls who were not professional masseuses and who only gave massages to Epstein. recalled certain details that signaled that girls in this second group were minors. For example, she was asked to help find SAT prep courses for one girl, and she recalled girls mentioning school and their parents. However, at her first proffer, she stopped short of acknowledging that she knew they were minors. +- Ghislaine Maxwell (friend / former girlfriend alleged to be involved in recruiting): The team met with her attorneys last week and she is assessing whether to proffer with us. +- (sexual partner / involved in massages / may be an abuse victim): Has retained counsel and they have asked for a week or so to speak with her before evaluating how to proceed. +- recalled that things changed dramatically during his last two years at the residence. Epstein became increasingly demanding, and staff were told not to speak to Epstein or his guests, to avoid eye contact, and to leave the room when he entered. recalled that, towards the end of his tenure, three young girls came by the house: and a third girl. He believed that was under 18 and was giving Epstein "massages," although he did not know what this entailed. During this period, was responsible for scheduling Epstein's frequent appointments with professional masseuses. During the last several weeks of his employment, was hired as Epstein's personal assistant, and began taking over answering Epstein's phones. At the very end of his + +tenure, told Epstein that he should slow down, that "these girls" would get him in trouble. Epstein remarked that it was fine, and that "these girls only care about money." When left Epstein's employment, Epstein told him: "I hope you keep your mouth shut." + +- : Retained , which is going to give us an attorney proffer. + +## New York Victims + +- : Victimized beginning in 2001, when she was approximately 14 years old. Recruited by an unidentified woman her outside her school on the Upper East Side. Provided nude massages to Epstein over approximately a year, each time for \$300 in cash. In fall 2002, while was massaging Epstein, he asked and without her consent and +- : Gave Epstein massages at the Manhattan mansion on two occasions, during which Epstein + - s. She recalled that Epstein told her: "you look so young." She brought a 19 year old friend to Epstein's house to give a massage, and recalls Epstein telling her not to bring her again, because she was too old. + +## Florida Victims + +- Victimized once in 2002 at the Florida estate. During the massage, Epstein She recruited one other minor girl to give Epstein a massage. +- Gave Epstein at least two massages in the early 2000's at the age of 16 or 17. During the first, Epstein The second involved more extensive abuse, which she was not yet prepared to describe during the first interview. +- : Gave Epstein massages twice in the early 2000s at the Florida estate, during which he . Has reservations about testifiying. +- : Recruited by a friend at the age of 13 or 14 in the early 2000s, while living in a trailer park in Palm Beach. Over a period of approximately three years, gave numerous massages to Epstein at the Palm Beach residence. Epstein Estimates that she may have brought as many as one hundred underage girls to Epstein's house for massages. During the Florida investigation, she was represented by an attorney paid by Epstein. +- : Florida victim who met with the team to discuss the status of the case. Indicated that she wished to cooperate with the investigation, but she was not prepared to discuss her experiences with Epstein that day. +- First met Epstein through her older sister in 2007 (while Epstein was being investigated) at the age of + - 17. Epstein specifically asked her age and told her, in substance, that they could not interact until she turned 18. After her 18th birthday, Epstein began having give him massages, during which A short time later, Epstein took Ms. and her sister on a trip to his private island in the Virgin Islands. During that trip, Epstein Between 2007 and 2009, Epstein ; the first few were nonconsensual. When Epstein was serving his jail sentence in Palm Beach, visited him at his office on at least one occasions and engaged in sexual conduct with him. In or around 2013, Epstein paid marry a girl whom Epstein wanted to be able to stay in the U.S. The two were married forte divorced in 2017. \$10,000 to then + +- In the early 2000s, when Ms. was 17 years old and working as a model, she was invited to Epstein's house a 19 year old model who was Epstein's girlfriend at the time. Epstein gave and cash to go shopping, and they purchased underwear together at the mall. They returned to Epstein's house, and Epstein asked to try on the underwear for him; felt as though she could not say no, and complied. That same weekend, invited to come to Epstein's house to receive a massage from a masseuse. She was told Epstein would not be there, and so she agreed. Shortly after undressed for the massage, the masseuse left the room, and Epstein entered. He insisted that , so that he could show her what he had learned from a chiropractor about "adjustments' Epstein then but did not touch her chest. After this experience, she refused to return to the house. + +Chief Public Corruption Unit United States Attorney's Office for the Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00086365/EFTA00086365.metadata.json b/marker2/ds9/EFTA00086365/EFTA00086365.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d46ca83fa2a124a3b6d7eae109cd3497b0ef8c50 --- /dev/null +++ b/marker2/ds9/EFTA00086365/EFTA00086365.metadata.json @@ -0,0 +1,216 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086365.pdf", + "engine": { + "marker_major": "2", + "marker_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": 7251, + "elapsed_seconds": 0.74, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Employees/Associates", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 218.70000000000002 + ], + [ + 137.58792114257812, + 218.70000000000002 + ], + [ + 137.58792114257812, + 232.5841064453125 + ], + [ + 30.6, + 232.5841064453125 + ] + ] + }, + { + "title": "New York Victims", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 108.53999999999999 + ], + [ + 115.8532943725586, + 108.53999999999999 + ], + [ + 115.8532943725586, + 121.9541015625 + ], + [ + 30.6, + 121.9541015625 + ] + ] + }, + { + "title": "Florida Victims", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 287.54999999999995 + ], + [ + 104.64269256591797, + 287.54999999999995 + ], + [ + 104.64269256591797, + 302.3340759277344 + ], + [ + 30.6, + 302.3340759277344 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 89 + ], + [ + "Line", + 44 + ], + [ + "Text", + 7 + ], + [ + "ListItem", + 6 + ], + [ + "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", + 87 + ], + [ + "Line", + 42 + ], + [ + "ListItem", + 11 + ], + [ + "ListGroup", + 3 + ], + [ + "SectionHeader", + 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 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Line", + 14 + ], + [ + "Text", + 4 + ], + [ + "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/EFTA00086365" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086368/EFTA00086368.md b/marker2/ds9/EFTA00086368/EFTA00086368.md new file mode 100644 index 0000000000000000000000000000000000000000..b4b60a695130b17b3069f6359b23db2b097bd8c9 --- /dev/null +++ b/marker2/ds9/EFTA00086368/EFTA00086368.md @@ -0,0 +1,78 @@ +**To:** " [REDACTED] (USANYS)" < [REDACTED] >, " [REDACTED] (USANYS)" + +< [REDACTED] >, " [REDACTED] (USANYS)" < [REDACTED] > + +**Cc:** " [REDACTED] (USANYS)" < [REDACTED] > + +**Subject:** this coming week + +**Date:** Sat, 27 Jul 2019 13:16:17 +0000 + +[REDACTED] + +- • [REDACTED] +- [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +[REDACTED] +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] +[REDACTED] + +[REDACTED] +[REDACTED] + +[REDACTED] +[REDACTED] + +**Wednesday, July 31** + +- • Pretrial conference in Epstein – 11 a.m. (PC) + +- • [REDACTED] +- [REDACTED] +- [REDACTED] + +[REDACTED] + +[REDACTED] +[REDACTED] + +- • [REDACTED] + +Friday, August 2 + +Other + +- • Epstein team is meeting on Monday afternoon with the defense attorneys, who apparently have some sort of proposal to present. (PC) + +- • [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED]). + +[REDACTED] + +Chief, Criminal Division + +United States Attorney's Office, SDNY + +[REDACTED] + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00086368/EFTA00086368.metadata.json b/marker2/ds9/EFTA00086368/EFTA00086368.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0fd50ac41ff68ae6a16da958fe9fc6c4aee9528b --- /dev/null +++ b/marker2/ds9/EFTA00086368/EFTA00086368.metadata.json @@ -0,0 +1,170 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086368.pdf", + "engine": { + "marker_major": "2", + "marker_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": 971, + "elapsed_seconds": 4.18, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Wednesday, July 31", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 585.6299999999999 + ], + [ + 124.23600000000002, + 585.6299999999999 + ], + [ + 124.23600000000002, + 600.21 + ], + [ + 31.212, + 600.21 + ] + ] + }, + { + "title": "Friday, August 2", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 82.62 + ], + [ + 108.32399999999998, + 82.62 + ], + [ + 108.32399999999998, + 96.38999999999999 + ], + [ + 30.6, + 96.38999999999999 + ] + ] + }, + { + "title": "Other", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 109.35000000000001 + ], + [ + 63.036, + 109.35000000000001 + ], + [ + 63.036, + 123.12 + ], + [ + 30.6, + 123.12 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 38 + ], + [ + "Span", + 23 + ], + [ + "Line", + 11 + ], + [ + "ListGroup", + 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": "surya", + "block_counts": [ + [ + "Span", + 17 + ], + [ + "Text", + 11 + ], + [ + "Line", + 9 + ], + [ + "ListGroup", + 6 + ], + [ + "SectionHeader", + 4 + ], + [ + "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/EFTA00086368" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086370/EFTA00086370.md b/marker2/ds9/EFTA00086370/EFTA00086370.md new file mode 100644 index 0000000000000000000000000000000000000000..6c629e30469a9401821271787798902c9b159515 --- /dev/null +++ b/marker2/ds9/EFTA00086370/EFTA00086370.md @@ -0,0 +1,59 @@ +**From:** Steve Baer <[REDACTED]> +**To:** Alan Dershowitz <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>, [REDACTED] <[REDACTED]>, Stan Pottinger <[REDACTED]>, Sigrid McCawley <[REDACTED]>, Barry Levine <[REDACTED]>, Nick Bryant <[REDACTED]>, Cecily <[REDACTED]>, Matt Weissing <[REDACTED]>, "David Boies" <[REDACTED]>, Seth Lehrman <[REDACTED]>, "Elan S. Carr" <[REDACTED]>, [REDACTED]>, Donna Baer <[REDACTED]>, "Dr. Miri Adelson" <[REDACTED]>, Sheldon <[REDACTED]>, Rabbi Marvin Hier <[REDACTED]>, "Rabbi Daniel" <[REDACTED]>, Rabbi Jon Hausman <[REDACTED]>, Rabbi Y <[REDACTED]>, Rav Yehuda Levin <[REDACTED]>, "Dr. Mary Ann Glendon" <[REDACTED]>, Laura <[REDACTED]>, Larry Kudlow <[REDACTED]>, "Rabbi Noson Leiter" <[REDACTED]>, David Brog <[REDACTED]>, "Norm Coleman" <[REDACTED]>, Mort & Rita Klein <[REDACTED]>, Andrew Kreig <[REDACTED]>, Andrew Lappin <[REDACTED]>, Richard & Nancy Becker <[REDACTED]>, Jake Bennett <[REDACTED]>, caroline <[REDACTED]>, PMBN <[REDACTED]>, Jay Sekulow <[REDACTED]>, "COS Mark Meadows" <[REDACTED]>, James Woolsey <[REDACTED]>, Mike Pompeo <[REDACTED]>, "Dr. Michael Stokes Paulsen" <[REDACTED]>, "David Yerushalmi, Esq. (AFLC)" <[REDACTED]>, "Dr. Paul Moreno" <[REDACTED]>, "Dr. Larry Arnn" <[REDACTED]>, "Cristov Dosev" <[REDACTED]>, Mike Huckabee <[REDACTED]>, Janet Huckabee <[REDACTED]>, Sarah Huckabee <[REDACTED]>, Pat Cippolone % <[REDACTED]>, Clare Lopez <[REDACTED]>, Frank Gaffney <[REDACTED]>, "Gen. Mike Flynn" <[REDACTED]>, "Dr. William R. Graham" <[REDACTED]>, "Dr. Victor Davis Hanson" <[REDACTED]>, "Dr. Peter Pry" <[REDACTED]>, John Guandolo <[REDACTED]>, Tom Trento <[REDACTED]>, Ambassador Hank Cooper <[REDACTED]>, Donna Rice Hughes <[REDACTED]>, Leonard Leo <[REDACTED]>, Patrick Trueman <[REDACTED]>, Rebbe Boteach <[REDACTED]>, Mick Mulvaney <[REDACTED]>, jason.greenblatt <[REDACTED]>, Eugene Kontorovich <[REDACTED]>, David Rubin <[REDACTED]>, David Friedman <[REDACTED]>, Daniel Pipes <[REDACTED]>, "Sen. Mitch McConnell %" <[REDACTED]>, Rand Paul <[REDACTED]>, Ben Sasse <[REDACTED]>, Lindsey Graham <[REDACTED]>, Joni Ernst <[REDACTED]>, "Gen. Jerry Boykin" <[REDACTED]>, "Sen. Deb Fischer" <[REDACTED]>, Mike Lee <[REDACTED]>, Ted Cruz <[REDACTED]>, fred fleitz <[REDACTED]>, "Dr. Will Happer" <[REDACTED]>, Ann Corkery <[REDACTED]>, "Carrie Severino" <[REDACTED]>, Katy French Talento <[REDACTED]>, Marjorie Dannenfelser <[REDACTED]>, Norm Coleman <[REDACTED]>, Jared <[REDACTED]>, Mike Evans <[REDACTED]>, Jan Willen van der Hoeve <[REDACTED]>, Ellen Margrete van der Hoeven <[REDACTED]>, Howard Kohr <[REDACTED]>, "Dr. Michael Brown" <[REDACTED]>, "Lee Zeldin" <[REDACTED]>, Terry Allen <[REDACTED]>, Sean <[REDACTED]>, Jim Jordan <[REDACTED]>, "Rep. Thomas Massie" <[REDACTED]>, "Rev. John Hagee" <[REDACTED]>, Matt Brooks <[REDACTED]>, Avi Lipkin <[REDACTED]>, Bezalel Smotrich <[REDACTED]>, Mitch Glaser <[REDACTED]>, Joel Chernoff <[REDACTED]>, "Myriam Levy Chernoff" <[REDACTED]>, Rabbi Chaim Steinmetz <[REDACTED]>, Soychika <[REDACTED]>, Rabbi Alter Tenenbaum + +Garlow Ben Shapiro Sco ;ins • • • • n • , John Desser Binyomin Feinberg < "Felix Bronstein" , "Joel Anandasamy" , "Rev. Jim Garlow" Lila Rose , Supergirl John Weaver "Jeff Wittenbrink" , Steven Baer David Hunt , Jon Voight Steve McEveety , Anthony Cuccolo , Gloria Allred Pr 41 "Geo , "Anna Garrison" , David Lane Natasha Srdoc Wayne Madsen Rosemary Schindler Robert George e T. Conwa " 4 , Nathan , Patricia Heaton -,John Shep Gary Sinise Jeanine , "Mariann Meier Lisa Bloom + +Subject: + +Date: Mon, 03 Aug 2020 16:21:53 +0000 + +Alan? + +Besides your (superb) defense work for Epstein and all enjoyers (Clinton, Barak, Wexner, Maxwell, Andrew, Trump, Dersh, etc) of his hospitality, did you tv, have any operational role in the apparent honeypot/blackmail ops? + +Don't you think now would be a good time to be reconciled a to your Maker? + +Glad to discuss. + +Shalom, + +Steve + +On Aug 1, 2020, at 1:01 PM, Steve Baer > wrote: + +![](_page_1_Picture_10.jpeg) + +## OFF THE RECORD + +https://variety.corn/2020/tv/news/alan-dershowitz-good-fight-cbs-apology-1234722149/ + +Excerpt: + +"From Scholar to Shyster, Alan Dershowitz Does Revisionist Law, Disowns His `1998 Off the-Cuff Interview' (PolitiZoom, January 21, 2020). + +Q: Is this what it has always been about? Killing the Moses Map? + +Q: Dr. D, why not tell all? Why not "Come to Jesus"? + +(Oops; a figurative phrase for secular penitence... or you could chat with Rabbis Lapin and Fleischer, or you could take it literally). + +Alan: Whatever your approach to your Almighty Maker, why not seek redemption --genuine reconciliation with Heaven and Hashem before you must face Him? + +No dodging that subpoena, those interrogatories, that trial. + +We all need His forgiveness, no? + +Shalom, + +Steve + +PS. Look what happens to Chosen People who de& YHWH for butchery like this, this, this, this and this. + +Professor, why o why should it go better for our USA? + +(This would make COVID-19 seem like the sniffles). + +Alan, why not start leading us in the paths of righteousness, for His name's sake? + +![](_page_2_Picture_13.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00086370/EFTA00086370.metadata.json b/marker2/ds9/EFTA00086370/EFTA00086370.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..56b583deecbeb13ec27142b450227bf7035aef9e --- /dev/null +++ b/marker2/ds9/EFTA00086370/EFTA00086370.metadata.json @@ -0,0 +1,145 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086370.pdf", + "engine": { + "marker_major": "2", + "marker_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": 5087, + "elapsed_seconds": 11.67, + "image_assets": [ + "_page_1_Picture_10.jpeg", + "_page_2_Picture_13.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "OFF THE RECORD", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 34.272, + 618.84 + ], + [ + 147.22325134277344, + 618.84 + ], + [ + 147.22325134277344, + 634.4830169677734 + ], + [ + 34.272, + 634.4830169677734 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "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": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 116 + ], + [ + "Line", + 58 + ], + [ + "Text", + 13 + ], + [ + "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", + 39 + ], + [ + "Line", + 18 + ], + [ + "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/EFTA00086370" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086370/_page_1_Picture_10.jpeg b/marker2/ds9/EFTA00086370/_page_1_Picture_10.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..b4e92d7044d31f15a2524e73e659431c35067d77 --- /dev/null +++ b/marker2/ds9/EFTA00086370/_page_1_Picture_10.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:29953a41f9000c2a75d28e0517f6cebfa72e1a3d46ea91c4a4df27a9016754de +size 1012 diff --git a/marker2/ds9/EFTA00086370/_page_2_Picture_13.jpeg b/marker2/ds9/EFTA00086370/_page_2_Picture_13.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..2736ff5f54d59174973e3d65e9a85823f5d7b60e --- /dev/null +++ b/marker2/ds9/EFTA00086370/_page_2_Picture_13.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:43553c2db86f344399f18ed73153b2eac8228295dd126f7b0e489a3935e1e6e6 +size 1451 diff --git a/marker2/ds9/EFTA00086373/EFTA00086373.md b/marker2/ds9/EFTA00086373/EFTA00086373.md new file mode 100644 index 0000000000000000000000000000000000000000..5b233b98cff4c77a0dd077f75846bb697422e4ef --- /dev/null +++ b/marker2/ds9/EFTA00086373/EFTA00086373.md @@ -0,0 +1,75 @@ +To: Kristina Lee Hendrickson • + +Cc: ' USANYS)" cM=NIMIIR + +Subject: RE: Epstein + +Date: Fri, 23 Jul 2021 22:15:30 +0000 + +Inline-Images: image001.jpg; image006.jpg; image007.gif; image002.jpg + +Hi Kristina, + +Hope all is well with you. Are you available for a call sometime early next week? I was hoping to ask you a few questions to follow up on an earlier document production. + +Thanks very much, + +Alison + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 + +From: Kristina Lee Hendrickson + +Sent: Monday, June 29, 2020 11:08 AM + +To: < >; Robert T Curran < + +Cc: Yui Cheung Chow + +Subject: RE: Epstein + +Hello, + +Hope all is going well for you! When I open the link for the subpoena, it says it is not available. + +Kristina + +KRISTINA HENDRICKSON I MANAGER - SPECIAL INVESTIGATIONS FINANCIAL INTELLIGENCE UNIT AMERICAN EXPRESS + +18850 N. 56th Street I PHOENIX, AZ 85058 + +MAIL CODE: AZ08.02.04 + +O: I E: + +![](_page_0_Picture_23.jpeg) + +![](_page_0_Picture_24.jpeg) + +Sent: Monday, June 29, 2020 6:33 AM + +To: Robert T Curran < + +![](_page_1_Picture_1.jpeg) + +This is a secure message. + +![](_page_1_Picture_2.jpeg) + +Click here by 2020-07-09 13:33 UTC to read your message. + +After that, open the attachment. + +More Info + +DIsclaimer: This email and its content are confidential and intended solely for the use of the addressee. Please notify the sender if you have received this email in error or simply delete it. + +Secured by Proofpoint Encryption, Copyright © 2009.2019 Proofpoint, Inc. 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LARJp,topE C. ":IS' SC OF ELI., • woo + +MOTION TO SEAL + +The United States of America, by and through the undersigned Assistant United States + +Attorney, hereby moves to seal its "Sealed Motion for Permission to Disclose Grand Jury Material" + +for the following reasons: + +1. The Application contains information regarding proceedings before West Palm + +Beach Federal Grand Jury 07-103, which is subject to the secrecy protections of Fed. R. Crim. P. + +6. + +2. Pursuant to Rule 6(eX6), "[r]ecords, orders, and subpoenas relating to grand-jury + +proceedings must be kept under seal to the extent and as long as necessary to prevent the + +unauthorized disclosure of a matter occurring before a grand jury." + +WHEREFORE, the United States respectfully requests that the Application and any Order + +related to the Application be sealed. + +Dated: May 30, 2017 Respectfully submitted, + +BENJAMIN G. GREENBERG + +ASSISTANT U.S. ATTORNEY + +Florida Bar No. + +500 South Australian Ave, Suite 400 West Palm Beach. Florida 33401 + +Tel: + +FGJ NO. 07-103 (WPB) + +IN RE: + +GRAND JURY PROCEEDINGS + +/ + +SEALED ORDER + +It is hereby ordered that the United States' Sealed Motion for Permission to Disclose Grand + +Jury Material and the Order granting same be SEALED until further Order of this Court, except + +that a copy of this Order, the Motion for Permission to Disclose Grand Jury Material and the Order + +granting same shall be provided to counsel for the United States. + +DONE AND ORDERED in chambers this day of May, 2017, at West Palm + +Beach, Florida. + +DANIEL T. K. HURLEY + +SENIOR UNITED STATES DISTRICT JUDGE + +cc: AUSA + +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +FGJ 07-103(WPB) + +IN RE: + +GRAND JURY PROCEEDINGS + +SEALED MOTION FOR PERMISSION TO DISCLOSE GRAND JURY MATERIAL + +The United States of America, by and through the undersigned Assistant United States + +Attorney, hereby moves the Court for permission to disclose certain materials relating to matters + +occurring before West Palm Beach Federal Grand Jury # 07-103. In support thereof, the + +Government states: + +1. In September 2006, as part of its investigation named "Operation Leap Year," the + +United States served a grand jury subpoena on a witness named See Exhibit 1 at P- + +003734 thru P-003735. Based upon the investigation, Ms. was identified as a potential + +victim of the lead target, Jeffrey Epstein. + +2. After service of the subpoena, Ms.= retained the services of James Eisenberg, + +Esq. to represent her. Jeffrey Epstein paid for that representation. + +3. Mr. Eisenberg communicated to me orally and in writing that Ms. would + +assert her Fifth Amendment privilege if she were forced to appear before the grand jury, and that + +the government needed to obtain immunity pursuant to 18 U.S.C. §§ 6001-6003 and a compulsion + +order from the Court to avoid the assertion of the privilege. Exhibit 2. + +4. Due to the expiration of the original grand jury, in January 2007, a new grand jury + +subpoena was issued on behalf of West Palm Beach Federal Grand Jury #07-103. Exhibit 1 at P- + +5. On January 24, 2007, the undersigned sent a letter to Mr. Eisenberg enclosing the + +subpoena and discussing the investigation and grand jury proceeding. Exhibit 1 at P-003736 thru + +P-003737. + +6. On February I, 2007, Mr. Eisenberg responded via letter. His letter discusses the + +grand jury subpoena, the investigation, and Ms. likely testimony. Exhibit 1 at P-003732 + +thru P-003733. + +7. On February 5, 2007, I provided Mr. Eisenberg with two proposed Kastigar letters + +that, again, discuss the grand jury's investigation. Exhibit 1 at P-003739 thru P-003743, P-003745. + +8. In response to a complaint from Mr. Eisenberg (see Exhibit 3), I prepared an + +"Authorization for Reimbursement of Unusual Expenses of Fact Witnesses" to pay for + +Suring Ms. grand jury testimony. Exhibit 1 at P-003744. + +9. On February 12, 2007, Mr. Eisenberg sent a letter detailing the reasons for Ms. + +refusal to testify without a compulsion order. This letter, again, discusses the grand jury's + +investigation and matters occurring before the grand jury. Exhibit 1 at P-003730 thru P-003731. + +10. Based upon Mr. Eisenberg's letter and representations, the U.S. Attorney's Office + +applied to the Justice Department for authorization to grant immunity pursuant to 18 U.S.C. §§ + +6001-6003. After receiving that authorization, in April 2007, the United States filed a Sealed + +Motion for an Order compelling the testimony of == Exhibit 1 at P-003714 thru P- + +003721. + +11. On April 16, 2007, the Court granted the government's Sealed Motion in a Sealed + +Order. Exhibit 3. Judge Middlebrooks was the judge who empaneled Federal Grand Jury 07-103. + +The Sealed Order states, in part, that the "Order shall be SEALED in accordance with Fed. R. + +Crim. P. 6(e)(6), except that a copy of this Order shall be provided to counsel for the United States, + +who may disclose the existence of the Order [to a list of persons]. Those persons may review the + +Order, but may not retain a copy of the Order, nor may they disclose the existence of the Order to + +any others." + +12. In 2008, Ms. became a petitioner in the matter of Jane Doe 1 and Jane Doe + +2 v. United States, S.D. Fla. Case No. 08-80736-Civ-Marra ("the Jane Doe suit"). Ms. was + +allowed to proceed, at her request, via the pseudonym "Jane Doe 2" because she was a minor + +during the criminal activity committed by Jeffrey Epstein. Ms. was an adult during all + +proceedings related to the grand jury subpoena. + +13. In her suit against the United States, Ms. avers, in part, that her "right to + +confer with the attorney for the Government in the case" and her "right to be treated with fairness + +and with respect for the victim's dignity and privacy," 18 U.S.C. § 3771(a)(5), (a)(7), were + +violated. I was the "attorney for the Government," although there was no "case" because the U.S. + +Attorney's Office never filed charges against Jeffrey Epstein or any other person involved in + +criminal activity with Ms.M. + +14. In the Jane Doe suit, U.S. District Judge Kenneth A. Marra allowed limited + +discovery. Exhibits 1 and 2 were listed on a privilege log and provided to Judge Marra in camera + +for review. The United States asserted that the items should not be produced because they were + +governed by Fed. R. Crim. P. 6(e) and included "[d]ocuments under seal pursuant to court order." + +Exhibit 4 at DE212-1 pp. 1, 6. + +15. There was extensive litigation regarding the privilege log, including the assertion + +of the confidentiality of grand jury materials. Judge Marra agreed with the government's assertion + +that Exhibit I involved matters occurring before the grand jury and ordered that they need not be + +produced. Exhibit 5 at pp. 5-10, 26, 28. + +16. In the Jane Doe suit, Ms. has filed a motion for summary judgment, asserting + +that there is no issue of material fact regarding her claim that her rights to confer and to be treated + +with respect were violated. In support of that motion, Ms. filed a Declaration. Exhibit 6. + +17. In the declaration, Ms. makes a number of assertions, including that "there + +could not have been any doubt in anyone's mind ... that Epstein sexually molested me as a minor"; + +"I believed that if I told the truth about what happened at Epstein's house, the police + +"; "I had been greatly intimidated, which is why I could not be truthful initially + +and I wanted to end the threat of the possibility of "; and "I wanted to assist + +the prosecutors in the investigation." Id. + +18. These statements are contradicted by Exhibits 1, 2, and 3, and, accordingly, the + +U.S. Attorney's Office now respectfully requests that the Court unseal redacted versions of + +Exhibits I, 2, and 3. + +19. This matter relates to issues occurring before the grand jury and, accordingly, is + +governed by Fed. R. Crim. P. 6(e). Under that Rule, the "court may authorize disclosure — at a + +time, in a manner, and subject to any other conditions that it directs — of a grand-jury matter: (i) + +preliminarily to or in connection with a judicial proceeding." + +Federal Rule of Criminal Procedure 6(e) provides that the traditional rule of grand jury secrecy may be placed aside under certain circumstances to allow for disclosure. Specifically, Rule 6(e)(3)(E)(i) states that a district court "may authorize disclosure—at a time, in a manner, and subject to any other conditions that it directs—of a grand jury matter ... preliminary to or in connection with a judicial proceeding." The Supreme Court has explained that a party seeking disclosure of grand jury materials must make a showing of a "particularized need" by demonstrating that (1) the materials are needed to avoid an injustice in another + +proceeding; (2) the need for disclosure is greater than the need for continued + +secrecy; and (3) the request is structured to cover only needed materials. + +United States v. Moussaoui, 483 F.3d 220, 235 (4th Cir. 2007) (citing Douglas Oil Co. v. Petrol + +Stops Northwest, 441 U.S. 211, 222 (1979)). + +20. Portions of Exhibits 1, 2, and 3 are relevant to a judicial proceeding, that is, the + +Jane Doe suit. The portions that the U.S. Attorney's Office wishes to disclose are attached hereto + +as Exhibit 7. Disclosure of these portions of the documents are necessary to avoid injustice in the + +Jane Doe suit, that is, to properly inform Judge Marra that Ms. did not, in fact, wish to + +confer with an attorney for the Government during the relevant time frame and she was treated + +with respect by the U.S. Attorney's Office and the investigative team. Given that Jane Doe 2 + +herself has made these materials relevant to the Jane Doe suit, the need to disclose Exhibit 7 + +outweighs the need for secrecy, and Exhibit 7, which is a redacted version of Exhibits 1, 2, and 3, + +properly limits the disclosure of the grand jury materials only to what is needed. + +21. Prior to filing this Motion, I inquired of Judge Marra's courtroom deputy whether + +the motion should be filed with Judge Marra. After speaking with the Clerk's Office, Judge + +Marra's courtroom deputy informed me that, because this related to the grand jury, the motion + +should be directed to the District Judge on duty. Pursuant to the Court's website, Senior U.S. + +District Judge Daniel T. K. Hurley is on duty for the month of May 2017. + +//I + +//I + +//I + +CONCLUSION + +For the foregoing reasons, the United States respectfully requests that it be permitted to + +disclose Exhibit 7 and file it in support of its Response to Ms. summary judgment motion. + +The United States further respectfully requests that the Court's Order make clear that, by filing + +Exhibits 4, 5, and 6 in support of this motion, it does not seek to have them sealed in the Jane Doe + +suit, and that they remain part of the public record in that matter. + +Respectfully submitted, + +BENJAMIN G. GREENBERG + +ACTING UNITED STATES ATTORNEY + +By: + +Assistant United States Attome + +Florida Bar No. + +500 South Australian Avenue, Suite 400 + +West Palm Beach, FL 33401 + +Telephone: Facsimile: I + +GOVERNMENT EXHIBIT + +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FCII 07-103 (WPB) + +IN RE: + +GRAND JURY PROCEEDINGS + +Party Filing Matter Under Seal + +ORDER RE: SEALED FILING Name: UNITED STATES OF AMERICA + +Addreas: AUSA S0CI S. Australian Ave, Ste 400 Telephone' West Palm Bach, FL. 33401 + +On behalf of (select one): • THE APPLICANT RESPONDENT + +Date sealed document filed: 04/16/07 + +If sealed pursuant to statute, cite statute: Fed. R. Crim. P. 6 + +If sealed pursuant to previously enteral protective order, dale of order and docket entry. + +The matter will remain soiled until: + +O Conclusion of Trial U Anot of First Defendant U Case Closing O Conclusion of Direct Appeal + +■ **Other End of Proem:lines** + +**O Permanently. Specify the authorizing law, Me. court order** + +**The moving party requests that when the sealing period tapirs, the filed matter should he (select one):** + +**O Unseakd and placed in • Destroyed U Returned to the party or counsel for the** + +**the public portion of the court Me party, as identified above** + +**It is ORDERED and ADJUDGED that the proposed sealed document is hereby:** + +**O Sealed O NOT Sealed O Other** + +**The matter may be unsealed atter.** + +**O Conclusion of Trial Cl Arrest of First Defendant O Remain Sealed** + +**U Case Closing U Conclusion of Direct Appeal t3 Other** + +**DONE and ORDERED at West Palm finch Florida this day of 2007.** + +**Uttard.Stalm.Disuic lease** + +**This documan has been disposed of lo the following manner by** + +**on** + +FGJ NO. 07403 (WPB) + +IN RE: + +GRAND JURY PROCEEDINGS + +MOTION TO SEAL + +The United States of America, by and through the undersigned Assistant United States + +Attorney, hereby moves to seal its Application for Order Compelling Witness Testimony before the + +Grand Jury for the following reasons: + +1. The Application contains information regarding proceedings before West Palm Beach + +Federal Grand Jury 07-103, which is subject to the secrecy protections of Fed. R. Crim. P. 6. + +2. Pursuant to Rule 6(e)(6), "Erjecords, orders, and subpoenas relating to grand-jury + +proceedings must be kept under seal to the extent and as long as necessary to prevent the + +unauthorized disclosure of a matter occurring before a grand jury." + +WHEREFORE, the United States respectfully requests that the Application and any Order + +related to the Application be sealed. + +Dated: April 16, 2007 Respectfully submitted, + +R. ALEXANDER ACOSTA + +ASSISTANT UNITED STA1 ES A ORNEY + +Florida Bar No. + +500 South Australian Ave, Suite 400 West Palm Beach, Florida 33401 + +Tel: Fax: + +FGJ NO. 07-103 (WPB) + +IN RE: + +GRAND JURY PROCEEDINGS + +ORDER + +It is hereby ordered that the United States' Application for Order Compelling Witness + +Testimony before the Grand Jury and the Order granting same be SEALED until further Order of + +this Court. + +DONE AND ORDERED in chambers this day of April, 2007, at West Palm Beach, + +Florida. + +DONALD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE + +cc: AUSA + +FGJ NO. 07-103 (WPB) + +IN RE: + +GRAND JURY PROCEEDINGS + +/ + +APPLICATION FOR ORDER COMPELLING WITNESS TESTLMONY + +The United States of America, through its undersigned attorney, makes application to this + +Court for an Order pursuant to the provisions of Title 18, United States Code, Section 6001, et seq., + +compelling== to give testimony and to provide other information, which she is likely to + +refuse to give or provide, on the matters about which she may be interrogated before the United + +States District Court for the Southern District of Florida, including a Grand Jury impaneled therein, + +as well as subsequent proceedings or trial, and respectfully alleges as follows: + +1. That ==. has been called to testify and provide other information before the + +United States District Court for the Southern District of Florida, including before a Grand Jury + +impaneled therein. + +2. That, in the judgment of the undersigned, the testimony or other information from + +may be necessary to the public interest. + +3. That is likely to refuse to testify or provide other information on the + +basis of her privilege against self-incrimination. + +4. That this Application is made with the approval of the Assistant Attorney General + +in charge of the Criminal Division of the Department of Justice or a duly designated Acting + +Assistant Attorney General, pursuant to the authority vested in him by Title 18, United States Code, + +Section 6003, and Title 28, Code of Federal Regulations, Sections 0.175 and 0.132(e). A copy of + +the letter from said Assistant Attorney General or his designee expressing such approval is attached + +hereto. + +5. That a Subpoena to Testify before Grand Jury 07-103 (WPB) has been served upon + +counsel for =, who has informed the undersigned that an Order compelling testimony + +is required before will appear and testify. Upon receipt of the Court's Order + +compelling such testimony, a new Grand Jury Subpoena will be issued commanding "•==l + +appearance on Tuesday, April 24, 2007 at 1:00 p.m. + +Respectfully submitted, + +R. ALEXANDER ACOSTA UNITED STATES ATTORNEY + +By: + +ASSISTANT UNITED STATES ATTORNEY + +Florida Bar No. + +500 S. Australian Ave, Suite 400 West Palm Beach, FL 33132 + +FAX S M + +2 + +FGJ 07-103(WPB) + +LN RE: + +GRAND JURY PROCEEDINGS + +SEALED ORDER + +On Application of the United States Attorney for the Southern District of Florida, and it + +appearing to the satisfaction of the Court: + +1. That has been called to testify and to provide other information before + +the United States District Court for the Southern District of Florida, including a Grand Jury + +impanelled therein; and + +2. That in the judgment of the said United States Attorney, has refused + +to testify and provide other information on the basis of her privilege against self-incrimination; and + +3. That in the judgment of the said United States Attorney, the testimony and other + +information from may be necessary to the public interest; and + +4. That the aforesaid Application has been made with the approval of the Assistant + +Attorney General in charge of the Criminal Division of the Department of Justice or a duly + +designated Acting Assistant Attorney General, pursuant to the authority vested in him by Title 18, + +United States Code, Section 6003, and Title 28, Code of Federal Regulations, Sections 0.175 and + +0.132(e). + +NOW, THEREFORE, it is ordered pursuant to Title 18, United States Code, Section 6002, + +that give testimony and provide other information which she refuses to give or to + +provide on the basis of her privilege against self-incrimination, as to all matters about which she may + +be interrogated before said United States District Court, including a Grand Jury impaneled therein, + +as well as any subsequent proceeding or trial. + +However, no testimony or other information compelled under this Order (or any information + +directly or indirectly derived from such testimony or other information) may be used against + +in any criminal case, except a prosecution for perjury, giving a false statement, or otherwise + +failing to comply with this Order. + +IT IS FURTHER ORDERED the this Order shall be SEALED in accordance with Fed. + +R. Crim. P. 6(e)(6), except that a copy of this Order shall be provided to counsel for the United + +States, who may disclose the existence of the Order to members of the Grand Jury, to the witness, + +to counsel for the witness, and to law enforcement officers engaged in the investigation pending + +before the Grand Jury. Those persons may review the Order, but may not retain a copy of the Order, + +nor may they disclose the existence of the Order to any others. + +DONE and ORDERED this day of April, 2007, at West Palm Beach, Florida. + +DONALD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE + +cc: AUSA + +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FGJ 07.103 (WPB) + +IN RE: + +GRAND JURY PROCEEDINGS + +ORDER RE: SEALED FILING + +Party Filing Matter Under Seal Name: UNITED STATES OP AMERICA + +Address: AUSA SOO S. Australian Are, Ste 400 Telephone: Wan Pam Back FL 33401 + +CM behalf of {select one): • 'rim Appucwr RESPONDENT + +Date sealed document filed: 04116/07 + +If sealed pursuant to statute, cite statute: Fed. It Crisis. P.6 + +If sealed pursuant to previously entered protective other, date of order and docket emery: + +The room will remain sealed until: + +0 Conclusion of Trial fa Arrest of First Defendant O Case Closing 0 Conclusion of Direct Appeal + +• Other End of Promedines + +U Permanently. Specify the authorizing law, nile, court order. + +The moving party requests that when the sealing period expires, the filed matter should be (select one): + +0 Unsealed and placed in + +the public portion of the coun file party, as identified above + +• Destroyed 0 Returned to the party or counsel for the + +It is ORDERED and ADJUDGED that the proposed sealed document is hereby: + +Sealed 3 NOT Scaled + +The matter may be unsealed after. + +O Conclusion of Trial 0 Arrest of Pint Defendant CI Case Closing 0 Conclusion of Direct Appeal + +DONE sod ORDERED at West Palm Beach. Florida this day of + +This document has been disposed of in the following manner + +on + +0 Other + +U Remain Sealed + +U Other + +2007. + +linked Stales District Judge + +by + +FGJ NO. 07-103 (WPB) + +IN RE: + +GRAND JURY PROCEEDINGS + +MOTION TO SEAL + +The United States of America, by and through the undersigned Assistant United States + +Attorney, hereby moves to seal its Application for Order Compelling Witness Testimony before the + +Grand Jury for the following reasons: + +1. The Application contains information regarding proceedings before West Palm Beach + +Federal Grand Jury 07-103, which is subject to the secrecy protections of Fed. R. Crim. P. 6. + +2. Pursuant to Rule 6(6)(6), "[r]ecords, orders, and subpoenas relating to grand-jury + +proceedings must be kept under seal to the extent and as long as necessary to prevent the + +unauthorized disclosure of a matter occurring before a grand jury." + +WHEREFORE, the United States respectfully requests that the Application and any Order + +related to the Application be sealed. + +Dated: April 16, 2007 Respectfully submitted, + +R. ALEXANDER ACOSTA UNITJ.,DATATES ATTORWY + +ASSISTANT UNITED STATES ATTORNEY + +Florida Bar No. + +500 South Australian Ave, Suite 400 West Palm Beach, Florida 33401 + +Tel: Fax: + +FGJ NO. 07-103 (WPB) + +IN RE: + +GRAND JURY PROCEEDINGS + +SaWER + +It is hereby ordered that the United States' Application for Order Compelling Witness + +Testimony before the Grand Jury and the Order granting same be SEALED until further Order of + +this Court. + +DONE AND ORDERED in chambers this day of April, 2007, at West Palm Beach, + +Florida. + +DONALD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE + +cc: EMI , AUSA + +FGJ NO. 07-103 (WPB) + +IN RE: + +GRAND JURY PROCEEDINGS + +APPLICATION FOR ORDER COMPELLING WITNESS TESTIMONY + +The United States of America, through its undersigned attorney, makes application to this + +Court for an Order pursuant to the provisions of Title 18, United States Code, Section 6001, et seq., + +compelling to give testimony and provide other information, which she is likely to + +refuse to give or provide, on the matters about which she may be interrogated before the United + +States District Court for the Southern District of Florida, including a Grand Jury impaneled therein, + +as well as subsequent proceedings or trial, and respectfully alleges as follows: + +1. That has been called to testify and provide other information before + +the United States District Court for the Southern District of Florida, including before a Grand Jury + +impaneled therein. + +2. That, in the judgment of the undersigned, the testimony and other information from + +may be necessary to the public interest. + +3. That is likely to refuse to testify and provide other information on the + +basis of her privilege against self-incrimination. + +4. That Ibis Application is made with the approval of the Assistant Attorney General + +in charge of the Criminal Division of the Department of Justice or a duly designated Acting + +Assistant Attorney General, pursuant to the authority vested in him by Tide 18, United States Code, + +Section 6003, and Title 28, Code of Federal Regulations, Sections 0.175 and 0.132(e). A copy of + +the letter from said Assistant Attorney General or his designee expressing such approval iS attached + +hereto. + +5. That counsel for has informed the undersigned that an Order + +compelling testimony is required before will appear and testify before the Grand Jury. + +Upon receipt of the Court's Order compelling such testimony, a Subpoena to Testify before Grand + +Jury 07-103 (WPB) will be issued commanding appearance on Tuesday, April 24, + +2007 at 1:00 p.m. + +By: + +Respectfully submitted, + +R. ALEXANDER ACOSTA UNITED STATES ATTORNEY + +MEW + +ASSISTANT UNITED STATES ATTORNEY + +Florida Bar No. + +500 S. Australian Ave, Suite 400 West Palm Beach, FL 33132 + +FAX + +FGJ 07-1 03(WPB) + +IN RE: + +GRAND JURY PROCEEDINGS + +BALED ORDER + +On Application of the United States Attorney for the Southern District of Florida, and it + +appearing to the satisfaction of the Court: + +I. That has been called to testify and to provide other information before + +the United States District Court for the Southern District of Florida, including a Grand Jury + +impaneled therein; and + +2. That in the judgment of the said United States Attorney, has refused + +to testify and provide other information on the basis of her privilege against self-incrimination; and + +3. That in the judgment of the said United States Attorney, the testimony and other + +information from may be necessary to the public interest; and + +4. That the aforesaid Application has been made with the approval of the Assistant + +Attorney General in charge of the Criminal Division of the Department of Justice or a duly + +designated Acting Assistant Attorney General, pursuant to the authority vested in him by Title 18, + +United States Code, Section 6003, and Title 28, Code of Federal Regulations, Sections 0.175 and + +0. I 32(e). + +NOW, THEREFORE, it is ordered pursuant to Title 18, United States Code, Section 6002, + +that give testimony and provide other information which she refuses to give or to + +provide on the basis of her privilege against self-incrimination, as to all matters about which she may + +be interrogated before said United States District Court, including a Grand Jury impaneled therein, + +as well as any subsequent proceeding or trial. + +However, no testimony or other information compelled under this Order (or any information + +directly or indirectly derived from such testimony or other information) may be used against + +in any criminal case, except a prosecution for perjury, giving a false statement, or otherwise + +failing to comply with this Order. + +IT IS FURTHER ORDERED the this Order shall be SEALED in accordance with Fed. + +R. Crim. P. 6(e)(6), except that a copy of this Order shall be provided to counsel for the United + +States, who may disclose the existence of the Order to members of the Grand Jury, to the witness, + +to counsel for the witness, and to law enforcement officers engaged in the investigation pending + +before the Grand Jury. Those persons may review the Order, but may not retain a copy of the Order, + +nor may they disclose the existence of the Order to any others. + +DONE and ORDERED this day of April, 2007, at West Palm Beach, Florida. + +DONALD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE + +cc: , AUSA + +EISENBERG & FOUTS, P.A. + +Attorneys At Law + +JAMES L. EISENBERG + +Florida Bar Board Certified Criminal Trial Lawyer + +National Board Of Trial Advocacy Cellfiled Criminal Mal Advocate + +KAI LI ALOE FOUTS + +Oat ClearlakeCentre, Suite 704,250Australian Avenue South,WestPalm Beach, FL3340I Fax: + +February 12, 2007 + +Asst. U.S. Attorney + +500 South Australian Avenue, Suite 400 + +West Palm Beach, FL 33401 + +Re: Grand Jury Subpoena for + +Dear + +As always, it was a pleasure speaking to you the other dilursuant to our telephone conference I am writing this letter to proffer my concerns for should she testify without immunity before a federal grand jury. Therefore, allow me to reiterate that Ms. will refuse to voluntarily cooperate with the federal government. She has a good faith basis for her position under the Fifth + +Amendment to the United States Constitution. + +We, of course, do not live or work in a vacuum. We have read many inflammatory remarks the Town of Palm Beach Police Chief has made to the media about the state court's handling of the Jeffrey Epstein investigation. The police chiefs remarks frighten both mysel rand my client. I am aware that the town police have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push to have one lady charged I remain unconvinced that they do not have the ability or political clout to push to have other ladies such as Ms.= charged. + +The proffered facts that raise my concerns are being provided via this proffer letter. Pursuant to our + +telephone conference agreement, this letter and its contents cannot be used against Mr. =. + +Ms.= is not at all certain of dates. She does remember meeting Mr. Epstein about three years ago. She is not certain of her age. it could have been when she was sixteen. A girlfriend asked her if she wanted a job giving massages. Ms.= agreed because she had knowledge of massages + +through her mother, who was a masseuse. + +Ms. = went to Mr. Epstein's house via taxi. Ms. girlfriend instructed Ms.=r that, if asked, she had to tell Mr. Epstein that she was eighteen years old. The friend was nineteen years old and looked old for her age, so passing for eighteen was not a problem. At + +the home Ms.= met Mr. Epstein and later "Tim a massage. The friend had told Ms. + +to give the message topless. Mr. Epstein told that if she were at all uncomfortable being topless, not to do it and it was not a requirement of employment as a masseuse. Ms. never + +touched Mr. Epstein in a sexual way and Mr. is. all. one Ms. At touched never point, /et + +Mr. Epstein did ask Ms. her age. Ms. insisted that she was eighteen years old. + +Ms. = continued to see Mr. Epstein over time and massages were given in a similar fashion. She was later asked if her friends wanted to work in a similar way and she asked some girls who did give Mr. Epstein massages. Ms.=r was never asked to bring girls of any age to Mr. Epstein's home. When she did have her friends come over, she instructed all of them that if asked, they insist + +that they were eighteen years old. She is not certain at all of any of these girls' real ages. + +In summary, our concern is that if the government believes that Mr. Epstein comm itted some federal offense, then Ms.= could he considered a co-conspirator. We believe no crime was committed. The Fifth Amendment was not intended to protect the guilty, however. It was enacted to protect citizens who fear prosecution notwithstanding their innocence. Our fear of any prosecution, + +especiallyjltt ligh f the Town police chiefs public remarks, is clearly in good faith. + +Sincer + +ISENE5R6r--- + +EISENBERG & FOUTS, P.A. + +Attorneys At Law + +JAMES L. EISENBERG + +Florida Bar Board Certified Crimisal trial Lawyer + +National Board Of Trial Advocacy Certified ethnical Trial Advocate + +KAI LI ALOE POUTS + +OneClear lake Centre,Su ite 704,250 Australian Avenue Sou CIL, West Palm Beach, FL 33401 Fax: + +February 1,2007 + +Asst. U.S. Attorney + +500 South Australian Avenue, Suite 400 + +West Palm Beach, FL 33401 + +Re: Grand Jury Subpoena for + +Dear + +I received your letter dated January 24, 2007 with regard to ME= I must admit I forced myself to wait several days to respond in order to "cool off' and not say anything I would regret + +later. Now that time has passed, allow me to respond appropriately. + +I. If you want to force Ms. MI to come to the grand jury room to + +personally invoke her Fifth Amendment ri lts, she will be there. That does remain her position. M onl re uest is that provide I will be there, but I am not + +and Ms. should not have It is this type of attitude, that your + +office refuses to accept the fact that it is Ms. decision not to cooperate with the government + +aitk sets her. Your office fails to recognize that merely corning to court is a problem for + +like Ms. M: and, under these circumstances, appears to be a waste of time at best and, in + +her mind, personal harassment. + +2. Rest assured that there is no conflict of interest in my representation of Ms. I= In this + +case I have always been asked and always will exercise independent judgment to follow my client's independent will. The remainder of your questions as to this matter arc really none of the + +Government's business. + +3. 1 will share with you that one of the reasons for our firm position that Ms. will + +invoke her Fifth Amendment right and choose not to voluntarily cooperate with the Government is + +our concern that the Government is not exercising independent judgment in this case. + +The history of this case has been in the newspapers. The case is being prosecuted in State court. Despite the state court prosecution, the Town of Palm Beach Police Chief went on what can only be + +, Asst. U.S. Attorney + +February 1, 2007 + +Page 'Iwo + +described as a public rampage in the newspaper when the case was not prosecuted to his liking that reminded me of a small child having a public temper tantrum. In my thirty years of experience, T have never seen a law enforcement officer like this publicly make what appeared to be a political ease in the newspaper for a prosecution and publicly criticize anyone who got in his way, including the elected State Attorney. This resulted in a federal investigation on a topic no one remembers the Federal Government ever being interested in prosecuting before. Although I am certain that you personally have not had your decision-making process compromised, the appearance that your office is being influenced by the Town of Palm Beach Police Chief's agenda is very real. Under these circumstances I don't see how any lawyer could advise any client to voluntarily cooperate. Of special concern is that the Town of Palm Beach Police have promoted prosecuting at least one of the + +girls who allegedly gave massages. + +One final thought. My client and my fear that Ms. could be prosecuted is enhanced by the demand for the personal appearance made in your letter. Your initial Kastiger letter fell far short of granting the functional equivalent of DOJ immunity. Several months ago I was given the distinct + +impression through our conversations that you were going to obtain DOJ immunity for Ms. + +Now the government is changing course for no apparent reason. This leads to speculation that the only reason for the nuriabout is that prosecution in either state or federal court is being considered + +by someone. + +directed at you personally. I want to repeat that you have always treated us with office should advise the Town Police Chief to act in a similar fashion. + +09/06/2006 14:53 FAX USA0 ISPB FL 2001 + +\*\*\* TX REPORT sea + +TRANSMISSION OK + +TX/RX. NO 2683 + +CONNECTION TEL 6592380 + +SUBADDRESS CONNECTION ID + +ST. TIME 09/06 14:62 USAGE T 01'00 PGS. SENT 2 RESULT OK + +U.S. Department of Justice + +United States Attorney Southern District of Florida + +500 South Australian Ave, Suite 400 West Palm Beach, Florida 33401 + +Facsimile + +. FACSIMILE COVER SHEET + +TO: JIM EISENBERG; ESO. DATE: September 6. 2006 + +FAX NO. # OF PAGES: 2 + +PHONE NO. RE: + +FROMt + +PRONE NO. + +ASSISTANT U.S. ATTORNEY + +commas; Dear Jim: Here is the copy of the original subpoena that you + +requested. Also, I confirmed with the secretary who rod the + +U.S. Department of Justice + +United States Attorney Southern District of Florida + +500 South Australian Ave, Suite 400 West Palm Beach, Florida 33401 + +Facsimile + +FACSIMILE COVER SHEET + +TO: JIM EISENBERG, ESQ. + +FAX NO, + +PHONE NO. + +DATE: + +# OF PAGES: + +RE: + +September 6, 2006 + +2 + +FROM: + +PHONE NO. + +ASSISTANT U.S. ATTORNEY + +COMMENTS: Dear Jim: Here is the copy of the original subpoena that you + +requested. Also, I confirmed with the secretary who re ared the + +September 8th subpoena that it was signed by AUSA + +As we discussed. does not need to appear before the grand jury until you have had a chance to confer with her and we + +have spoken and agreed to a mutually convenient date. + +Thank you for your assistance. + +U.S. Department of Justice + +United States Attorney Southern District of Florida + +500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 + +Facsimile: + +January 24, 2007 + +DELIVERY BY HAND James L. Eisenberg, Esq. 250 S Australian Ave, Ste 704 West Palm Beach, FL 33401-5007 + +Re: Federal Grand Jury Subpoena + +Dear Jim: + +A new grand jury has been tided and I have enclosed a new subpoena for= MI. As 1 mentioned earlier, Ms is not a target of this investigation and the United States seeks her testimony solely as a victim/winless. During our last conversation regarding Ms. , you indicated that she was unwilling to speak with us pursuant to a Kastigar letter and that she also was unwilling to speak with the grand jury and intends to invoke the Fifth Amendment if questioned. Please confer with her to confirm whether this remains her position. If it is, please advise in writing. Even if Ms.= is inclined to invoke her Fifth Amendment rights, she must still appear pursuant to the subpoena so that I may ask her questions that would not require the invocation of the Fifth Amendment. If she still invokes, I intend to move to compel her answers. If you or your client is unavailable on February 6, + +2007, please let me know of another Tuesday when you are available. + +I also am concerned about a potential conflict of interest in your representation of Ms. In case of future litigation regarding this issue, please provide me with information + +regarding who is paying (directly or indirectly) for your services on behalf of Ms. MI, the scope of your representation and whether you are taking direction on this matter from anyone other than Ms. =. If any formal or informal joint defense agreements exist, whether in writing or otherwise, please provide a copy of such agreements. If the agreement + +is purely oral, please provide a written summary of its terms. + +JAMES EISENBERG, ESQ. JANUARY 24, 2007 + +PAGE 2 + +Ilook forward to your response. + +Sincerely, + +R. Alexander Acosta + +By: + +04 k44 + +Assistant United States Attorney + +This subpoena is issued upon application + +United States District Court SOUTHERN DISTRICT OF FLORIDA + +TO: SUBPOENA TO TESTIFY + +BEFORE GRAND JURY FGJ 07-103(WPB)-TuesJNo. OLY-13/2 + +SUBPOENA FOR: + +PERSON X DOCUMENTS OR OBJECT[SI + +YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury oftheUniteri States District + +Court at the place, date and time specified below. + +PLACE: + +United States District Courthouse + +701 Clematis Street + +West Palm Beach, Florida 33401 + +ROOM: + +Grand Jury Room + +DATE AND TIME: February 6, 2007 + +1:0Oprn\* + +YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): + +ANY AND ALL NOTES, LEVIERS, CARDS, GIFTS, PAYMENTS. AND PHOTOGRAPHS YOU HAVE RECEIVED + +FROM JEFFREY EPSTEIN + +ANY AND ALL PHOTOGRAPHS WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN + +ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS OR TELEPHONE + +MESSAGES THAT YOU HAVE SENT TO AND/Oft RECEIVED FROM JEFFREY EPSTELN, + +\*Please coordinate your compliance with this subpoena and confirm the date and time , and location of our a earance with Special Agent Federal Bureau of Investigation, Telephone: + +This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf + +of the court. + +DATE: + +January 23, 2007 + +Narns\_Address and Phone Number of Assistant U.S. Attorney + +Ann= C. Assistant U.S. Attorney + +500 So. Australian Avenue, Suite 400 West Palm Beach FL 33401.6235 + +U.S. Department of Justice + +United States Attorney Southern District of Florida + +500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 + +Facsimile: + +February 5, 2007 + +DELIVERY BY HAND + +Ms. + +do James L. Eisenberg, Esq. 250 S Australian Ave, Ste 704 West Palm Beach, FL 33401-5007 + +Re: Grand Jury Testimony of + +Dear Ms. M: + +This letter confirms the understanding between yourself and the United States Attorney's + +Office for the Southern District of Florida. + +You have represented that you will truthfully answer questions of the federal government in + +its investigation of the procurement of prostitutes, amongst others. You will supply complete and truthful information to the attorneys and law enforcement officers of the federal government and to any Federal Grand Jury which may conduct an investigation, as welt as in any other proceeding related to or growing out of this investigation. The obligation of truthful disclosure includes your obligation to provide the attorneys and law enforcement officers of the federal government with any documents, records or other tangible evidence within your custody or control relating to the matters about which you are questioned. You will neither attempt to protect any person or entity through + +false information or omission, nor falsely implicate any person or entity. + +No statements provided by you on this date in this matter pursuant to this agreement will be + +offered into evidence in any criminal case against you, except during a prosecution for perjuryand/or giving a false statement. However, if it is determined that you have materially violated any provision of this agreement, all statements made by you shall be admissible in evidence against you in any + +proceeding. + +The federal government remains free to use information derived from the grand jury + +testimony directly or indirectly for the purpose of obtaining leads to other evidence, which may be used against you. You expressly waive any right to claim that such evidence should not be introduced because it was obtained as a result of the grand jury testimony. Furthermore, the federal government may use statements made in the grand jury testimony and all evidence derived directly or indirectly therefrom for the purpose of cross-examination, if you testify at any trial or if you + +Ms. + +FEBRUARY 5, 2007 + +PAGE 2 + +suborn testimony that contradicts your prior statements and testimony. + +No additional promises, agreements and conditions have been entered into other than those + +set forth in this letter and none will be entered into unless in writing and signed by all parties. + +Sincerely, + +R. Alexander Acosta United States Attorney + +By: + +Assistant United States Attorney + +I have read this agreement and discussed it with my attorney, and I hereby acknowledge that it + +fully sets forth my agreement with the office of the United Stales Attorney for the Southern District of Florida. I state that there have been no additional promises, agreements or representations made to me + +by any officials of the United States in connection with this matter. + +Dated: February 2007 + +West Palm Beach, Florida + +Witnessed by: + +James L Eisenber • Es + +Attorney for + +U.S. Department of Justice + +United States Attorney Southern District of Florida + +DELIVERY BY HAND James L. Eisenberg, Esq. 250 S Australian Ave, Ste 704 West Palm Beach, FL 33401-5007 + +Re: + +Dear Mr. Eisenberg: + +500 South Australian Ave., Suite 400 West Palm Beach, Ft 33401 + +Facsimile: + +February 5, 2007 + +I am writing to clarify the ground rules for the interview with your client, + +("your client"), to occur February , 2007. + +As I mentioned earlier, Ms. is not a target or subject of this investigation, but + +instead is being interviewed solely as a victim/witness. However, to address your concern about criminal exposure, if your client complies with every provision of this agreement, then the United States Attorney's Office for the Southern District of Florida ("this Office") will treat all statements made by your client during the interview as statements made pursuant to Rule 11(0 of the Federal Rules of Criminal Procedure. This is not a grant of immunity, which can be given only with approval of the Justice Department, but protects your client from having the statements made by her during the interview from being used against her directly. To guard against any misunderstandings concerning the interview of your client, + +this letter sets forth the terms of this agreement. + +Your client agrees to be fully interviewed, that is, to provide information concerning + +your client's knowledge of, and participation in criminal activity, including but not limited to the procurement of prostitutes. The protection of this letter applies to an interview that will be conducted by this Office, Special Agents of the Federal Bureau of investigation, and any other federal law enforcement agency this Office may require. Under this agreement, no information disclosed by your client during the interview will be offered in evidence against her in any criminal or civil proceeding, provided that your client complies with this agreement and that the information your client furnishes is truthful, complete, and accurate. + +JAMES L. EISENBERG, ESQ. + +RE: + +FEBRUARY 2, 2007 + +PAGE 2 + +then this Office may use such information in any matter or proceeding and your client is subject to prosecution for perjury, obstruction of justice, and making false statements to government agencies. Any such prosecution may be based upon information provided by your client during the course of the interview, and such information, including your client's statements, will be admissible against your client in any grand jury or other proceeding. + +The government also may use statements made by your client in the interview and all + +evidence derived directly or indirectly therefrom for the purpose of impeachment or cross-examination if she testifies at any trial or hearing, and/or in any rebuttal case against your client in a criminal trial in which she is a defendant or a witness. These provisions are necessary to ensure that your client does not make or offer any false representation or statement in any proceeding or to a government agency or commit perjury during any + +testimony. + +Your client further agrees that attorneys for the United States may be present at the + +interview, and agrees not to seek disqualification of any such govermnent attorney from any + +proceeding or trial because of their participation at the interview. + +The entire agreement between the United States and your client is set forth in this + +letter. No additional promises, agreements, or conditions have been entered into and none + +will be entered into unless in writing and signed by all parties. + +If the foregoing accurately reflects the understanding and agreement between this + +Office and your client, it is requested that you and your client execute this letter as provided + +below. + +Sincerely, + +R. Alexander Acosta United States Attorney + +By: + +Assistant United States Attorney + +have received this letter from my attorney, James L. Eisenberg, Esquire, have read + +it and discussed it with my attorney, and I hereby acknowledge that it fully sets forth my understanding and agreement with the Office of the United States Attorney for the Southern + +JAMES L. EISENBERG, ESQ. + +RE: + +FEBRUARY 2, 2007 + +PAGE 3 + +District of Florida. I state that there have been no additional promises or representations made to me by any official of the United States Government or by my attorney in connection + +with this matter. + +Dated: + +Witnessed by: + +James L. Eisenberg, Esquire + +U.S. Department of Justice Authorization for Reimbursement + +of Unusual Expenses of Fact Witnesses + +Request for Unusual Expense(s) of Fact Witness (For United States Attorney's Office Use Only) + +1. Case Name + +9. Payment to be made to: + +4. Lbcatlonof Court task Pole-n 2. Court Docket Number + +5. Contact Person + +Control if • + +3. Requesting AUSA + +6, contact Person Number + +8. Vendor Name & Address. Phone #, TIN/SSN + +10. Receiptfinvolce Is: + +11. Type of Unusual Expense: El Medically Necessary Item + +(Attached Supporting Statement) + +• Excess Lodging/Per Diem Ei Travel & Transportation + +• Pretrial Conference Waiver + +• Other + +12. Explanation: + +1 + +13. Start Date of Service (MO/DA/YR) 14. End Data of Senile. (MOIDANR) 15. Amount 2-A/O 7 1 24 /0 7 + +16. Justification: + +17. I hereby certify that the eXpenses and services listed on thls document are appropriate and are within the Federal laws and regulations. I fully understand that I can be held personally liable or be subject to disciplinary action for improperly using + +government funds or services that exceed delegated authority or that violate Federal laws or regulations. + +Signature of Requesting AUSA Date + +18. Name & Title of Approving Official 19. Date (MO/DA/YR) 20. Signature of Approving Official + +EISENBERG & FOUTS, P.A. + +ATTORNEYS AT LAW + +JAMES L. EISENBERG Suitt 704. Oat Cleartake Centre 250 Australian Avenue So. Wen Palm Beach. FL 33401 BOARD CERTIFIED CRIMINAL TRIAL LAW5'ER + +561-659-2009 Fax + +EISENBERG & FOUTS, P.A. + +Attorneys At Law + +JAMES L. EISENBERG + +Florida Bar Board Certified Cele°Iasi Trial Lawyer + +National Board Of Trial Advocacy Certified Criminal Trial Advocate + +KAI LI ALOE FOUTS + +One Clearlake Centre, Suite 704, 250 Australian Avenue South, West Palm Bach, FL 33401 Fax + +September 21, 2006 + +, Asst. U.S. Attorney + +500 South Australian Avenue, Suite 400 + +West Palm Beach, FL 33401 + +Re: Grand Jury Subpoena for + +Dear + +Please allow me to confirm my latest e-mail to you. I did receive your e-mail of last week with attachments and passed them on to my client. At this time, I can only say that my client does not want to do eit of your suggestions. She does not want to give a statement under the immunity + +ed with its Kastigar exception and she does not want to testify before the grand jury 5" Amendment grounds. With this client, I am sorry, but I must have a formal grant + +e she will say anything. + +I GOVERNMENT EXHIBIT + +2 + +FGJ 07-103(WPB) + +IN RE: + +GRAND JURY PROCEEDINGS + +SEALED ORDER + +On Application of the United States Attorney for the Southern District of Florida, and it + +appearing to the satisfaction of the Court: + +1. That has been called to testify and to provide other information before + +the United States District Court for the Southern District of Florida, including a Grand Jury + +itnpanelled therein; and + +2. That in the judgment of the said United States Attorney, has refused + +to testify and provide other information on the basis of her privilege against self-incrimination; and + +3. That in the judgment of the said United States Attorney, the testimony and other + +information from may be necessary to the public interest; and + +4. That the aforesaid Application has been made with the approval of the Assistant + +Attorney General in charge of the Criminal Division of the Department of Justice or a duly + +designated Acting Assistant Attorney General, pursuant to the authority vested in him by Title 18, + +United States Code, Section 6003, and Title 28, Code of Federal Regulations, Sections 0.175 and + +0.132(e). + +NOW, THEREFORE, it is ordered pursuant to Title 18, United States Code, Section 6002, + +provide on the basis of her privilege against self-incrimination, as to all matters about which she may + +be interrogated before said United States District Court, including a Grand Jury impaneled therein, + +as well as any subsequent proceeding or trial. + +However, no testimony or other information compelled under this Order (or any information + +directly or indirectly derived from such testimony or other information) may be used against + +•M in any criminal case, except a prosecution for perjury, giving a false statement, or otherwise + +failing to comply with this Order. + +IT IS FURTHER ORDERED the this Order shall be SEALED in accordance with Fed. + +Crim. P. 6(e)(6), except that a copy of this Order shall be provided to counsel for the United + +States, who may disclose the existence of the Order to members of the Grand Jury, to the witness, + +to counsel for the witness, and to law enforcement officers engaged in the investigation pending + +before the Grand Jury. Those persons may review the Order, but may not retain a copy of the Order, + +nor may they disclose the existence of the Order to any others. + +DONE and ORDERED this AC day of April, 2007t Palm Beach, Florida. + +DONALD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE + +cc: AUSA + +Case 9:08-cv-80736-KAM Document 212 Entered on FLSD Docket 07/19/2013 Page 1 of 2 + +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +Case No. 08-80736-Civ-Marra/Matthewman + +JANE DOES #1 AND #2, + +l'et itioners, + +v . + +UNITED STATES OF AMERICA, + +Respondent. + +UNITED STATES' NOTICE OF FILING PRIVILEGE LOG + +Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United + +States of America, by and through the undersigned Assistant United States Attorney, hereby gives + +notice of its filing of its Privilege Log, which is attached hereto. + +The documents referenced in the Privilege Log are being delivered today to the Chambers + +of U.S. District Judge Kenneth A. Marra for ex pane in camera review, pursuant to the Court's + +Omnibus Order. + +Respectfully submitted, + +WIFREDO A. FERRER + +UNITED STATES ATTORNEY + +By: + +Assistant United States Attorney + +Florida Bar No. + +500 South Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Telephone: Facsimile: + +Case 9:08-cv-80736-KAM Document 212 Entered on FLSD Docket 07/19/2013 Page 2 of 2 + +CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on July 19, 2013,1 electronically filed the foregoing document + +with the Clerk of the Court using CM/ECF. According to the Court's website, counsel for all parties + +are able to receive notice via the CM/ECF system. + +Assistant United States Attorney + +SERVICE LIST + +Jane Does 1 and 2 v. United States, Case No. 08-80736-C1V-MARRA/MATTHEWMAN United States District Court, Southern District of Florida + +Fort Lauderdale FL 33301-3268 + +Fax: + +Paul G. Cassell + +S.J. Quinney College of Law at the + +University of Utah 332 S. 1400 E. + +Salt Lake Ci Utah 84112 + +Fax: (801) 585-6833 + +E-mail: + +Attorneys for Jane Doe # 1 and Jane Doe # 2 + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 1 of 23 + +PRIVILEGE LOG + +Bates Range Description Privilege(s) Asserted + +Box #1 P-000001 thru P-000039 + +File folder entitled "CORR RE GJ SUBPOENAS" containing correspondence related to various d jury subpoenas and attorney handwritten notes + +6(e) Work Product + +Box #1 P-000040 thru P-000549 + +Operation Leap Year Grand Jury Log containing subpoenas OLY-01 through OLY-81, correspondence and research related to enforcement of same, documents produced in response to some subpoenas; and attorney (la handwritten notes + +6(e) Work Product Contains documents subject to investigative privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation + +Box #1 P-000550 thru P-000621 + +File folder entitled "Ritz Compact Flash SW" containing copies of a sealed search warrant application, warrant, and supporting documents + +6(e) Contains information subject to investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation + +Box #1 P-000622 thru P-000693 + +File folder entitled "PNY Technologies Compact Flash SW" containing copies of a sealed search warrant application, warrant, and supporting documents + +6(e) Contains information subject to investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation + +Box #1 P-000694 thru P-000781 + +File folder entitled "JE Corporations" containing attorney research on Epstein-owned corporations and prior litigation + +Work Product Contains information subject to investigative privilege + +Box #1 P-000782 thru P-000803 + +File folder entitled "Capital One" containing subpoena and correspondence 6(e) + +Box #1 P-000804 thru P-000854 + +File folder entitled "DTG Operations/Dollar Rent-a-Car" containing subpoena and responsive documents + +6(e) Contains documents and information subject to investigative privilege Also contains documents and information subject to privacy rights of victims who are not parties to this litigation + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2.013 Page 2 of 23 + +Bates Range Description Privilege(s) Asserted + +Box #1 P-000855 thru P-000937 + +File folder entitled "JP Morgan Chase" containing subpoena, correspondence, and responsive documents + +6(e) Contains documents and information subject to investigative privilege + +Box #1 P-000938 thru P-000947 + +File folder entitled "Washington Mutual" containing subpoena, correspondence, and responsive documents + +6(e) Contains documents and information subject to investigative privilege + +Box #1 P-000948 thru P-000982 + +File folder entitled "Computer Search &" containing legal research on computer search and handwritten notes on indictment preparation + +Work Product Attorney-Client Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation + +Box #1 P-000983 thru P-001007 + +File folder entitled "Attorney Notes from Document Review" containin typed and handwritten attorney notes, target letters, correspondence re grand jury subpoena + +Work product 6(e) Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation + +Box #1 P-001008 thru P-001056 "Notes Worts Product + +6(e) Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation + +File folder entitled from Fed Ex Records" cor.stisin handwritten and typed attorney ( notes and screen shots of FedEx subpoena response electronic file + +Box #1 P-001057 thru P-001959 + +File folder entitled "Colonial Bank Records" containing records received in response to grand jury subpoena + +6(e) Contains information subject to investigative privilege + +Box #1 P-001960 Thru P-002089 + +File folder entitled "OLY Grand Jury Log Vol 2: OLY-51 THROUGH" containing subpoenas numbered OLY-51 through OLY-81 with related correspondence + +6(e) Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 4 of 23 + +Bates Range Description Privilege(s) Asserted + +Box #1 P-003212 Thru P-003545 Indictment preparation binder containing metaanalysis charts of telephone/flight/grand jury information for a number of victim/witne s, + +Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +and + +Box #1 P-003546 Thru P-003552 + +FBI Reports of March 2008 interviews of additional witness/victim located in New York + +Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #1 P-003553 Thru P-0035558 + +Printout of filenames from Federal Express subpoena response with Attorney notations Work product 6(e) + +Box #1 P-003556 Thru P-003562 + +Document entitled "Identified Numbers" with accompanying handwritten attorney list compiled from grand jury materials and attorney analysis of records + +Work product 6(e) Contains information subject to investigative privilege + +Box #1 P-003563 Thru P-003629 Folder entitled "Flight Manifests" containing manifests received pursuant to grand jury subpoena + +6(e) Contains information and documents subject to investigative privilege + +Box #1 P-003630 Thru P-003633 + +File folder entitled "Recent AttonStes" containing handwritten attorney ) notes regarding document review and case strategy + +Work product 6(e) Investigative privilege Deliberative process + +Box #1 P-003634 Thru P-003646 File folder bearing victim name containing FBI interview report from May 2008 tele one activity report with attorney ) handwritten notes, related grand jury material + +Work product Attorney-client privilege 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 5 of 23 + +Bates Range Description Privilege(s) Asserted + +Box #1 P-003647 Thru P-003651 + +File folder entitled "Summary of Sexual Activity" containing chart bearing handwritten title "Sexual Activity — Summary" with meta-analysis of information, sorted by name of each victim/witness, including name and identifying information of each victim/witness + +Work product 6(e) Investigative privilege Deliberative process Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #1 P-003652 Thru P-003663 File folder entitled "Victim Civil Suits" Not privileged. + +Produced to counsel for Petitioners + +Box #1 P-003664 Thru P-003678 File folder entitled "Research re JE Websites" containing attorney research + +Work product + +Box #1 P-003679 Thru P-003680 + +File folder entitled (N.Y. AUSA)" containing attorney I I handwritten notes Work product + +Box #1 P-003681 Thru P-003687 File folder entitled "Dr. " containing Work product attorney a) memo to expert witness and Investigative privilege + +handwritten attorney notes + +Box #1 P-003688 Thru P-003693 File folder entitled "I[j GO Interview" containing attorney handwritten notes of interview, and attorney handwritten notes regarding potential charges + +Work product Investigative privilege Also contains information subject to privacy rights of victims who are not parties to this litigation + +Box #1 P-003694 Thru P-003711 File folder entitled "Research re Travel for + +Prostitution" containing attorney a + +handwritten notes regarding grand jury presentation, chart entitled "Brought to Epstein's House" with handwritten notes, Message Pad meta-analysis chart, summary of evidence related to one victim/witness, and relevant grand jury information + +Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #1 P-003712 Empty file folder bearing name of victim/witness Investigative privilege + +Also contains information subject to privacy rights of victim who is not a party to this litilation + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 6 of 23 + +Bates Range Description Privilege(s) Asserted + +Box #1 P-003713 Thru P-003746 + +File folder entitled "TO MO" containing grand jury subpoenas, motion and order to compel testimony, and correspondence regarding same + +6(e) Documents under seal pursuant to court order + +Box #1 P-003747 Thru PM03751 + +File folder entitled' 'containing 6(e) + +subpoena and correspondence regarding same + +Box #1 P-003752 Thru P-004295 File folder entitled "PBPD Investigative File" obtained via subpoena + +6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #1 P-004296 Thru P-004350 + +File folder bearing name of victim/witness containing meta-analysis chart showing telephone calls, travel, and grand jury materials relevant to possible charges + +Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not es to this liti ation + +Box #1 P-004351 Iliru P-004381 File folder entitled Documents Work product + +53909-004" containing attorney research related to bias issue + +Box #1 P-004382 Thru P-004478 File Folder entitled "FEDEX" containing documents obtained via subpoena + +6(e) Investigative privilege + +Box #1 P-004479 Thru P-004551 + +File Folder entitled "State of Delaware Records" containing documents obtained in preparation for indictment + +6(e) Investigative privilege Work product + +Box #1 P-004552 Thru P-004555 File folder entitled "Jet Blue Records" containing documents obtained via subpoena + +6(e) Work product Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #1 P-004556 Thru P-004560 + +File folder entitled "FL EMPLOYMENT RECORDS" containing FDLE records on targets and witnesses obtained at attorney request + +Investigative privilege Work product + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 7 of 23 + +Bates Ran e Descri don Privil s Asserted + +Box #1 P-004561 Thru P-004565 Filed folder entitled " + +containing attorney handwritten notes of interview + +Work product Investigative privilege + +Box #1 P-004566 Thru P-004716 File folder entitled 6(e) + +Work product Investigative privilege Also contains information and documents subject to privacy rights of victims who are not ies to this liti tion + +RECORDS 23-0001 THROUGH 23-" containing documents obtained via subpoena + +Box #1 P-004717 Thru P-004722 + +File folder entitled " Work product containing attorney research regarding witness Investigative privilege + +Box #1 P-004723 Thru P-004725 + +File folder entitled "BEAR STEARNS RESEARCH" containing attorney research regarding potential witness and subpoena recipient + +Work Product Investigative privilege + +Box #1 P-004726 Thru P-004819 + +File folder entitled "LAWSUITS INVOLVING EPSTEIN CORP'S" containing attorney research regarding Epstein's past personal and business liti ative practices + +Work Product Investigative privilege + +Box #1 P-004820 Thru P-004959 + +Filed folder entitled "SEC RECORDS" containing attorney research regarding Epstein financial relationships + +Work Product Investigative privilege + +Box #1 P-004960 Thru P-005059 + +File folder entitled "Message Pads" containing selected items from evidence obtained via subpoena + +Work Product 6(e) investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #1 P-005060 Thru P-005081 + +File folder bearing name of victim/witness containing correspondence with counsel for victim/witness, attorney witness outline with attorney handwritten notes, attorney handwritten notes regarding witness reports and case preparation + +Work Product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #1 P-005082 Thru P-005083 File folder entitled "New York Trip" containing attorney notes re witness interview + +Work product Investigative privilege + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 8 of 23 + +Bates Range Description Privilege(s) Asserted + +P-005084 thru P-005107 are non responsive documents and have been removed + +Box #1 P-005108 Thru P-005193 File folder entitled " containing Work product attorney research on select expert, use of experts Investigative privilege + +at trials in child exploitation cases, and additional research materials on offenders and victims + +Box #1 P-005194 Thru P-005300 + +File folder entitled "Extra Copies" containing meta-analysis chart and 302's of victim/witnesses used in preparing indictment package + +Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not rties to this liti ation + +Box #1 P-005301 Thru P-005331 + +File folder entitled 6(e) STATEMENT" containing transcript obtained via Investigative privilege + +subpoena + +Box #1 P-005332 Thru P-005341 + +File folder entitled' containing Work product + +attorney research on select expert, including Investigative privilege + +attorney handwritten notes + +Box #1 P-005342 mm P-005387 File folder entitled "Info re Planes" containing correspondence regarding subpoenas and documents received in response to subpoenas + +6(e) Investigative privilege + +Box #1 P-005388 Thru P-005442 + +File folder entitled "Police Reports & PC Affidavit" containing portions of police reports with attorney notes, related phone records, a list entitled "Victims" with identifying information and attorney handwritten notes, photographs and DAVID information, and additional attorney research regarding Epstein sexual activity + +Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #1 P-005443 Thru P-005496 File folder entitled "[Victim name] Transcript of Interview & GJ Transcript" + +6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #1 P-005497 Thru P-005556 + +File folder entitled "Bear Steams Subpoena Resp." containing material received in response to subpoena + +. + +6(e) Investigative privilege + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 9 of 23 + +Bates Range Description Privilege(s) Asserted + +Box #1 P-005557 Thru P-005576 U.S. Attorney's Office Criminal Case File Jacket containing file opening documents, expert witness payment documents + +Work product Deliberative process + +Box #1 P-005578 Thru P-005583 + +U.S. Attorney's Office Asset Forfeiture Case File Jacket containing file opening and file closing documents + +Work product Deliberative process + +Box #1 P-005584 Thru P-005606 + +File folder entitled "6001 Immunity Request" containing internal memoranda seeking witness immunity and correspondence with counsel for witness regarding same + +6(e) Work product and deliberative process (as to internal memoranda) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #2 P-005607 Thru P-005914 + +File folder entitled "MASTER PHONE RECORDS" containing meta-analysis of all phone, travel, and grand jury data for all victim/witnesses for indictment preparation + +Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #2 P-005915 Thru P-005977 + +File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation + +Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #2 P-005978 Thru P-006050 + +File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation + +Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #2 P-006051 Thru P-006065 + +File folder bearing name of victim/witness containing meta-analysis of all phone, travel, and + +Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +grand jury data related to that victim/witness for indictment preparation + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 10 of 23 + +Bates Range Description Privilege® Asserted + +Box #2 P-006066 Thru P-006220 + +File folder entitled "JANE DOE #4" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation + +Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #2 P-006221 Thru P-006222 File folder entitled ""JANE DOE #12" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation + +Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #2 P-006223 Thru P-006522 + +File folder entitled "CORRECTED PHONE RECORDS 5/31/07" containing meta-analysis of all phone, travel, and grand jury data related to all victims/witnesses for indictment preparation + +Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #2 P-006523 Thru P-006802 + +File folder entitled "[Victim Name] Phone Records" containing telephone records received in response to subpoena + +Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #2 P-006803 Thu P-006860 + +File folder entitled "Lists of Identified Phone Numbers" containing charts of information culled from grand jury materials, interviews, and other investigation, with attorney handwritten notes, and information to issue follow-up grand jury subpoena + +Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #2 P-006861 Thru P-007785 + +File folder entitled "EPSTEIN. CELL PHONE RECORDS" containing documents received via subpoena with attorney handwritten notes and highlighting + +Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 11 of 23 + +Bates Range Description Privilege(s) Asserted + +Box #2 P-007786 Thru P-008120 + +Folder entitled "OLY GRAND JURY LOG: OLY-01 THROUGH OLY-50" containing subpoenas, correspondence regarding same, 6(e) letters, attorney handwritten notes regarding records received in response to subpoenas + +Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #2 P-008121 Thru P-008139 Handwritten flight logs received in response to subpoena + +6(e) Investigative privilege + +Box #2 P-008140 Thru P-008298 + +Grand jury presentation folder containing attorney handwritten notes, typed outline with additional handwritten notes, complete indictment package dated 2/19/2008, victim list with identifying information, photographs, and summary of activity + +Work product 6(e) Investigative privilege Also contains information and documents subject to privacy rights of victims who are not parties to this litigation + +Box #2 P-008299 Thru P-008363 + +File folder entitled "FINAL AGREEMENTS" containing subfolder entitled "Agrints Filed in State Court" (P-008300-P-008327 [not being withheld as privileged — have been produced to opposing counsel]); signed Non-Prosecution Agreement, Addendum, and operative portion of 12/19/2007 nAcosta letter (P-008328-P-008343 [not being withheld as privileged — have been produced to opposing counsagiubfolder entitled "12/19/07 Acosta- Ltr" containing unredacted copies of that letter (11- 008344-P-008363 [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11d' Circuit + +Box #2 P-008364 Thru P-008382 File folder entitled Immunity Request" containing internal memoranda, Justice Department documentation, and subpoena regarding immunity request + +6(e) Work Product Deliberative Process Investigative privilege + +Box #2 P-008383 Thru P-008516 + +File folder containing March 18, 2008 grand jury presentation materials, including "Operation Leap Year Revised Indictment Summary Chart (by victim)," grand jury materials, draft indictments, victim reference list, grand jury subpoena log + +Work product 6(e) Investigative privilege Deliberative process Also contains information and documents subject to privacy rights of victims who are not esti: liislitiation g + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 12 of 23 + +Bates Range Description Privilege(s) Asserted + +Box #2 P-008517 Thru P-008535 + +6/25/2007 Letter from Gerald Lef urt to and + +[pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by I Ith Circuit] + +Box #2 P-008536 Thru P-008542 + +Handwritten attorney notes to prepare for interview of Jane Doe #2 + +Work product Investigative Privilege Contains information subject to privacy rights of victims who are not parties to this suit + +Box #2 P-008543 Thru P-008549 Handwritten attorney notes regarding May 8, 2007 grand jury presentation + +Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit + +Box #2 P-008550 Thru P408615 File folder entitled "Most Recent Indictment & Good Cases" containing draft indictment and legal research + +Work product 6(e) Investigative privilege Deliberative process Contains information subject to privacy rights of victims who are not parties to this suit + +Box #2 P-008616 Thru P-008686 + +File folder entitled "FBI Summary Charts" containing chart prepared at direction of AUSA, containing victim names, identifying information, summary of activity, and other information relevant to indictment + +Work product Attorney-Client Privilege 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit + +Box #2 P-008687 Thru P-008776 + +File folder entitled "[Victim name]/Jane Doe #4" containing phone records and meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation + +Work product 6(e) Investigative privilege Contains information and documents subject to privacy rights of victims who are not parties to this suit + +Box #2 P-008777 Thru P-008808 + +File folder entitled "[Victim name]/Jane Doe #5" containing handwritten notes and meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation + +Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 13 of 23 + +Bates Range Description Privilege(s) Asserted + +Box #2 P-008809 Thru P-008847 + +File folder entitled "[Victim name]/Jane Doe #6" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation + +Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit + +Box #2 P-008848 Thru P-008862 File folder entitled "[Victim name]/Jane Doe #7" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation + +Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit + +Box #2 P-008863 Thru P-008890 + +File folder entitled "[Victim name]/Jane Doe #8" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation + +Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit + +Box #2 P-008891 Thru P-009103 File folder entitled "Certified Copy of State Case" containing certified copy of Epstein state criminal cases and change of plea transcript [not being withheld as privileged — copy provided to opposing counsel] + +Box #2 P-009104 Thru P-009111 + +File folder entitled "Meeting Timeline" containing typed notes summarizing meetings with opposing counsel prepared at request of R. Alexander Acosta, with handwritten correction and typed guideline estimate + +Work product Deliberative process + +Box #2 P-009112 Thru P-009113 11/26/2008 Email from Ro Black to + +and m Jeffrey Epstein + +(work release) [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stab 11th Circuit + +Box #2 P-009114 Thru P-009115 7/3/2008 Email from to + +at PBSO re Epstein work release with + +attachment [not being withheld as privileged produced too sin counsel + +Box #2 P-009116 Thru P-009125 + +12/6/2007 Letter from to Jay P. Lefkowitz re Jeffrey Epstein (victim notification) [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11th Circuit]) + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 14 of 23 + +Bates Range Description Privilege(s) Asserted + +Box #2 P-009126 Thru P-009134 + +File folder entitled "[Victim name]/Jane Doe #9" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation + +Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit + +Box #2 P-009135 Thru P-009141 + +File folder entitled "[Victim name]/Jane Doe #13" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation + +Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit + +Box #2 P-009141A Thru P-009141C + +File folder entitled "[Victim name]/Jane Doe #12" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation + +Work product . + +6(e) Investigative privilege Contains information subject to privacy rights of victims who are not arties to this suit + +Box #2 P-009142 Thru P-009152 File folder entitled " ' Work product + +6(e) Investigative privilege Contains information subject to privacy rights of victims who are not ies to this suit + +containing meta-analysis of all phone, travel, and grand jury data related to that individual for indictment preparation + +Box #2 P-009153 Thru P-009156 File folder entitled ' Work product + +6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit + +containing meta-analysis of all phone, travel, and grand jury data related to that individual for indictment preparation + +Box #2 P-009157 Thru P-009208 File folder entitled "[Victim name]/Jane Doe #1" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation + +Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit + +Box #2 P-009209 Thru P-009213 File folder entitled "[Victim name]/Jane Doe #2" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation + +Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 15 of 23 + +Bates Range Description Privilege(s) Asserted + +Box #2 P-009214 Thru P-009271 + +File folder entitled "[Victim name]/Jane Doe #3" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation + +Work product 6(e) Investigative privilege Contains information subject to privacy rights of victims who are not parties to this suit + +Box #2 P-009272 Thru P-009354 File folder entitled "Purpose of Travel faces" containing attorney research and handwritten notes + +Work product + +Box #2 P-009355 Thru P-009403 File folder entitled "Interstate Commerce Cases" containing attorney research and handwritten notes + +Work product + +Box #2 P-009404 Thru P-009536 File folder entitled "Attorney Conflict Research" containing attorney research and handwritten notes + +Work product + +Box #2 P-009537 Thru P-009574 + +File folder entitled "Mann Act/Travel to Have Sex w/Minor containing attorney research and handwritten notes + +Work product + +Box #2 P-009575 Thru P-009603 File folder entitled "Travel Act" containing attorney research and handwritten notes + +Work Product + +Box #2 P-009604 Thru P-009711 + +File folder entitled "Florida Prostitution/Lewdness Statutes" containing attorney research and handwritten notes + +Work Product + +Box #2 P-009712 Thru P-009819 Booklet entitled "Attorney General Guidelines for Victim and Witness Assistance" [not being withheld as privileged — produced to opposing counsel) + +Box #2 P-009820 Thru P-009965 File folder entitled "Corporate Liability Itsrch" containing attorney research and handwritten notes + +Work Product + +Box #2 P-009966 Tim P-010096 + +File folder entitled "Research re Knowledge of Age Unnecessary" containing attorney research and handwritten notes and copy of grand jury subpoena + +Work Product 6(e) + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 16 of 23 + +Bates Range Description Privilege(s) Asserted + +Box #2 P-010097 Thru P-010276 + +File folder entitled "Money Laundering" containing attorney research and handwritten notes + +Work Product + +Box #2 P-010277 Thru P-010394 + +File folder entitled "1960 & Aiding/Abetting" containing attorney research and handwritten notes + +Work Product + +Box #2 P-010395 Thu P-010488 + +File folder entitled "18 USC § 2255 Cases" containing attorney research and handwritten notes + +Work Product + +Box #2 P-010489 Thru P-010509 + +File folder entitled "Research re Overt Acts & Witness Testimony" containing attorney research and handwritten notes + +Work Product + +Box #2 P-010510 Thru P-010525 + +File folder entitled "Extradition" containing attorney research and handwritten notes + +Work Product + +Box #2 P-010526 Thru P-010641 + +File folder entitled "Rsrch re Crime Victims Rights" containing attorney research, handwritten notes, draft victim notification letter, and draft correspondence to Jay Lefkowitz (Also contains a November 28 2007 letter from Kenneth Starr to , and a November 29, 2007 letter from Jay Lefkowitz to R. Alexander Acosta (P-010528 thru P-010530 and P410556 thru P-010559). Pursuant to the Court's Order, these will be produced to opposing counsel upon lift of stay by 11th Circuit) + +Work Product Deliberative Process + +Box #2 P-010642 Thru P-01650 + +File folder entitled "immunity" containing attorney research on granting immunity to witnesses + +Work Product + +Box #2 P-010651 Thu P410659 + +File folder entitled "Research re G.J. Transcript" containing attorney research and draft pleadings re compelling production of grand jury transcript with subpoena + +Work Product 6(e) Deliberative process + +Box #2 P-010660 Thru P-010757 + +File folder entitled "Research re O1 Transcript" containing grand jury subpoena, 6(e) letters, attorney research and correspondence related to subpoena + +Work Product 6(e) + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 17 of 23 + +Bates Range Description Privilege(s) Asserted + +Box #2 P-010758 Thru P-010793 + +File folder entitled "Original Proposed Ind." containing draft indictment + +Work Product 6(e) Deliberative process + +Box #2 P-010794 Thru P-010829 File folder entitled "Epstein" containing sample indictments and attorney research re potential charges with attorney notes + +Work Product + +Box #2 P-010830 Thru P-010853 File folder entitled "1591 & Money Laundering" containing attorney research and handwritten notes + +Work Product + +Box #2 P-010854 Thru P-010876 File folder entitled "18 USC 2425" containing attorney research and handwritten notes + +Work Product + +Box #2 P-010877 Thru P-010920 + +File folder entitled "Knowledge of Age" containing attorney research and handwritten notes + +Work Product + +Box #2 P-010921 Thru P-011049 File folder entitled "2423(b) Constitutionality and Purpose of Travel" containing attorney research and handwritten notes + +Work Product + +Box #2 P-011050 Thru P-011212 + +File folder entitled "Mistake not a Defense" containing attorney research and handwritten notes + +Work Product + +Box #2 P-011213 Thru P-011237 File folder entitled "Research re `Pandering'" containing attorney research and handwritten notes + +Work Product + +Box #2 P-011238 Thm P-011319 + +File folder entitled "Research re Grand Jury Instructions" containing attorney research and handwritten notes + +Work Product 6(e) + +Box #2 P-011320 Thru P-011361 + +File folder entitled "Telephone = Facility of Commerce" containing attorney research and handwritten notes + +Work Product + +Box #2 P-011362 Thru P-011374 + +File folder entitled "Def of Prostitution" containing attorney research and handwritten notes + +Work Product + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 18 of 23 + +Bates Range Description Privilege(s) Asserted + +Box #2 P-011375 Thru P-011456 File folder entitled "Relevant Florida Statutes" containing attorney research and handwritten notes + +Work Product + +Box #2 P-011457 Thru P-011626 + +File folder entitled "Unit of Prosecution Research" containing attorney research and handwritten notes + +Work Product + +Box #3 P-011627 Thru P-011662 + +File folder entitled "Attorney Notes" containing attorney handwritten and typed notes + +Work Product + +Box #3 P-011663 Thru P-011698 and P-012189 thru P-4112361 (gap was scanning error) + +File folder entitled "Drafts" containing draft indictments with attorney handwritten notes, draft internal memoranda, relevant witness interview reports and grand jury material and attorney handwritten notes + +6(e) Work Product Deliberative Process Investigative Privilege Contains information subject to privacy rights of victims who are not parties to this + +Box #3 P-011699 Thru P-011777 + +File folder entitled "6/9/09 Signed Indictment" containing signed indictment package dated 6/9/2009 with corrections + +6(e) Work product Deliberative process + +Box #3 P-011778 'Mu P-011788 + +File folder entitled "6/12/09 Victim Notif. Log" containing chart with victim contact information and attorney notes regarding dates and type of contacts + +Work product + +Box #3 P-011789 Thru P-011879 File folder entitled "Breach Memo" containing memorandum analyzing breach of Non-Prosecution Agreement with attachments + +Work product Deliberative process + +Box #3 P-011880 ThIll P-011922 File folder entitled "Overt Act Lists" containing handwritten notes cross-checking all overt acts alleged in draft indictment by victim and typed overt act summary charts for indictment preparation + +Work product Attorney-client privilege Deliberative process 6(e) + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 19 of 23 + +Bates Range Description Privilege(s) Asserted + +Box #3 P-011923 Thru P-011966 Folder entitled "Responses to Arguments from JE + +Counsel" containing: + +Work product Deliberative process 6(e) Attorney-Client Privilege + +■ **7/13/2007 letter from** + +**to with handwritten** + +**attorney (Lourie) notes;** + +■ **6/2 /2 I from Gerald Lefcourt** + +**Matt Menchal , and with** + +**handwritten attorney •** ■ **6/25/2007 email fro to** + +**Matt Menchel and** + +**entitled "Thoughts on Lefcourt's letter" Handwritten and typed attorney I ) notes regarding main themes raised by Epstein counsel** + +**Box #3 P-011967 Thru P-012016** + +**Composition book entitled "Operation Leap Year" containing attorney handwritten notes regarding investigation and case strategy** + +**Work product Investigative privilege 6(e) Contains information subject to privacy rights of victims who are not parties to this litigation** + +**Box #3 P-012017 Thru P-012055** + +**Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Incorporated** + +**Memorandum of Law** + +**6(e)** + +**Box #3 P-012056 Thru P-012088** **Affidavit of Roy Black, F-sq. in Support of Motion of Jeffrey Epstein to Intervene and to** + +**Quash Grand Jury Subpoenas** + +**6(e)** + +**Box #3 P-012089 Thru P-012129** + +**United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury** + +**Subpoenas and Cross-Motion to Compel** + +**6(e)** + +**Box #3 P-012130 Thru P-012150** **Declaration o i 6(e)** + +**Box #3 P-012151 Thru P-012167** **Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash** + +**Subpoenas** + +**6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation** + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 20 of 23 + +Bates Range Descri i tion Privilege(s) Asserted + +Box #3 P-012168 Thru P-012170 + +Ex Parte Declaration Number Two in Support of United States' Response to Motion to Quash + +Subpoenas + +6(e) Investigative Privilege + +Box #3 P-012171 Thru P-012173 Supplement to Ex Parte Declaration Number One in Support of United States' Response to Motion + +to Quash Subpoenas + +6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation + +Box #3 P-012174 Thru P-012176 + +Draft of September 2009 letter from + +to Roy Black regarding breach of Non + +Prosecution Agreement with handwritten attorney + +MEM notes + +Work Product Attorney-Client Privilege Deliberative Process + +Box #3 P-012177 Thru P-012178 Undated handwritten attorney I notes Work Product + +Attorney-Client Privilege Deliberative Process + +regarding negotiations and allegations + +Box #3 P-012179 Thru P-012188 File Folder entitled "FBI G.J. Log" containing copy of FBI jury subpoena log with + +attorney handwritten notes + +6(e) Work Product Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation + +Box #3 P-012362 Thru P-012451 + +File folder entitled "Key Documents" containing correspondence between AUSA and case agent regarding indictment prep questions, victim identification information, corrections to draft indictment, indictment preparation timeline, key grand jury material + +6(e) Work Product Attorney-Client privilege Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation + +Box #3 P-012451 That P-012452 + +File folder entitled "Victim List" containing list of victims with dates of birth and age information + +. + +Work Product Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 21 of 23 + +Bates Range Description Privilege(s) Asserted + +Box #3 P-012453 Thru P-012623 Complete indictment package marked "Originals 12/12/07" + +- + +Work-product Deliberative process 6(e) Also contains documents subject to investigative privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation + +Box #3 P-012624 Thru P-012653 + +Folder entitled "(Victims) Additional 302's" containing reports of interviews conducted in June 2007, October 2007, and March 2008. + +Investigative Privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation + +Box #3 P-012654 Thru P-012864 + +3-ring binder entitled "Child Molesters: A Behavioral Analysis" with attorney mit handwritten notes + +Work-product + +Box #3 P-012865 Thru P-013226 + +Indictment preparation binder containing: witness/victim list with identifying information, sexual activity sumisiephone call summary chart, attorney handwritten notes, + +3iiirons of state investigative file, attorney + +typed notes, relevant pieces of grand + +jury materials, telephone records/flight records analysis charts, victim/witness photographs, DAVID records, NCICs, and related materials for persons identified as Jane Does #9, 10, 11, 12, 13, 14 + +Work Product Deliberative Process 6(e) Also contains documents subject to investigative privilege Also contains documents subject to privacy rights of victims who are not parties to this litigation + +Box #3 P-013227 April 23, 2008 Memo from to Privacy Act + +Office of Professional Responsibility re Self Reporting, Corrected Version of the previously + +submitted April 21, 2008 Lett + +Box #3 P-013226 Thm P-013230 April 21, 2008 Letter from to Privacy Act + +Office of Professional Responsibility re Self + +Reporting + +Box #3 P-013231 Thru P-013239 April 22, 2008 Letter fro to Privacy Act + +Office of Professional Responsibility re Self- + +Report of Allegation of Conflict of Interest + +Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 22 of 23 + +Bates Range Descriptio Privilege(s) Asserted + +Box #3 P-013240 Thru P-013247 April 21, 2008 Letter from to Privacy Act + +Office of Professional Responsibility re Self + +Reporting with attachments + +Box #3 PM 13248 Thru P-013251 + +Emails between , Assistant Attorney-Client Privilege + +General Counsel, Executive Office for United States Attorneys, and First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated + +August 24 and August 29 2011 + +Box #3 P-013252 Thru P-013253 Emails between , Assistant Attorney-Client Privilege + +General Counsel, Executive 1 r nited States Attorneys, and First Assistant U.S. Attorney, Southern District of Florida, regarding Recusal matter, dated July 28, + +August 3, and August 24 2011 + +Box #3 P-013254 Thru P-013257 Emails between , Assistant Attorney-Client Privilege + +General Counsel, Executive Office for United States Attorneys, and First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated + +August 24 and August 29 2011 + +Box #3 P-013258 Thru P-013259 + +Emails between =, Assistant Attorney-Client Privilege + +General Counsel, Ex c ' c r nited States Attorneys, and First Assistant U.S. Attorney, Southern District of Florida, regarding Formal Notice of Office-wide Recusal of Southern District of Florida dated July + +28 and Au + +Box #3 P-013260 Thru P-013262 Email fronl , Assistant General Counsel, Executive Office for United States Attorneys, to Wifredo Ferrer (U.S. Attorney, D LRobert O'Neill (U.S. Attorney, MDFL), + +(FAUSA, SDFL), we + +(FAUSA, MDFL) regarding Formal + +Notice of Office-wide Recusal of Southern District of Florida dated Au 24 2011. CC's AG) + +SAEO), + +(USAEO) (USAEO) + +Attorney-Client Privilege + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 1 of 51 + +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO.:08-CV-80736-KAM + +JANE DOE 1 and JANE DOE 2, + +Petitioners, + +vs. + +UNITED STATES OF AMERICA, + +Respondent. + +OPINION AND ORDER + +This cause is before the Court on various discovery related matters. In response to + +Petitioners' first requests for production, the respondent Government asserted various privileges + +in three privilege logs and submitted nearly 15,000 pages of documents for in camera inspection. + +(DEs 212-1, 216-1, 329-1). Petitioners object to every privilege asserted. (DE 265). + +Intervenor Jeffrey Epstein supports the Government's assertion that certain grand jury + +materials should remain secret, and he moves to prevent disclosure of those materials. (DE 263). + +Petitioners filed a response. (DE 271). + +Finally, the Government objects to the relevancy of several of Petitioners' requests for + +production. (DE 260). Petitioners responded (DE 266) and filed a supporting supplement (DEs + +267, 268). + +The Court has conducted its in camera review of materials submitted, has carefully + +considered the materials and the parties' submissions, and is fully advised in the premises. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 2 of 51 + +I. Background + +This is a case against the United States for allegedly violating the Crime Victims' Rights + +Act (CVRA), 18 U.S.C. § 3771, by failing to involve Petitioners (and other similarly situated + +victims of Intervenor Epstein) in the process that ultimately led to a federal non-prosecution + +agreement between the Government and Epstein. (DE I). The parties and intervenors debate the + +discoverability of documents that show exactly what led to the non-prosecution agreement. + +In March 2011, Petitioners moved "to allow use of correspondence between the U.S. + +Attorney's Office and counsel for Epstein" to prove their CVRA case. (DE 51 at 1). Petitioners + +argued that the correspondence was relevant as it "shows that the U.S. Attorney's Office was + +aware of its statutory obligation to inform the victims of the non-prosecution agreement," and + +that they should be allowed to use it "as it sheds important light on the events surrounding the + +non-prosecution agreement, which are central to the victims' arguments that the U.S. Attorney's + +Office violated their rights." (Id. at 5, 6). The Court granted Petitioners' request and ordered the + +Government to "(p)roduce responsive documents in response to all outstanding requests for + +production of documents encompassing any documentary material exchanged by or between the + +federal government and persons or entities outside the federal government (including without + +limitation all correspondence generated by or between the federal government and Epstein's + +attorneys)" (DE 190 at 2). The Court also ordered the Government to produce all responsive + +documents "other than communications generated between the federal government and outside + +persons or entities." (K.). If the Government claimed privilege over any of these documents, the + +Court ordered the Government to (1) file "a privilege log clearly identifying each document(' by + +author(s), addressee(s), recipients(s), date, and general subject matter and such other identifying + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 3 of 51 + +data," and (2) to "submit all responsive documents withheld on claim of privilege to the court for + +in camera inspection." (Id.). + +The Government produced 1,357 pages of documents to Petitioners, filed three privilege + +logs, and submitted nearly 15,000 pages to the Court for in camera inspection. (See DE 257 at + +2). The Government asserts that the documents submitted for in camera inspection are privileged + +for reasons such as the privacy rights of non-party victims, grand jury secrecy under Federal Rule + +of Criminal Procedure 6(e),' and the attorney-client, work product, deliberative process, and + +investigative privileges. (DEs 212-1; 216-1, 329-1). Moreover, with the Court's leave (DE 257 + +at 4), the Government objects to the relevancy of several of Petitioners' requests for production + +(DE 260). + +H. Discussion + +District courts have "broad discretion in shaping the scope of discovery under + +Fed.R.Civ.P. 26(b)." Williams v. City of Dothan, 745 F.2d 1406, 1415 (11th Cir. 1984). The + +Court will first address matters related to whether a privilege protects the submitted documents + +from discovery and then turn to whether any otherwise non-privileged documents are relevant to + +Petitioners' CVRA case. Specific rulings as to the submitted documents are found in the Table + +appended to this Opinion and Order. + +A. Privilege Assertions + +1. Challenge to the Sufficiency of Government's Privilege Assertions + +Petitioners raise several general objections to the Government's privilege logs. They + +In a previous ruling, the Court noted that Plaintiffs formally requested the release of + +grand jury materials, but the Court reserved "ruling as to whether the materials in question are + +protected from disclosure by Federal Rule of Criminal Procedure 6(e)." (DE 257 at 3). + +Case 9:08-cv-80736-KAM Document 330 Entered on FLED Docket 07/06/2015 Page 4 of 51 + +argue that the Government's logs are inadequate because they do not "clearly identify" the + +documents as ordered by this Court. (DE 265 at 2; DE 190 at 2). The Court has reviewed the + +Government's privilege logs and the documents that they describe, and the Court finds that the + +logs—describing nearly 15,000 pages of documents— are adequate to facilitate a meaningful in + +camera inspection and assessment of the asserted privileges. To the extent inadequacies may be + +present, the Court finds that judicial resources would not be best spent by requiring the + +Government to submit a revised, more detailed log. See N.L.R.B. v. Jackson Hosp. Corp. 257 + +F.R.D. 302, 307 (D.D.C. 2009) (court may remedy inadequate privilege log by in + +camera inspection of described documents or permitting party another chance to submit a more + +detailed log). + +Petitioners also argue that the Government has failed to provide the factual underpinnings + +necessary to hold that certain privileges apply, specifically the deliberative process privilege, + +investigative privilege, work product privilege, and attorney—client privilege. Discussed in more + +detail below, the Court finds it unnecessary to consider whether the deliberative process and + +investigative privilege apply in this case as other, stronger, privileges are at play, or, as discussed + +further below, many of the documents over which the deliberative process and investigative + +privileges are asserted are irrelevant to this proceeding. Regarding the work product and + +attorney—client privileges, and the Court has considered the materials submitted and the + +Government's arguments, and finds that the Government has submitted sufficient evidence to + +evaluate its claims of privilege. (See DE 238-1) (discussing documents prepared by the United + +States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O-Quinn, + +253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 5 of 51 + +pleading to decide application of work product privilege). The Court will therefore evaluate each + +claim of privilege as it relates to the documents submitted. + +2. Grand Jury Secrecy + +The Government asserts that many of the documents identified in its logs are protected by + +Federal Rule of Criminal Procedure 6(e), which governs the secrecy of grand jury proceedings. + +(See DE 212-I; DE 216-1 at 4, 6). These documents include subpoenas issued and documents + +received and prepared during the course of grand jury investigations into whether Epstein + +committed indictable federal offenses. (DE 212-1 at 1). Petitioners argue that the Court can (and + +should) authorize disclosure in this case. (DE 265 at 17). + +"It has long been a policy of the law that grand jury proceedings be kept secret . . . . The + +English rule of grand jury secrecy has been incorporated into our federal common law and + +remains an integral part of our criminal justice system." United States v. Aisenberg 358 F.3d + +1327, 1346 (11th Cir. 2004) (internal quotation marks omitted). "Rule 6(e) of the Federal Rules + +of Criminal Procedure codifies this secrecy principle and prohibits the disclosure of grand jury + +material except in the limited circumstances provided for in Rule 6(e)(3)." Id. One such + +exception is Rule (6)(e)(3)(E)(i), which permits a court to authorize disclosure "preliminary to or + +in connection with a judicial proceeding." Fed. R. Crim. P. 6(e)(3)(E)(i). Additionally, a court + +has inherent authority to disclose grand jury materials beyond the literal wording of Rule 6(e)(3) + +in "exceptional circumstances." Aisenberg, 358 F.3d at 1347. "The district court has + +`substantial discretion' in determining whether grand jury materials should be released." Id. at + +1349 (quoting Douglas Oil Co. v. Petrol Stops N.W., 441 U.S. 211, 223 (1979)). + +Whether proceeding under Rule 6(e)(3) or the court's inherent authority, there are well + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 6 of 51 + +settled guidelines for determining when grand jury secrecy may be broken. Id. at 1347. + +Specifically, the parties seeking disclosure must show: + +(1) "that the material they seek is needed to avoid a possible + +injustice in another judicial proceeding"; + +(2) "that the need for disclosure is greater than the need for + +continued secrecy"; and + +(3) "that their request is structured to cover only material so + +needed." + +Id. at 1348 (citing Douglas Oil Co.,N.W., 441 U.S. 211, 222 (1979)). These demanding + +standards apply even after the grand jury has concluded its operations. Id. The burden of + +demonstrating that the need for disclosure outweighs the need for secrecy rests on the party + +seeking disclosure. Id. "In order to carry this burden, the party seeking disclosure of grand jury + +material must show a compelling and particularized need for disclosure." Id. That is, "the + +private party must show circumstances had created certain difficulties peculiar to this case, which + +could be alleviated by access to specific grand jury materials, without doing disproportionate + +harm to the salutary purpose of secrecy embodied in the grand jury process." Id. at 1348-49 + +(internal quotation marks omitted) (emphasis in original). + +Accordingly, the grand jury proceedings at issue are "presumptively secret," see In re + +Subpoena to Testify, 864 F.2d 1559, 1562 (11th Cir. 1989), and Petitioners have the heavy + +burden of overcoming this presumption! Petitioners argue that they have met their burden in + +their response to Epstein's motion to uphold grand jury secrecy. (DE 271 at 3). + +2 Because the burden lies with Petitioners, Petitioners' argument that disclosure is appropriate because the Government "has not attempted to defend its invocation of grand jury + +secrecy" is of no moment. (DE 278 at 10). + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 7 of 51 + +Regarding whether (1) grand jury materials are "needed to avoid a possible injustice" in + +this case, Petitioners argue that "an injustice may occur" if the materials are not disclosed to + +them. (DE 217 at 4). They argue that the possibility for injustice exists because this Court has + +already recognized that aspects of this case "must be considered in the historical factual context + +of the entire interface between Epstein, the relevant prosecutorial authorities and the federal + +offense victims—including an assessment of the allegation of a deliberate conspiracy between + +Epstein and the federal prosecutors to keep the victims in the dark on the pendency of + +negotiations between Epstein and the federal authorities." (ILI.) (quoting the Court's Order at DE + +189 at 12 n.6). They also argue that injustice may result without the grand jury materials because + +the "critical starting point for the victims' case" is proof that the Government had an "extremely + +strong case against Epstein." (lik). + +The Court concludes that Petitioners have not met their heavy burden of demonstrating a + +compelling and particularized need for the disclosure of grand jury materials pertaining to the + +investigation of Epstein. Materials that the Government presented in secrecy to a grand jury + +relative to a case against Epstein are not part of the "interface" that occurred between Epstein, + +prosecuting authorities, and the victims. As the Court has already explained, the harm in this + +case did not arise out of the Government's failure to secure a grand jury indictment against + +Epstein. (DE 189 at 10) ("The victim's CVRA injury is not the government's failure to + +prosecute Epstein federally—an end within the sole control of the government."). Rather, the + +harm in this case arose from the Government's alleged failure to confer adequately with + +Petitioners before deciding to abandon a federal case against Epstein. (t1.). The Court has + +reviewed the portions of the submitted documents to which grand jury secrecy is invoked, and it + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 8 of 51 + +finds that none of the grand jury materials produced has a bearing on the Government's alleged + +failure to confer with Petitioners before electing to forego a federal prosecution. + +The Court also concludes that Petitioner's asserted need to prove that the Government + +had an "extremely strong case against Epstein" does not justify the disclosure of secret grand jury + +materials. Petitioners seek to use the grand jury materials as the means to an improper end—a + +judicial determination that the Government made an inexplicably poor decision when it decided + +not to prosecute Epstein. + +"(T]he Government retains `broad discretion' as to whom to prosecute." Wayte v. United + +States, 470 U.S. 598, 607 (1985). The CVRA incorporates this principle, providing that + +Irdothing in this chapter shall be construed to impair the prosecutorial discretion" of federal + +prosecutors. 18 U.S.C. § 3771(d)(6). Courts tread lightly where prosecutorial discretion is + +concerned because "the decision to prosecute is particularly ill-suited to judicial review." Wayte, + +470 U.S. at 607; see also 35 Geo. L.J. Ann. Rev. Crim. Proc. 203, 203 n.648 (2006). "Such + +factors as the strength of the case, the prosecution's general deterrence value, the Government's + +enforcement priorities, and the case's relationship to the Government's overall enforcement plan + +are not readily susceptible to the kind of analysis the courts are competent to undertake." Wayte, + +470 U.S. at 607 (emphasis added); see also Town of Newton v. Rumery, 480 U.S. 386, 396 + +(1987) (courts normally must defer to prosecutorial decisions about whom to prosecute because, + +"[lin addition to assessing the strength and importance of a case, prosecutors also must consider + +other tangible and intangible factors, such as government enforcement priorities.") (emphasis + +added). + +Petitioners asserted strategy of demonstrating that the Government had an improper + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 9 of 51 + +motive to hide its "extremely strong" case asks the Court to decide (or assume) that the + +Government did in fact have an "extremely strong" case against Epstein. As Petitioners point + +out, the Government has not admitted that it believed it had a "strong case" for prosecution. (DE + +266 at 8)? In light of this refusal to admit the strength of the case, Petitioners seek grand jury + +materials to present to the Court the case for prosecuting Epstein. (14, at 9). Basically, + +Petitioners ask the Court to interject itself in place of the Government and adjudicate whether the + +Government erred, and thus had a motive for hiding its error, when it decided not to prosecute + +Epstein. As the Supreme Court has articulated, "courts are [not] competent to undertake" the + +kind of analysis necessary to assess the "strength of the case" for or against any particular + +prosecution. Wayte, 470 U.S. at 607; see alsoUnited States v. Armstrong, 517 U.S. 456, 465 + +(1996) (Judicial deference to prosecutors' decisions "rests in part on an assessment of the relative + +competence of prosecutors and courts."). Nor is the Court competent to undertake an analysis of + +how strong the Government perceived its case against Epstein at the time it decided not to + +prosecute. Stated plainly, whether the Government had a "strong" case against Epstein was for + +the Government to decide in its sole discretion; the Court will not foray into matters related to + +assessing the strength of the Government's case against Epstein. + +3 In response to Petitioners Request for Admission regarding whether the Government had a case for "federal prosecution against Epstein for many federal sex offenses," (DE 266 at 8), + +the Government responded: + +The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses. Except as otherwise admitted above, the government denies Request No. I. + +(DE 213-1 at 1). + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 10 of 51 + +Accordingly, because the Court will not—and cannot—endeavor to assess the strength of + +the Government's case against Epstein at the time it decided to enter into the non-prosecution + +agreement, the Court concludes that Petitioners have not shown that they will suffer an injustice + +in this case if they are denied access to materials that the Government presented to grand juries + +during their investigation into whether Epstein committed federal crimes. Likewise, Petitioners + +have not shown that their need for these materials is compelling or particularized to their asserted + +interests under the CVRA. Therefore, the Court will deny Petitioners access to the materials over + +which grand jury secrecy applies under Fed. R. Crim. P. 6(e). + +3. Work Product Doctrine + +The Government asserts that many of the documents submitted are protected by the + +attorney work-product privilege. (DE 212-1 at 1-21; DE 216-1 at 1-14). These documents + +include draft correspondences and indictments, as well as attorney research and handwritten + +notes. (See, e.g. DE 212-1 at 2, 17). Petitioners argue that the work-product privilege is + +unavailable for a number of reasons. (DE 265 at 6, 8, 14-16). + +The work-product doctrine traces its roots to the Supreme Court's recognition that "it is + +essential that a lawyer work with a certain degree of privacy, free from unnecessary intrusion by + +opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The + +privilege is codified at Federal Rule of Civil Procedure 26(b)(3): + +Ordinarily, a party may not discover documents and tangible things that are prepared in anticipation of litigation or for trial by or for another party or its representative (including the other party's attorney, consultant, surety, indemnitor, insurer, or agent). But, subject to Rule 26(6)(4), those materials may be discovered if: + +(i) they are otherwise discoverable under Rule 26(b)(1); and + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 11 of 51 + +(ii) the party shows that it has substantial need for the materials to prepare its case and cannot, without undue hardship, obtain their + +substantial equivalent by other means. + +Fed. R. Civ. P. 26(b)(3)(A). Although fact-based work product may be disclosed on a showing + +of "substantial need," the court must avoid "disclosure of the mental impressions, conclusions, + +opinions, or legal theories of a party's attorney or other representative concerning the litigation." + +Id. 26(b)(3)(B). Such "opinion work product enjoys a nearly absolute immunity and can be + +discovered only in very rare and extraordinary circumstances." Cox v. Adm'r U.S. Steel & + +Carnegie, 17 F.3d 1386, 1422 (11th Cir. 1994). In the context of government attorneys, the + +"work-product privilege applies to . . . discussions between prosecutors and investigating agents, + +both state and federal." United States v. Zingsheim, 384 F.3d 867, 872 (7th Cir. 2004) (citing + +FTC v. Grolier Inc., 462 U.S. 19 (1983)). + +The work-product privilege extends only to documents that an attorney prepares "in + +anticipation of litigation." Fed. R. Civ. P. 26(a)(3)(A). Petitioners argue that the work-product + +privilege does not apply to the submitted documents because they were not prepared "in + +anticipation of [the instant] CVRA litigation." (DE 265 at 7). Retreating somewhat from this + +initial assertion, Petitioners argue that "[m]any of the documents at issue here were not prepared + +in anticipation of litigation, and certainly not in anticipation of the litigation about the Crime + +Victims' Rights Act." (EL). + +Although "[s]ome older cases took the position that the work-product immunity applied + +only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. + +Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that + +documents produced in anticipation of litigating one case remain protected in a subsequent case fl + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 12 of 51 + +if they were created by or for a party to the subsequent litigation," Underwriters Ins. Co. v. + +Atlanta Gas Light Co., 248 F.R.D. 663, 668 (N.D. Ga. 2008). These cases rely on the Supreme + +Court's dicta in Federal Trade Communication v. Grolier, Inc., that "the literal language of [Rule + +26(b)(3)] protects materials prepared for ay litigation or trial as long as they were prepared by or + +for a party to the subsequent litigation." 462 U.S. 19, 25 (1983) (emphasis in original); see also 8 + +Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 519 n.47 (3d ed. 2010) (collecting + +cases). Similarly, the work-product doctrine applies regardless of whether litigation actually + +ensued, so long as it can be fairly said that the document was prepared or obtained because of the + +prospect of litigation. See Kent Corp. v. N.L.R.B., 530 F.2d 612, 623 (5th Cir. 1976) (holding + +that agency documents produced when deciding "to prosecute or not to prosecute" were protected + +work product, regardless of "whether litigation actually ensured"). + +After its in camera review, the Court finds that the majority of work-product documents + +identified by the Government were prepared or obtained by the Government because of the + +reasonable prospect of litigating a criminal case against Epstein. (DE 212-1 at 1-21; DE 216-1 at + +1-12; DE 329-I at 1-18).4 This CVRA litigation and the underlying criminal investigation are + +integrally related, and the work-product doctrine protects from discovery materials prepared in + +anticipation of either in the instant litigation. + +° The Government asserts that the work-product doctrine applies to documents prepared + +by attorneys in the Department of Justice's Office of Professional Responsibility (OPR) in + +response to Petitioners' counsel's request for an investigation into the Government's handling of + +the Epstein case. (DE 216-1 at 12-14). Although these documents were prepared by Government attorneys, the Government has not demonstrated that they were prepared "in anticipation of litigation or for trial" so as to be protected work product. Fed. R. Civ. P. + +26(b)(3)(A). As discussed in the next section, however, the Court has thoroughly reviewed these documents and finds that they are not relevant, or likely to lead to materials relevant to the instant + +CVRA litigation. (See infra Sect. B.3.) + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 13 of 51 + +Petitioners argue that the work-product doctrine "does not apply" in this case for two + +additional reasons. First, they argue that the doctrine does not apply in a case brought by crime + +victims against the federal prosecutors who were bound to protect their rights under the CVRA. + +(DE 265 at 13). Second, they argue that the doctrine does not apply because the conduct of those + +prosecutors is a "central issue" in this case. (a. at 15). The Courts finds these arguments + +unavailing. + +First, Petitioners argue that the "work product doctrine does not apply to claims advanced + +by crime victims that federal prosecutors have violated their public responsibilities under the + +Crime Victims' Rights Act." 0,1. at 14). Because the CVRA compels prosecutors to make their + +"best efforts" to notify victims of their rights, Petitioners argue that the Government cannot + +withhold documents that "might allow them to protect those very rights." (lcl at 15). By way of + +illustration, Petitioners offer the case of In re Grand Jury Subpoena Duces Tecum, where the + +Eighth Circuit broadly stated that "the general duty of public service calls upon government + +employees and agencies to favor disclosure over concealment." 112 F.3d 910, 920 (8th Cir. + +1997). + +A closer inspection of In re Grand Jury Subpoena reveals that it does not stand for the + +categorical rule that the work product doctrine is inapplicable in cases against public prosecutors. + +The statement on which Petitioners rely was made in the context of determining whether to + +recognize a previously undefined privilege: "whether an entity of the federal government may use + +the attorney-client privilege to avoid complying with a subpoena by a federal grand jury." Id. at + +915 (emphasis added); see also id. at 921 ("We believe the strong public interest in honest + +government and in exposing wrongdoing by public officials would be ill-served by recognition of + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 14 of 51 + +a governmental attorney-client privilege applicable in criminal proceedings inquiring into the + +actions of public officials."). The Eighth Circuit did not purport to espouse a broad-ranging rule + +that defeated existing, well-defined privileges such as the work product doctrine. This is + +important, as the Supreme Court has recognized that the "work-product doctrine is distinct from + +and broader than the attorney-client privilege." United States v. Nobles, 422 U.S. 225, 238 + +(1975) (citing Hickman, 329 U.S. at 508). In fact, the Eighth Circuit went on to consider the + +application of the work product doctrine and concluded that it did not apply because the materials + +in question were not prepared in "anticipation of litigation." 112 F.3d at 924-25. It did not find + +the work product doctrine wholly inapplicable based on a goal of public disclosure. + +In light of the well-established bounds of the work product doctrine—which grants public + +prosecutors "near absolute immunity" over their mental impressions in subsequent civil + +litigation—the Court finds that the CVRA's mandate that prosecutors make their "best efforts" to + +accord crime victims their rights does not create a "very rare and extraordinary circumstance" in + +which discovery of protected work product would be allowed. See Cox, 17 F.3d at 1422. + +Second, Petitioners argue that the work product doctrine does not apply because the + +conduct of the Government's attorneys is a "central issue" in this case. (a. at 15). Some lower + +courts have held that disclosure of opinion work product is "justified principally where the + +material is directly at issue, particularly if the lawyer or law firm is a party to the litigation." 8 + +Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2026, p. 567 & n.19 (3d ed. 2010) (collecting + +cases). To satisfy this showing, however, the party seeking disclosure of opinion work product + +must make "a far stronger showing of necessity and unavailability by other means" than is + +needed to justify discovery of fact-based work product. Id. (quoting Upjohn Co. v. United States + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 15 of 51 + +449 U.S. 383, 402 (1981)); see also In re Doe, 662 F.2d 1073, 1080 (4th Cir. 1981) (even under + +crime-fraud exception to work product doctrine, party "must show a greater need for the opinion + +work product material than was necessary in order to obtain the fact work product material"). + +The Court finds that Petitioners have not made the strong showing of necessity and + +unavailability required to disclose the mental impressions of counsel that might be at issue in this + +case. (See DE 265 at 16). Discovery of opinion work product is most often granted in bad-faith + +settlement cases, where "mental impressions [of the underlying counsel] are the pivotal issue in + +the current litigation." Holmgren v. State Farm Mut. Auto. Ins. Co., 976 F.2d 573, 577 (9th Cir. + +1992). Other than by analogizing to bad-faith actions, Petitioners have not demonstrated how + +delving in to the "mental impressions" of Government attorneys is pivotal to proving their + +allegations that the Government failed to accord them their rights under the CVRA. (See DE 265 + +at 15). Insofar as they seek to demonstrate that the attorneys' mental impressions should have led + +them to conclude that prosecution was the best course, such inquiry cannot be allowed for + +reasons discussed above. Elsewhere, Petitioners assert that they can prove their case by + +demonstrating a "conspiracy between the Government and defense counsel to deliberately + +conceal vital information from the victims." (DE 266 at 7). Because of the availability of this + +method of proof, Petitioners lack a compelling need to gain access to internal Government work + +product evidencing its internal mental impressions regarding the Epstein matter. + +Finally, Petitioners argue that any work-product protection available in this case should + +be negated because the Government's communications facilitated "misconduct" by depriving the + +victims of their rights under the CVRA. (DE 265 at 6). The Eleventh Circuit has recognized that + +"[t]he crime-fraud exception presents one of the rare and extraordinary circumstances in which + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 16 of 51 + +opinion work product is discoverable." Cox, 17 F.3d at 1422. The Eleventh Circuit has not + +indicated whether this "rare and extraordinary" exception extends to instances of "misconduct" + +in the form of violating a civil rights statute, such as the CVRA. Even so, the Court finds that + +such alleged "misconduct" does not rise to the level of conduct that triggers an exception to the + +work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401 (D.C. Cir. 1985) + +(exception to attorney-client privilege applied where alleged wrongdoing included "perjured + +testimony, document destruction, and similar misconduct"); United States v. Myers, 593 F.3d + +338, 347 n.14 (4th Cir. 2010) (noting that exception applied where litigant "defrauded" public + +defender by submitting false invoices). Petitioners' allegation that the Government failed to + +accord them their full CVRA rights—the allegation at the heart of this case—does not rise to the + +level of conduct sufficiently serious enough to displace the work product privilege. + +Moreover, Petitioners fail to set forth prima facie evidence that the Government in fact + +committed "misconduct" in this case. To invoke the crime-fraud exception, the party seeking + +disclosure must (1) make a prima facie showing that the material was produced in the + +commission of criminal or fraudulent conduct and (2) that it was produced "in furtherance of the + +criminal or fraudulent activity or was closely related to it." Cox 17 F.3d at 1416; see also id. at + +1422 (noting that same "two-part test" applies in context of both attorney client privilege and + +work product doctrine). Petitioners argue that the fact that the OPR "collected information about + +possible improper behavior" establishes a prima facie case of Government misconduct. (DE 265 + +at 7). An investigation into wrongdoing does not presuppose that wrongdoing took place. After + +its in camera review, the Court finds that Petitioners have not made a prima facie showing of + +serious misconduct sufficient to negate the protections of the work product doctrine. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 17 of 51 + +Materials constituting the opinion work product of the Government's attorneys shall + +therefore be withheld from Petitioners. Certain documents that the Court considers fact-based + +work product may be produced subject to relevancy considerations discussed below. + +B. Relevancy of Requests for Production + +In addition to asserting privileges, the Government responds to Petitioners' first request + +for production by arguing that many of the materials requested are not relevant to the instant + +CVRA litigation. (DE 260). + +Rule 26 of the Federal Rules of Civil Procedure defines the general scope of discovery as + +follows: + +Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense—including the existence, description, nature, custody, condition, and location of any documents or other tangible things and the identity and location of persons who know of any discoverable matter. . . . Relevant information need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of + +admissible evidence. + +Fed. R. Civ. P. 26(6)(1). "Discovery should ordinarily be allowed unless it is clear that the + +information sought has no possible bearing on the claims and defenses of the parties or otherwise + +on the subject matter of the action." Milinazzo v. State Farm Ins. Co., 247 F.R.D. 691, 695-96 + +(S.D. Fla. 2007) (citing Dunkin' Donuts, Inc. v. Mary's Donuts. Inc., No. 01-0392, 2001 WL + +34079319, at •2 (S.D. Fla. Nov. 1, 2001)). + +1. Request No. 1—the FBI File on the Epstein Matter and Indictment Material + +In their first request for production, Petitioners seek the file generated by the FBI in the + +Epstein matter, including all documents "collected as part of its case against and/or investigation + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 18 of 51 + +of Epstein." (DE 260 at 2). Petitioners also request that the Government produce all prosecution + +memoranda and draft indictments prepared in the case. (151). The Government argues that such + +materials regarding its decision to prosecute Epstein are irrelevant to the issue of whether they + +denied Petitioners their rights under the CVRA. (ILL). Petitioners disagree. They argue that + +"materials going to the strength of the Government's case against Epstein" are a "vital part" of + +their case against the Government. (DE at 266 at 8). "Those materials would directly + +demonstrate that the Government had an extremely strong case against Epstein, giving the + +Government a motive for needing to keep the victims in the dark about the plea deal." (D. The + +Court concludes that discovery should not extend to these materials. + +First, the Court finds that all prosecution memoranda, research into indictable offenses, + +and draft indictments are protected opinion work product. These documents were created by the + +Government in anticipation of a possible prosecution of Epstein and evince the Government's + +internal mental impressions, legal theories, and strategy concerning the issues presented by a + +possible prosecution. As discussed above, Petitioners have not demonstrated "rare and + +extraordinary circumstances" justifying an exception to this well-established protection. + +Second, the Court finds that the information in the FBI's file regarding its investigation + +into Epstein has no possible bearing on the CVRA claim that is the subject matter of this action. + +Petitioners assert that the relevancy of this material is to "directly demonstrate that the + +Government had an extremely strong case against Epstein." (DE 266 at 8). As discussed above, + +this Court is ill-equipped to decide that the Government did in fact have a "strong case" for + +prosecution and made a hard-to-explain decision to forego a federal prosecution in lieu of a state + +plea. Rather, the inquiry for the Court is whether the Government afforded Petitioners their + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 19 of 51 + +rights under the CVRA, which does not turn on its decision whether to initiate a federal + +prosecution. See 18 U.S.C. § 3771(d)(6). Materials going to the "strength" of the Government's + +case for prosecution—and whether the Government had a motive to hide an embarrassing + +misstep in failing to prosecute—have no relevance to that inquiry. + +2. Request No. 10—Materials Proving that the FBI was Mislead about Likelihood + +of Prosecution + +Request number 10 requests "[alit documents, correspondence, and other information + +relating to discussions between the U.S. Attorney's Office and the FBI concerning the status of + +the investigation and the plea discussions with Epstein, as well as what kind of charges would + +appropriately be filed against Epstein," and "(41 documents, correspondence, and other + +information relating to the U.S. Attorney's Office's representations to the FBI and any other state + +or local law enforcement agency about how this case was being handled." (DE 274 at 5). The + +Government argues that communications it had with the FBI are irrelevant because the "decision + +on whether to prosecute belongs to the United States Attorney." (DE 260 at 3). Petitioners argue + +that these communications between the United States Attorney's Office and the FBI lie at the + +"heart of this case" because they will prove that the Government mislead the FBI about the + +progress of the Epstein case, and the FBI in turn mislead the victims. (DE 266 at 9). The Court + +concludes that discovery should not extend to these materials. + +First, the vast majority of documents responsive to this request—communications + +between the U.S. Attorney's Office and the FBI—are protected from disclosure under either + +principles of grand jury secrecy, the opinion work product doctrine, or both. (See Table). + +Second, the only portion of FBI materials which the Court has not found to be protected + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 20 of 51 + +by either grand jury secrecy or work product protection—the file folder labeled "(Victims) + +Additional 302's," P-012624-012653 (DE 212-1 at 21)—is not responsive to the instant request + +as it does not contain communications from the United States Attorney's Office to the FBI, + +which was then in a position to relay communications to the victims. Rather, these materials + +contain fact-based summaries of statements provided by victims to interviewing FBI agents. + +They are not relevant to this proceeding. + +3. Request No. 16—Materials Proving that Prosecutors had Improper Relationships + +with Persons Close to Epstein + +Request number 16 seeks materials demonstrating that persons inside the United States + +Attorney's Office had improper relationships with persons close to Epstein. (DE 260 at 3). + +Petitioners argue that these documents "show[] that a prosecutor working inside the U.S. + +Attorney's Office when the deal was being arranged left the office shortly thereafter and began + +representing persons close to Epstein (such as his pilots)." (DE 266 at 11). They argue that such + +materials are relevant to their CVRA case because "if one of the prosecutors in the Office was + +not working for the best interests of the United States, but rather for those of Epstein, that would + +be clear evidence of motive to intentionally keep the victims in the dark." (a. at 11). The Court + +concludes that production of such documents should not issue. + +After its in camera review, the Court finds that the documents discussing the issue of + +whether an improper relationship existed between a former prosecutor and Epstein's co- + +conspirators are not relevant to this proceeding. The issue of whether a prosecutor violated + +ethical canons by representing persons with close ties to Epstein after his retirement from the + +United States Attorney's Office does not bear on the issue of whether the Government violated + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 21 of 51 + +Petitioners' CVRA rights during its negotiations with Epstein. The only impropriety to which + +Petitioners point occurred after the prosecutor's departure from the Government. The + +OPR—which opened an inquiry into the matter at Petitioners' counsel's request—closed their + +inquiry into the matter by noting that the OPR has jurisdiction to investigate allegations of + +misconduct involving only current Department of Justice attorneys. (See P-013937;5 see also P- + +0013946). The OPR did not investigate the matter further, and it issued no factual + +determinations on whether a conflict existed before the prosecutor's departure. Any OPR + +correspondence regarding this inquiry that is not otherwise privileged is irrelevant to this CVRA + +litigation. (See Table at P-013944, P-013945). + +In the same vein, correspondence between the United States Attorney's Office and the + +OPR regarding self-reporting of conflicts alleged by Epstein's defense counsel are irrelevant to + +this proceeding.' (DE 212-1 at 21-22); see Table at P-013227-013247). + +4. Request No. 18—Documents Concerning Recusal of the United States Attorney's + +Office for the Southern District of Florida + +Request number 18 seeks information about why the United States Attorney's Office for + +the Southern District of Florida was "'conflicted out' of handing various issues related to the + +Epstein case." (DE 266 at 11). Specifically, it requests "all documents, correspondence, and + +other information regarding the potential conflicts of interest that the Justice Department + +discussed or determined existed for the USAO SDFL, as well as any referral that was made to + +5 This is a draft letter addressed to Petitioners' counsel from an OPR attorney. The Court + +assumes Plaintiff's counsel received the final version of this letter explaining the OPR's reasons + +for closing its investigation. + +Ironically, Epstein's counsel raised conflict-of-interest concerns because they believed + +that certain prosecutors were too close to persons associated with the victims. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 22 of 51 + +Main Justice or to any other District, including any documents that were transmitted to any other + +District regarding the conflict and regarding what was to be investigated." (DE 260 at 4). + +Petitioners argue that such materials are relevant because they "show why the victims did not + +receive proper notifications about the non-prosecution agreement that the [United States + +Attorney's Office for the Southern District of Florida] negotiated with Epstein." (DE 266 at II). + +The Court concludes that the materials are not relevant in that regard. + +First, the Court fords that the responsive documents are shielded by governmental + +attorney-client privilege. The responsive documents are internal Department of Justice + +correspondences between attorneys for the United States Attorney's Office for the Southern + +District of Florida and the Executive Office of United States Attorneys. (DE 212-1 at 22-23); + +see Table at P-013248-13278). One of the Executive Office's functions is to "[p]rovide general + +legal interpretations, opinions, and advice to United States Attorneys in areas of recusals." + +Offices of the United States Attorneys, United States Department of Justice, + +http://www.justice.gov/usao/eousahnission-and-functions (last visited June 19, 2015). The + +internal documents that Petitioners seek relate to the provision of legal advice by the Executive + +Office to the United States Attorney's Office for the Southern District of Florida regarding how + +to proceed in the Epstein matter given the initiation of CVRA litigation by Petitioners. These + +communications are solely between attorneys within the United States Department of Justice. + +The communications do not constitute the commission of crime, fraud, or misconduct, but rather + +simply advise how to proceed given that allegations of misconduct have been made, i.e., + +allegations that the Government violated the victims' CVRA rights. + +Moreover, the documents related to the recusal determination are not relevant to matters + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 23 of 51 + +concerning whether the Government violated Petitioners' CVRA rights several years before. + +Petitioners speculate that the reason that the Southern District recused "may have to do with the + +Office's treatment of the victims." (DE 266 at 12). The Court has reviewed the recussal + +materials, and they do not indicate that the Office had to step away from the Epstein matter + +because of its handling of victims' notifications, but rather because of the perceived conflict that + +would exist if the Office continued to investigate Epstein after the institution of CVRA litigation + +by Petitioners. The recusal materials have no relevancy to anything that occurred prior to the + +institution of the instant litigation by Petitioners. + +5. Request No. 19—Materials Related to Defense's Assault on Prosecution + +In request number 19, Petitioners seek all documents supporting, or contradicting, a + +statement made by a United States Attorney to the media that Epstein launched "a yearlong + +assault on the prosecution and theprosecutors." (DE 260 at 4). After its in camera review, the + +Court has not identified any documents that are responsive to this request that are not otherwise + +protected opinion work product. No production under this request is necessary. + +6. Request No. 25—Initial Disclosures under FRCP 26(a)(1) + +Finally, Petitioners request that the Government comply with its obligation to serve initial + +disclosures under Federal Rule of Civil Procedure 26(a)(1). Although Petitioners have already + +served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly + +held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the + +Government maintains that the rule governing initial disclosures in civil litigation does not apply + +to it in this case. (DE 274 at 8). The Court disagrees. The Government shall serve its Rule + +26(a)(1) disclosures on Petitioners within 14 days of this Opinion and Order. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 24 of 51 + +C. Other Considerations + +Before concluding, the Court finds it necessary to address certain aspects of the + +Government's privilege logs. + +As mentioned, the Court previously ordered the Government to provide Petitioners all + +"documentary material exchanged by or between the federal government and persons or entities + +outside the federal government." (DE 190 at 2). Petitioners state that they "have now obtained + +the full text of correspondence between the defense attorneys and the prosecutors." (DE 298 at + +6). The documents produced for in camera review contain correspondence between the + +Government and counsel for both Epstein and Petitioners. Some of the documents were + +• + +inadvertently marked as privileged; some of the documents bear handwritten notes of + +Government attorneys, and some are part of communication chains made up of both internal and + +external communications. The Table at the end of this order indicates instances where such + +communications appear. The Court requests that the Government certify within 14 days that + +Petitioners have been provided with all external communications. + +Additionally, the Court has identified several documents that are asserted "work product," + +but which are nothing more than factual complications of information regarding victim + +identification. The Court finds that Petitioners have a compelling need to know which + +individuals the Government considered to be victims or potential victims at the time it negotiated + +the non-prosecution agreement. As indicated in the Table, the Government should confer with + +Petitioners regarding the names of the individuals identified in these documents. If Petitioners + +have not been previously provided with these names, then Petitioners should have production of + +the indicated documents. The parties should stipulate to an appropriate protective order to + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 25 of 51 + +protect the victims' identity. + +III. Conclusion + +Accordingly, it is hereby ORDERED AND ADJUDGED that the Government shall + +produce documents consistent with the following Table. It is further ORDERED AND + +ADJUDGED that Intervenor Epstein's Motion for the Court to Protect From Disclosure Grand + +Jury Materials (DE 263) is GRANTED, and Petitioners' Motion to Seal (DE 267) is DENIED in + +light of this Court's Order at DE 326; DE 268 is hereby UNSEALED. + +DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, + +Florida, this 6i° day July, 2015. + +KENNETH A. MARRA United State District Judge + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 26 of 51 + +TABLE Detail of Privilege and Relevancy Holdings + +Bates Range Ruling on Privilege or Relevancy Comment (as necessary) + +1:000001-000039' Protected from discovery by grand jury secrecy and opinion work product privilege. + +1:000040-000549 Protected from discovery by grand jury secrecy and opinion work product privilege. + +1:000550-000621 Protected from discovery by grand jury secrecy. 1:000622-000693 Protected from discovery by grand jury secrecy. + +1:000694-000781 Protected from discovery by opinion work product + +privilege. + +1:000782-000803 Protected from discovery by grand jury secrecy. I :000804-000854 Protected from discovery by grand jury secrecy. + +1:000855-000937 ' Protected from discovery by grand jury secrecy. + +1:000938-000947 Protected from discovery by grand jury secrecy. + +1:000948-000982 Protected from discovery by opinion work product + +privilege. + +1:000983-001007 Protected from discovery by grand jury secrecy and opinion work product privilege. + +1:001008-001056 Protected from discovery by grand jury secrecy and opinion work product privilege. + +1:001057-001959 Protected from discovery by grand jury secrecy. 1:001960-002089 Protected from discovery by grand jury secrecy. 1:002090-002169 Protected from discovery by grand jury secrecy. 1:002170-002246 Protected from discovery by grand jury secrecy. + +1:002247-002265 Protected from discovery by grand jury secrecy. + +1:002266-002386 Protected from discovery by grand jury secrecy and opinion work product privilege. + +1:002387-002769 Protected from discovery by grand jury secrecy and opinion work product privilege. + +The first digit indicates the box number, with an "S" indicating materials identified in + +the supplemental privilege logs (DEs 216-1, 329-1). The numbers following the colon are page + +ranges. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 27 of 51 + +1:002770-003211 Protected from discovery by grand jury secrecy and opinion work product privilege. + +1:003212-003545 Protected from discovery by grand jury secrecy and opinion work product privilege. + +1:003546-003552 Protected from discovery by opinion work product + +privilege. + +1:003553-003555 + +B + +Protected from discovery by opinion work product + +privilege. + +1:003556-003562 Protected from discovery by grand jury secrecy and opinion work product privilege. + +1:003563-003629 Protected from discovery by grand jury secrecy. + +1:003630-003633 Protected from discovery by opinion work product + +privilege. + +1:003634-003646 Protected from discovery by grand jury secrecy and opinion work product privilege. + +1:003647-003651 Produce victim identities. Document bears no indication + +that it was directly related to grand jury presentation, and it does not exhibit the mental impressions of counsel but rather the cumulation of facts. Petitioners should be provided with the victim identities under an appropriate protective order. + +1:003664-003678 Protected from discovery by opinion work product + +privilege. + +1:003679-003680 Protected from discovery by opinion work product + +privilege. + +1:003681-003687 Protected from discovery by opinion work product + +privilege. + +1:003688-003693 Protected from discovery by opinion work product + +privilege. + +1:003694-003711 Protected from discovery by grand jury secrecy and opinion work product privilege. + +1:003712 Produce victim identity. Contains nothing other than the + +written name of one victim. The Court finds that no privilege applies, and Petitioners should be made aware that this victim was known to the Government. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 28 of 51 + +1:003713-003746 Protected from discovery by grand jury secrecy. 1:003747-003751 Protected from discovery by grand jury secrecy. 1:003752-004295 Protected from discovery by grand jury secrecy. + +1:004296-004350 Protected from discovery by grand jury secrecy; also + +contains no materials relevant or likely to lead to discovery of materials relevant to the instant CVRA + +litigation. + +1:004351-004381 Protected from discovery by work product privilege. + +1:004382-004478 Protected from discovery by grand jury secrecy. + +1:004479-004551 Protected from discovery by grand jury secrecy and opinion work product privilege. + +1:004552-004555 Protected from discovery by grand jury secrecy and opinion work product privilege. + +1:004556-004560 Production not necessary; not relevant or likely to lead + +to the discovery of materials relevant to the instant + +CVRA litigation. + +Contains factual information regarding the employment and wage history of Epstein's employees, obtained during the investigation into Epstein and his associates. No bearing on victim notification or rights. + +1:004561-004565 Protected from discovery by opinion work product + +privilege. + +1:004566-004716 Protected from discovery by grand jury secrecy. + +1:004717-004722 Protected from discovery by opinion work product + +privilege. + +1:004723-004725 Protected from discovery by opinion work product + +privilege. + +1:004726-004819 Protected from discovery by opinion work product + +privilege. + +1:004820-004959 Protected from discovery by opinion work product + +privilege. + +1:004960-005059 Protected from discovery by grand jury secrecy; also not + +relevant or likely to lead to the discovery of materials + +relevant to the instant CVRA litigation. + +Contains factual information regarding the call history of Epstein (and associates) to victims, obtained during investigation into Epstein and associates. Contains no information bearing on Government's obligation to + +crime victims. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 29 of 51 + +1:005060-005081 Partially protected from discovery by opinion work + +product privilege. + +Attorney handwritten notes arc protected from discovery; the underlying correspondence is not and should be produced. The Government Must certify that Petitioners have been provided the correspondence. + +1:005082-005083 Protected from discovery by opinion work product + +privilege. + +1:005108-005193 Protected from discovery by opinion work product + +privilege. + +1:005194-005300 Protected from discovery by opinion work product + +privilege. + +1:005301-005331 Protected from discovery by grand jury secrecy. + +1:005332-005341 Protected from discovery by opinion work product + +privilege. + +1:005342-005387 Protected from discovery by grand jury secrecy. + +1:005388-005442 Except P-005420, protected from discovery by grand + +jury secrecy and opinion work product privilege. + +The victims list at P-005420 bears no indication that it was produced to a grand jury and bears no attorney mental impressions. Petitioners should be provided with the victim identities under an appropriate + +protective order. + +1:005443-005496 Protected from discovery by grand jury secrecy. 1:005497-005556 Protected from discovery by grand jury secrecy. + +1:005557-005576 Protected from discovery by opinion work product + +privilege. + +1:005578-005583 Protected from discovery by opinion work product + +privilege. + +1:005584- 005606 Except P-005590-005595 and P-005596, protected + +from discovery by grand jury secrecy and opinion work + +product privilege. + +P-005590-005595 and P-005596 are correspondence documents sent to victim's counsel. No privilege applies. The Government must certify that Petitioners have been provided the correspondence. + +2:005607-005914 Protected from discovery by grand jury secrecy and opinion work product privilege. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 30 of 51 + +2:005915-005977 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:005978-006050 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:006051-006065 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:006066-006220 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:006221-006222 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:006223-006522 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:006523-006802 Protected from discovery by grand jury secrecy. + +2:006803-006860 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:006861-007785 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:007786-008120 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:008121-008139 Protected from discovery by grand jury secrecy. + +2:008140-008298 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:008364-008382 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:08383-008516 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:008536-008542 Protected from discovery by opinion work product + +privilege. + +2:008543-008549 Protected from discovery by opinion work product + +privilege. + +2:008550-008615 Protected from discovery by opinion work product + +privilege. + +2:008616-008686 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:008687-008776 Protected from discovery by grand jury secrecy and opinion work product privilege. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 31 of 51 + +2:008777-008808 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:008809-008847 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:008848-008862 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:008863-008890 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:009104-009111 Protected from discovery by opinion work product + +privilege. + +2:009126-008134 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:009135-009141 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:009141A-00914 + +1C + +Protected from discovery by grand jury secrecy and + +opinion work product privilege. + +2:009142-009152 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:009153-009156 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:009157-009208 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:009209-009213 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:009214-009271 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:009272-009354 Protected from discovery by opinion work product + +privilege. + +2:009355-009403 Protected from discovery by opinion work product + +privilege. + +2:009404-009536 Protected from discovery by opinion work product + +privilege. + +2:009537-009574 Protected from discovery by opinion work product + +privilege. + +2:009575-009603 Protected from discovery by opinion work product + +privilege. + +2:009604-009711 Protected from discovery by opinion work product + +privilege. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 32 of 51 + +2:009820-009965 Protected from discovery by opinion work product + +privilege. + +2:009966-010096 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:010097-010276 Protected from discovery by opinion work product + +privilege. + +2:010277-010394 Protected from discovery by opinion work product + +privilege. + +2:010395-010488 Protected from discovery by opinion work product + +privilege. + +2:010489-010509 Protected from discovery by opinion work product + +privilege. + +2:010510-010525 Protected from discovery by opinion work product + +privilege. + +2:010526-010641 Protected from discovery by opinion work product + +privilege, + +The correspondence between the Government and Epstein's counsel is not privileged and should be produced. The Government must certify that it + +has been produced. + +2:010642-010650 Protected from discovery by opinion work product + +privilege. + +2:010651-010659 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:010660-010757 Protected from discovery by grand jury secrecy and opinion work product privilege. + +2:010758-010793 Protected from discovery by opinion work product + +privilege. + +2:010794-010829 Protected from discovery by opinion work product + +privilege. + +2:010830-010853 Protected from discovery by opinion work product + +privilege. + +2:010854-010876 Protected from discovery by opinion work product + +privilege. + +2:010877-010920 Protected from discovery by opinion work product + +privilege. + +2:010921-011049 Protected from discovery by opinion work product + +privilege. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 33 of 51 + +2:011050-011212 Protected from discovery by opinion work product + +privilege. + +2:011213-011237 Protected from discovery by opinion work product + +privilege. + +2:011238-011319 Protected from discovery by opinion work product + +privilege. + +2:011320-011361 Protected from discovery by opinion work product + +privilege. + +2:011362-011374 Protected from discovery by opinion work product + +privilege. + +2:011375-011456 Protected from discovery by opinion work product + +privilege. + +2:011457-011626 Protected from discovery by opinion work product + +privilege. + +3:011627-011662 Protected from discovery by opinion work product + +privilege. + +3:011663-012361 Protected from discovery by grand jury secrecy and opinion work product privilege. + +3:011699-011777 Protected from discovery by grand jury secrecy and opinion work product privilege. + +3:011778-011788 Produce victim identities. Document does not exhibit the + +mental impressions of counsel but rather the cumulation of facts. Petitioners should be provided with the victim identities under an appropriate + +protective order. + +3:011789-011879 Protected from discovery by opinion work product + +privilege. + +3:011880-011922 Protected from discovery by opinion work product + +privilege. + +3:011923-011966 Protected from discovery by opinion work product + +privilege. + +The underlying correspondence between Government and Epstein's counsel should be produced without attorney annotations. The Government must certify that Petitioners have this correspondence. + +3:011967-012016 Protected from discovery by opinion work product + +privilege. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 34 of 51 + +3:01217-012055 Protected from discovery by grand jury secrecy. 3:012056-012088 Protected from discovery by grand jury secrecy. + +' 3:012089-012129 Protected from discovery by grand jury secrecy. + +3:012130-012150 Protected from discovery by grand jury secrecy. 3:012151-012167 Protected from discovery by grand jury secrecy. + +3:012168-012170 Protected from discovery by grand jury secrecy. + +3:012171-012173 Protected from discovery by grand jury secrecy. + +3:012174-012176 Protected from discovery by opinion work product + +privilege. + +Final versions of sent correspondence should be produced. The Government must certify whether Petitioners have any sent version of this + +correspondence. + +3:012177-012178 Protected from discovery by opinion work product + +privilege. + +3:012179-012188 Protected from discovery by grand jury secrecy and opinion work product privilege. + +3:012362-012451 Protected from discovery by grand jury secrecy and opinion work product privilege. + +3:012451-012452 Produce victim identities. Document does not exhibit the + +mental impressions of counsel but rather the cumulation of facts. Petitioners' need outweighs investigative privilege. Petitioners should be provided with the victim identities under an appropriate + +protective order. + +3:012453-012623 Protected from discovery by grand jury secrecy and opinion work product privilege. 3:012624-012653 Production not necessary; documents are not relevant or + +likely to lead to the discovery of materials relevant to + +this CVRA litigation. + +The Court has reviewed the content of the FBI "302's," which are forms prepared by FBI agents to document interviews. These interview reports summarize the various victims' interactions with Epstein, and do not indicate a conveyance of information from the FBI to the victims regarding the likelihood of + +prosecution. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 35 of 51 + +3:012654-012864 Protected from discovery by opinion work product + +privilege. + +3:012865-013226 Protected from discovery by grand jury secrecy and opinion work product privilege. + +3:013227 Production not necessary; not relevant or likely to lead + +to the discovery of materials relevant to this CVRA + +litigation. + +Involves OPR investigation into Epstein's allegation that certain prosecutors had conflicts of interest. Not relevant to victims' CVRA + +rights. + +3:013228-013230 Production not necessary; not relevant or likely to lead + +to the discovery of materials relevant to this CVRA + +litigation. + +Involves OPR investigation into Epstein's allegation that certain prosecutors had conflicts of interest. Not relevant to victims' CVRA + +rights. + +3:013231-013239 Production not necessary; not relevant or likely to lead + +to the discovery of materials relevant to this CVRA + +litigation. + +Involves OPR investigation into Epstein's allegation that certain prosecutors had conflicts of interest. Not relevant to victims' CVRA + +rights. + +3:013240 -O13247 Production not necessary; not relevant or likely to lead + +to the discovery of materials relevant to this CVRA + +litigation. + +Involves OPR investigation into Epstein's allegation that certain prosecutors had conflicts of interest. Not relevant to victims' CVRA + +rights. + +3:013248-013251 Protected from disclosure by the attorney-client + +privilege; also not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. + +3:013252-013253 Protected from disclosure by the attorney—client + +privilege; also not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. + +3:013254-013257 Protected from disclosure by the attorney—client + +privilege; also not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. + +3:013258-013259 Protected from disclosure by the attorney-client + +privilege; also not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. + +3:013260-013262 Protected from disclosure by the attorney-client + +privilege; also not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 36 of 51 + +3:013263-013271 Protected from discovery by attorney-client and opinion + +work product privilege; also not relevant or likely to lead to the discovery of materials relevant to this CVRA + +litigation. + +3:013272-013278 Protected from disclosure by the attorney—client + +privilege; also not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. + +S:013279 013280 Protected from discovery by opinion work product + +privilege. + +S:013281 Protected from discovery by opinion work product + +privilege. + +S:013282-013283 Protected from discovery by opinion work product + +privilege. + +S:013284 Protected from discovery by opinion work product + +privilege. + +S:013285-013289 Protected from discovery by opinion work product + +privilege. + +S:013290-013292 Protected from discovery by opinion work product + +privilege. + +8:013293-013299 Protected from discovery by opinion work product + +privilege. + +The portions of this correspondence between the Government and Epstein's counsel should be produced. The Government must certify that Petitioners have been provided with these outside + +correspondences. + +S:013300-013303 Protected from discovery by opinion work product + +privilege. + +5:013304-013325 Protected from discovery by opinion work product + +privilege. + +8:013326-013329 Protected from discovery by opinion work product + +privilege. + +S:013330-013333 Protected from discovery by opinion work product + +privilege. + +S:013334-013337 Protected from discovery by opinion work product + +privilege. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 37 of 51 + +5:013342-013350 Protected from discovery by opinion work product + +privilege. + +The underlying correspondence between Epstein's counsel and the Government should be produced without attorney annotations. The Government must certify that Petitioners have been provided with these outside correspondences. + +S:013351-013361 Protected from discovery by opinion work product + +privilege. + +The underlying correspondence between Epstein's counsel and the Government should be produced without attorney annotations. The Government must certify that Petitioners have been provided with these outside correspondences. + +S:013362-013366 Protected from discovery by opinion work product + +privilege. + +Any version of the letter actually sent to Epstein's counsel should be produced. Government must certify whether it has been produced. + +S:013367-013372 Protected from discovery by opinion work product + +privilege. + +Any version of the letter actually sent to Epstein's counsel should be produced. Government must certify whether it has been produced. + +S:013373-013503 Protected from discovery by opinion work product + +privilege. + +S:013504-013507 Protected from discovery by opinion work product + +privilege. + +S:013508-013514 Partially protected from discovery by opinion work + +product privilege. + +Only the top portion of P-013509 contains materials internal to the Government—a one-sentence email between two United States Attorneys. The Government must certify that Petitioners have the remainder of P-013509 and P-013510-013514, as these communications are between the Government and Epstein's + +counsel. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 38 of 51 + +\$:013515-013525 Protected from discovery by opinion work product + +privilege. + +Any final version of the letter actually sent to Epstein's counsel should be produced. Government must certify whether it has been produced. + +S:013526-013527 Protected from discovery by opinion work product + +privilege. + +S:013528-013530, 013532-013537 + +Protected from discovery by opinion work product + +privilege. + +S:013531 Protected from discovery by grand jury secrecy. + +S:013538-013553 Protected from discovery by opinion work product + +privilege. + +S:013554-013608 Protected from discovery by opinion work product + +privilege. + +S:013609-013615 Protected from discovery by grand jury secrecy. + +S:013616-013621 Protected from discovery by opinion work product + +privilege. + +S:013622-013643 Protected from discovery by opinion work product + +privilege. + +S:013644-013653 Protected from discovery by opinion work product + +privilege. + +S:013654-013745 Protected from discovery by opinion work product + +privilege. + +S:013747-013810 Protected from discovery by opinion work product + +privilege. + +S:013811-013833 Protected from discovery by opinion work product + +privilege. + +S:013834-013835 Protected from discovery by opinion work product + +privilege. + +S:013836-013837 Protected from discovery by opinion work product + +privilege. + +S:013838-013841 Protected from discovery by opinion work product + +privilege; also not relevant material or likely to lead to discovery of material relevant to the instant CVRA + +litigation. + +The underlying correspondence between Epstein's counsel and the Government should be produced without attorney annotations. The Government must certify that Petitioners have been provided with these outside correspondences. + +Case 9:08-cv-80736-KAM Document 330 Entered on PLSD Docket 07/06/2015 Page 39 of 51 + +S:013842 Protected from discovery by opinion work product + +privilege; also not relevant material or likely to lead to discovery of material relevant to the instant CVRA + +litigation. + +S:013843-013844 Protected from discovery by opinion work product + +privilege. + +3:013845-013846 Protected from discovery by opinion work product + +privilege. + +S:013847-013849 Protected from discovery by opinion work product + +privilege. + +S:013850 Protected from discovery by opinion work product + +privilege. + +S:013851-013853 Protected from discovery by opinion work product + +privilege. + +S:013854 Protected from discovery by opinion work product + +privilege. + +S:013855 Protected from discovery by opinion work product + +privilege. + +S:013856-013857 Protected from discovery by opinion work product + +privilege. + +S:013858 Protected from discovery by opinion work product + +privilege. + +3:013861-013865 Protected from discovery by opinion work product + +privilege. + +S:013866 Protected from discovery by opinion work product + +privilege. + +5:013867-O13868 Protected from discovery by opinion work product + +privilege. + +S:013869 Protected from discovery by opinion work product + +privilege. + +S:013870-013871 Produce; not protected from discovery by any privilege. Only the top portion of the + +email chain contains + +correspondence internal to the Government, and this does not divulge any mental impressions or legal theories. The rest of the email chain is between the Government and Epstein's counsel. It should be produced. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 40 of 51 + +S:013872 Protected from discovery by opinion work product + +privilege. + +Besides internal Government correspondence, contains one email correspondence between the Government and Epstein's counsel, which will be + +produced at P-013870-013871. + +S:013873 Protected from discovery by opinion work product + +privilege. + +S:013876-013877 Partially protected from discovery by opinion work + +product privilege. + +The email correspondence at P—013877 is between the Government and Epstein's counsel, and not privileged. The Government must certify that Petitioners have been provided with these outside + +correspondences. + +S:013878-013879 Protected from discovery by opinion work product + +privilege. + +S:013880-013882 Partially protected from discovery by opinion work + +product privilege. + +Only the top two email correspondences are internal to + +the Government. The remaining emails, starting at the bottom of P-013880 and running through P-013882, are between the Government and Epstein's counsel, and should be produced. The Government must certify that Petitioners have been provided with these outside correspondences. + +S:013883 Protected from discovery by opinion work product + +privilege. + +S:013884-013886 Protected from discovery by opinion work product + +privilege. + +5:013887 Protected from discovery by opinion work product + +privilege. + +S:013888 Protected from discovery by opinion work product + +privilege. + +S:013889-013890 Protected from discovery by opinion work product + +privilege. + +S:013891 Protected from discovery by opinion work product + +privilege. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 41 of 51 + +S:013894-013898 Protected from discovery by opinion work product + +privilege. + +S:013899 Protected from discovery by opinion work product + +privilege. + +5:013900-013901 Protected from discovery by opinion work product + +privilege. + +S:013902 Protected from discovery by opinion work product + +privilege. + +S:013903-013904 Identical to the email chain at S:013870-013871, and should likewise be disclosed. S:013905 Partially protected from discovery by opinion work + +product privilege. + +Email correspondence at bottom of page between Government and Epstein's counsel should be produced. The Government must certify that Petitioners have been provided with these outside + +correspondences. + +5:013906 Protected from discovery by opinion work product + +privilege. + +S:013909-013911 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +5:013912-013914 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +S:013915-013918 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +S:013919-013921 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +S:013922-013924 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +S:013925-013927 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +The final version of this letter, + +which is addressed to + +Petitioners' counsel, should be available to Petitioners. + +S:013928-013930 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +The final version of this letter, + +which is addressed to + +Petitioners' counsel, should be available to Petitioners. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 42 of 51 + +S:013931-013933 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +The final version of this letter, + +which is addressed to + +Petitioners' counsel, should be available to Petitioners. + +S:013934-013936 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +S:013937-013939 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +The final version of this letter, + +which is addressed to + +Petitioners' counsel, should be available to Petitioners. + +S:013940-013942 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +S:013943 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +S:013944 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +S:013945 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +S:013946 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +5:013947 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +S:013948-013951 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +S:013952-013953 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +S:013954-013955 Not relevant or likely to lead to material relevant to the instant CVRA litigation. + +S:013956-013969 Protected from discovery by opinion work product + +privilege. + +S:'13970-13971 Protected from discovery by opinion work product + +privilege; also, not relevant or likely to lead to material + +relevant to this CVRA litigation. + +S:13972 Protected from discovery by opinion work product + +privilege. + +S:13973-13976 Protected from discovery by opinion work product + +privilege. + +The Government's Second Supplemental Privilege Log begins here. (DE 329-1). + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 43 of 51 + +S:13977-13979 Protected from discovery by opinion work product + +privilege. + +S:13980 Protected from discovery by opinion work product + +privilege. + +S:I3981 Protected from discovery by opinion work product + +privilege. + +S:13982 Protected from discovery by opinion work product + +privilege. + +S:I3983-13984 Protected from discovery by opinion work product + +privilege. + +S:13985-13989 Protected from discovery by opinion work product + +privilege. + +S:13990-I 3991 Protected from discovery by opinion work product + +privilege. + +S:13992-13994 Protected from discovery by opinion work product + +privilege. + +S:13995-14010 Protected from discovery by opinion work product + +privilege; also, not relevant or likely to lead to material + +relevant to this CVRA litigation. + +S:S:14011-14025 Protected from discovery by opinion work product + +privilege. + +S:14026-14027 Protected from discovery by opinion work product + +privilege. + +S:14028-14030 Protected from discovery by opinion work product + +privilege. + +S:14031-01432 Protected from discovery by opinion work product + +privilege. + +S:14033 Protected from discovery by opinion work product + +privilege. + +S: 14034 Protected from discovery by opinion work product + +privilege. + +S: 14035 Protected from discovery by opinion work product + +privilege. + +S: 14036 Protected from discovery by opinion work product + +privilege. + +S:14037 Protected from discovery by opinion work product + +privilege. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 44 of 51 + +S:14038-14041 Protected from discovery by opinion work product + +privilege. + +5:14042 Protected from discovery by opinion work product + +privilege. + +S:14043-14044 Protected from discovery by opinion work product + +privilege. + +5:14045-14046 Protected from discovery by opinion work product + +privilege. + +5:14047 Protected from discovery by opinion work product + +privilege. + +5:14048 Protected from discovery by opinion work product + +privilege. + +5:14049-14050 Protected from discovery by opinion work product + +privilege. + +5:14051 Protected from discovery by opinion work product + +privilege. + +5:14052 Protected from discovery by opinion work product + +privilege. + +5:14053 Protected from discovery by opinion work product + +privilege. + +S:14054 Protected from discovery by opinion work product + +privilege. + +5:14055 Protected from discovery by opinion work product + +privilege. + +5:14056 Protected from discovery by opinion work product + +privilege. + +S:14057 Protected from discovery by opinion work product + +privilege. + +5:14058 Protected from discovery by opinion work product + +privilege. + +S:14059-1406I Protected from discovery by opinion work product + +privilege. + +S:14062-14068 Protected from discovery by opinion work product + +privilege. + +S:14069 Protected from discovery by opinion work product + +privilege. + +S:I4070-14074 Protected from discovery by opinion work product + +privilege. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 45 of 51 + +S:14075-14089 Protected from discovery by opinion work product + +privilege. + +S:14090-14102 Protected from discovery by opinion work product + +privilege. + +S:14103-14107 . Protected from discovery by opinion work product + +privilege. + +S:14108-14134 Protected from discovery by opinion work product + +privilege. + +S:14135-14149 Protected from discovery by opinion work product + +privilege. + +S:14150-14156 Protected from discovery by opinion work product + +privilege. + +5:14157-15160 Protected from discovery by opinion work product + +privilege. + +5:14161 Protected from discovery by opinion work product + +privilege. + +S:14162-14170 Protected from discovery by opinion work product + +privilege. + +S:14171-14174 Protected from discovery by opinion work product + +privilege. + +S:14175-14203 Protected from discovery by opinion work product + +privilege. + +S:14204-14205 Protected from discovery by opinion work product + +privilege. + +8:14206-14216 Partially protected from discovery by opinion work + +product privilege. + +The portions of the email chain from Epstein's counsel are not privileged. The Government mast certify that this outside correspondence has been + +produced. + +S:I4217-14238 Partially protected from discovery by opinion work + +product privilege. + +The portions of the email chain from Epstein's counsel are not privileged. The Government must certify that this outside correspondence has been + +produced. + +5:14239-14242 Protected from discovery by opinion work product + +privilege. + +S:14243.14251 Protected from discovery by opinion work product + +privilege. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 46 of 51 + +S:14252-14275 Partially protected from discovery by opinion work + +product privilege. + +The portions of the email chain from Epstein's counsel are not privileged. The Government must certify that this outside correspondence has been + +produced. + +5:14276 Protected from discovery by opinion work product + +privilege. + +S:I4277-14282 Protected from discovery by opinion work product + +privilege. + +S:14283-14284 Protected from discovery by opinion work product + +privilege. + +S:I4285-14298 Protected from discovery by opinion work product + +privilege. + +S:14299-14307 Protected from discovery by opinion work product + +privilege. + +S:14308-14310 Protected from discovery by opinion work product + +privilege. + +S:14311-14329 + +L + +Partially protected from discovery by opinion work product privilege; outside correspondence and P- + +014315-014316 must be produced. + +The Government must certify that the outside correspondence has been produced. The correspondence at P-014315- 014316 must be produced; this fact-based material is not opinion work product as it does + +not reveal the mental + +impressions of counsel, and the court finds that Petitioners have a compelling need for the information contained therein. This need also outweighs any deliberative-process privilege that may apply. It not + +protected by the attorney-client privilege, as the Government has not demonstrated that FBI agen provided this information in an attempt to secure legal advice or a legal opinion from the United States Attorney's Office. The correspondence must be produced pursuant to an appropriate protective order. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 47 of 51 + +S:14330-14337 Partially protected from discovery by opinion work + +product privilege. + +The portions of the email chain from Epstein's counsel are not privileged. The Government must certify that this outside correspondence has been + +produced. + +S:14338-14354 Protected from discovery by opinion work product + +privilege. + +S:14355-14361 Protected from discovery by opinion work product + +privilege. + +S:I4362-14402 Protected from discovery by opinion work product + +privilege. + +S:14403-14414 Protected from discovery by opinion work product + +privilege. + +5:14415-14420 Protected from discovery by opinion work product + +privilege. + +5:14421- 14428 Protected from discovery by opinion work product + +privilege. + +5:14429-14439 Protected from discovery by opinion work product + +privilege. + +S: 14440 Protected from discovery by opinion work product + +privilege. + +S:14441 Protected from discovery by opinion work product + +privilege. + +S:14442 Protected from discovery by opinion work product + +privilege. + +5:14443 Protected from discovery by opinion work product + +privilege. + +5:14444 Protected from discovery by opinion work product + +privilege. + +S:14445.14447 Protected from discovery by opinion work product + +privilege. + +S:I4448-14454 Protected from discovery by opinion work product + +privilege. + +S:14455-14456 Protected from discovery by opinion work product + +privilege. + +S:I4457-14464 Protected from discovery by opinion work product + +privilege. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 48 of 51 + +S:14486 Protected from discovery by opinion work product + +privilege. + +S:14487 Protected from discovery by opinion work product + +privilege. + +S:I4488-14499 Protected from discovery by opinion work product + +privilege. + +S:14500 Protected from discovery by opinion work product + +privilege. + +8:14501-14506 Protected from discovery by opinion work product + +privilege. + +8:14507-14508 Protected from discovery by opinion work product + +privilege. + +S:14509-14519 Protected from discovery by opinion work product + +privilege. + +S:14520 Produce. The Government has not + +supported its assertion of attorney-client privilege: the email does not, in and of itself, demonstrate that it was a communication between an attorney and clients regarding the provision of legal services or legal advice. Petitioners' need for this material outweighs any deliberative process or investigative privilege that may apply. + +5:14521.14522 Protected from discovery by opinion work product + +privilege. + +8:14523 Protected from discovery by opinion work product + +privilege. + +S:14524-14550 Protected from discovery by opinion work product + +privilege. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 49 of 51 + +S:1455I Produce. The Government has not + +supported its assertion of attorney-client privilege: the email, authored by an FBI agent, does not indicate that it is a client communication seeking legal services or advice from an attorney, the United States Attorney's Office. Petitioners' need for this material outweighs any investigative privilege that may apply. This must be produced pursuant to an appropriate + +protective order. + +S:I4552 Protected from discovery by opinion work product + +privilege. + +5:14553-14556 Protected from discovery by opinion work product + +privilege. + +S:14557 Production not necessary as not relevant or likely to lead + +to material relevant to this CVRA litigation. + +S:14558 Protected from discovery by opinion work product + +privilege. + +S:I4559-14562 Protected from discovery by opinion work product + +privilege. + +S:I4563-14565 Protected from discovery by opinion work product + +privilege. + +5:14566-14568 Protected from discovery by opinion work product + +privilege. + +5:14569-14573 Protected from discovery by opinion work product + +privilege. + +5:14574-14583 Protected from discovery by opinion work product + +privilege. + +5:14584-14622 Protected from discovery by opinion work product + +privilege. + +S:14623-14627 Protected from discovery by opinion work product + +privilege. + +5:14628 Protected from discovery by opinion work product + +privilege. + +5:14629 Protected from discovery by opinion work product + +privilege. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 50 of 51 + +S:14630-14631 Protected from discovery by opinion work product + +privilege. + +S:I4632-14646 Protected from discovery by opinion work product + +privilege. + +S:I4647-14649 Protected from discovery by opinion work product + +privilege. + +S:14650-14653 Protected from discovery by opinion work product + +privilege. + +S:I4654-14655 Protected from discovery by opinion work product + +privilege. + +S:I4656-14665 Protected from discovery by opinion work product + +privilege. + +S:14666-14693 Protected from discovery by opinion work product + +privilege. + +S:I4694-14706 Protected from discovery by opinion work product + +privilege. + +S:14707-14711 Protected from discovery by opinion work product + +privilege. + +S:14712-14716 Protected from discovery by opinion work product + +privilege. + +5:14717-14721 Protected from discovery by opinion work product + +privilege. + +5:14722-14727 Protected from discovery by opinion work product + +privilege. + +S:14728-14742 Protected from discovery by opinion work product + +privilege. + +S:14743-14780 Protected from discovery by opinion work product + +privilege. + +S:14781-14800 Protected from discovery by opinion work product + +privilege. + +S:14801-14810 Protected from discovery by opinion work product + +privilege. + +S:14811-14829 Protected from discovery by opinion work product + +privilege. + +S:14830-14837 Protected from discovery by opinion work product + +privilege. + +S:14838-14843 Protected from discovery by opinion work product + +privilege. + +Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 51 of 51 + +S:14844-1485I Protected from discovery by opinion work product + +privilege. + +S:]4852-14864 Protected from discovery by opinion work product + +privilege; also not relevant or likely to lead to material + +relevant to this CVRA litigation. + +Involves self-reporting to OPR regarding Epstein's allegation that certain prosecutors had conflicts of interest. Not relevant to victims' CVRA + +rights. + +S:I4865 Protected from discovery by opinion work product + +privilege. + +S:14866-I4883 Protected from discovery by opinion work product + +privilege. + +5:14884-14886 Protected from discovery by opinion work product + +privilege. + +S:14887-14894 Protected from discovery by opinion work product + +privilege. + +S:14895-14900 Protected from discovery by opinion work product + +privilege. + +5:14901-14906 Protected from discovery by opinion work product + +privilege. + +S:14907-14911 Protected from discovery by opinion work product + +privilege. + +S:14912-I4919 Protected from discovery by opinion work product + +privilege. + +5:14920-14923 Protected from discovery by opinion work product + +privilege. + +The Government notes that a redacted version has been produced to Petitioners. (DE 329-1 at 18). Only the unredacted version is + +privileged. + +Case 9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 2 of 4 + +DECLARATION OF + +1. My name is • and I was born in + +2. I was paid by Jeffrey Epstein to interact sexually with him as a minor on dozens of occasions in his mansion in Palm Beach, Florida from around 2002 to 2005, and also to bring him other girls who were my approximate age for the same purposes. I understand that evidence collected from Epstein's home showed conclusively that I was there as a minor, along with many other underage girls. Given how many girls Epstein was sexually abusing, there could not have been any doubt in anyone's mind that had access to the testimonial and other evidence that Epstein sexually molested me as a minor (and many + +others). + +3. My son was very young when the FBI came to speak with me the first time. I did not know what to do and I was scared. I called Epstein, who told me not to worry and that he would hire an attorney for me. I + +believed that if I told the truth about what happened at Epstein's + +house, the policel That made me really + +scared. + +4. Through the attorney that Jeffrey Epstein obtained for me, it was + +arranged for me to give a statement to the prosecutor investigating + +Epstein. + +5. While with the attorney Epstein obtained for me I gave a statement to the prosecutor that was favorable to Epstein. The prosecutors knew + +the truth because of the volume of evidence they had, and they + +continued to recognize me as a victim of Epstein's crimes. + +6. I had been greatly intimidated, which is why I could not be truthful + +initiall and I wanted to end the threat of the possibility of + +My involvement with Epstein from a very young age + +was a deep, dark secret and Epstein told me to keep it a secret. I knew + +that I was expected to keep it a secret. + +7. The more I thought about what was going on, the more I realized that what Epstein had done to both me and my friends was wrong and that anyone who was not very wealthy would be punished. At this time, I + +Case 9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 3 of 4 + +wanted Epstein held accountable the same way anyone else would be. I spoke about this with one of m friends around May 2008. I then called an attorney, around June 2008, understanding that he was hired to get the prosecutors to talk to us and hear the truth from me. That was especially important to me because I was finally represented by someone other than Epstein's attorney and wanted to + +talk to the prosecutors about everything I knew. + +8. The prosecutors had a lot of information revealing the truth about the situation at Epstein's house. I had lot of information, too, because I was one of the young teenagers who had brought many other young teenagers to Epstein for the purpose of getting paid by Epstein. I wanted to assist the prosecutors in the investigation. I hired Mr. + +to let them know that I was cooperative and ready to tell + +them all of the helpful information I had. I understood that Mr. + +did that. + +9. I authorized Mr. to join me in the lawsuit against the U.S. + +Attorney's Office to enforce my rights and to try to get me my chance to confer with the prosecutors before Mr. Epstein took a plea or the case was resolved in any way. I just wanted to be treated fairly in the + +process. + +10. When Epstein pled guilty to a state crime at the end of June 2008, no one notified me that his plea had anything to do with my case against him. I did not know, for example, that this plea had some connection to a crime he committed against me particularly. In fact, at this young age, I had no idea what was going on and nobody tried + +to explain it to me. + +11. In Jul 2008 • • + +I learned for the first time at that hearing that the + +prosecutors worked out some sort of secret deal with Epstein that might block his prosecution for crimes against me. It also appeared that there was a lot of continued communication between Epstein and + +the U.S. Attorney's Office. I was really upset that the U.S. + +Attorney's Office seemed like it would not talk with me or the other victims about what was going on. It was easier to get them to talk to + +me when I was represented by Epstein's attorney. + +Case 9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 4 of 4 + +12. I wanted to see this secret deal that the Government had with + +Epstein, but they would not give it to me Later, the other victims and I finally got to see the secret deal after the judge + +forced the prosecutors to show it to us. + +13. I understand that I did not initially help the investigation by + +speaking on Epstein's behalf untruthfully. But I was intimidated and had good reason — reasons that I think + +everyone who was talking to me could obviously see. Also, the agents and attorneys obviously had a lot of evidence that provided + +proof of what Epstein had actually done. Epstein was still supporting me, providing me a lawyer and in my mind protecting me, so I was in + +a position where I felt I had to say certain things. And Epstein + +expected me to say those things. + +14. Once I wanted to cooperate and tried to cooperate, I was never + +given the opportunity to confer with prosecutors from the time they were informed by my attorney that I was a cooperating witness. I was never told about the secret deal until after it was already concluded. I + +would have had my attorney object if I had been given the chance. 15. I don't feel like I was treated fairly in this process. And I know + +Epstein got a really good plea deal because he is rich and powerful. + +That doesn't seem fair either. + +Executed this O h , day of January, 2015. + +EISENBERG & FOUTS, P.A. + +Attorneys At Law + +JAMES L EISENBERG + +Florida Bar Board Certified Criminal Trial Lawyer + +National Board Of Trial Advocacy Certified Criminal Trial Advocate + +KM LI ALOE FOUTS + +One Clearlake Centre, Suite 704,250 Australian Avenue South, West Palm Beach, FL 33401 Fax: + +September 21, 2006 + +Asst. U.S. Attorney + +500 South Australian Avenue, Suite 400 + +West Palm Beach, FL 33401 + +Re: =Subpoena fora + +Dear M, + +Please allow me to confirm my latest e-mail to you. I did receive your e-mail of last week with attachments and pegged them on to my client. At this time, I can only say that my client does not want to do ei q of your suggestions. She does not want to give a statement under the irnmuni ed with its Kastigar exception and she does not want to test + +5'h Amendment grounds. With this client, I am sorry, but I must have a formal grant + +of m it y f.re she will say anything. + +GOVERNMENT EXHIBIT + +EISENBERG & FOUTS, P.A. + +Attorneys At Law + +JAMES L EISENBERG + +0011alli Bar Board Cmilflui Criminal Thal Lawyer + +&Sakai Board Of Trial Advocacy Corilltrd Criminal Trial Advocate + +KAI LI ALOE POUTS + +OneClearlako Cenfro,Suito 704, 250 Australian Avenue So u lb, Wesi Palm Beach, FL 3340i Fax: + +February 12, 2007 + +Asst. U.S. Attorney + +500 South Australian Avenue, Suite 400 + +West Palm Reach, FL 33401 + +Re: + +Dear + +for + +As always, it was a pleasure speaking to you the other . Pursuant to out telephone conference I am writs this letter to ffer my concerns fo oul she testify without immunity before a Therefore, allow me to reiterate that U refuse to voltuttarily cooperate with the federal government. She has a good faith basis for position under the Fifth + +Amendment to the United States Constitution. + +We, of coins; do not live or work in a vacuum. We have read many inflammatory remarks the Town of Palm Beath Police Chief has made to the media about the state court's handling of the Jeffrey Epstein investigation. The police chiefs remarks frighten both myself and my client I am aware that the own police have prepared documents to charge at least one of Mr. Epstein's lady friends. in state court. If they can push to have one lady charged I remain unconvinced that they do not have the ability or political clout to push to have other ladies such as Ms charged. + +The proffered facts that raise my concerns are being provided via this proftbr letter. Pursuant to our telephone conference agreement, this letter and its contents cannot be used against Mr. NM + +MMIlis not at all certain of dates. She does remember meeting Mr. Epstein about three years ago. She is not certain of her age, it could have been when she was sixteen, A girlfriend asked her if she wanted a job giving massages. Ms..Magreed because she had knowledge of massages + +through her mother, who was a masseuse. + +Mt. went to Mr. Epstein's house via told. Ms. s girlfriend instructed Ms. hat, if asked, she had to tell Mr. Epstein that she was eighteen years old. The friend was nineteen years old and Illlooked old for her age, so passing for eighteen was not a problem. At + +the home Ms anet Mr. Epstein and later gave him a massage. The friend had told Ms. + +to give the message topless. Mr. Epstein told that if she were at all uncomfortable being topless, not to do it and it was not a requireme employment as a masseuse. Ms never touched Mr. Epstein in a sexual way and Mr. Epstein never touched Meat all. At one point, Mr. Epstein did ask Ms. !Cher age. Ms. Minsisted that she was eighteen years old. + +Msalicontinue,d to see Mr. Epstein over time and massages were given in a similar fashion. She was later asked If her friend ted to work in a similar way and she asked some girls who did give Mr. Epstein massages. M never asked to bring girls of any age to Mr. Epstein's home. When she did have her friends come over, she instructed all of them that if asked, they insist + +that they were eighteen years old. She is not certain at all of any of these girls' real ages. + +In summary, our concern is that if the government believes that Mr. Epstein committed some federal offense, then Ms could he considered a co-conspirator. We believe no crime was committed.. The Fifth Amendment was not intended to protect the guilty, however, It was enacted to protect citizens who fear prosecution notwithstanding their innocence. Our fear of any prosecution, + +especially ' ligh i f the Town police chiefs public remarks, is clearly in good faith. + +EISENBERG & FOUTS, P.A. + +Attorneys At Law + +JAMES L. EISENBERG + +Florida Bar Board Certified Criminal Mal Unger + +Nallonal Board Ot Trial Advocacy Certified Criminal Trial Advocate + +KM LI ALOE FOUTS + +One Clearlako Centre, Suite 704,250 Australian Avenue Soul li,West Palm Beach, F1,3340I + +February 1, 2007 + +Asst U.S. Attorney + +500 South Australian Avenue, Suite 400 + +West Palm Beach, FL 33401 + +Re: Grand Jury Subpoena fbiln + +Dear + +I received your letter dated January 24, 2007 with regard t Ji l I must admit I forced myself to wait several days to respond in order to "cool o l an no say anything I would regret + +later. Now that time has passed, allow me to respond appropriately. + +1. If you want to force Ms. IIII , to come to the to + +personally invoke her Fifth Amendment ri its she will be there. That does remain her position. My o st is that isovid . I will be there, but I am not paid t and Ms. should not have It is this type of attitude, that your office refuses to accept the fact that it is Ms s decision not to cooperate with the government + +that u sets her. office fails to recognize that merely coming to court is a problem for + +like Ms d, under these circumstances, appears to be a waste of time at best and, in + +her mind, persona unussment + +2. Rest assured that there is no conflict of interest in my representation of Ms In this + +ease I have always been asked and always will exercise independent judgment to follow my client's independent will. The remainder of your questions as to this matter are really none of the + +Government's business. + +3. 1 will share with you that one of the reasons for our firm position that Mr will + +invoke her Fifth Amendment right and choose not to voluntarily cooperate with the Government is + +our concern that the Government is not exercising independent judgment in this case. + +The history of this case has been in the newspapers. The case is being prosecuted in State court. Despite the state court prosecution, the Town of Palm Beach Police Chief went on what can only be + +U.S. Department of Justice + +United States Attorney Southern District ofFlorida + +DELIVERY BY HAND James L. Eisenberg, Esq. 250 S Australian Ave, Ste 704 West Palm Beach, FL 33401-5007 + +Dear Jim: + +500 South Australian Ave.. Suite 400 Wert Palm Beach, FL 33401 + +(\$61) 820-8711 Facsimile: + +January 24, 2007 + +Re: Federal- + +have enclosed a new subpoena fora + +As I mentioned earlier, Ms. s not a target of this investigation and the United + +Sta her testimony solely as a vie 'm/witness. During our last conversation regarding Ms you indicated that she was unwilling to speak with us pursuant to a Kastigar letter and that she also was unwilling to speak with the Mftand intends to invoke the Fifth Amendment if questioned. Please confer with her to confirm whether this remains her position. If it is, please advise in writing. Even if Ms. MU inclined to invoke her Fifth Amendment rights, she must still appear pursuant to the subpoena so that I may ask her questions that would not require the invocation of the Fifth Amendment. If she still invokes, I intend to move to compel her answers. If you or your client is unavailable on February 6, + +2007, please let me know of another Tuesday when you are available. + +I also am concerned about a potential conflict of intereatin your representation of Ms. In case of future litigation regarding this issue, please provide me with ilhimation i ng who is paying (directly Or indirectly) for your services on behalf of Ms. the + +scope of your representation and whether you are taking direction on this matter from anyone other than Ms.M. If any formal or informal:joint defense agreements exist, whether in writing or otherwise, please provide a copy of such agreements. lithe agreement + +is purely oral, please provide a written summer)/ of its terms. + +JAMES EISEN13ERG, ESQ. JANUARY 24, 2007 + +PAGE 2 + +I look forward to your response. + +Sincerely, + +R. Alexander Acosta nited States Attome + +By: + +Assistant United States Attorney + +This subpoena is issued upon application + +United States District Court SOUTHERN DISTRICT OF FLORIDA + +TO: a SUBPOENA TO TESTIFY + +SUBPOENA FOR: + +PERSON X DOCUMENTS OR OBJECTS] + +YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District + +Court at the place, date and time Specified below. + +PLACE: + +United States District Courthouse + +701 Clematis Street + +West Palm Beach, Florida 33401 + +ZOOM • + +DATE AND TIME: February 6, 2007 + +1100Pnit + +YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): + +\*Please coordinate your compliance with this subpoena and confirm the date and time , and location of our a earance with Special Aget , Federal Bureau of Investigation, Telephone: + +This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf + +of the court. + +DRIB: + +January 23, 2007 + +Name Address and Phone Number of Assistant U.S. Attorney + +Assistant U.S. Attorney + +500 So. Australian Avenue, Suite 400 West Pahnlle c FL 334014235 + +U.S. Department of J ustice + +United States Attorney Southern District of Florida + +500 South Australian Ave., Suite 400 Wert Palm Beach, FL 33401 + +(S60820-871/ Facsimile: + +February 5, 2007 + +DELIVERY BY HAND + +do James L. Eisenberg, Esq. 250 S Australian Ave, Ste 704 West Palm Beach, FL 33401-5007 + +Re: Testimony of + +Dear Ms... + +This letter confirms the understanding between yourself and the United States Attorney's + +Office for the Southern District of Florida. + +You have represented that you will truthfully answer questions of the federal government in + +its investigation of the procurement of prostitutes, amongst others. You will supply complete and truthful i o • a i o r is t e attorneys and law enforcement officers of the federal government and to any ich may conduct an investigation, as well as in any other proceeding rela to or growing out of this investigation. The obligation of tnithful disclosure includes your obligation to provide the attorneys and law enforcement officers of the federal government with any documents, records or other tangible evidence within your custody or control relating to the matters about which you are questioned. You will neither attempt to protect any person or entity through + +false information or omission, nor falsely implicate any person or entity. + +No statements provided by you on this date in this matter pursuant to this agreement will be + +offered into evidence in any eri mi nal case against you, except during aprosecution for perjury and/or giving a false statement. HoWever, i fit is determined that you have materially violated any provision of this agreement, all statements made by you shall be admissible in evidence against you in any + +proceeding. + +The federal government remains free to use information derived from the testimony directly or indirectly for the purpose of obtaining leads to other evidence, whic may e used against you. You expressly waive any right to claim that such evidence should not be introduced because it was obtained as a result of the grand Jury testimony. Furthermore, the federal government may use statements made in the grand jury testimony and all evidence derived directly or indirectly therefrom for the purpose of cross-examination, if you testify at any trial or if you + +FEBRUARY 5,2007 + +PAGE 2 + +suborn testimony that contradicts your prior statements and testimony. + +No additional promises, agreements and conditions have been entered into other than those + +set forth in this letter and none will bo entered into unless in writing and signed by all parties. + +Sincerely, + +R. Alexander Acosta United States Attorney + +PY: + +Assistant United States Attorney + +have read this agreement and discussed it with my attorney, and I hereby acknowledge that it + +fully sets forth my agreement with the office of the United States Attorney for the Southern District of Florida. I state that there have been no additional promises, agreements or representations made to me + +by any officials of the United States in connection with this matter. + +Dated: February 2007 + +West Palm Beach, Florida + +Witnessed by: + +James L Eisenber Bs . + +Attorney fo + +U.S. Department of Justice + +United States Attorney Southern District orlorida + +SOO South Australian Avo,'Suite400 West Palm Bleach, AL 33401 + +fracsItnt + +February 5, 2007 + +PELIVERY BY HAND James L. Eisenberg, Esq. 250.8 Australian Ave, Ste 704 West Palm Beach, FL 33401-5007 + +Rer + +Dear Mr. Eisenberg: + +I am writing to clarify the ground rules for• the interview with your client + +("your client"), to occur February , 2007. + +As I mentioned earlier, Ms. s not a target or subject of this investigation, but + +instead is being interviewed solely as a victim/vvitness. However, to address your concern aboµt criminal exposure, if your client complies with every provision of this agreement, then the United States Attorney's (Met for the Southern District of Florida ("this Office") will treat all statements made by your client during the interview as statements made pursuant to Rule 11(0 of the Fedora' Rules of Criminal Procedure. This is not a grant of immunity, which can be given only with approval of the Justice Department, but protects your client from having the statements made by her during the interview from being used against her directly. To guard against any misunderstandings concerning the interview of your client, + +this letter sets forth the terms of this agreement. . + +Your client agrees to be fully interviewed, that is, to provide information concerning + +your Client's knowledge of, and participation in criminal activity, including but not limited . to the procurenient of prostitutes: The protection,of till latter applies to an interview that will be conducted by this Office, Special Agents of the Federal Bureau of Investigation, and any other federal law enforcement agency this Office may require. Under this agreement, no information disclosed by your olient during the interView will be offered in evidence against her in any criminal or civil proceeding, provided that your• client complies with this agreement and that the information your client furnishes is truthfhlEcomplete, and accurate. + +If, however, your client gives materially false, incomplete, or misleading information; + +JAM MEER°, Pao. + +PAGE 2 + +then this Office may use such information in any matter or• proceeding and your client is subject to prosecution for perjury, obstruction of.justice, and making. false statements to. government agencies. Any such prosecution maybe based upon infoimation prOvided by your client during the course of the interview, and such infertnation, including your client's statements, will be admissible against your client in any grand jury or other proceeding. + +• The government also may use statements made by your client in the interview and all evidence derived directly or indirectly therefrom for the purpose of impeachment or cross-examination if she testifies at any trial or hearing, and/or in any rebuttal case against your client in a criminal trial in which she is a defendant or a witness. These provisions are necessary to ensure that your client does not make or offer any false representation or statement in any proceeding or to a government agency or commit perjury during any + +testimony. + +Your .client further agrees that attorneys for the United States may be present at the + +interview, and agrees not to seek.disqualification of any such government attorney from any + +proceeding or trial because'of their participation at the interview. ' + +The entire agreement.between the United States and your client is set forth in this + +letter. No additional promises, agreements, or conditions have been entered into and none + +will be entered into unless in writing and signed by all parties. + +If the foregoing accurately reflects- the understanding and •agreement between this + +Office and your client, it is requested that you and your client execute this letter as provided + +below. + +Sincerely, + +R. Alexander AcOsta United States Attorney + +By: + +Assistant United. States Attorney + +I have received this letter from my attorney, lames.L. Eisenberg, Esquire, have read + +it and discussed it with my attorney, and I hereby acknowledge that it fully sets forth my understanding andagreerbent with the Office of the United States Attorney for.the Southern + +James L. EISENBERG ESQ. + +RE: + +FEBRUARY 2, PAGE .3 + +District of Florida. I state that there have been no additional promises or representations made to me by any official of the United States Government or by my attorney in connection + +with this matter. + +Dated: + +Witnessed by: + +James L. Eisenberg, Esquire + +U.S. Department of Justice Authorization for Reimbursement + +of Unusual Expenses of Fact Witnesses + +Request for Unusual Expense(s) of Fact Witness (For United Stales Attorneys Office Use Only) + +Control if + +2. Court Docket Number Peen Illitfiriti Al LOA + +OU rig S. Contact Prim + +tms Pam + +1:1• ••••••••••• + +7. Witness Name & one 0. SSN 8. Vendor Name & Address, Phone It, TIN/SSN + +9. Payment t6 be made to: 10. Recelpt/invoice Is: + +11. Type of Unusual Expense: 12. Explanation: + +❑ Medically Necessary Item + +(Attached Supporting Statement) + +ID Excess Lodging/Per Diem ❑ Travel & Transportation ❑ Pretrial Conference Waiver + +❑ Other + +18. Start Date of Service (dOlDANR) + +2 41O 7 18. Juslifidabon: + +14. End Date of Service (MO/DANR) + +2-4 /0 7 + +15. Amount + +17.1 hereby certify that the expenses and services listed on this docuMent are appropriate and are within the Federal laws and regulations. I fully understand that I can be held personally gable or besubject to disciplinary action for Improperly using + +government funds or services that exceed delegated authority or that violate Federal laws or regulations. + +Signature of Requesting AUSA Data + +18. Nellie& Title of Approving Official 19. Date (MO/DANR) 20. Signature of Approving Official + +IN RE: + +SEALED ORDER + +On Application of the United States Attorney for the Southern District of Florida, and it + +appearing to the satisfaction of the Court: + +1. That has been called to testify and to provide other information before + +. the United States District Court for the Southern District of Florida, + +and + +2. That in the judgment of the said United States Attorney, 'as refused + +to testify and provide other information on the basis of her privilege against self-incrimination; and + +3. That in the judgment of the said United States Attorney, the testimony and other + +information from may be necessary to the public interest; and + +4. That the aforesaid Application has been made with the approval of the Assistant + +Attorney General in charge of the Criminal Division of the Department of Justice or a duly + +. . + +designated Acting Assistant Attorney General, pursuant to the authority vested in him by Title 18, + +United States Code, Section 6003, and Title 28, Code of Federal Regulations, Sections 0.175 and + +0.132(e). + +NOW, THEREFORE, it is ordered pursuant to Title 18, United States Code, Section 6002, + +.1 + +provide on the basis of her privilege against self-incrimination, as to all matters about which she may + +be interrogated before said United States District Courtl + +as well as any subsequent proceeding or trial. + +However, no testimony or other information compelled under this Order (or any information + +directly or indirectly derived from such testimony or other information) may be used againstMI + +in any criminal case, except a prosecution for perjury, giving a false statement, or otherwise + +failing to comply with this Order. + +IT IS FURTHER ORDERED the this Order shall be SEALED in accordance with Fed. + +R. Crim. P. 6(e)(6), except that a copy of this Order shall be provided to counsel for the United + +States, who may disclose the existence of the Order to the witness, + +to counsel for the witness, and to law enforcement officers engaged in the investigation + +Those persons may review the Order, but may not retain a copy of the Order, + +nor may they disclose the existence of the Order to any others. + +DONE and ORDERED this /.' day of + +cc: AUSA + +DONALD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE + +FGJ NO. 07-103 (WPB) + +IN RE: + +GRAND JURY PROCEEDINGS + +SEALED ORDER + +This matter comes before the Court on the United States' Sealed Motion for Permission to + +Disclose Grand Jury Material. The Court has considered the Motion and attachments thereto, and + +finds that the United States has shown a "particularized need" for the limited disclosure of + +materials related to matters occurring before the Grand Jury. The Court further finds that the + +United States has shown that: (1) the materials are needed to avoid an injustice in another + +proceeding, that is, Jane Doe 1 and Jane Doe 2 v. United States, S.D. Fla. Case No. 08-80736- + +Civ-Marra; (2) the need for disclosure is greater than the need for continued secrecy; and (3) the + +request is structured to cover only needed materials. + +Accordingly, the United States Attorney's Office for the Southern District of Florida may + +disclose Exhibit 7 to its Motion for Permission to Disclose Grand Jury Material, and file those in + +the public portion of the Court file in S.D. Fla. Case No. 08-80736-Civ-Marra. + +Furthermore, Exhibits 4, 5, and 6 to the government's Sealed Motion for Permission to + +Disclose Grand Jury Material are already part of the public portion of the Court file in S.D. Fla. + +Case No. 08-80736-Civ-Marra. The government has not sought to remove them from the public + +portion of that Court file, and they remain part of the public record in that matter. + +IT IS SO ORDERED. + +DONE AND ORDERED in chambers this day of May, 2017, at West Palm Beach, + +Florida. + +DANIEL T. K. 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b/marker2/ds9/EFTA00086518/EFTA00086518.md new file mode 100644 index 0000000000000000000000000000000000000000..4b87351be23f07af83eceb2473ad6fd77dc3f6ac --- /dev/null +++ b/marker2/ds9/EFTA00086518/EFTA00086518.md @@ -0,0 +1,152 @@ +**From:** [REDACTED] <[REDACTED]> +**To:** [REDACTED] <[REDACTED]>, "[REDACTED]" +<[REDACTED]> +**Cc:** "[REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED]" +[REDACTED])" <[REDACTED]> + +**Subject:** RE: Epstein + +**Date:** Mon, 26 Jul 2021 20:29:29 +0000 + +**Inline-Images:** image002.jpg; image006.jpg; image007.jpg; image008.jpg; image009.gif + +--- + +I will certainly assist if I am able. + +[REDACTED] + +Director/Investigations +American Express Global Security +New York Office +200 Vesey St, +New York, NY 10285-010201 + +Direct Line: [REDACTED] + +Fax: [REDACTED] + +![](_page_0_Picture_139.jpeg) + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Monday, July 26, 2021 4:21 PM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: Epstein + +Hello, + +The documentation that the FIU produces is for SAR supporting documentation and are not certified records. I believe [REDACTED] in Global Security did certify records that he provided you so he may be able to help you with your questions. + +[REDACTED] – can you assist? Let me know if I can help with anything. + +Thank you, + +[REDACTED] + +[REDACTED] | MANAGER - SPECIAL INVESTIGATIONS +FINANCIAL INTELLIGENCE UNIT +AMERICAN EXPRESS +18850 N. 56th Street | PHOENIX, AZ 85058 +MAIL CODE: AZ08-02-04 +O: [REDACTED] | E: [REDACTED] + +From: + +Subject: (External] RE: Epstein + +Hi + +Hope all is well with you. Are you available for a call sometime early next week? I was hoping to ask you a few questions to follow up on an earlier document production. + +Thanks very much, + +Assistant United States Attorney + +Southern District of New York + +One Saint Andrew's Plaza + +New York, NY 10007 + +From: + +Sent: Monday, June 29, 2020 11:08 AM + +To: >; > + +Cc: Yui Cheung Chow • >; + +Subject: RE: Epstein + +Hello, + +Hope all is going well for you! When I open the link for the subpoena, it says it is not available. + +I MANAGER - SPECIAL INVESTIGATIONS + +FINANCIAL INTELLIGENCE UNIT + +AMERICAN EXPRESS + +18850 N. 56th Street I PHOENIX, AZ 85058 + +MAIL CODE: AZ08.02.04 + +O: I E: + +![](_page_1_Picture_30.jpeg) + +![](_page_1_Picture_31.jpeg) + +From: + +Sent: Monday, June 29, 2020 6:33 AM + +To: + +Cc: Yui Cheung Chow • > + +>; > + +Subject: RE: Epstein + +![](_page_2_Picture_0.jpeg) + +r PA RTNI ENT, JUSTICE + +![](_page_2_Picture_2.jpeg) + +This is a secure message. + +Click here by 2020-07-09 13:33 UTC to read your message. + +After that, open the attachment. + +More Info + +Disclaimer: This email and its content are confidential and intended solely for the use of the addressee. Please notify the sender if you have received this email in error or simply delete it. + +Secured by Proofpoint Encryption, Copyright 2009.2019 Proofpoint, Inc. All rights reserved + +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 + +Ce courrier et toute piece jointe qu'il contient sont reserves au seul destinataire indique et peuvent contenir des renseignements confidentiels et privilegies. Si vous n'etes pas le destinataire prevu, toute divulgation, duplication, utilisation ou distribution du courrier ou de toute piece jointe est interdite. Si vous avez regu cette communication par erreur, veuillez nous en aviser par courrier et detruire immediatement le courrier et les pieces jointes. Merci. + +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." + +renseignements confidentiels et privilégiés. Si vous n'êtes pas le destinataire prévu, toute divulgation, duplication, utilisation ou distribution du courrier ou de toute pièce jointe est interdite. Si vous avez reçu cette communication par erreur, veuillez nous en aviser par courrier et détruire immédiatement le courrier et les pièces jointes. 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Could we plan to speak at 4:30 tomorrow afternoon? Is the direct line below the best number to reach you? + +From: + +Sent: Monday, July 26, 2021 5:23 PM + +To: Ic >; + +Cc: (USANYS) + +Subject: RE: Epstein + +Yes, all day. + +Director/Investigations American Express Global Security New York Office 200 Vesey St, New York, NY 10285-010201 Direct Line: Fax: + +![](_page_0_Picture_16.jpeg) + +From: + +Sent: Monday, July 26, 2021 4:34 PM + +To: + +Cc: (USANYS) < + +Subject: (External] RE: Epstein + +Thanks very much. My question is about additional records we may be seeking, based on what we've learned from the prior production. It would be helpful to talk through the categories of materials we are seeking, to get a sense of what records American Express might have. Are you available for a call tomorrow to discuss? + +Sent: Monday, July 26, 2021 4:29 PM + +To: + +Cc: (USANYS) < >; + +Subject: RE: Epstein + +I will certainly assist if I am able. + +Director/Investigations + +American Express Global Security + +New York Office + +200 Vesey St, + +New York, NY 10285-010201 + +Direct Line: + +Fax: + +![](_page_1_Picture_14.jpeg) + +From: + +Sent: Monday, July 26, 2021 4:21 PM + +To: + +Cc: (USANYS) > + +Subject: RE: Epstein + +Hello, + +The documentation that the Fill produces is for SAR supporting documentation and are not certified records. I believe in Global Security did certify records that he provided you so he may be able to help you with your questions. + +— can you assist? Let me know if I can help with anything. + +Thank you, + +I MANAGER - SPECIAL INVESTIGATIONS FINANCIAL INTELLIGENCE UNIT AMERICAN EXPRESS + +18850 N. 56th Strcct I PHOENIX. AZ 85058 + +MAIL CODE: AZ08.02-04 + +O: I E: + +From: + +Sent: Friday, July 23, 2021 3:16 PM + +Hope all is well with you. Are you available for a call sometime early next week? I was hoping to ask you a few questions to follow up on an earlier document production. + +Thanks very much, + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 + +From: + +Sent: Monday, June 29, 2020 11:08 AM + +To: >; > + +Cc: >; + +Subject: RE: Epstein + +Hello, + +Hope all is going well for you! When I open the link for the subpoena, it says it is not available. + +I MANAGER - SPECIAL INVESTIGATIONS FINANCIAL INTELLIGENCE UNIT AMERICAN EXPRESS + +18850 N. 56th Street I PHOENIX, AZ 85058 + +MAIL CODE: AZ08-02-04 + +O: I E: + +![](_page_2_Picture_19.jpeg) + +![](_page_2_Picture_20.jpeg) + +Sent: Monday, June 29, 2020 6:33 AM + +To: + +Cc: > + +Subject: RE: Epstein + +![](_page_2_Picture_27.jpeg) + +DEPARTMENT,JUSTICE + +![](_page_2_Picture_29.jpeg) + +More Info + +Disclaimer: This email and its content are confidential and intended solely for the use of the addressee. Please notify the sender if you have received this email in error or simply delete it. + +Secured by Proofpoint Encryption, Copyright fED 2009-2019 Proofpoint, Inc. All rights reserved + +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 + +Ce courrier et toute piece jointe qu'il contient sont reserves au seul destinataire indique et peuvent contenir des renseignements confidentiels et privilegies. Si vous n'etes pas le destinataire prevu, toute divulgation, duplication, utilisation ou distribution du courrier ou de toute piece jointe est interdite. Si vous avez regu cette communication par erreur, veuillez nous en aviser par courrier et detruire immediatement le courrier et les pieces jointes. Merci. + +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 + +Ce courrier et toute piece jointe qu'il contient sont reserves au seul destinataire indique et peuvent contenir des renseignements confidentiels et privilegies. Si vous n'etes pas le destinataire prevu, toute divulgation, duplication, utilisation ou distribution du courrier ou de toute piece jointe est interdite. Si vous avez regu cette communication par erreur, veuillez nous en aviser par courrier et detruire immediatement le courrier et les pieces jointes. Merci. + +American Express made the following annotations + +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 + +Ce courrier et toute piece jointe qu'il contient sont reserves au seul destinataire indique et peuvent contenir des renseignements confidentiels et privilegies. Si vous n'etes pas le destinataire prevu, toute divulgation, duplication, utilisation ou distribution du courrier ou de toute piece jointe est interdite. Si vous avez rep cette communication par erreur, veuillez nous en aviser par courrier et detruire immediatement le courrier et les pieces jointes. 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Mon, 26 Jul 2021 21:33:01 +0000 + +Inline-Images: image001.jpg; image002.jpg; image004.jpg; image005.jpg; image006.gif + +Yes and yes. + +Director/Investigations + +American Express Global Security + +New York Office + +200 Vesey St, + +New York, NY 10285-010201 + +Direct Line: + +Fax: + +![](_page_0_Picture_16.jpeg) + +From: + +Sent: Monday, July 26, 2021 5:26 PM + +To: + +Cc: (USANYS) + +Subject: (External] RE: Epstein + +Thanks very much. Could we plan to speak at 4:30 tomorrow afternoon? Is the direct line below the best number to reach you? + +From: + +Sent: Monday, July 26, 2021 5:23 PM + +To: I 'c s; + +Cc: (USANYS) ; + +Subject: RE: Epstein + +Yes, all day. + +Director/Investigations + +American Express Global Security + +Direct Line: + +Fax: + +![](_page_1_Picture_3.jpeg) + +From: + +Sent: Monday, July 26, 2021 4:34 PM + +To: + +Cc: (USANYS) < + +Subject: (External] RE: Epstein + +Thanks very much. My question is about additional records we may be seeking, based on what we've learned from the prior production. It would be helpful to talk through the categories of materials we are seeking, to get a sense of what records American Express might have. Are you available for a call tomorrow to discuss? + +Thanks, + +From: + +Sent: Monday, July 26, 2021 4:29 PM + +To: + +Cc: (USANYS) + +Subject: RE: Epstein + +I will certainly assist if I am able. + +Director/Investigations + +American Express Global Security + +New York Office + +200 Vesey St, + +New York, NY 10285-010201 + +Direct Line: + +Fax: + +![](_page_1_Picture_26.jpeg) + +From: + +Sent: Monday, July 26, 2021 4:21 PM + +The documentation that the FIU produces is for SAR supporting documentation and are not certified records. I believe in Global Security did certify records that he provided you so he may be able to help you with your questions. + +— can you assist? Let me know if I can help with anything. + +Thank you, + +I MANAGER - SPECIAL INVESTIGATIONS FINANCIAL INTELLIGENCE UNIT AMERICAN EXPRESS + +18850 N. 56th Street I PHOENIX, AZ 85058 + +MAIL CODE: AZ08.02-04 + +O: I E: + +From: + +Sent: Friday, July 23, 2021 3:16 PM + +To: + +Cc: (USANYS) + +Subject: [External] RE: Epstein + +Hi + +Hope all is well with you. Are you available for a call sometime early next week? I was hoping to ask you a few questions to follow up on an earlier document production. + +Thanks very much, + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 + +From: + +Sent: Monday, June 29, 2020 11:08 AM + +To: > + +Cc: > >; + +Subject: RE: Epstein + +Hello, + +Hope all is going well for you! When I open the link for the subpoena, it says it is not available. + +![](_page_3_Picture_4.jpeg) + +![](_page_3_Picture_5.jpeg) + +Sent: Monday, June 29, 2020 6:33 AM + +To: + +Cc: + + + +Subject: RE: Epstein + +![](_page_3_Picture_12.jpeg) + +D EPA RTMENT,JUSTICE + +![](_page_3_Picture_14.jpeg) + +This is a secure message. + +Click here by 2020-07-09 13:33 UTC to read your message. + +After that, open the attachment. + +More Info + +Disclaimer: This email and its content are confidential and intended solely for the use of the addressee. Please notify the sender if you have received this email in error or simply delete it. + +Secured by Proofpoint Encryption, Copyright (0 2009.2019 Proofpoint, Inc. All rights reserved. + +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 ajouto le commentaire suivant + +Ce courrier et toute piece jointe qu'il contient sont reserves au seul destinataire indique et peuvent contenir des renseignements confidentiels et privilegies. Si vous n'etes pas le destinataire prevu, toute divulgation, duplication, utilisation ou distribution du courrier 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. + +"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 ajouté le commentaire suivant + +Ce courrier et toute pièce jointe qu'il contient sont réservés au seul destinataire indiqué et peuvent contenir des renseignements confidentiels et privilégiés. Si vous n'êtes pas le destinataire prévu, toute divulgation, duplication, utilisation ou distribution du courrier ou de toute pièce jointe est interdite. Si vous avez reçu cette communication par erreur, veuillez nous en aviser par courrier et détruire immédiatement le courrier et les pièces jointes. Merci. + +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 ajouté le commentaire suivant + +Ce courrier et toute pièce jointe qu'il contient sont réservés au seul destinataire indiqué et peuvent contenir des renseignements confidentiels et privilégiés. Si vous n'êtes pas le destinataire prévu, toute divulgation, duplication, utilisation ou distribution du courrier ou de toute pièce jointe est interdite. Si vous avez reçu cette communication par erreur, veuillez nous en aviser par courrier et détruire immédiatement le courrier et les pièces jointes. Merci. + +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 ajouté le commentaire suivant + +Ce courrier et toute pièce jointe qu'il contient sont réservés au seul destinataire indiqué et peuvent contenir des renseignements confidentiels et privilégiés. Si vous n'êtes pas le destinataire prévu, toute divulgation, duplication, utilisation ou distribution du courrier ou de toute pièce jointe est interdite. Si vous avez reçu cette communication par erreur, veuillez nous en aviser par courrier et détruire immédiatement le courrier et les pièces jointes. 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+From: Sent: Thursday, July 29, 2021 5:47 PM + +To: Subject: Trial Subpoena + +Hi and M, + +We want to track down school records for Attached is a subpoena to the school. I listed the phone number I found on the website ( It looks like there may be a Student Records department in case that is helpful ). Would you please make contact and serve the subpoena? To the extent they raise confidentiality issues, you can have them contact me. Please let me know if you have any questions. + +Thanks very much, + +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/EFTA00086533/EFTA00086533.metadata.json b/marker2/ds9/EFTA00086533/EFTA00086533.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a946746d96f90907b89b1a8cfeef99ae81a0b126 --- /dev/null +++ b/marker2/ds9/EFTA00086533/EFTA00086533.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086533.pdf", + "engine": { + "marker_major": "2", + "marker_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": 771, + "elapsed_seconds": 0.63, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 24 + ], + [ + "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/EFTA00086533" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086534/EFTA00086534.md b/marker2/ds9/EFTA00086534/EFTA00086534.md new file mode 100644 index 0000000000000000000000000000000000000000..74a77fb3d64007477df811d181124516f5d70e16 --- /dev/null +++ b/marker2/ds9/EFTA00086534/EFTA00086534.md @@ -0,0 +1,27 @@ +## PnitetratatesPistria Court SOUTHERN DISTRICT OF NEW YORK + +TO: + +![](_page_0_Picture_3.jpeg) + +## GREETINGS: + +WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before the United States District Court for the Southern District of New York, 40 Foley Square, in the Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the following date, time and place: + +Appearance Date: November 29, 2021 Appearance Time: 9:00 a.m. Appearance Place: 40 Foley Square, Courtroom 906 to testify and give evidence in the following matter: + +## United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +and not to depart the Court without leave thereof, or of the United States Attorney, and that you bring with you and produce at the above time and place the following: + +Records, includin but not limited to registration paperwork and student files, reflecting the dates of enrollment at for the following student: + +- • + +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 Jul 30 2021 + +![](_page_0_Picture_13.jpeg) + +![](_page_0_Picture_14.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00086534/EFTA00086534.metadata.json b/marker2/ds9/EFTA00086534/EFTA00086534.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d98ebc5f45972e65611665d74726d3b82aa156e3 --- /dev/null +++ b/marker2/ds9/EFTA00086534/EFTA00086534.metadata.json @@ -0,0 +1,148 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086534.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1276, + "elapsed_seconds": 0.81, + "image_assets": [ + "_page_0_Picture_3.jpeg", + "_page_0_Picture_13.jpeg", + "_page_0_Picture_14.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "PnitetratatesPistria Court \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 186.048, + 91.53 + ], + [ + 432.9361572265625, + 91.53 + ], + [ + 432.9361572265625, + 129.603515625 + ], + [ + 186.048, + 129.603515625 + ] + ] + }, + { + "title": "GREETINGS:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 56.304, + 224.37 + ], + [ + 132.25616455078125, + 224.37 + ], + [ + 132.25616455078125, + 239.4735107421875 + ], + [ + 56.304, + 239.4735107421875 + ] + ] + }, + { + "title": "United States v. 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On the penalties: + +Title 18, United States Code, Section 2423 (transportation of minors) – maximum penalty is 10 years' imprisonment +Title 18, United States Code, Section 2422 (coercion and enticement) – maximum penalty is 5 years' imprisonment +Title 18, United States Code, Section 1591 (sex trafficking) – maximum penalty is 40 years' imprisonment + +--- + +**From:** [REDACTED] (CRM) < [REDACTED] (CRM) +**Sent:** Thursday, August 12, 2021 5:49 AM +[REDACTED] < [REDACTED] >; [REDACTED] < [REDACTED] (USANYS) < [REDACTED] (CRM) +**Cc:** [REDACTED] (CRM) +**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. 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 statements of counsel that the witness has consented. + +1. 2. Which [REDACTED] did the witness apply to and what was the year of her application/attendance? + +[REDACTED] + +1. 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 MLA requests relates to a broader investigation. + +1. 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 be greater than one year and less than life (with no death penalty involved), so is there a need to be more precise? + +![](_page_1_Picture_1.jpeg) + +United States Embassy 33 Nine Elms Lane London SW11 7US + +![](_page_1_Picture_3.jpeg) + +From: (CRM) + +Sent: Thursday, August 12, 2021 9:03 AM + +To: + +(U + +C (CRM) (CRM) + +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, Witness. 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, + +![](_page_1_Picture_17.jpeg) + +![](_page_1_Picture_20.jpeg) + +![](_page_2_Picture_1.jpeg) + +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 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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Will likely be here til noon, so you should go ahead without me. + +On Aug 12, 2021, at 11:02 AM, [REDACTED] (USANYS) [REDACTED] > wrote: + +One/both of you free to try [REDACTED]? + +--- + +**From:** [REDACTED] (CRM) [REDACTED] +**Sent:** Thursday, August 12, 2021 10:58 AM +**To:** [REDACTED] (USANYS) [REDACTED] [REDACTED] +**Subject:** RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and America' + +Sorry - Just getting through the piles of email. I am around for the next hour or so, then later tonight. Anything soon work for you? + +Thx + +--- + +[REDACTED] +*U.S. Department of Justice Attaché - London* + + + +United States Embassy +[REDACTED] +London SW11 7US + +[REDACTED] + +From: IUSANYS Sent: Thursday, August 12, 2021 1:53 PM To: c: (CRM) Subject: RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators straining relations between UK and America' + +We just tried you. Is there a good time for you to connect this morning? + +Thanks, + +From: (CRM) Sent: ursday, August 12, 2021 4:03 AM To: Cc: (CRM) (CRM) 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, 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 soft this out. + +Thanks, + + + +United States Embassy + +London SW I I 7US + +![](_page_2_Picture_4.jpeg) + +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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STERNHEIM, ESQ. + +Law Offices of Bobbi C. Sternheim + +[REDACTED] +[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. + +It is my understanding that the new MDC Zoom platform does not preclude third parties who have the access information + +to the Zoom "Courtroom" from interfering (inadvertently or intentionally) with Ms. Maxwell's privileged communication. \ No newline at end of file diff --git a/marker2/ds9/EFTA00086543/EFTA00086543.metadata.json b/marker2/ds9/EFTA00086543/EFTA00086543.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9efe98a5b7641208883679d8597aed2b526d443a --- /dev/null +++ b/marker2/ds9/EFTA00086543/EFTA00086543.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086543.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1906, + "elapsed_seconds": 7.62, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Text", + 61 + ], + [ + "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", + 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/EFTA00086543" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086545/EFTA00086545.md b/marker2/ds9/EFTA00086545/EFTA00086545.md new file mode 100644 index 0000000000000000000000000000000000000000..8bdee19a2473cf191e4630f4f27595bb0420b825 --- /dev/null +++ b/marker2/ds9/EFTA00086545/EFTA00086545.md @@ -0,0 +1,144 @@ +From: To: (USANYS)' CRM " + +Subject: RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators straining relations between UK and America' + +Date: Thu, 12 Aug 2021 17:00:33 +0000 + +Attachments: 2021.07.30\_Order\_Regarding\_Local\_Rule\_23.1.pdf + +Inline-Images: image001.png + +As discussed, attached is the order from Judge Nathan regarding Local Criminal Rule 23.1. + +Best, + +From: l' (CRM) Sent: Thursda , Au ust 12, 2021 11:14 AM + +To: USANYS ) < + +Subject: RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and America' + +I will dial in in 5 minutes. + +U.S. aepartment oj Justice Attaché - London + +![](_page_0_Picture_12.jpeg) + +United States Embassy + +London SW11 7US + +From: (USANYS) Sent: Thursday, August 12, 2021 4:12 PM + +To (CRM) + +Subject: RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and America' + +From (CRM) MINIMM + +Sent: Thursday, August 12, + +To: (USANYS) + +Subject: RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and America' + +Sorry - Just getting through the piles of email. I am around for the next hour or so, then later tonight. Anything soon work for you? + +Thx + +U.S. Department of Justice Attaché - London + +![](_page_1_Picture_8.jpeg) + +United States Embassy + +London SW11 7US + +From: USANYS) + +Sent: Thursday, August 12, 2021 1:53 PM + +(CRM) + +Cc: '(CRM) , (CRM) + +Subject: RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and America' + +We just tried you. Is there a good time for you to connect this morning? + +Thanks, + +From: (CRM) + +Sent: T urs ay, August 12, 2021 4:03 AM + +To: + +(USANYS) + +Cc: (CRM) (CRM) + +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] + +--- + +[REDACTED] +*U.S. Department of Justice Attaché - London* + +![](_page_2_Picture_113.jpeg) + +United States Embassy +[REDACTED] +London SW11 7US + +[REDACTED] + +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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NATHAN, District Judge: + +The Government has moved for an order requiring David Markus to comply with Local Criminal Rule 23.1 following an op-ed that he authored opining on the merits of this pending case. Dkt. No. 309. + +Mr. Markus is plainly a lawyer associated with the defense in this case. His formal representation has involved handling at least one pre-trial issue for Ms. Maxwell—in particular, appeals to the Second Circuit of this Court's bail-denial determinations. Dkt. No. 173; see also United States v. Maxwell, Nos. 21-58-cr(L), 21-770-cr (2d Cir.). Beyond that, he has held himself out as Ms. Maxwell's attorney in press related to the current trial stage, including in the op-ed at issue in the Government's letter application, which describes him as "Maxwell's appellate counsel." He has also attended a proceeding in this matter and spoken on Ms. Maxwell's behalf to the press afterwards while identified as Ms. Maxwell's attorney. See Stephen Rex Brown, Ghislaine Maxwell Makes First In-Person NYC Court Appearance, N.Y. Daily News (Apr. 23, 2021), https://www.nydailynews.cornrnew-yorkrny-ghislaine-maxwellarraignment-20210423-b3aza5eh7bddna7r247px2yb7e-story.html. + +Nevertheless Mr. Markus argues that he is not subject to Rule 23.1 because he does not currently represent Ms. Maxwell in any proceedings and has not made an appearance in this + +Court. Dkt. No. 314. Rule 23.1 is not so superficial nor easily circumvented. Nothing in the rule limits its application to lawyers who have formally noticed an appearance. To the contrary, as the text throughout the rule makes clear, it applies to statements made by lawyers (and others) "associated" with "pending or imminent criminal litigation." S.D.N.Y. Local Criminal Rule 23.1(a) (last updated Oct. 29, 2018); see also Rule 23.1(b) ("a lawyer participating in or associated with the investigation"); Rule 23.1(c) ("lawyer or law firm associated with the prosecution or defense"). An attorney need not be of record in order to be sufficiently "associated" with a case as to justify application of disciplinary rules regarding extrajudicial statements. Lawyers who have not filed a formal notice of appearance may still possess information that lends a perception by the public that their remarks on a pending case hold greater authority. See In re Hinds, 449 A.2d 483, 496 (N.J. 1982); see also People v. Buttafiroco, 599 N.Y.S.2d 419 (Nassau Cty. Ct. 1993). + +Such is the case with Mr. Markus's role in the pending matter. As noted, Mr. Markus has attended a proceeding in this Court, after which he spoke to the press on Ms. Maxwell's behalf. He has represented Ms. Maxwell on appeals of this Court's pre-trial bail determinations. Moreover, Mr. Markus has identified himself as Ms. Maxwell's appellate lawyer in a published op-ed discussing his opinion of the merits of this case. These facts mean that the public, which includes potential jurors, may perceive Mr. Markus as an authoritative source of information regarding the pending matter and may readily consider his remarks to be accurate and reliable. Mr. Markus is therefore ORDERED to comply with Local Criminal Rule 23.1. + +The Government does not ask the Court to discipline Mr. Markus based on his op-ed and the Court declines to consider whether it violated Rule 23.1 given the potential lack of clarity with respect to whether Mr. Markus was bound by the rule. The Court emphasizes that the rule + +provides illustrative examples of statements that "presumptively involve a substantial likelihood that their public dissemination will interfere with a fair trial or otherwise prejudice the due administration of justice within the meaning of the rule." S.D.N.Y. Local Criminal Rule 23(d). + +Going forward, Mr. Markus and all lawyers associated with the pending case are now clearly on notice that their conduct falls under the purview of Local Criminal Rule 23.1. Indeed, the above concerns do not apply only to Mr. Markus. This Court has previously noted that "counsel[,] agents for the parties and counsel for potential witnesses" must take care to "protect the Defendant's right to a fair trial by an impartial jury." Dkt. No. 28. This Court is cognizant that criminal matters heading toward trial are especially sensitive to extrajudicial statements. All those associated with this case must act to ensure the case is tried solely in court or else they risk being deemed responsible for any trial delay or for undermining the integrity of the upcoming trial. See S.D.N.Y. Local Criminal Rule 23.1(h). In addition to the impact it could have on this matter, failure to comply could also result in attorney discipline. Id. Rule 23.1(i). + +SO ORDERED. + +Dated: July 30, 2021 + +New York, New York ASLA (d i + +ALISON J. NATHAN United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00086550/EFTA00086550.metadata.json b/marker2/ds9/EFTA00086550/EFTA00086550.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fd09269de61b605e38676a49ac49c1802365df58 --- /dev/null +++ b/marker2/ds9/EFTA00086550/EFTA00086550.metadata.json @@ -0,0 +1,164 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086550.pdf", + "engine": { + "marker_major": "2", + "marker_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": 4972, + "elapsed_seconds": 0.89, + "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, 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(The New York Times Customer Care)" + +Date: July 28, 2021 at 9:23:15 PM EDT + +Cc: + +Subject: Jeffrey Epstein & Chislaine Maxwell: + +Reply-To: The New York Times Customer Care + +It k- Please type your reply above this line -0 0 + +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) + +Dear Richard, + +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 nytnews@nytimes.com. They will be delighted to better help you! + +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. + +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 8393 Pardee Hollow Road Wayland, New York 14572 Phone 585-728-3074 Fax 585-728-3746 + +From: + +Sent: Wednesday, July 21,2021 2:24 PM + +To: curtissway@gmail.com + +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 Audrey Strauss 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 + +8393 Pardee Hollow Road + +Wayland, New York 14572 + +Phone 585-728-3074 + +Fax 585-728-3746 + +From: + +Sent: Sunday, July 11, 2021 7:05 PM + +To: curtissway@gmail.com + +Subject: Re: Federal Courts: + +This is too narrow a topic for us. This stuff goes on all over the place. It's a local news story. + +The world is filled with huge corruption which takes up all of our resources. + +Good luck. + +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 + +Richard C. Curtiss +8393 Pardee Hollow Road +Wayland, New York 14572 +Phone 585-728-3074 +Fax 585-728-3746 + +From: [REDACTED] + +Sent: Friday, January 15, 2016 8:16 AM + +To: Richard C Curtiss + +Cc: [REDACTED] +[REDACTED] +[REDACTED] + +Subject: Re: Supreme Court Submission: Judicial Conduct + +Good morning - + +I've been in touch with the marshals this morning and forwarded to [REDACTED] 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. + +[REDACTED] + +Clerk of the Second Circuit Court of Appeals + +From: [REDACTED] <[REDACTED]> +Sent: Friday, January 15, 2016 7:59 AM +To: Richard C Curtiss <[curtissway@gmail.com](mailto:curtissway@gmail.com)> +Subject: Re: Electronic Filling, Western District of New York + +Dear Mr. Curtiss - + +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, + +[REDACTED] + +Second Circuit + +Agency Appeals + +agencycases@ca2.uscourts.gov + +212-857-8544 + +Attorney Admissions + +admissions@ca2.uscourts.gov + +212-857-8603 + +212-857-8640 + +Calendar + +212-857-8595 + +Case Initiation + +newcases@ca2.uscourts.gov + +212-857-8551 + +Case Closing + +caseclosing@ca2.uscourts.gov + +212-857-8560 + +Civil Appeals + +civilcases@ca2.uscourts.m + +212-857-8576 + +Criminal/Prisoner Appeals + +criminalcases@ca2.uscourts.m + +212-857-8515 + +Helpdesk (CM/ECF) + +ecfhelpdesk@ca2.uscourts.gov + +212-857-8630 + +Records + +212-857-8620 + +To: RICHARD C. CURTISS + +Sent: Wednesday, February 03, 2016 4:49 PM + +Subject: AUTO: 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 + +Sent: Monday, September 16, 2019 11:13 AM + +To: CURTISSWAY@GMAIL.COM + +Subject: RE: City of New York - Correspondence #1-1-7159508 Message to Agency Head, OCME - Other + +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 for timely responses on media inquiries. + +Thanks, + +Office of the Chief Medical Examiner + +520 1st Avenue + +New York, NY 10016 + +212-447-2030 + +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 + +8393 Pardee Hollow Road + +Wayland, New York 14572 + +Phone 585-728-3074 + +Fax 585-728-3746 + +From: + +Sent: Wednesday, October 30, 2019 4:36 PM + +To: Richard Curtiss - + +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 2,2015 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 + +New York, NY 10007 + +646-836-6300 + +646-836-7673 (fax) + +"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' Me; 'House Speaker Nancy Pelosi' 'Congressman Jerrold Nadler (Judiciary Committee)' + +Cc: 'Senate Minority Leader Chuck Schumer' • 'General Counsel Keith Castaldo (Senator Gillibrand)' < ' + +Subject: RE: tSVUNSE. uovernment tmpioyee unions + +Dear Chairman Schiff, Chairman Nadler and House Speaker Pelosi: US House of Representatives + +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 8393 Pardee Hollow Road Wayland, New York 14572 Phone 585-728-3074 Fax 585-728-3746 + +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/EFTA00086554/EFTA00086554.metadata.json b/marker2/ds9/EFTA00086554/EFTA00086554.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..728f9131fcd331797496c93c9ceb01b00251258d --- /dev/null +++ b/marker2/ds9/EFTA00086554/EFTA00086554.metadata.json @@ -0,0 +1,352 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086554.pdf", + "engine": { + "marker_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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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 + +Dear Richard, + +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 [nytnews@nytimes.com](mailto:nytnews@nytimes.com). They will be delighted to better help you! + +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 + +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 + +8393 Pardee Hollow Road + +Wayland, New York 14572 + +Phone 585-728-3074 + +Fax 585-728-3746 + +From: jimwdean@aol.com + +Sent: Wednesday, July 21,2021 2:24 PM + +To: curtissway@gmail.com + +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 + +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 Audrey Strauss 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 8393 Pardee Hollow Road Wayland, New York 14572 Phone 585-728-3074 Fax 585-728-3746 + +From: jimwdean@aol.com + +Sent: Sunday, July 11, 2021 7:05 PM + +To: curtissway@gmail.com + +Subject: Re: Federal Courts: + +This is too narrow a topic for us. This stuff goes on all over the place. It's a local news story. + +The world is filled with huge corruption which takes up all of our resources. + +Good luck. + +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 8393 Pardee Hollow Road Wayland, New York 14572 Phone 585-728-3074 Fax 585-728-3746 + +From: + +Sent: Friday, January 15, 2016 8:16 AM + +Cc: [REDACTED] +[REDACTED] + +Subject: Re: Supreme Court Submission: Judicial Conduct + +Good morning - + +I've been in touch with the marshals this morning and forwarded to [REDACTED] 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. + +[REDACTED] + +Clerk of the Second Circuit Court of Appeals + +From: [REDACTED] <[REDACTED]> +Sent: Friday, January 15, 2016 7:59 AM +To: Richard C Curtiss <[curtissway@gmail.com](mailto:curtissway@gmail.com)> +Subject: Re: Electronic Filling, Western District of New York + +Dear Mr. Curtiss - + +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, + +[REDACTED] + +Clerk of Court + +U. S. Court of Appeals + +Second Circuit + +Agency Appeals +[agencycases@ca2.uscourts.gov](mailto:agencycases@ca2.uscourts.gov) + +212-857-8544 + +Attorney Admissions +[admissions@ca2.uscourts.gov](mailto:admissions@ca2.uscourts.gov) + +212-857-8603 +212-857-8640 + +212-857-8595 + +Case Initiation + +[newcases@ca2.uscourts.gov](mailto:newcases@ca2.uscourts.gov) + +212-857-8551 + +Case Closing + +[caseclosing@ca2.uscourts.gov](mailto:caseclosing@ca2.uscourts.gov) + +212-857-8560 + +Civil Appeals + +[civilcases@ca2.uscourts.gov](mailto:civilcases@ca2.uscourts.gov) + +212-857-8576 + +Criminal/Prisoner Appeals + +[criminalcases@ca2.uscourts.gov](mailto:criminalcases@ca2.uscourts.gov) + +212-857-8515 + +Helpdesk (CM/ECF) + +[ecfhelpdesk@ca2.uscourts.gov](mailto:ecfhelpdesk@ca2.uscourts.gov) + +212-857-8630 + +Records + +212-857-8620 + +----- Original Message ----- + +From: + +[REDACTED] + +To: RICHARD C. CURTISS <[curtissway@gmail.com](mailto:curtissway@gmail.com)> + +Sent: Wednesday, February 03, 2016 4:49 PM + +Subject: AUTO: [REDACTED] 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. + +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: Worthy-Davis, Aja (OCME) On Behalf Of OCME Website Mail (OCME) + +Sent: Monday, September 16,2019 11:13 AM + +To: CURTISSWAY@GMAIL.COM + +Subject: RE: City of New York - Correspondence #1-1-7159508 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 media inquiries. for timely responses on + +Thanks, + +Office of the Chief Medical Examiner + +520 1st Avenue + +New York, NY 10016 + +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 + +8393 Pardee Hollow Road + +Wayland, New York 14572 + +Phone 585-728-3074 + +Fax 585-728-3746 + +From: + +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 + +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 + +New York, NY 10007 + +646-836-6300 + +646-836-7673 (fax) + +"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' senator@schumer.senate.gov- Senator@Gillibrand.senate.gov. 'General Counsel Keith Castaldo (Senator Gillibrand)' + +Subject: RE: RESPONSE: Government Employee Unions + +Dear Chairman Schiff, Chairman Nadler and House Speaker Pelosi: US House of Representatives + +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 + +8393 Pardee Hollow Road + +Wayland, New York 14572 + +Phone 585-728-3074 + +Fax 585-728-3746 + +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 + +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/EFTA00086564/EFTA00086564.metadata.json b/marker2/ds9/EFTA00086564/EFTA00086564.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..14dd2c24cb08be094e124308dc7ae2950611d626 --- /dev/null +++ b/marker2/ds9/EFTA00086564/EFTA00086564.metadata.json @@ -0,0 +1,352 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086564.pdf", + "engine": { + "marker_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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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/EFTA00086574/EFTA00086574.metadata.json b/marker2/ds9/EFTA00086574/EFTA00086574.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1a942f0fab0b65f595adc1a0fb13e967c3dc2445 --- /dev/null +++ b/marker2/ds9/EFTA00086574/EFTA00086574.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086574.pdf", + "engine": { + "marker_major": "2", + "marker_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": 560, + "elapsed_seconds": 2.79, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Text", + 19 + ], + [ + "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/EFTA00086574" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086575/EFTA00086575.md b/marker2/ds9/EFTA00086575/EFTA00086575.md new file mode 100644 index 0000000000000000000000000000000000000000..fe0d544a32e986643374afd02b06c136833a5cb2 --- /dev/null +++ b/marker2/ds9/EFTA00086575/EFTA00086575.md @@ -0,0 +1,92 @@ +[REDACTED] + +[REDACTED] + +England + +[REDACTED] + +Telephone [REDACTED] + +[REDACTED] + +US Attorney for the Southern District of New York + +[REDACTED] + +New York City + +NY 10007 + +USA + +June 23, 2020 + +Dear [REDACTED] + +I sent the enclosed letter to your predecessor in connexion with the Epstein inquiry. I hope that it now may be of some use to you. + +Since it was written, Lord (Peter) Mandelson has sought a major international position, as head of the World Trade Organization. He would therefore find it even more difficult to resist any request for information from your office. + +Yours sincerely, + +[REDACTED] + +[REDACTED] + +Telephone + +Mr Geoffrey S Berman US Attorney for the Southern District of New York 1 St Andrew's Plaza New York City NY 10007 USA June 15, 2020 + +Dear Mr Berman, + +I hope that you are successful in your efforts to secure a full account from Prince Andrew of his relationship with Jeffrey Epstein. As you no doubt know, the Prince is almost universally discredited in our country and he can expect no support for a refusal to answer any questions you, and other law enforcement personnel may wish to put to him. + +You might also find it useful to seek information from the British politician Peter Mandelson (Lord Mandelson). Perhaps you have already taken this course. Although not as deep a relationship as Andrew's, Mandelson's intimacy with Epstein lasted over a period of years and he stayed in at least two of Epstein's properties, including the New York mansion. On one stay he was accompanied by his partner Reinaldo Avila da Silva, who might also repay interview. + +Mandelson is gay. This is widely known and I assume that Epstein would not have offered him the services of any underage girls. I would not be surprised if Epstein offered the services of men or boys to those of 1 + +his guests whom he thought might enjoy them. I have no basis for this other than the observation that predators like Epstein are generally prompted by the drive for power over avulnerable individual rather than sexual gratification. That drive would have been satisfied by offering a vulnerable boy to his guests as much as avulnerable girl, and it would allow him to blackmail anyone who took advantage. Epstein would have had access to boys who were brothers, friends or lovers of the girls he exploited. + +Mandelson may have no relevant information about Epstein's sexual crimes but he may have some about his business and financial dealings if those are part of your investigation. Like Andrew, he might give you other names in the Epstein circle, particularly of course, any he introduced to Epstein himself. He could tell you what information or other services Epstein expected in return for his hospitality (I am certain there were some.) It might be of interest to you to discover who brought them together and by what means. + +Like Andrew, Mandelson is very unpopular in this country, and would be hard put to resist any request for information from you. + +Iwonder also if you have sought any information from Kevin Spacey. You may not know that Epstein's associates, Andrew, Mandelson and Spacey had social or professional connexions with each other in England. + +Ihope that these suggestions might be of value to you. There is no need to reply. I have no personal interest in the outcome of your inquiries. I simply believe that all of Epstein's associates should give full cooperation to the cause of justice. + +Yours sincerely, + +![](_page_2_Picture_6.jpeg) + +BY AIR MAIL +per avion +Royal Mail® + +![](_page_3_Picture_14.jpeg) + +![](_page_3_Picture_15.jpeg) + +![](_page_3_Picture_16.jpeg) + +![](_page_3_Picture_17.jpeg) + +![](_page_3_Picture_18.jpeg) + +*[Faint handwritten text and markings]* + +US Albany +Sov (Acm District of New York +( st Andrew ) Plaza +NEW YORK 10007 NY + +USA + +10007 761 0014 + +[Redacted text block] + +![](_page_3_Picture_24.jpeg) + +![](_page_3_Picture_25.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00086575/EFTA00086575.metadata.json b/marker2/ds9/EFTA00086575/EFTA00086575.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6f4308e299c5f95ffda72728ea96c74435a5949a --- /dev/null +++ b/marker2/ds9/EFTA00086575/EFTA00086575.metadata.json @@ -0,0 +1,153 @@ +{ + "source_pdf": 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b/marker2/ds9/EFTA00086579/EFTA00086579.md @@ -0,0 +1,1089 @@ +To: + +![](_page_0_Picture_2.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Date: Thu, 11 Feb 2021 13:14:19 +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; Blosteinjpg; KCGMarch2017.jpg + +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. + +https://www.sec.gov/Archives/edgar/data/1592386/000110465921020227/tm216148d1 ex99-1.htm + +What is tangible book? + +WHY does receivable not fluctuate? + +WHY all the trading inventory for an HFT with no OMM? + +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 Dilorio + +Sent: Friday, November 6, 2020 7:09 AM + +![](_page_1_Picture_13.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. + +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 + +Payable: \$675 million + +Difference: \$1.2 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 SONY and Sell Side analists covering NITE/VIRT + +Cheers! + +Christopher Dilorio + +Whistleblower + +From: Chris Dilorio e > + +Sent: Wednesday, October 14, 2020 9:00 AM + +![](_page_2_Picture_24.jpeg) + +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://innasdaq.comIstatic-files/6b1ca278-75f0-4259-9372-5b3351126a8b + +ir.nasdaq.com + +121 e <2 h"' 21 e 416 \$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. + +![](_page_4_Picture_1.jpeg) + +### 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.' Dilorio Whistleblower + +From: Chris Dilorio < Sent: Thursday, September 17, 2020 9:17 AM + +![](_page_5_Picture_2.jpeg) + +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.' Dilorio Whistleblower + +![](_page_5_Picture_10.jpeg) + +From: Chris Dilorio Sent: Wednesday, September 16, 2020 3:01 PM + +![](_page_5_Picture_12.jpeg) + +**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 <[REDACTED]> + +**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/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 + +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 + +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 + +The SEC has known about the Knight/KCG/VIRT accounting fraud and securities fraud for years. I TOLD THEM. + +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_8_Picture_3.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... + +...ww.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. + +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 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 Criantu 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.govilitigation/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_12_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 + +tutps://www.netelement.com/press-releases/release-content/10734671#.XwRXGuWSnIV + +![](_page_12_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_12_Picture_20.jpeg) + +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 e > + +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. + +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_16_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 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_23_Picture_5.jpeg) + +Sent: Wednesda 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 1 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: 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. + +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 J Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Tuesday, April 28, 2020 7:24 AM + +![](_page_27_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. + +vo.vw.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.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 + +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.govinewsinews-releasesifincen-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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a/marker2/ds9/EFTA00086617/EFTA00086617.md b/marker2/ds9/EFTA00086617/EFTA00086617.md new file mode 100644 index 0000000000000000000000000000000000000000..e7b58828c9b25345cc267ed2c472bb2e0452451e --- /dev/null +++ b/marker2/ds9/EFTA00086617/EFTA00086617.md @@ -0,0 +1,1168 @@ +To: + +![](_page_0_Picture_2.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Date: Fri, 12 Feb 2021 21:31:38 +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; Blosteinjpg; KCGMarch2017.jpg + +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_1_Picture_10.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. ET. Contents: Prepared Remarks; Questions and Answers; Call Participants; Prepared Remarks: Operator. Good day, and ... + +www.fool.com + +Cheers! + +Christopher J Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio + +Sent: Thursday, February 11, 2021 6:14 AM + +![](_page_1_Picture_20.jpeg) + +![](_page_2_Picture_0.jpeg) + +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. + +https://www.sec.gov/Archives/edgar/data/1592386/000110465921020227/tm216148d1 ex99-1.htm + +What is tangible book? + +WHY does receivable not fluctuate? + +WHY all the trading inventory for an HFT with no DMM? + +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 Dilorio + +Sent: Friday, November 6 2020 7:09 AM + +![](_page_2_Picture_16.jpeg) + +![](_page_3_Picture_124.jpeg) + +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](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 + +Payable: \$675 million + +Difference: \$1.2 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 + +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/NJ 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://irmasdaq.com/static-files/6b1ca278-75f0-4259-9372-5b3351126a8b + +ir.nasdaq.com + +121e<2h- 21e<16\$8;1<76.23\$54-:;2((1-&22 + +irnasclaq.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. + +https://www.finextra.com/pressarticle/49357/otkritie-capital-taps-sungard-for-automated-ruble-conversion + +![](_page_5_Picture_8.jpeg) + +# 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 SDNY. + +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: Thursda 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 <[REDACTED]> + +**Sent:** Wednesday, September 16, 2020 3:01 PM + +![](_page_7_Picture_97.jpeg) + +**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 + +![](_page_7_Picture_104.jpeg) + +--- + +**From:** Chris Dilorio <[REDACTED]> + +**Sent:** Wednesday, September 16, 2020 9:20 AM + +![](_page_7_Picture_107.jpeg) + +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) 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! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio < + +Sent: Monday, September 14, 2020 9:22 AM + +To: + +Subjec : w: orma appea or pre iminary • enial covered action 2015-016/ Knight Capital TCR & Appendix + +I look forward to speaking with you + +Regards, + +Chris + +From: Chris Dilorio .zz > + +Sent: Monday, September 14, 2020 6:02 AM + +u jec : w: Formal appeal or preliminary oemal covered action -uib/ Knignt capital ppen + +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 + +## \$L4 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 + +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=9e2b4e49-5ee2-48f6-b8c7-03d39d02b5ca + +![](_page_9_Picture_11.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 + +![](_page_10_Picture_1.jpeg) + +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. 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. + +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 <[REDACTED]> + +**Sent:** Tuesday, July 7, 2020 6:09 AM + +![](_page_11_Picture_139.jpeg) + +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. + +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-releases/release-content/1062906/4.XwRXEOWSnIV + +![](_page_13_Picture_8.jpeg) + +# 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 + +Imps://www.netelement.com/press-releases/release-content/10734671#.XwRXGuWSnIV + +![](_page_13_Picture_13.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. + +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 Dilorio + +Whistleblower + +From: Chris Dilorio < + +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. + +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 FIN RA + +.✓ww.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 + +## 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 ... + +www.sec.gov + +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 + +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 ... + +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-lawm1 + +![](_page_17_Picture_14.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, + +#### 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) + +www.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 Laney. + +Cheers! + +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 10O's as I previously stated + +corrected below + +Chris + +From: Chris Dilorio + +Sent: Tuesda June 23 2020 9:48 AM + +C + +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/Rakishev/Trump/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 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,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 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. 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 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: 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. + +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! + +ChristopherJ Dilorio + +Whistleblower + +From: Chris Dilorio e > + +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: 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 tor preliminary denial covered action ZU15-Ulb/ 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? + +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. + +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. + +VONW.seciov + +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 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 + +Sent: Tuesday, April 28, 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. + +hups://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.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 + +[REDACTED] + +Whistleblower + +--- + +**From:** Chris Dilorio <[REDACTED]> + +**Sent:** Sunday, April 26, 2020 9:36 AM + +**To:** [REDACTED] + +**Subject:** Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +--- + +**From:** Chris Dilorio <[REDACTED]> + +**Sent:** Friday, April 24, 2020 8:18 AM + +[REDACTED] >; [REDACTED] <[REDACTED]>; +[REDACTED] <[REDACTED]>; [REDACTED] + +**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](https://www.finra.org/sites/default/files/fda_documents/2009018668801_FDA_KMX39652.pdf) + +### of - FINRA + +which is FINRA a party, to the entry of findings and violations consistent with the allegations of the (as Complaint sanctions amended and by the Offer of Settlement), to the imposition of the set forth and below, understands fully that this Order will become part of Respondent's permanent disciplinary and record may anybe considered in future actions brought by FINRA. BACKGROUND ... + +## 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. se c.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/ + +# 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" + +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 OCIE Examinations of Bernard L. Madoff Investment Securities, LLC Executive Summary Background. On June 25, 2009, the Securities and Exchange Commission's + +vAyw. sec .g ov + +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-bi n/b rowse-edgar?compa ny.Gar pa &owne r=exclude&actio n=getcompa ny + +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&CI K=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. + +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 + +In February 2019, the SEC brought an action against Joshua Sason/NewLead + +told the SEC about Magna/ Sason ALSO in my 2013 TCR. + +https://www.sec.gov/litigation/litreleases/2019/lr24403.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. + +www.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. + +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 \$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 I 7a 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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+GHISLAINE MAXWELL, + +Defendant. + +: 20 Cr. 330 (MN) + +x + +MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOIES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX + +Jeffrey S. Pagliuca + +Laura A. Menninger + +HADDON, MORGAN & FOREMAN P.C. + +150 East 10th Avenue + +Denverile. + +Phone: + +Mark S. Cohen + +Christian R. Everdell + +COHEN & GRESSER LLP + +800 Third Avenue New + +York, NY 10022 + +Phone: + +Bobbi C. Stemheim + +Law Offices of Bobbi C. Stemheim + +33 West 19th Street - 4th Floor + +New York NY 10011 + +Phone: + +Attorneys for Ghislaine Maxwell + +### TABLE OF CONTENTS + +| TABLE OF CONTENTS TABLE OF AUTHORITIES TABLE OF EXHIBITS FACTUAL BACKGROUND A. The Protective Order Maxwell B. Maxwell's April and July 2016 depositions C. D. E. ARGUMENT A. Evidence I. The role of protective orders in civil litigation | ii iv 1 2 2 4 6 6 10 11 11 11 | +|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------| +| 2. The government circumvented the protective order | 12 | +| 3. The government violated due proces • | 14 | +| 4. This court possesses the inherent authority to order suppression | 15 | +| B. | At A Minimum, This Court Should Order A Hearing At Which Maxwell May Inquire | +| McMahon | 16 | +| CONCLUSION | 16 | +| Certificate of Service | 18 | + +## TABLE OF AUTHORITIES + +### Cases + +| Benkovitch v. Gorilla, Inc., | No. 2:15-ev-7806 (WJM), 2017 WL 4005452 (D.N.J. Sept. 12, 2017) | | +|------------------------------------------|-----------------------------------------------------------------|--------| +| Brown v. Maxwell, | 929 F.3d 41 (2d Ck 2019) | 3, 6 | +| Chambers v. NASCO, Inc., | 510 U.S. 32 (1991) | 17 | +| Chemical Bank v. Affiliated FM Ins. Co., | 154 F.R.D. 91 (S.D.N.Y. 1994) | passim | +| Franks v. Delaware, | 438 U.S. 154 (1978) | 18 | +| Giglio v. U.S., | 405 U.S. 150 (1972) | 16 | +| Maxwell, | 325 F. Supp. 3d 428 (S.D.N.Y. 2018) | 6 | +| Klein v. Weidner, Civ. | No. 08-3798, 2017 WL 2834260 (E.D. Pa. June 30, 2017) | 17 | +| Manhattan Review LLC v. Ytni, | 16 Civ. 0102 (LAK) (JCF), 2017 WL 11455317 (S.D.N.Y. Sept. | | +| 21, 2017) | | 17 | +| Martindeli v. Intl Tel. & Tel. Corp., | 594 F.2d 291 (2d Cir. 1979) | 12, 13 | +| S.E.C. v. TheStreet.Com, | 273 F.3d 222 (2d Cir. 2001) | 12 | +| Stewart v. Hudson Hall LLC, | 20 Civ. 885 (SLC), 2020 WL 7239676 (S.D.N.Y. Dec. 9, 2020) 12 | | +| United States v. Avellino, | 136 F.3d 249 (2d Cir. 1998) | 16 | +| United States v. Cortina, | 630 F.3d 1207 (7th Cir. 1980) | 16 | +| United States v. Lambus, | 897 F.3d 368 (2d Cir. 2018) | 16 | +| United States v. Paredes-Cordova, No. | S I 03 CR. 987DAB, 2009 WL 1585776 (S.D.N.Y. June | | +| 8, 2009) | | 18 | +| United States v. Rajaratnam, | 719 F.3d 139 (2d Ck. 2013) | 18 | +| United States v. Valentine, | 820 F.2d 565 (2d Cir. 1987) | 16 | +| Young v. United States, | 481 U.S. 787 (1987) | 16 | + +#### Other Authorities + +#### Rules + +#### Constitutional Provisions + +### TABLE OF EXHIBITS + +EXHIBIT A: Civil Protective Order + +EXHIBIT BMProtective Order Proposal + +EXHIBIT C: Sealed Affirmation and Application, USAO Ref. No. 2018R01618, 2/5/2019 + +EXHIBIT D: Transcript, 3/26/2019 + +EXHIBIT E: Transcript, 4/9/2019 + +EXHIBIT F: Sealed Order (19 Misc. 149 (CM)), 4/9/2019 + +EXHIBIT G: Sealed Memorandum Decision and Order Granting the Government's Application to Modify the Protective Order (19 Misc. 149 (CM)), 4/9/2019 + +EXHIBIT H: Sealed Order (I 9-MC-00179 (SN)), 4/16/2019 + +EXHIBIT I: Sealed Letter to Judge Netbum, 4/9/2019 + +Ghislaine Maxwell moves to suppress all evidence the government obtained from a grand jury subpoena it issued to Boies Schiller Flexner LLP and to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena. + +### INTRODUCTION AND SUMMARY OF THE ARGUMENT + +Counts Five and Six allege that Maxwell committed perjury during two civil depositions conducted by Boies Schiller in a defamation action it filed against Maxwell on behalf of one of the firm's clients.M. Maxwell, Case No. 15-cv-7433 (LAP) (S.D.N.Y). A Protective Order entered in that case prohibited the parties and their lawyers from sharing confidential discovery material (including the two Maxwell depositions) with anyone else, including with the government and law enforcement. Faced with that Protective Order, the government issued a grand jury subpoena for Boies Schiller's file and instituted an ex parte proceeding before Chief Judge McMahon to modify the Protective Order. By proceeding ex pane, the government ensured that no one before the court would be able to contest the accuracy of its representations in support of its application. + +The government then took full advantage. Judge McMahon, citing this Court's decision in Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 (S.D.N.Y. 1994), asked the government, point blank, whether Southern District prosecutors had previously met with the Boies Schiller firm or otherwise "collu[dedr with that firm in arranging the discovery request. The government lawyer assured Judge McMahon that the prosecutors had no idea what was in Boies Schiller's file. Indeed, he insisted, there had been no contact whatsoever between Boies Schiller and United States Attorney's Office before the government commenced its investigation. Nor, said the prosecutor, did Boies Schiller have any role instigating the Maxwell inquiry. + +To paraphrase Mary McCarthy's philippic about Lillian Hellman, every word of the government's representation was untrue, "including 'and' and `the." The government knew what was in the Boies Schiller file; the law firm had provided that information well before the investigation began. The government did indeed have previous contact with the firm. And Boies Schiller was instrumental in fomenting the Maxwell prosecution. + +The record is surpassingly clear: But for the government's misrepresentation, witting or not, Judge McMahon never would have permitted the circumvention of the civil Protective Order, on which Maxwell relied in agreeing to sit for her depositions. This Court therefore has both the authority and the duty to suppress the fruits of that misrepresentation, including the deposition transcripts and the two perjury counts based on those transcripts. If the Court is disinclined to exercise that inherent authority on the present record, Maxwell should be granted a hearing to examine the circumstances that resulted in the government's misrepresentations to Judge McMahon. + +# FACTUAL BACKGROUND + +# A. The Protective Order in v. Maxwell + +Counts Five and Six of the superseding indictment allege that Maxwell committed perjury during two civil depositions taken in v. Maxwell, a civil defamation case Virginia =filed in 2015. claimed that Maxwell defamed her when Maxwell's attorney-hired press agent denied as "untrue" and "obvious numerous allegations, over the span of four years, that Maxwell had participated in a scheme to cause to be "sexually abused and trafficked" by Jeffrey Epstein. + +&#x27; See Norman Mailer, "An Appeal to Lillian Hellman and Mary McCarthy," 5111/80 New York Times. + +a public figure required to prove actual malice, had an uphill battle—even she was constrained to acknowledge that many of her public statements were false. Using a timehonored if unfortunate litigation tactic, her lawyers at Boies Schiller therefore sought to turn the lawsuit into a proxy prosecution of Epstein. Not surprisingly, discovery in the case was bitter, hard-fought, and wide-ranging. It spanned more than a year and included large document productions, many responses to interrogatories, and thirty-some depositions, including depositions of and Maxwell as well as several third parties. See Brown v. Maxwell, 929 F.3d 41, 46, 51 (2d Cir. 2019) (explaining that discovery was "hard-fought" and "extensive" and noting that the court file, which includes only some of the documents created during discovery, totals in the "thousands of pages"). + +sought and obtained a wide variety of private and confidential information about Maxwell and others, including information about financial and sexual matters. Brown, 929 F.3d at 48 n.22. Given the intimate and highly confidential nature of the discovery exchanged between the parties, the district court entered a stipulated Protective Order. See Ex. A. The Protective Order included a mechanism for one party to challenge another party's confidentiality designation (such a challenge never occurred) and provided that it did not apply to any information or material disclosed at trial. (Because the case settled before trial, that sole exception to the Protective Order was never triggered.) + +Notably, Boies Schiller sought to add a "law enforcement" exception to the Protective Order, doubtless because the firm was eager to enlist the government in its campaign against Maxwell. In particular, Boies Schiller proposed to include a provision stating that "CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case and any related matter, including but not limited to, investigations by law enforcement." Ex. B 1(a)(4) (emphasis supplied). Maxwell flatly rejected this proposal, and it was never included in the Protective Order. Ex. A.2 To the contrary, the order strictly limited the parties' disposition of Confidential Material, including at the conclusion of the case. In particular, paragraph 12 of the order provided that: + +[a]t the conclusion of this case, unless other arrangements are agreed upon, each document and all copies thereof which have been designated as CONFIDENTIAL shall be returned to the party that designated it CONFIDENTIAL, or the parties may elect to destroy CONFIDENTIAL documents. Where the parties agree to destroy CONFIDENTIAL documents, the destroying party shall provide all parties with an affidavit confirming destruction. + +Ex. Al 12. + +## B. Maxwell's April and July 2016 depositions + +Relying on the confidentiality protections of the Protective Order, Maxwell declined to invoke her privilege against compulsory self-incrimination and agreed to testify at her April 2016 deposition. In that deposition, attorneys asked Maxwell whether "Jeffrey Epstein [had] a scheme to recruit underage girls for sexual massages? If you know." Maxwell replied, "I don't know what you're talking about." And when asked to "[I]ist all the people under the age of 18 that you interacted with at any of Jeffrey's properties," Maxwell responded, "I'm not aware of anybody that I interacted with, other than obviously I who was 17 at this point." Count Five of the superseding indictment alleges those two answers were false. + +Following the deposition Minoved to compel Maxwell to answer additional intimate and personal questions that she had previously declined to answer. In support of the motion, Boies Schiller assured the district court that "[s]uch questions are entirely appropriate in the discovery phase of this case, particularly where any answers will be maintained as confidential under the Protective Order in this case." + +&#x27;This proposal was rejected because of justifiable concerns about the misuse and abuse of this information by plaintiff and her lawyers including the selection and misleading leaking of confidential material to the media, other false claimants, and the government.

The district court granted the motion. In requiring Maxwell to answer highly intrusive questions "relating to [her] own sexual activity" and "her knowledge of the sexual activity of others," the court held that Maxwell's "privacy concerns are alleviated by the protective order in this case."

Secure in the belief that the Protective Order would be honored, Maxwell appeared at a second deposition, in July 2016. and answered hundreds of pages worth of questions about her "own sexual activity" and "her knowledge of the sexual activities of others." From the very first question, Maxwell discussed the intimate details of her sexual activity with Epstein, with other adult men, with other adult women, the use of sex toys, participation in "threesomes," and a full gamut of other sordid sexual topics. She was asked where she had sex, when she had sex, with whom she had sex, what types of sexual predilections Epstein had, whether others watched her having sex, whether she watched other people having sex, and whether she slept with clothes on. She was asked whether Epstein had sex with any number of women, and the names of women he might have had sex with. Maxwell was also grilled extensively about massages: when, where, what she was wearing, who gave them.

Count Six of the superseding indictment alleges that Maxwell provided false testimony when she testified during her July 2016 deposition that: (1) she could not recall whether sex toys or devices were used in sexual activities at Epstein's Palm Beach house; (2) she did not know whether Epstein possessed sex toys or devices used in sexual activities; (3) she wasn't aware that Epstein was having sexual activities with anyone other than herself when she was with him; and (4) she never gave anyone, including Accuser-23, a massage.

The indictment refers to the accusers as Minor Victim-1, Minor Victim-2, and Minor Victim-3. We will refer to them as Accuser-1, Accuser-2, and Accuser-3.

C. The Settlement And Boies Schiller's Refusal To Comply With The Protective Order

In 2017, the parties settled the defamation claim, and the case was dismissed. Maxwell, 325 F. Supp. 3d 428, 436 (S.D.N.Y. 2018), vacated and remanded sub nom. Brown, 929 F.3d 41. As the district court found, "a significant, if not determinative, factor" in reaching a settlement was its confidentiality. Id. at 446.

After the case was settled and concluded, Maxwell repeatedly invoked Paragraph 12 of the Protective Order and demanded that either return or destroy all confidential information, including her deposition transcripts. Boies Schiller refused. Instead, and unbeknownst to Maxwell, Boies Schiller produced some 90,000 pages of discovery material to the government, including both of Maxwell's deposition transcripts.

D. The Government's False Statements To Judge McMahon

Only in August 2020, after she was indicted in this case, did Maxwell finally learn that the government had obtained the Boies Schiller file by grand jury subpoena. Maxwell also learned that, to overcome the strictures of the Protective Order, the government had instituted an ex parte proceeding before Judge McMahon, Case No. 19-Misc.-149 (CM) (S.D.N.Y). Ex. C. Needless to say, neither Maxwell nor her attorneys were given the opportunity to oppose that application or to contest the government's representations in support of the application. This was all in direct violation of Paragraph 14 of the Protective Order, which provides that the order may be modified by the court only "for good cause shown following notice to all parties and an opportunity to be heard." Ex. Al 14 (emphasis added).

In its ex parte application, the prosecutors professed that they had sought out Boies Schiller's file only because "publicly available information regarding the [Giuffre v. Maxwell]

Litigation, including the complaint and other docketed filings ... appear[ed] to make reference to certain subjects relating to the Investigation." That "publicly available information," the government claimed, indicated that the Boies Schiller file might "contain information relevant to the ongoing Investigation" of Jeffrey Epstein. Ex. C, 14. Nowhere did the government acknowledge that Boies Schiller had in fact approached the prosecutors multiple times well before the grand jury subpoena issued.

In March 2019, in the first appearance before Judge McMahon, the Government continued this refrain, professing ignorance about what was in Boies Schiller's file or who was deposed in the case. The prosecutor defended the subpoena's breadth—which sought all "copies of discovery and related materials" irMv. Marvell—on the ground that the government simply had too little knowledge of what was in the law firm's files to craft a more narrowly tailored subpoena:

Here, we are essentially unable to significantly narrow the request for information in part for exactly the reasons that you describe. We have either little or no additional information than the Court does in terms of what materials there are, who was deposed, and that is in marked contrast to some of the other cases.

Ex. D, p 17. For all the government knew, according to the Assistant U.S. Attorney, what he was seeking was "page after page of people taking the Fifth." Ex. D, p 19.

The government appeared a second time before Judge McMahon in April 2019. Ex. E. Judge McMahon held that conference for one reason: to learn "about contacts between the United States Attorney's Office and the Boies Schiller law firm prior to the issuance of the subpoena." Ex. E, p 2. The Assistant U.S. Attorney told Judge McMahon that the government's investigation began on either November 30 or December 3, 2018, omitting mention of any contacts between Boies Schiller and the government prior to that time:

In the initial days and weeks of the investigation, we endeavored to identify information about the subject of the investigation, including, among other things,

possible victims who we should speak to. In the process of doing so, we identified certain counsel that were identified as representing victims or witnesses either in public filings or in media reports. Boies Schiller was among those plaintiff attorneys. So following the opening of the investigation, we were in touch with Boies Schiller, among other plaintiff and witness counsel, in connection with their representation of witnesses or victims.

With respect to Boies Schiller in particular, we quickly came to learn during the investigation that they had at the time either active or recently completed civil litigation and so asked them, as is our standard practice, told them, I should say, that we expected to make document requests. They generally advised us that they believed there was a protective order that would govern at least some of the materials, and that is why we ultimately made the application to the Court.

Ex. E, 99 pp 2-3.

Those representations were false. At the time the government claims it began the investigation (late November or early December 2018), its knowledge of the civil case was not based exclusively on public filings. It knew that Boies Schiller possessed relevant information because the firm had come to the government asking it to open an investigation. In particular, on February 29, 2016, AUSA met with attorneys from Boies Schiller, who "urged to open an investigation of Epstein and Maxwell!' Then, after Maxwell's two depositions, David Boies himself apparently approached the government in the summer of 2016, asking "if the Southern District would consider charging Maxwell with perjury." Brown, supra n.2. Said Mr. Boies:

"We were saying to anyone who would listen: We've got clients who were abused. Some of them were underage. We have the evidence. There's a whole record that's been developed. We can establish beyond any reasonable doubt there was a massive sex trafficking ring going on."

Id.

Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020), https://www.nydailynews.cominew-yorlc/ny-jeffrey-epstein-maxwell-case-20201013 jinz117zdrzdgrbbs7yc6bfnszu-stoty.htnal.

At that time, however, the government did not act. Boles "was particularly frustrated by the failure to pursue a perjury charge [against Maxwell]," reported one person, who recalled him saying, "We have her dead to rights."5 Id. All of this contradicts The government's representations to Judge McMahon, who specifically asked if the government had any contact with Boies Schiller before it issued the subpoena.

Reassured by the government that no contact had occurred, Judge McMahon modified the Protective Order so that Boles Schiller could comply with the subpoena. Ex. F. Judge McMahon found that Maxwell could not have reasonably relied on the Protective Order as prohibiting Boies Schiller from cooperating with the government. In making this finding, Judge McMahon relied on the Assistant U.S. Attorney's misrepresentations, and she distinguished the government's subpoena to Boies Schiller from the subpoena at issue in Chemical Bank. Said Judge McMahon:

[T]he onl thing on which Maxwell or anyone else might reasonably have relied is that or her lawyers would not do what the defendant in Chemical Bank did—that is, forward discovery materials in their possession to prosecutors for the purpose of fomenting an investigation. not faced with that situation. Nothing in this record suggests to me that or Boies Schiller had anything to do with the Government's dila convene a grand jury to look into the matters that were the subject of the ction. On the contrary—the Government has advised the Court that it contacted Boies Schiller as part of its search for parties who might have been victims in its investigation; and that Boies Schiller told the Government that it could not consensually produce at least some documents in its files because of the existence of the Protective Order. There is no evidence of "collusion," to invoke a term of the moment, and it is quite clear that Boles Schiller did not foment the Government's investigation. Moreover, the Assistant United States Attorney has represented to this Court that he has no idea what is in Boies Schiller's files, and that for all he knows every witness who was deposed stood on his/her Fifth Amendment rights and refused to answer questions.

Ex. G, p 21.

5 Ms. Maxwell strenuously disagrees with Mr. Boles' comments. We reference them here only to show their connection to the perjury counts that the government subsequently charged.

Contrary to the government's misrepresentations, Boies Schiller did foment the investigation (or at least it tried to). And the evidence of "collusion" between the government and Boies Schiller was ample, tracing to at least early 2016 and precisely designed to have Maxwell charged with perjury.°Had Judge McMahon known the truth, she likely would have denied the government's application to modify the= v. Maxwell Protective Order, and the government would have been unable to secure a copy of Boies Schiller's ninety-thousand-page file, including Maxwell's two deposition transcripts.

E. Judge Netburn Separately Rejects An Identical Gambit By The Government

Around the same time that Judge McMahon granted the government's ex parte request, Magistrate Judge Netburn rejected an identical request from the government in a different civil case, Jane Doe 43 v. Epstein, Case No. 17-cv-616 (JGK) (SN). Judge Netbum recognized the government's conduct for what it was: an attempt to deprive Maxwell of notice and an opportunity to be heard. Ex. H. Indeed, Judge Netbum rebuffed the government even after it alerted her to Judge McMahon's order. Ex. I. As Judge Netbum found, the government's "abstract concern" about the "secrecy" of its investigation—a concern that exists with any investigation and is hardly unique to this case—could not overcome the parties' reasonable reliance on the Protective Order or justify the government's secret, ex parte application. Ex. H, p 6. Judge Netburn also implicitly recognized what Judge McMahon never knew—that Boies Schiller was all too eager for the government to investigate and prosecute Maxwell:

6 Maxwell has not yet been provided discovery of whether Boies Schiller shared actual sealed materials or the contents of sealed materials during its meetings with the United States Attorney's Office in 2016. As noted below, the bare minimum that is required here is an evidentiary hearing to probe the extent to which Boies Schiller "colluded," in a Chemical Bank sense, with the prosecutor's office.

[T]he extraordinary posture of the case requires the Court to police carefully government intrusions into areas of protections agreed to by civil litigants and soordered by the Court. The Government is attempting to side-step these protections by serving a subpoena only upon a party who is willing (and perhaps eager) to comply with the Government's investigation.

Ex. H, p 6.

ARGUMENT

A. Pursuant To Its Inherent Power, This Court Should Suppress The Evidence Obtained From Boies Schiller, And Dismiss Counts Five And Six, Which Are The Fruits Of That Evidence

1. The role of protective orders in civil litigation.

Protective orders serve a "vital function" in civil litigation. Martindell v. Int'l Tel. & Tel. Corp., 594 F.2d 291, 295 (2d Cir. 1979). They promote "the `secure the just, speedy, and inexpensive determination' of civil disputes, by encouraging full disclosure of all evidence." Id. (quoting Fed. R. Civ. P. 1). "If protective orders were easily modified . . . parties would be less forthcoming in giving testimony and less willing to settle their disputes." S.E.C. v. TheStreet.Com, 273 F.3d 222, 230 (2d Cir. 2001). In particular, as here, "witnesses might be expected frequently to refuse to testify pursuant to protective orders if their testimony were to be made available to the Government for criminal investigatory purposes in disregard of those orders." Martindell, 594 F.2d at 295-96. Parties thus rely on protective orders, and courts strictly enforce them. See, e.g., Stewart v. Hudson Hall LLC, 20 Civ. 885 (SLC), 2020 WL 7239676, at \*2 (S.D.N.Y. Dec. 9, 2020) ("In the Second Circuit, there is a strict standard for modification of a protective order entered by a district court." (citation and quotation marks omitted)).

This case illustrates just how crucial a protective order is. The Maxwell depositions sought highly intrusive evidence of the most personal aspects of Maxwell's life. Her sexual practices. Her sexual preferences. Her sexual partners. In urging the district court to permit these extraordinary intrusions—in what should have been a simple defamation case-Boies Schiller

expressly invoked the assurances of the Protective Order. So did the district court in permitting these intrusions and ordering Maxwell to sit for a second deposition. Maxwell likewise relied on the Protective Order in choosing to render such intimate details, rather than assert her Fifth Amendment privilege as she had every right to do.

And why shouldn't Maxwell have relied on the Protective Order? The central protection in the Order was that none of Maxwell's answers could be disclosed to the government. Boies Schiller had expressly sought a law enforcement exception but was rebuffed. Instead, the law firm was required either to return the confidential material or, at Maxwell's option, to destroy it. Maxwell had every reason to take that assurance seriously, even if Boies Schiller did not.

2. The government circumvented the protective order.

Faced with a duly entered Protective Order—which quite deliberately omitted any "law enforcement" exception—the government had lawful options to pursue the confidential= discovery. It could have moved to intervene in the civil case and to amend the Protective Order. It could have issued a subpoena for the materials and given Maxwell an opportunity to respond. Martindell, 594 F.2d at 294. It could even have applied for a search warrant, assuming (counterfactually) that it could show probable cause in support of such a warrant.

The government did none of those things. Instead, it initiated an ex parte proceeding and secured a secret modification of the Protective Order based on material misrepresentations to the presiding judge. This was not among the lawful options available to the government.

It cannot fairly be disputed that Judge McMahon's ruling to amend the Protective Order was based on the government's misrepresentations. Immediately before issuing her decision, Judge McMahon held a hearing with the sole purpose of asking the prosecutor, point blank, about the government's contacts with Boies Schiller. Judge McMahon's stated reason for so inquiring was to ensure that the government and Boies Schiller had not coordinated as the parties

had in the Chemical Bank case. In no uncertain terms, Judge McMahon explained why she had haled the prosecutor back into court:

I'll be very up-front with you. I want to make sure I'm not in a Chemical Bank kind of situation, so I would like to know about 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.

Ex. E, p 2.

In Chemical Bank, a protective order precluded parties to a civil case from disclosing confidential documents to others. 154 F.R.D. at 92-93. Despite this prohibition, counsel for the defendant approached the Manhattan District Attorney's Office and suggested that it had evidence of criminal violations relating to the case. Id. at 93. A grand jury issued a subpoena, and the defendant produced to the government various confidential documents without complying with any of the specific procedures or exceptions provided in the protective order. Id. Once this collusion came to light, the district court reprimanded the defendant for its "disregard of the [protective] order[]" and admonished its behavior as "contrary to the traditions of the Bar which dictate that court orders be respected." Id.

In addressing the government's application here, Judge McMahon specifically asked whether Boies Schiller had acted as the defendant did in Chemical Bank. The prosecutor omitted any mention of his office's previous meetings with the firm, and falsely led the court to believe that Boies Schiller had not encouraged its investigation. Reassured by the misrepresentations, Judge McMahon commented:

Nothing in this record suggests to me that for Boies Schiller had anything to do with the Government's d ii • • to convene a grand jury to look into the matters that were the subject of the Action. On the contrary—the Government has advised the Court that it contacte Boies Schiller as part of its search for parties who might have been victims in its investigation; and that Boies Schiller told the Government that it could not consensually produce at least some documents in its files because of the existence of the Protective Order. There is no evidence of

"collusion," to invoke a term of the moment, and it is quite clear that Boies Schiller did not foment the Government's investigation.

Had Judge McMahon known the truth, she likely would not have granted the government's application to modify the Protective Order to allow Boies Schiller to comply with the subpoena.

3. The government violated due process.

The government's conduct cannot be squared with elemental due process. U.S. CONST. amend. V. Pursuant to this guarantee, "[t]he responsibility of a public prosecutor differs from that of the usual advocate; his duty is to seek justice, not merely to convict." Young v. United States, 481 U.S. 787, 803 (1987). The government engages in misconduct and violates due process when it materially misrepresents facts before a court. See United States v. Valentine, 820 F.2d 565, 570 (2d Cir. 1987) (holding that the government violated due process and reversing conviction when the government mischaracterized the substance of grand jury testimony).

The prosecutor may well have known that his representations to Judge McMahon were false (or at best misleading). But the Assistant U.S. Attorney's personal knowledge doesn't matter. "An individual prosecutor is presumed ... to have knowledge of all information gathered in connection with his office's investigation of the case." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998); see also Giglio v. U.S., 405 U.S. 150, 154 (1972) ("The prosecutor's office is an entity and as such it is the spokesman for the Government. A promise made by one attorney must be attributed, for these purposes, to the Government."). At the barest minimum, a federal prosecutor has a duty to check the entire file to ensure that his representations to a federal judge, submitted on behalf of the office he serves and under oath, are true and complete. The Assistant U.S. Attorney did not discharge that basic function.

4. This court possesses the inherent authority to order suppression.

Incident to its inherent power to superintend proceedings, this Court has the authority to suppress the fruits of the government's misrepresentation. See, e.g., United States v. Cortina, 630 F.3d 1207, 1214 (7th Cir. 1980) ("The court has inherent authority to regulate the administration of criminal justice among the parties before the bar .... [by] exclud[ing] evidence taken from the defendant by willful disobedience of law." (citation omitted)); United States v. Lambus, 897 F.3d 368, 386 (2d Cir. 2018) ("It is within the court's inherent authority to suppress evidence gathered unlawfully in order to maintain the integrity of its own proceedings . . . ."); Benkovitch v. Gorilla, Inc., No. 2:15-cv-7806 (WJM), 2017 WL 4005452, at \*2 (D.N.J. Sept. 12, 2017) ("District courts have `inherent authority' to impose a variety of sanctions, including . . . suppression of evidence . . . .").

It does not matter that the government made its misrepresentations to Judge MelvIttlion and not directly to this Court. "As long as a party receives an appropriate hearing, . . . the party may be sanctioned for abuses of process occurring beyond the courtroom . . ." Chambers v. NASCO, Inc., 510 U.S. 32, 57 (1991). "Courts have held that inherent authority sanctions may be imposed for misconduct in another court where the misconduct is . . . in some way related to the case before the sanctioning court." Klein v. Weidner, Civ. No. 08-3798, 2017 WL 2834260, at \*6 (E.D. Pa. June 30, 2017) (citation and alteration omitted); Manhattan Review LLC v. Yen, 16 Civ. 0102 (LAK) (JCF), 2017 WL 11455317, \*7 n.3 (S.D.N.Y. Sept. 21, 2017) ("The inherent power ... can punish conduct before a different court if it is intimately related to the relevant case." (citing Klein, 2017 WL 2834260, at \*4)). Here, the government's misrepresentation to Judge McMahon was not simply "related" to Counts Five and Six; only by the government's deception was it able to obtain the factual predicate for those counts. Accordingly, the Court may exercise its inherent authority to suppress that evidence. And it should.

B. At A Minimum, This Court Should Order A Hearing At Which Maxwell May Inquire Into The Circumstances Surrounding The Government's Misrepresentations To Judge McMahon

If the Court is disinclined to grant relief on the present record, then at a minimum it should hold an evidentiary hearing to probe the government's misstatements to Judge McMahon and the extent to which the prosecutor's office had, in fact, coordinated with Boies Schiller prior to the issuance of the grand jury subpoena. These factual issues go directly to whether the predicate finding for Judge McMahon's ruling—namely, that no Chemical Bank collusion had occurred—was mistaken. See, e.g., United States v. Paredes-Cordova, No. SI 03 CR. 987DAB, 2009 WL 1585776, at \*1 (S.D.N.Y. June 8, 2009) ("An evidentiary hearing is normally required to address motions to suppress where a factual issue is in dispute.").

An evidentiary hearing is warranted for an additional reason as well: If it turns out that the prosecutor knew (or was reckless in not knowing) that Boies Schiller had previously approached his office, both before and after the Maxwell depositions, in an effort to stir up a criminal prosecution and dangled the deposition transcripts as a carrot, then suppression would be warranted on that basis alone. Cf. Franks v. Delaware, 438 U.S. 154, 155-56 (1978); United States v. Rajaratnani, 719 F.3d 139, 146 (2d Cir. 2013) ("Franks instructs a district court to hold a hearing to determine whether the alleged misstatements or omissions in the warrant or wiretap application were made intentionally or with reckless disregard for the truth and, if so, whether any such misstatements or omissions were material.").

CONCLUSION

For these reasons, this Court should: (1) suppress all evidence the government obtained from Boies Schiller and any other evidence derived therefrom; or (2) suppress the April and July 2016 depositions and all evidence derived therefrom; and (3) dismiss Counts Five and Six. Maxwell requests an evidentiary hearing on this Motion.

Dated: January 25, 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:

Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 00 Third Avenue New York, NY 10022 Phone:

Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York NY 10011 Phone:

Attorneys for Chislaine Maxwell

Certificate of Service

I hereby certify that on January 25, 2021, served by email, pursuant Rule 2(B) of the Court's individual practices in criminal cases, the Memorandum of Ghislaine Maxwell in Support of Her Motion Under the Due Process Clause to Suppress All Evidence Obtained from the Government's Subpoena to Boies Schiller and to Dismiss Counts Five And Six upon the following:

U.S. Attorney's Office, SDNY

New York, NY 10007

s/ Christian R. Everdell

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April 9, 2019 11:45 a.m. + +HON. COLLEEN MCMAHON, + +Chief District Judge + +## APPEARANCES + +GEOFFREY S. BERMAN + +United States Attorney for the Southern District of New York + +Assistant United States Attorney + +(In the robing room) + +THE COURT: This is 19 Misc. 149, In Re Grand Jury Subpoena. I've had one conference with the government in this matter. You want to put your appearance on the record. + +MR. : Yes. Good morning, your Honor. + +for the government. + +THE COURT: Mr. , I now know a lot more about what's going on than I did the last time we were together. My question is this: I'll be very up-front with you. I want to make sure I'm not in a Chemical Bank kind of situation, so I would like to know about 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. + +MR. : Yes, your Honor. So with respect to this investigation, the investigation was opened in late November or early December, either on Friday, November 30, or Monday, December 3. + +THE COURT: OK. + +MR. : In the initial days and weeks of the investigation, we endeavored to identify information about the subject of the investigation, including, among other things, possible victims who we should speak to. In the process of doing so, we identified certain counsel that were identified as representing victims or witnesses either in public filings or + +1 2 3 4 5 in media reports. Boies Schiller was among those plaintiff attorneys. So following the opening of the investigation, we were in touch with Boies Schiller, among other plaintiff and witness counsel, in connection with their representation of witnesses or victims. + +6 7 8 9 10 11 12 13 With respect to Boies Schiller in particular, we quickly came to learn during the investigation that they had at the time either active or recently completed civil litigation and so asked them, as is our standard practice, told them, I should say, that we expected to make document requests. They generally advised us that they believed there was a protective order that would govern at least some of the materials, and that is why we ultimately made the application to the Court. + +14 15 16 THE COURT: OK. That's all I needed to know. I want to make two little changes in this opinion, and if you come back in an hour, you'll have it. + +17 MR. : OK. + +18 THE COURT: All right. + +19 MR. : Thank you, your Honor. + +20 THE COURT: And we are granting your request. + +21 MR. : Understood. Thank you, your Honor. + +22 THE COURT: OK. + +23 (Adjourned) + +24 + +25 + +SOUTHERN DISTRICT REPORTERS, P.C. 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Robert W. Sweet in a civil defamation action, Giuffre v. Maxwell, No. 15-cv-7433 (S.D.N.Y.) ("the Giuffre Action"), in order to permit the law firm of Boies Schiller Flexner LLP ("Boies Schiller") to comply with a grand jury subpoena. + +The application is granted. + +## I. Background + +## A. The Protective Order + +In September 2015, Virginia L. Giuffre commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey Epstein ("Epstein"). (15-cv-7433, Dkt. No. 1.) Boies Schiller represented the plaintiff in the litigation, and continues to represent her on a pending post-settlement appeal, which is described below. + +On March 3, 2016, Maxwell moved before the assigned judge, the Hon. Robert W. Sweet, for entry of a protective other for materials produced in discovery. Maxwell cited + +statutory and common law privacy concerns. (Dkt. No. 38 at 1.) Maxwell submitted a proposed form of order for Judge Sweet's consideration. (Dkt. No. 39-1.) + +Giuffre represented that she "[did] not oppose the entrance [sic] of a Protective Order in this case, but [did] oppose a Protective Order in the form proposed by Defendant because it is overly broad and can lead to abuse and over designation[.]" (15-cv-7433, Dkt. No. 40 at 2.) Giuffre redlined Maxwell's proposed protective order, deleting some provisions and (insofar as is relevant) adding language to paragraph 4—stating that confidential information "shall not be disclosed or used for any purpose except the preparation and trial of this case"—to provide that confidential materials also could be disclosed with impunity "in any related matter, including but not limited to, investigations by law enforcement." (15-cv-7433, Dkt. No. 41-5 1 4.) Maxwell opposed these modifications. (15-cv-7433, Dkt. No. 49.) + +At a hearing held on March 17, 2016, Judge Sweet concluded that "of course" a protective order was warranted. (Hrg. Tr., 15-cv-7433, Dkt. No. 66, at 4:25-5:1.) He gave no reason, but as Maxwell made her motion on the basis of privacy concerns, and Giuffre consented to entry of some form of a protective order for the same reason, I assume that Judge Sweet found privacy concerns to constitute good cause—which, given the subject matter of the lawsuit, would certainly have been warranted. + +Judge Sweet did not, however, resolve any of the disputes between the parties about what should or should not be in the order. Instead, he directed the parties to come up with an agreement to which everyone could stipulate. (Id. at 5:1-12.) By the end of the hearing, Giuffre, who was eager to take Maxwell's deposition, agreed to the form of order originally proposed by Maxwell. (Id 9:7-24.) The court agreed that it would "so order" Maxwell's proposed version + +pursuant to the parties' stipulation. Judge Sweet made no specific findings about any provision of that order. (Id 9:25-10:6.) + +On March 18, 2016, the court formally entered the Protective Order. (15-cv-7433, Dkt. No. 62.) It provided, as such orders generally do, that any documents, materials and/or information designated confidential by the parties (the "Confidential Materials") would be subject to the protections of, and could be disclosed to non-parties only in accordance with the terms of, the Protective Order. (Id. fl 1-5.) The Protective Order also required all parties, at the conclusion of the case, either to return to the party who made the confidentiality designation, or (in the alternative) to destroy, each document and all copies of Confidential Materials in their possession. (Id 9¶ 5-7, 12.) This destruction obligation extended to the parties' lawyers as well as to the parties themselves. (Id ¶ 12.) + +The Protective Order specified that if Confidential Materials were contained in any document presented to the court, the filing "shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York." (Id ¶ 10.) The docket sheet in Giulfre v. Maxwell reveals that such motions were frequently made and routinely granted. As a result, a vast amount of the Giuffre Action was conducted, in effect, in secret—despite the fact that there was immense public interest in the matter. + +The Giuffre Action was settled and dismissed with prejudice pursuant to a joint stipulation for dismissal on May 25, 2017, which was shortly before the trial was to begin. (15 cv-7433, Dkt. No. 919.) The terms of the settlement remain confidential. (15-cv-7433, Dkt. No. 953 at 10.) + +## B. Attacks on the Protective Order + +Both during and after the settlement of the Giuffle Action, third parties made highlypublicized applications to have documents that were filed under seal by order of Judge Sweet unsealed and made public. (15-cv-7433, Dkt. Nos. 362, 550, 935.) Harvard Law professor and criminal defense lawyer Alan Dershowitz, whom Giuffre publicly alleged of perpetrating sex crimes alongside Epstein, moved to unseal a limited portion of the record in order to clear his name. (15-cv-7433, Dkt. No. 364 at I.) Alt-right activist and provocateur Michael Cernovich also sought to unseal the papers filed as part of Maxwell's motion for summary judgment, arguing, "Cemovich Media cannot conduct its Forth [sic] Estate function if this Court allows the Parties to conduct their dispute outside of the normal sunlight of transparency and accessibility." (15-cv-7433, Dkt. No. 551 at 1.) The Miami Herald Media Company and investigative journalist Julie Brown, whose feature story about Epstein recently garnered significant public interest, also moved post-settlement to unseal the entire record. (15-cv-7433, Dkt. No. 936.) + +All such applications were denied by Judge Sweet. (15-cv-7433, Dkt. Nos. 439 (sealed), 892, 953.) A consolidated appeal from the orders denying the unsealing motions is currently pending before the Second Circuit. Giuffre v. Maxwell, No. 18-2868 (2d Cir.). On March 6, 2019, the Court of Appeals heard argument on the consolidated appeal, which was widely covered in the legal press. I think it is fair to say that during the argument, the panel seemed critical of the district court's failure to make specific findings about why any particular document as to which unsealing was sought should remain sealed. For example, Circuit Court Judge Jose A. Cabranes stated that Maxwell's lawyer "[couldn't] possibly be serious" when he argued that no documents should be made public, even after the case had settled.' + +Priscilla DeGregory, Documents related to pedophile Jeffrey Epstein may be unsealed, N.Y. Post (Mar. 6, 2019), https://nypost.cont/2019/03/06/documents-related-topedophiledeffrey-epstein-may-be-unsealed/. + +Shortly after the oral argument, the Court of Appeals issued an unusual order, giving the parties to the appeal ten days to explain why all papers submitted in connection with Maxwell's unsuccessful motion for summary judgment should not immediately be unsealed. (18-2868, Dkt. No. 138.) The docket reveals that responsive filings were in fact delivered to the Court of Appeals; no further order has been entered in the Second Circuit. + +The consolidated appeal relates only to the unsealing of what would, but for the Protective Order and Judge Sweet's repeated decisions to permit materials to be filed under seal and his refusal to unseal those materials on the motions of the Intervenors, be publicly available in the files of the court. They do not address materials that may be in the files of the parties or their counsel. + +## C. The Government's Application + +In late November or early December 2018, the Government commenced an investigation into Epstein and others for unlawfully trafficking minors, in violation of 18 U.S.C. §§ 1591, 1594(c) and unlawfully enticing minors in violation of 18 U.S.C. § 2422(b). (Sealed Aft and Appl. of AUSA dated Feb. 5, 2019 ("Gov't Appl."), Dkt. No. 1,113.) + +As part of that investigation, the Government issued a subpoena to Boies Schiller "requiring the production of copies of discovery and related materials in [the Giuffiv Action]." (Gov't Appl., ¶ 5.) These materials are arguably subject to the Protective Order. + +On February 5, 2019, the Government made an ex parte, in camera application to Judge Sweet under the All Writs Act, 28 U.S.C. § 1651(a), seeking to relieve Boies Schiller from the Protective Order so that it could respond to the subpoena. The Government represented in that application that Boies Schiller was willing to comply with the subpoena but for the Protective + +Order. (Letter from AUSA to the Hon. Robert W. Sweet, dated Feb. 28, 2019 ("Gov't Letter Br."), Dkt. No. 2, at 1.) + +Judge Sweet asked for further briefing. On February 28, 2019, the Government submitted a letter brief in camera, to which it appended a copy of the Protective Order and a proposed order granting the relief requested. (See Gov't Letter Br.) Neither the initial application nor the subsequent letter brief was initially filed with the Clerk of Court. + +Prior to ruling on the Government's application, Judge Sweet died. The open application was referred to me. + +1 directed that a miscellaneous docket number be assigned to the Government's application and that all materials theretofore sent to Judge Sweet's chambers be filed under seal.2 + +I also held two conferences in which I questioned the U.S. Attorney's Office about the application. + +## II. The Government's Application, While Irregular, Is Granted + +## A. Procedural Irregularities Attendant to This Application + +In the ordinary course, one would expect this application to arise in a different procedural posture. + +First, one would have expected Boies Schiller, the recipient of the subpoena, to have either (1) moved for relief from the Protective Order, or (2) moved to quash the subpoena. See In re Grand Jury Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d 1221, 1225 (2d Cir. 1991) ("The proper procedure .. . is .. . to subpoena the deposition transcripts for use in a pending proceeding such as a grand jury investigation or trial, in which the issue could be raised + +2 All materials under this docket number, 19-mc-I49, including this opinion, will be kept under seal as related to a pending grand jury investigation. + +by motion to quash or modify the subpoena ... or to seek permissive intervention in the private action.") (internal quotations omitted); but see Palmieri v. State of N Y., 779 F.2d 861, 862 (2d Cir. 1985) (considering appeal where the New York State Attorney General, rather than the subject of the subpoena, was the moving party). + +During the conference, the Government was not able to explain why it, rather than Boies Schiller, made the application. Boies Schiller is perfectly capable of protecting its own interests. The law firm's failure to seek for itself permission to respond to the subpoena seems particularly mysterious in light of the fact that it has filed papers on behalf of Giuffre, in both the district and appellate proceedings, supporting the intervenors' applications to unseal the entire record. See, e.g., Br. for Pl.-Appellee Virginia L. Giuffre, Giuffre v. Maxwell, No. 18-2868 (2d Cir. Dec. 27, 2018), ECF No. 83 at 1 ("Ms. Giuffre ... is now prepared to have the world see what the record contains."). I suppose that Boies Schiller might not want to seem too cooperative with the Government, especially if it is concerned about ending up as a defendant in a lawsuit alleging breach of contract if it has failed to return or destroy the Confidential Materials in its possession. See Alai Nissay Dowa Ins. Co. v. ProSight Specialty Mgmt Co., No. 12-cv-3274, 2012 WL 3583176, at \*6 (S.D.N.Y. Aug. 21, 2012). But that does not strike this Court as a reason for the Government to carry the firm's water—the moreso because Judge Sweet ruled some months before he died that the intervenors' appeals in Giuffie meant the lawsuit had not "concluded," and so had postponed the day when that contractual obligation kicked in. (15-cv-7433, Dkt. No. 967 at 6.)3 + +3 This ruling came in response to a motion by Maxwell to compel Giuffre's compliance with the document destruction provision. It argued that Giuffre's obligations thereunder were triggered at the time of settlement. (I5 cv-7433, Did. Nos. 957.) Judge Sweet denied that motion in light of the pending appeals. (I 5-cv-7433, Mt. No. 967). + +Alternatively, the Government could have moved ex parte for permissive intervention in the Giuffie Action, and then sought modification of the Protective Order. Permissive intervention is the appropriate procedural device when any non-party seeks to modify a protective order. AT&T Corp. v. Sprint Corp., 407 F.3d 560, 562 (2d Cir. 2005) ("We have stated that permissive intervention is the proper method for a nonparty to seek a modification of a protective order."); H.L. Hayden Co. of New York v. Siemens Med Sys., Inc., 797 F.2d 85, 90 (2d Cir. 1986) ("[W]e continue to adhere to our holding in Martindell [v. International Tel. and Tel. Corp., 594 F.2d 291, 294 (2d Cir. 1979)], that `this extraordinary writ [mandamus] would hardly be available ... where the only purpose was to obtain modification of a pretrial order for investigative purposes.'). Or it could have filed a writ of mandamus, since "mandamus lies to compel a judge to unseal documents shown to be material and necessary in litigation," United States v. Davis, 702 F.2d 418, 423 (2d Cir. 1983). But the Government has done neither of the above; instead, it has moved pursuant to the All Writs Act. It cites no authority for that procedure. + +Nonetheless, there is precedent in this Circuit for granting procedurally puzzling applications by the Government to unseal materials for use by a grand jury. For example, in Davis, 702 F.2d 418, the Government, which was not a party to the underlying civil litigation, successfully "moved the Bankruptcy Court for an order permitting it access to the materials under seal," including transcripts of examinations taken under Rule 205 and exhibits marked at those examinations. Id at 420-21. On appeal, the Second Circuit rejected the defendantappellants' argument that the bankruptcy court had abused its discretion in granting the Government's application: "A court may direct access to such material upon a proper showing of + +need. Here such a showing was amply demonstrated. To have refused access to these records in the face of a subpoena from a grand jury would have been an abuse of discretion." Id. at 423. + +I will, therefore, consider the Government's application. + +## B. The Martindell Standard Applies + +Ordinarily, "Where there has been reasonable reliance by a party or deponent, a District Court should not modify a protective order granted under Rule 26(c)." S E.C. v. TheStreet Com, 273 F.3d 222, 229 (2d Cir. 2001). However, the Second Circuit established a limited exception to this rule in Martindell v. International TeL and Tel. Corp., 594 F.2d 291 (2d Cir. 1979). + +Martindell arose after the Government made an informal, telephonic request to the district court in a stockholder derivative suit for access to deposition transcripts, which were subject to a protective order and which the Government planned to use in a criminal investigation. Id. at 293. The district court denied the Government's request to modify the protective order to enable it to access the transcripts. Id. Affirming the lower court, the Second Circuit reasoned that, when the Government moves to modify a protective order, it is especially appropriate to require a higher showing, because the Government both (i) possesses extraordinary police powers that it can use to obtain the information in other ways, and (ii) typically seeks the information "in the context of a public investigation in which the assertion of a privilege might be of critical importance." In re Agent Orange Prod. Liab. Litig., 104 F.R.D. 559, 570 (E.D.N.Y. 1985), aff'd, 821 F.2d 139 (2d Cir. 1987) (citing Martindell, 594 F.2d at 295). The court concluded, "After balancing the interests at stake, we are satisfied that, absent a showing of improvidence in the grant of a Rule 26(c) protective order or some extraordinary circumstance or compelling need, none of which appear here, a witness should be entitled to rely upon the enforceability of a protective order against any third parties, including the Government, + +and that such an order should not be vacated or modified merely to accommodate the Government's desire to inspect protected testimony for possible use in a criminal investigation[.]" Martindell, 594 F.2d at 296. + +Since Martindell, "It is well-settled [in this Circuit] ... that a Rule 26(c) protective order may be overturned or modified [only] based on a finding of improvidence, extraordinary circumstances or compelling need." Andover Data Servs., a Div. of Players Computer, Inc. v. Statistical Tabulating Corp., 876 F.2d 1080,1083 (2d Cir. 1989). Moreover, the Second Circuit has held that Martindell applies to the Government, as well as to any other third party seeking to modify a protective order. TheStreet Com, 273 F.3d at 229 n.7. + +The Government argues that Martindell should not apply to the instant application, for three reasons. (Gov't Letter Br. at 3-5.) + +First, it argues that the rule of Martindell is inapplicable because here the grand jury issued a valid and proper subpoena to Boies Schiller, while in Martindell the Government "'was proceeding outside of its usual investigative powers to secure the requested testimony, not by grand jury subpoena,' Davis, 702 F.2d at 422." (See Gov't Letter Br. at 3-4.) However, the statement from Davis that is quoted above concerned the testimony of a non-party appellant whose testimony was not subject to a Rule 26(c) protective order, but rather to an informal "understanding of confidentiality" that was never reduced to writing. Davis, 702 F.2d at 422. The opinion underscored that the parties' unwritten understanding about the confidentiality of this deponent's testimony would not trump a formal grand jury subpoena. That discussion is irrelevant to the question of whether this Court is required to apply the Martindell rule in evaluating this application. + +Second, the Government argues that Martindell does not apply when "as here, the protective order is on its face temporary or limited." (Gov't Letter Br. at 4.) But the Protective Order in this case is at least arguably not temporary or limited. It would have expired had the case gone to trial, but, as the case settled, it appears to me to bind the parties permanently. It is true that nothing in the Protective Order seems to prevent either Giuffre or Maxwell from making public documents that were designated confidential by that party once the lawsuit is over. However, as to documents designated confidential by the other party, the promise of confidentiality plainly survives termination of the lawsuit—even to the point of requiring that those materials be returned or destroyed. + +Third, the Government argues that applying Martindell to its application here "would risk rendering [Martindellj in even further conflict with the well-reasoned decisions of numerous other Circuits." (Gov't Letter Br. at 5 n.3.) Martindell is indeed an outlier; every other Circuit that has considered the clash between protective orders and grand jury subpoenas has questioned its wisdom and has come up with a standard more favorable to the Government's position. See generally Dane L. Steffenson, Are Rule 26(c) Protective Orders Viable Against Grand Juries?, 26 Golden Gate U. L. Rev. 183 (1996); 8A Fed. Prac. & Proc. Civ. § 2044.1 (3d ed. Nov. 2018). I happen to agree with the other Circuits, but Martindell is the law in this Circuit, and I am not at liberty to ignore it. + +The Government argues that the Court should decline to analyze its request pursuant to Martindell in light of Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 (S.D.N.Y. 1994). Like this case, Chemical Bank arose in a somewhat unusual posture: a party to a protective order unilaterally approached the Manhattan District Attorney's Office, "suggesting that it had evidence of criminal violations relating to the case." Id. at 93. The District Attorney then issued + +a grand jury subpoena, with which the party (the defendant) complied. At no point did the defendant seek relief from the protective order. Id When the other party to the protective order learned of the defendant's blatant disregard of its obligations, it moved for sanctions in the civil action. Id. + +The district court condemned the defendant's behavior as "entirely unnecessary and inappropriate," but nonetheless refused to sanction the defendant—apparently because, had the defendant sought relief from that order, the judge would have granted its request. Id. at 93-94. While the Martindell factors were never mentioned expressly by the district court, Judge Broderick observed that the confidentiality order did not implicate "technological trade secrets, currently sensitive customer lists, or contemporarily sensitive competitive information which could benefit rivals"—factors that, if present, he would have had more difficulty balancing against the investigative needs of law enforcement. Id. at 94. + +There are three reasons why Chemical Bank does not justify this Court's refusing to apply the Martindell factors to the Government's application. First and foremost, the opinion of another district judge does not trump an opinion from the Second Circuit. Second, while a reader of Chemical Bank cannot be certain whether the district court complied with Martindell, the language quoted above certainly suggests that the district court engaged in the balancing exercise that Martindell contemplated. Finally, nothing in the record suggests that the Government's investigation in this case was occasioned by Boies Schiller—a point to which I will return later in this opinion. + +The Court will, therefore, analyze the Government's request in light of the Martindell factors. + +## C. On the Current Record, the Court Cannot Find That the Protective Order Was "Improvidently Granted" + +Under Martindell, a Rule 26(c) protective order may be modified, for among other reasons, where a party can show "improvidence in the grant." 594 F.2d at 296. While the Government has not moved for modification on these grounds, I address this factor in light of the current proceedings before the Second Circuit. + +The term is not well understood. See United States v. Talco Contractors, Inc., 153 F.R.D. 501, 511 (W.D.N.Y. 1994) (observing that the Circuit "provided no guidance as to what might constitute `improvidence in the grant of a ... protective order"'). To date, the Second Circuit has identified two ways in which an order might be considered "improvidently granted." The first is, essentially, that it was issued in bad faith. However, this is a high bar. For example, a sealing order is "improvidently granted" where the presiding judge "reasonably should have recognized that [it] would facilitate or further criminal activity." Palmieri, 779 F.2d at 865-66. But there is absolutely no evidence that the district court harbored any such realization; indeed, at the time Judge Sweet entered the Order, it appeared that criminal activity against Maxwell and Epstein was a thing of the past.° Nothing in the record indicates that the entry of the Protective + +4 In 2007, financier Jeffrey Epstein plead guilty to two prostitution charges in state court, arising from allegations that he "assembl[ed] a large, cult-like network of underage girls—with the help of young female recruiters" (including Maxwell)—whom he coerced into performing sex acts "behind the walls of his opulent waterfront mansion," among other locations, "as often as three times a day." Julie K. Brown, How a future Trump Cabinet member gave a serial sex abuser the deal of a lifetime, Miami Herald (Nov. 28, 2018), https://www.miamiherald.com/news/locaVarticle220097825.html. The deal also included a non-prosecution agreement with the Department of Justice, which immunized Epstein and four named accomplices from all federal charges, broadly immunized "any potential co-conspirators," and—in contravention of federal law—kept the agreement secret from Epstein's victims. hi Epstein served just thirteen months in county jail, during part of which he was permitted to continue working from his downtown office. Id. + +In November 2018, the Miami Herald published a series of feature articles describing the allegations against Epstein and suggesting that the plea deal constituted Government misconduct. Liam Stack, U.S. Opens Inquiry Into Handling of Jeffrey Epstein's Sex Abuse Case, N.Y. Times (Feb. 6, 2019), https://www.nytimes.com/2019/02/06/usgbi-jeffrey-epstein.html. The exposi garnered attention from the media and from Congress and has apparently prompted an investigation by the Department of Justice. Id Whether the grand jury subpoena arose out of this renewed interest in Epstein's behavior is ultimately not relevant to the Court's decision—but it seems likely. + +Order itself facilitated or furthered criminal activity; and the record contains no evidence of bad faith. + +The second way in which a protective order might be "improvidently granted" is if the presiding judge did not require the moving party to show "good cause" for entering an order that permitted documents to be filed with the court under seal. It was long the law that the parties needed to make a document-by-document showing of good cause whenever discovery materials were filed with the court under seal. In re Agent Orange Prod. Liab. Litig., 821 F.2d 139, 148 (2d Cir. 1987) (Agent Orange). + +In recent years, however, the Second Circuit has relaxed the Rule 26(c) "good cause" showing for discovery materials that are never filed with the court, in light of changes to the Federal Rules of Civil Procedure. TheStreet Com, 273 F.3d at 233 n.11. The new, more lax standard recognizes that, "Without an ability to restrict public dissemination of certain discovery materials that are never introduced at trial, litigants would be subject to needless annoyance, embarrassment, oppression, or undue burden or expense." Iridium India Telecom Ltd. v. Motorola, Inc., 165 F. App'x 878, 881 (2d Cir. 2005) (summary order) (emphasis added) (quoting TheStreet Com, 273 F.3d at 229). + +As a result, the "good cause" showing necessary for entry of a blanket pretrial protective order like the one entered in Giuffre is not onerous. Dorsett v. Cty. of Nassau, 289 F.R.D. 54, 67 (E.D.N.Y. 2012). "[W]here "a protective order (1) is entered on a showing of good cause as required by Rule 26(c), (2) is limited to the context of pretrial civil discovery, and (3) does not restrict the dissemination of the information if gained from other sources," it is not improvidently granted. Id (quoting Seattle Times Co. v. Rhinehart, 467 U.S. 20, 37 (1984)); see also FragranceNetcom, Inc. v. Fragrancel.com, Inc., No. 06-cv-2225, 2010 WL 11606632, at •4 + +(E.D.N.Y. Mar. 15, 2010) (order was not improvidently granted where "parties were concerned about exchanging commercially sensitive material with their direct competitors"). In fact, at least one district court in this Circuit has held that "stipulated, umbrella confidentiality orders are not per se improvident even if good cause was not shown." Intl Equity Inn., Inc. v. Opportunity Equity Partners Ltd., No. 05-cv-2745, 2010 WL 779314, at \*4 (S.D.N.Y. Mar. 2, 2010) (emphasis added), objections overruled, No. 05-cv-2745, 2010 WL 1459178 (S.D.N.Y. Apr. 12, 2010), aff'd, 415 F. App'x 286 (2d Cir. 2011). + +The Protective Order entered by Judge Sweet was certainly not "improvidently granted" under the standard articulated in Dorsett. The Protective Order was granted on the basis of legitimate privacy concerns on the part of both Giuffre and Maxwell, as well as third parties. See In re Ionosphere Clubs, Inc., 156 B.R. 414, 435 (S.D.N.Y. 1993), affd, 17 F.3d 600 (2d Cir. 1994) (finding "no showing of improvidence where the justifications for the Protective Orders [were] immediately apparent"). Material turned over in discovery that was ultimately used at trial would have been publicly available. (Protective Order 1 13 ("This Protective Order shall have no force and effect on the use of any CONFIDENTIAL INFORMATION at trial in this matter.").) The Second Circuit may well be on the verge of making material used in connection with the summary judgment motions publicly available, though of course I cannot predict what order will ultimately issue from the Court of Appeals. And there does not appear to be any problem with the entry of a Protective Order that specifically contemplates case-by-case consideration of whether materials filed with the court should or should not be sealed. + +I have no idea whether Judge Sweet made the requisite findings in his decisions granting the various motions to seal publicly-filed documents that were made in Giuffie. See, e.g., TheStreet Com, 273 F.3d 222, 231 (2d Cir. 2001) ("While Martindell established a general and + +strong presumption against access to documents ... we have held more recently in United States v. Amodeo, 44 F.3d 141, 145 (2d Cir.1995) ('Amodeo P ), that a subspecies of sealed documents in civil cases—so-called 'judicial documents'—deserve a presumption in favor of access.") (emphasis in original). That, I gather, is the subject of the pending appeal. Press reports of the oral argument suggest that perhaps the neceggary findings might not have been made before certain court filings were sealed. I cannot and will not pretend not to know that the issue is out there. However, I know of no reason why it would have been improper to shield sensitive materials from public disclosure before any court filings were made. + +## D. If Any Party Relied on the Protective Order To Shield Confidential Materials from Disclosure to Law Enforcement, That Reliance Was Unreasonable + +Under Martindell, a court must consider the degree to which the party opposing unsealing (or, in this case, the party who could be expected to oppose unsealing) reasonably relied on the protective order. "Once a confidentiality order has been entered and relied upon, it can only be modified if an 'extraordinary circumstance' or 'compelling need' warrants the requested modification." v. Ernst & Ernst, 677 F.2d 230, 232 (2d Cir. 1982) (emphasis added) (internal quotation omitted). + +I will assume, for purposes of argument, that Maxwell would oppose releasing Boies Schiller from the terms of the Protective Order in order to accommodate the grand jury subpoena; that is fairly obvious from her refusal to agree to a protective order that would have permitted Boies Schiller to comply with the subpoena without a court order authorizing compliance. I further assume she would argue that she relied on the Protective Order in deciding whether and how to comply with various discovery requests. The question to be decided is whether such reliance was reasonable. + +"An examination of Second Circuit case law reveals the following factors are relevant when determining whether a party has reasonably relied on the protective order: (1) the scope of the protective order; (2) the language of the order itself; (3) the level of inquiry the court undertook before granting the order; and (4) the nature of reliance on the order." In re Ethylene Propylene Diene Monomer (EPDM) Antitrust Ling., 255 F.R.D. 308, 318 (D. Conn. 2009). + +The first factor—the scope of the Protective Order—favors granting the Government's application for modification. As discussed, the Protective Order was "a broad blanket order, stipulated to by the parties, which afforded the parties the discretion to designate whatever they produced as 'confidential.' Nielsen Co. (U.S), LLC v. Success Sys., Inc., 112 F. Supp. 3d 83, 120 (S.D.N.Y. 2015). Blanket pretrial protective orders, drafted by the parties and "so ordered" by the court, are common. This case was no exception. "A broad protective order is less likely to elicit reliance 'because it is more difficult to show a party reasonably relied on a blanket order in producing documents or submitting to a deposition.' Id. (quoting EPDM, 255 F.R.D. at 319). + +The second factor—the language of the Protective Order itself-similarly weighs in favor of modification. The Protective Order provided that confidential information could be used at trial. (Protective Order, 11 4, 13.) As the Second Circuit has repeatedly held, a temporary or limiting provision in a protective order undercuts a finding of reasonable reliance, because from the outset there was the very real possibility that material produced in discovery would end up in the public record. See, e.g., Agent Orange, 821 F.2d at 147. The very fact that material would have to be unsealed for trial undercuts a finding of reliance. + +Additionally, where material contained in court filings is concerned, any expectation of confidentiality is necessarily grounded on the court's decision whether to grant the motion to seal (presumably after weighing the necessary factor)—not reliance on the protective order. And + +while the Protective Order also had a permanent aspect about it—Le., it provides for the return or destruction of documents upon conclusion of the case (see Protective Order ¶ 12)—this provision neither trumped the law concerning the public's right of acePcs to materials filed in court, nor specifically required the designating party to maintain confidentiality over its own designated materials once the Protective Order expired. (See Id) + +Of course, this case contains an unusual fact that might seem to render Maxwell's reliance on a blanket Protective Order reasonable, as against even disclosure pursuant to a grand jury subpoena. We know that Maxwell refused to agree to any Protective Order containing a provision that is customary in all the protective orders entered by this Court: a provision permitting the production of confidential materials to law enforcement without further order of the court. (See Def. 's Reply in Further Supp. of Mot. for Protective Order, 15-cv-7433, Dkt. No. 49 at 5.) This might seem ironic, since Maxwell argued, in support of her motion for entry of a protective order, that prosecution of anyone based on Giuffre's allegations was unlikely. (Id) But whether prosecution seemed likely or not, Maxwell did indeed bargain for such a provision; and for whatever reason, Giuffre and Boies Schiller agreed to it. + +However, the Protective Order entered by Judge Sweet contains a provision that permits the court to order disclosure of Confidential Material in circumstances other than those listed in Paragraph 5 (a)—(h). See Protective Order ¶ 5 ("CONFIDENTIAL INFORMATION shall not, without the consent of the party producing it or further Order of the Court, be disclosed[.]") (emphasis added). All the list of exceptions at subparagraphs 5(a) through (h) does is indicate when there is no need for the opponent's consent or a court order before disclosure can be made. As the Protective Order plainly gives the court the power to enter an order compelling disclosure to anyone—law enforcement included—Maxwell could not reasonably have relied on the + +absence of automatic permission for such disclosure to shield anything she said or produced from a grand jury's scrutiny. As the court reasoned in EPDM, 255 F.R.D. at 321, language stating that the party receiving designated confidential information "shall not use or disclose the information except . . . by such orders as may be issued by the Court during the course of this litigation" did "not lend itself to reasonable reliance that [the Protective Order] will afford permanent secrecy." See also Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 126 (2d Cir. 2006), where, in view of a provision that said, "This Confidentiality Order shall not prevent anyone from applying to the Court for relief therefrom," the Second Circuit held, "Given this provision, it is difficult to see how the defendants can reasonably argue that they produced documents in reliance on the fact that the documents would always be kept secret." + +Third, there is no evidence before me indicating that the court undertook any sort of detailed inquiry prior to entering the Protective Order. (Hrg. Tr., 15-cv-7433, Dkt. No. 66 at 4:25-5:12.). Obviously, I was not there, but I have reviewed the transcript of the argument on the motion for a protective order, and it seems clear that the parties were given ample discretion to designate discovery materials as confidential, with virtually no oversight unless those materials were to be filed with the court—in which case a motion for sealing had to be made.5 (Protective Order ¶ 10); of Litton Indus., Inc. v. Lehman Bros. Kuhn Loeb Inc., 122 F.R.D. 433, 435 (S.D.N.Y. 1988) (declining to enforce protective order where "the protective order did not adjudicate the appropriateness of confidentiality as to particular items of discovery"). The fact + +&quot;The question about a protective order, of course there should be a protective order in this case. You are good lawyers, and you have been around this track more times than I have and so you can prepare consensually a better protective order than I can, and I urge you to do that. And, in fact, I will give you two weeks to do that. Should you fail, you can present whatever materials you wish to me and I will decide what the protective order is going to be. That's not a good idea because you know the case better than I do, obviously, and so I urge you to resolve it by your litigation skills and not leave it up to the ignorant district court judge who doesn't really get into this kind of thing very often. So you run a risk if you leave it to me." (Hrg. Tr., 15-cv-7433, Dkt. No. 66 at 4:25- 5:12.) + +that confidentiality originated with the consent of the parties, and not with a judicial determination that the materials at issue were deserving of protection, militates against a finding of reasonable reliance. "[C]ourts have been reluctant to find reliance, or that reliance was reasonable, where a protective order is, as here, a blanket order entered by stipulation of the parties." In re NASDAQ Mkt.-Makers Antitrust Litig., 164 F.R.D. 346, 356 (S.D.N.Y. 1996). + +As for the last factor, the nature of the parties' reliance on the order does seem to weigh against modification. "The classic situation in which a party `relies' on a protective order is where the party creates material during the course of the litigation on the understanding that it will be kept confidential—for example, by .. . giving confidential testimony." Allen v. City of N.Y., 420 F. Supp. 2d 295, 300-01 (S.D.N.Y. 2006). The record shows that Giuffre likely could not have secured Maxwell's deposition—at least in the absence of substantial court involvement—without the Protective Order.6 Maxwell specifically mentioned "the specter of some theoretical prosecution" when arguing in support of the entry of her version of the Protective Order. Although, as noted above, she discounted the likelihood of any such prosecution (see supra, at 18.), she argued that, "A witness adverse to Plaintiff would be reluctant to testify and may be bullied into asserting a Fifth Amendment privilege to avoid the potential of information being forwarded to a prosecutor by the Plaintiff or her lawyers." (Def's Reply in Further Supp. of Mot. for Protective Order, 15-cv-7433, Dkt. No. 49 at 5); of Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 743 (2d Cir. 1987) ("[O]ne of the primary reasons the protective order was originally entered was to prevent plaintiffs from using the threat + +6 I cannot possibly second guess how Judge Sweet ran this litigation; he had far more experience than I and was justly respected for it. Had the case been before me, Maxwell would have been required to testify, or she would have been held in contempt or had issues resolved against her, Protective Order or no. And in every case in which I sign a protective order, I require the parties to agree to an addendum—the very terms of which would render blanket reliance on eternal confidentiality unreasonable. My practices make it difficult to put myself into Judge Sweet's shoes for purposes of this application. But do so I must. + +of turning over their discovery to the government in order to coerce a settlement"). The parties also settled just a short time before trial; such a settlement could have been occasioned, at least in part, to avoid the public disclosure of any confidential materials. + +However, the only thing on which Maxwell or anyone else might reasonably have relied is that Giuffre or her lawyers would not do what the defendant in Chemical Bank did—that is, forward discovery materials in their possession to prosecutors for the purpose of fomenting an investigation. But I am not faced with that situation. Nothing in this record suggests to me that Giuffre or Boies Schiller had anything to do with the Government's decision to convene a grand jury to look into the matters that were the subject of the Giuffre Action. On the contrary—the Government has advised the Court that it contacted Boies Schiller as part of its search for parties who might have been victims in its investigation; and that Boies Schiller told the Government that it could not consensually produce at least some documents in its files because of the existence of the Protective Order. There is no evidence of "collusion," to invoke a term of the moment, and it is quite clear that Boies Schiller did not foment the Government's investigation. Moreover, the Assistant United States Attorney has represented to this Court that he has no idea what is in Boies Schiller's files, and that for all he knows every witness who was deposed stood on his/her Fifth Amendment rights and refused to answer questions. + +The literal terms of the Protective Order permit the court to authorize the release of Confidential Materials by parties to the Order "for good cause shown." (Protective Order, 1 14.) Any party who read the order had to be aware that it contained no promise that Confidential Materials would forever be withheld from a prosecuting agency—especially where, as here, a duly empowered grand jury seeks their production. + +This decision accords with those of other courts in this Circuit. "Where a protective order contains express language that limits the time period for enforcement, anticipates the potential for modification, or contains specific procedures for disclosing confidential materials to non-parties, it is not reasonable for a party to rely on an assumption that it will never be modified." EPDM, 255 F.R.D. at 320. More to the point, "Uncertainty about the ultimate outcome of a protective order will mean that no deponent may always effectively rely on a protective order to secure his right against self-incrimination." Andover Data Servs., 876 F.2d at 1084 (quoting In re Grand Jury Subpoena, 836 F.2d 1468, 1478 (4th Cir. 1988)). + +Because Maxwell's reliance on the Protective Order to shield her from the court-ordered disclosure of Confidential Materials pursuant to a grand jury subpoena was unreasonable, the Court may exercise its discretion to grant the Government's application. "Where a litigant or deponent could not reasonably have relied on the continuation of a protective order, a court may properly permit modification of the order. In such a case, whether to lift or modify a protective order is a decision committed to the sound discretion of the trial court." TheStreet Com, 273 F.3d at 231 (internal quotation omitted); accord Gambale v. Deutsche Bank AG, 377 F.3d 133, 142 n.7 (2d Cir. 2004) ("If reliance would be unreasonable, it is within the discretion of the court to vacate or modify a protective order."). + +For the reasons discussed below, the Court finds that modification of the Protective Order is appropriate to aid law enforcement. + +## E. The Government Has Shown "Extraordinary Circumstances" That Warrant Modification of the Protective Order + +The Government has persuasively demonstrated extraordinary circumstances, which would entitle it to modification in any event. + +The term "extraordinary circumstances" is not well defined. See Talco Contractors, Inc., 153 F.R.D. at 511. However, the Second Circuit has recognized that this requirement may be met in circumstances involving significant public interest, particularly where no good cause showing was made to the court initially. See Agent Orange, 821 F.2d at 148 ("exceptionally pervasive protection granted appellants during the pretrial stages of this litigation, coupled with the fact that appellants never were required to show good cause," as well as the fact that there was "enormous public interest in the Agent Orange litigation," demonstrated extraordinary circumstances); but see Ionosphere Clubs, 156 B.R. at 435 ("[M]ere breadth" of a protective order does not, by itself constitute "extraordinary circumstances."). Indeed, some district courts in this Circuit go one step further, holding that "The heightened Martindell `extraordinary circumstances' standard . .. is not appropriate in cases with stipulated protective orders that grant parties open-ended and unilateral deference to protect whichever discovery materials they choose." EPDM, 255 F.R.D. at 321. + +Here, as discussed, no party was required to make a good cause showing before designating any particular discovery materials as confidential. Moreover, there is significant public interest: the Government has convened a grand jury to investigate a serious crime (potentially involving multiple victims), which from its inception has garnered extensive publicity, and which (most recently) includes troubling allegations of misconduct on the part of Government officials, including a then-United States Attorney who is now a member of the President's Cabinet. The Court agrees with the Government that, because the investigation is not publicly known, "the ordinary exercise of grand jury power [Le., to subpoena witnesses to testify and to produce documents] . . . would implicate and invite the very risk of disclosure—and the possibility of alerting potential criminal targets that they are under investigation, causing them to + +destroy evidence, flee from prosecution, or otherwise seriously jeopardize the Investigation that caused the Government to proceed via subpoena [to Boies Schiller] and its related Application." (Gov't Letter Br. at 5.) + +To be sure, the convenience of having potentially incriminating testimony readily available does not in and of itself rise to the level of an extraordinary circumstance. In Martindell itself, for example, the Second Circuit found no extraordinary circumstance because "the Government, by discharging the grand jury investigating the matters in connection with which the Government sought the witnesses' deposition transcripts, apparently chose not to use grand jury investigative prorecses to obtain their testimony." 594 F.2d at 296 n.5. Therefore, the mere unavailability of the information was not extraordinary. Similarly, in Nosik v. Singe, 40 F.3d 592 (2d Cir. 1994), the Circuit again declined to find that the Government had made a showing of extraordinary circumstance, explaining, "[T]he possibility that [an individual] might one day invoke the Fifth Amendment at her criminal trial does not automatically create for prosecutors a compelling need for the testimony that [the individual] might have given [in the civil proceeding] . [.] Prosecutors often make do without the testimony of a defendant." Id at 595-96 (citing Martindell, 594 F.2d at 296). + +Here, however, the extraordinary amount of publicity surrounding all aspects of what I will call the Epstein matter does create practical limitations to the grand jury's ability to secure certain information with the secrecy it requires to conduct an appropriately thorough and thoughtful investigation. Moreover, it does not appear to this Court that we are in a situation in which the Government seeks information merely to "ascertain the truth of much of what it has independently discovered." Minpeco, 832 F.2d at 743. This is not a case, like United States v. Oshatz, 700 F. Supp. 696, 703 (S.D.N.Y. 1988), where the Government was trolling for evidence + +to use at a trial, rather than seeking information as part of a criminal investigation or grand jury proceeding. See also Botha v. Don King Productions, Inc., No. 97-cv-7587, 1998 WL 88745, at \*3 (S.D.N.Y. Feb. 27, 1998) (Ville Government may not use its `awesome' investigative powers to seek modification of a protective order merely to compare the fruits of . . . discovery in a civil action with the results of a prosecutorial investigation in a criminal action."). + +Additionally, the Government is not on a fishing expedition, merely hoping to inspect the protected materials for possible use in a future criminal investigation. In Martindell, 594 F.2d at 296, the Second Circuit concluded that the purported public interest in obtaining all relevant evidence was less than compelling in view of the Government's subpoena power. Here, however, a grand jury that is presently conducting an investigation has issued a subpoena for the productionpf documents as part of an ongoing investigation. The Government's interest is bolstered when the request is made by a grand jury, rather than informally by the United States Attorney. See, e.g., In re Grand Jury Subpoena Duces Tecum Dated Oct 29, 1992, 1 F.3d 87, 94 n.4 (2d Cir. 1993). The Government's application is therefore based on more than a desire to "exploit[] . the fruits of private litigation." Martindell, 594 F.2d at 296. And the fact that the request comes from a grand jury, whose proceedings are by law conducted in secret, In re Petition of Craig, 131 F.3d 99, 101 (2d Cir. 1997), gives Maxwell the degree of protection that could reasonably be expected in the context of a criminal investigation. + +Finally, while in other circumstances the breadth of the subpoena might be troubling, here the Government is in no position to narrow its request, because the Giuffre Action was litigated entirely almost under seal. Cf. Grand Jury Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d at 1223 (noting that a "lengthy report" of the bankruptcy examination, which included deposition excerpts, "was made available to the public"). The fact that the Second + +Circuit—even before a final order disposing of the intervenors’ appeal—has been critical of that fact, and has demanded an explanation for why it should not immediately unseal at least the materials filed in connection with the motion for summary judgment, lends force to the Government’s request, despite its breadth. + +For these reasons, the Government has demonstrated extraordinary circumstances warranting a modification of the Protective Order. + +**III. Conclusion** + +For the reasons stated above, the Court GRANTS the Government’s application to modify the Protective Order, in order to permit Boies Schiller to comply with the subpoena. + +The Clerk of Court is ORDERED to file this memorandum opinion and order under seal. + +The Clerk of Court is also respectfully requested to close the open application at Docket Number 2. All materials in this matter, 19 Misc. 149; are ORDERED to be kept under seal until further notice. + +Dated: April 9, 2019 + +![]()\_\_\_\_\_ +Chief Judge + +BY HAND TO AUSA [REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00086685/EFTA00086685.metadata.json b/marker2/ds9/EFTA00086685/EFTA00086685.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..01697a14fcafd0e4d524001b72376709b440e9c5 --- /dev/null +++ b/marker2/ds9/EFTA00086685/EFTA00086685.metadata.json @@ -0,0 +1,1654 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086685.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 27, + "chars": 52028, + "elapsed_seconds": 7.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "EXHIBIT G", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 227.052, + 381.51 + ], + [ + 386.8426513671875, + 381.51 + ], + [ + 386.8426513671875, + 413.1134338378906 + ], + [ + 227.052, + 413.1134338378906 + ] + ] + }, + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 69.26899999999999, + 72.08999999999999 + ], + [ + 294.41900634765625, + 72.08999999999999 + ], + [ + 294.41900634765625, + 102.11248779296875 + ], + [ + 69.26899999999999, + 102.11248779296875 + ] + ] + }, + { + "title": "SEALED MEMORANDUM DECISION AND ORDER GRANTING \nTHE GOVERNMENT'S APPLICATION TO MODIFY THE PROTECTIVE ORDER", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 80.916, + 217.89000000000004 + ], + [ + 531.7979736328125, + 217.89000000000004 + ], + [ + 531.7979736328125, + 247.99249267578125 + ], + [ + 80.916, + 247.99249267578125 + ] + ] + }, + { + "title": "I. 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diff --git a/marker2/ds9/EFTA00086713/EFTA00086713.md b/marker2/ds9/EFTA00086713/EFTA00086713.md new file mode 100644 index 0000000000000000000000000000000000000000..347c3046afc87c03b5c0c8e89b75da365c4b1239 --- /dev/null +++ b/marker2/ds9/EFTA00086713/EFTA00086713.md @@ -0,0 +1,396 @@ +## Exhibit D + +## EXHIBITS + +![](_page_2_Picture_185.jpeg) + +[REDACTED], maiden name [REDACTED], date of birth [REDACTED], Social Security Account Number [REDACTED] Social Security Number [REDACTED] United States Citizen and Australian Permanent Resident, residence [REDACTED], [REDACTED] was interviewed at the United States Consulate in Sydney, Australia. [REDACTED] was advised of the identity of the interviewing agents and purpose of the interview. Present during the interview was Federal Bureau of Investigation Special Agent [REDACTED] and via telephone, Assistant United States Attorney [REDACTED] [REDACTED] provided the following information: + +b6 +b7C + +[REDACTED] was born in Sacramento, California to parents [REDACTED] date of birth [REDACTED] currently resides in [REDACTED] and [REDACTED] date of birth [REDACTED] currently resides in [REDACTED] [REDACTED] moved to Palm Beach County, Florida with her parents when she was four years old and returned to California at age 11. She returned to Florida at age 13 and was placed in a rehabilitation or foster care facility in West Palm Beach, Florida. + +b6 +b7C + +[REDACTED] ran away from the rehabilitation facility when she was approximately 14 years old, and while living on the streets in Miami, Florida, she met [REDACTED] + +b6 +b7C + +[REDACTED] + +[REDACTED] was training [REDACTED] to be an escort [REDACTED] gave [REDACTED] a life off of the streets which made her feel + +Investigation on 03/17/2011 at Sydney, Australia (In Person) +File # 31E-MM-108062 Date drafted 07/05/2013 +by [REDACTED] + +b6 +b7C + +This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its contents are not to be distributed outside your agency. + +Continuation of FD-302 of [redacted], On 03/17/2011, Page 2 of 12 + +like she was locked into the relationship. [redacted] gave [redacted] pharmaceutical drugs toward the end of their relationship. + +b6 +b7C + +[redacted] + +[redacted] relationship with [redacted] ended while she was at a private ranch near Ocala, Florida. [redacted] telephonically contacted a childhood friend, [redacted] from a telephone at the ranch. [redacted] knew [redacted] from elementary school and called him at the home telephone of his parents [redacted] told [redacted] she was very lonely, and [redacted] asked her why she did not leave [redacted] telephone conversation with [redacted] the recreational vehicle (RV) [redacted] was staying in at the ranch [redacted] did not strike her [redacted] pack her belongings and told her she was going to live with another man. + +b6 +b7C + +[redacted] +[redacted] felt that she was sent to [redacted] but did not know the specifics of the arrangement. [redacted] engaged in sexual activity with [redacted] who was described as a white male [redacted] stated [redacted] stayed with [redacted] LNU for approximately one or two weeks before the police located her and returned her to her parents. [redacted] was interviewed by a male detective. [redacted] parents were still married at the time and lived near [redacted] Florida. [redacted] believed there was an FBI investigation related to [redacted] She never saw [redacted] again after + +b6 +b7C + +In approximately June 1998 or 1999, [redacted] began working at Donald Trump's Mar-A-Lago Club in Palm Beach, Florida. [redacted] father [redacted] was able to help her gain employment as a baby sitter and later as a locker room attendant at the club. [redacted] started studying for her GED and wanted to become a massage therapist. In August, [redacted] was reading an anatomy/massage book and was approached by [redacted] [redacted] and help her get her masseuse accreditation. [redacted] + +b6 +b7C + +[redacted] consulted her father about the opportunity and at approximately 5:00 p.m. the same day, her father drove her to a residence at [redacted] + +Continuation of FD-302 of [redacted], On 03/17/2011, Page 3 of 12 + +[redacted] Florida. [redacted] spoke with [redacted] father and told him it was a wonderful opportunity for [redacted]. [redacted] met [redacted] also known as [redacted] was led upstairs [redacted] + +b6 +b7C + +Once upstairs in [redacted] [redacted] instructed [redacted] to wash her hands prior to beginning the massage. The massage began [redacted] demonstrated massage techniques to [redacted]. + +b6 +b7C + +During the course of the massage, [redacted] questioned [redacted] about her past, including her time as a runaway. [redacted] was also asked if she took birth control. + +b6 +b7C + +[redacted] + +b6 +b7C + +[redacted] was given instruction and began kissing [redacted] [redacted] + +b6 +b7C + +At the conclusion, [redacted] instructed [redacted] to obtain two warm wash clothes. One wash cloth was used to clean [redacted] second was [redacted] to help him relax. [redacted] described [redacted] and [redacted] then moved to the steam room and shower where [redacted] massaged [redacted] with soap and a loofah in the shower. + +b6 +b7C + +At the conclusion of the shower, [redacted] went downstairs and [redacted] + +b6 +b7C + +Arrangements [redacted] for [redacted] to return to the house the following day after work. [redacted] cellular phone number was given to [redacted] + +times The same routine and pattern of massages and sexual activity between and continued for between one and two weeks. At b6 + +31E-MM-108062 + +Contumatoon of FD-302 of .0, 03/17/2011 page 4 of 12 + +b7C + +job at Mar-A-Lago and travel 'offered the option to quit her There was also discussion of receiving massage training. was to be paid \$200.00 per day for travel and 5200.00 per hour for massages. + +Early in her relationship with' eti and was introduced as 'assistant. + +b6 b7C + +soon began traveling For the initial six months, traveled around the United States and Caribbean, b6 including California, New York City, New Mexico, and various business b7C trips. During those trips' I + +Six to nine months after began working for was introduced tcl '.NU,I in b6 1Florida. b7C fat the time. met the couple at a condominium next to the 'The condominium was bought' and was a provided a normal massage t 'In the condominium, NU. Shortly thereafter' LNU provided an erotic massage to RE and paid cash 'In addition, paid years old at the timer cleaned She was was 16 + +advised' (introduced her to the drug Xanax. She explained that Xanax helped her escape from reality but allowed her to still function normally. Xanax helped her go forward with what she was doing with land others. Her habit went from two pills per day up to eight pills per day. + +second client was an academic of some sort described as an older American male from Miami International Airport to' 'by commercial airline. airport byl Jand then taken to the island by boat. was picked up at the b6 b7C + +b6 b7C + +Continuation of FD-302 of [redacted], On 03/17/2011, Page 5 of 12 + +pointed out that [redacted] instructed [redacted] to entertain the client [redacted] and wanted to ride jet skis and participate in other island activities [redacted] spent two days on the island with the client. [redacted] assumes the client also traveled [redacted] commercially. + +b6 +b7C + +During the following several months, [redacted] traveled internationally [redacted] Prior to her traveling abroad, [redacted] assisted [redacted] in getting her passport. [redacted] got passport photographs of herself and provided them to [redacted] The remaining paperwork was taken care of by [redacted] traveled to Paris, France, the South of France, London, England, Africa, and Spain. While in Paris, [redacted] recalled staying at a hotel overlooking the Champs-Elysees. While traveling [redacted] traveled on [redacted] a black plane. During the international travel, [redacted] At times, [redacted] would [redacted] + +b6 +b7C + +Rarely a day would pass [redacted] + +[redacted] contacted [redacted] through [redacted] and wanted to talk to [redacted] about [redacted] and offered [redacted] a contract. [redacted] agreed to the contract for her story and was paid \$140,000 for the story, \$10,000 when the article was printed, and another \$10,000 to be wired into [redacted] account in May 2011. The contract prevented [redacted] from talking to any other press for a specified period. [redacted] advised that she provided [redacted] with detailed information [redacted] + +b6 +b7C + +[redacted] + +b6 +b7C + +[redacted] + +b6 +b7C + +Continuation of FD-302 of Virginia L. [REDACTED], On 03/17/2011, Page 6 of 12 + +[REDACTED] + +b6 +b7C + +[REDACTED] + +[REDACTED] At age 16, [REDACTED] +met [REDACTED] +[REDACTED] believed she and [REDACTED] were +approximately the same age. [REDACTED] and [REDACTED] + +b6 +b7C + +[REDACTED] +[REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] would dress +[REDACTED] + +b6 +b7C + +[REDACTED] +[REDACTED] + +b6 +b7C + +[REDACTED], though [REDACTED] explained +[REDACTED] provided an +[REDACTED] +[REDACTED] described [REDACTED] + +b6 +b7C + +An unknown individual [REDACTED] +[REDACTED] saw [REDACTED] when she arrived at +[REDACTED] +[REDACTED] had [REDACTED] +[REDACTED] said that day was a low stage in her relationship +because she could not believe [REDACTED] +[REDACTED] +[REDACTED] never + +b6 +b7C + +Conanuatoon of FD-302 of On 03/17/2011 Pase 7 of 12 + +saw I believed the girls may have been' b6 I but b7C was not certain of[ 'involvement. + +b6 b7C + +had a picture of herself she wanted to giver + +described some of the unique interior areas of + +which referred to which was where stayed. + +While in New York, also stayed at an apartment on 66th street was aware of additional apartments in the same building. According to he apartment building on 66th street was owned b IUFFRE advised that she had a photo raph of the interior of the 66th Street apartment among other photos + +advised that some of her photographs that were provided to her civil attorneys by her family were not returned. One of the missing photos depicted wearing a pink dress while seated on a quad bike. + +was' 'female that formerly lived inr + +b6 b7C + +b6 b7C + +b6 b7C + +CONFIDENTIAL GIUITREO01241 + +Alhambra Castle in Spain. recalled visiting + +31E-MM-108062 + +Continuation of FD-302 of o n 03/17/2011 page 8 of 12 + +LNU and went shopping together and purchased clothing and sex toys. explained that) + +used a cellular telephone' 'She believed it was a New York City number but could not recall the number. and + +could only remember faces) Inot their names. did not' I but she did try unsuccessfully to get + +recalled) not recall the wording. advised) but she could b6 ILNU. b7C + +b6 b7C + +b6 b7C + +at a hotel d Rock Café in New in traveled Ito a self-help conference New Orleans, Louisiana. The hotel w q near the H Orleans. traveled the worl .ncluding the USVI, and the United New York, Santa Fe, Palm Beach, France, Africa, Spain Kingdom. + +b6 b7C + +eventually traveled to the United Kingdom and + +b6 b7C + +CONFIDENTIAL GIllITRE001242 SDNY\_GM\_00114989 + +Continuation of FD-302 of [redacted], On 03/17/2011, Page 9 of 12 + +while there, [redacted] approached [redacted] in a very excited manner and told her they had to go shopping to pick out a dress because [redacted] would be dancing with [redacted] + +b6 +b7C + +[redacted] and [redacted] went shopping and purchased makeup, clothing, and a Burberry bag. The items were purchased with [redacted] and [redacted] returned [redacted] instructed [redacted] to get ready. When [redacted] came down after getting ready, she was introduced to [redacted] + +b6 +b7C + +[redacted] + +[redacted] traveled to CLUB TRAMP [redacted] danced [redacted] at CLUB TRAMP [redacted] + +[redacted] + +[redacted] stayed at CLUB TRAMP for an hour or hour and a half and drank a couple of cocktails before returning to [redacted] had not received any direction from [redacted] + +[redacted] After returning to [redacted] [redacted] requested [redacted] to take a photograph of her [redacted] advised that she still had the original photograph in her possession and would provide it to the interviewing agents. [redacted] proceeded with [redacted] + +[redacted] + +Approximately two months later, [redacted] met [redacted] at [redacted] + +[redacted] + +b6 +b7C + +[redacted] [redacted] recalled [redacted] +LNU, [redacted] + +[redacted] recalled [redacted] joking about trading [redacted] in because she was getting too old. + +Continuation of FD-302 of [redacted], On 03/17/2011, Page 10 of 12 + +[redacted] recalled meeting [redacted] [redacted] was using Xanax heavily at the time, [redacted] and her recollection was not clear. She remembered there were many models on the island that did not speak English along with a modeling person who had an unknown accent. + +b6 +b7C + +[redacted] +[redacted] + +b6 +b7C + +[redacted] did not have a problem with [redacted] using prescription drugs. [redacted] was described by [redacted] as a [redacted] + +b6 +b7C + +[redacted] (TRUE NAME UNKNOWN) [redacted] a ranch employee in [redacted] but [redacted] could not recall his name. She did have a photograph of the ranch employee. + +b6 +b7C + +[redacted] met numerous famous people [redacted] including academics, politicians, and celebrities. She met [redacted] and [redacted] and [redacted] + +b6 +b7C + +[redacted] received many gifts [redacted] including jewelry, watches, bags, shoes, make up, clothing, and home furnishings. [redacted] [redacted] left all of the items behind when she traveled to Thailand to receive massage training. + +b6 +b7C + +In August 2002, [redacted] traveled by commercial airline to Bangkok, Thailand and began her massage training at International Training Massage School(ITM) where she received her massage certification. She stayed at the Princess Hotel in Thailand [redacted] but never did. [redacted] met her future husband, [redacted] during her visit to Thailand. [redacted] contacted [redacted] telephonically and told him she had fallen in love with someone. [redacted] + +b6 +b7C + +31E-MN-108062 + +Continuation of FD-302 of On 03/17/2011 pue 11 of 12 + +had not heard from' telephone call from[ 'During that call,' stated he was an FBI agent. He was trying to determine what she knew about She did not tell' anything about her knowledge of I She also received another telephone call from a person that indicated he was an FBI agent. She did not tell that individual anything either. She also received a call from an attorney that was trying to determine if she had spoken with anyone or was willing to speak to anyone) 'She received a explained that she was receiving telephone calls from people whom she did not know and that she was uncomfortable telling them anything over the telephone. + +One or two weeks later, an unknown attorney and' contacted telephonicallyi + +was using a cellular telephone belonging to her husband. She nor her husband could recall the telephone number but advised that the carrier was OPTUS telephone company. + +reviewed a series of photographs of individuals and identified the following: + +Page 1, number 1, + +Page 1, number 2 LNU, a.k.a + +Page 2, number 1, J + +Page 2, number 6, + +Page 3, number 2, + +Page 4, number 3, LNU + +Page 4, number 7, + +Page 4, number 8, + +Page 5, number 1, + +advised that the following were familiar to her, but she could not recall their names or her association to them: + +b6 b7c + +b6 b7C + +b6 b7C + +Continuation of FD-302 of On 03/17/2011 .fts, 12 of 12 + +Page 1, number 4 + +Page 2, numbers 7 and 8 + +Page 3, number 8 + +Page 4, number 1 + +Page 5, numbers 5 and 8 + +The images reviewed by were placed in a lA envelope of the case file. + +When questioned about United States Customs and Border (CBP) Patrol records of her entries into the United States, advised that her January 2001 record was the return from her London, England trip' 'The April 2001 CBP record was her return to the United States' March and May 2001 CPB records. could not recall her travel from advised that her United States Passport was turned over to the United States Consulate in Sydney, Australia. + +On March 18, 2011, writer, SA' and traveled to residence where she provided 20 photographs and her ITM massage school certification. FD-597 Receipts for Property were executed for the items and a copy was provided to It is noted that the receipts were dated based on the United States Eastern Standard Time Zone date. 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EXHIBIT A + +To: Gmax From: Jeffrey Sent: Fri 7/31/2009 3:48:17 PM Subject: Re: + +no there is no criminal anything" we can file a rotective order, saying you were nowhere near the person during the relevant dates.. you will never have to testify.. it is the same as ifsued you for harrasment + +On Fri, Jul 31, 2009 at 11:24 AM, Gmax la wrote: + +If I get served what does it mean - I have a set court date to attend and ans questions about you - a grand jury - or what? + +— Original Message --- + +From: Jeffrey Epstein To: Gmax Sent: Thu Jul 30 23:08:22 2009 Subject: Re: + +its a different lawsuit" they are serving anyone they have read about + +On Thu, Jul 30, 2009 at 9:25 PM, Gmax < wrote: + +He came to the house and asked if I was there - sounded like the description of guy who tried to serveMit had jane doe and my name on it + +Original Message — + +From: Gmax To: Sent: u u . • • + +Some guy apparently is trying to serve me %via subpeoena..what is this about + +**From:** jeffrey E. [REDACTED] +**Sent:** Sunday, January 25, 2015 4:41 AM +**To:** G Maxwell +**Subject:** Re: + +ok, with me, You have done nothing wrong and I would urge you to start acting like it. go outside, head high, not as an escaping convict. go to parties. deal with it. I had lisa svenson the swedish ocean ambassador yesteady she said no one on her ocean panel takes this stuff seriously and you would be welcoe to the ocean conference water conference etc. + +On Sat, Jan 24, 2015 at 1:22 PM, G Maxwell <[REDACTED]> wrote: +I would appreciate it if [REDACTED] would come out and say she was your g'friend - I think she was from end 99 to 2002 + +THE TERRAMAR PROJECT +FACEBOOK +TWITTER +G+ +PINTEREST +INSTAGRAM +PLEDGE +THE DAILY CATCH + +-- + +please note + +The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE + +Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [REDACTED] and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved + +PRIVILEGED GM\_001098 +GM\_01098 +CONFIDENTIAL \ No newline at end of file diff --git a/marker2/ds9/EFTA00086727/EFTA00086727.metadata.json b/marker2/ds9/EFTA00086727/EFTA00086727.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e13877affefda721bfd827b58f2278cf5661f6ae --- /dev/null +++ b/marker2/ds9/EFTA00086727/EFTA00086727.metadata.json @@ -0,0 +1,130 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086727.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2354, + "elapsed_seconds": 5.58, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "EXHIBIT A", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 227.66400000000002, + 379.89 + ], + [ + 385.72802734375, + 379.89 + ], + [ + 385.72802734375, + 413.1134338378906 + ], + [ + 227.66400000000002, + 413.1134338378906 + ] + ] + } + ], + "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", + 52 + ], + [ + "Line", + 26 + ], + [ + "Text", + 12 + ], + [ + "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", + 16 + ], + [ + "PageFooter", + 8 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00086727" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086730/EFTA00086730.md b/marker2/ds9/EFTA00086730/EFTA00086730.md new file mode 100644 index 0000000000000000000000000000000000000000..93dd3b68f63e19a1824f52589932b91e314c8412 --- /dev/null +++ b/marker2/ds9/EFTA00086730/EFTA00086730.md @@ -0,0 +1,25 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x • UNITED STATES OF AMERICA, v. 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GHISLAINE MAXWELL, Defendant. • x + +20 Cr. 330 (MN) + +## NOTICE OF MOTION + +ORAL ARGUMENT REQUESTED + +## DEFENDANT GHISLAINE MAXWELL'S NOTICE OF MOTION TO DISMISS COUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT BECAUSE THE ALLEGED MISSTATEMENTS ARE NOT PERJURIOUS AS A MATTER OF LAW (Pretrial Motion # 4) + +PLEASE TAKE NOTICE that, upon the accompanying memorandum of law and exhibits, Defendant Ghislaine Maxwell, through counsel, hereby moves to dismiss Counts Five and Six of the Superseding Indictment because the alleged misstatements are not perjurious as a matter of law. + +Dated: January 25, 2021 New York, New York Respectfully submitted, + +s/ Jeffrey S. Pagliuca + +Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver CO 80203 Phonel + +Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: + +Bobbi C. Stemheim Law Offices of Bobbi C. 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Cohen + +Mark S. Cohen mcohen®cohengresser.com Christian Everdell ceverdell@cohengresser.com 800 Third Avenue, 21' Floor New York, NY 10022 Phone: Fax: + +Jeffrey S. Pagliuca Laura A. Menninger + +HADDON, MORGAN & FOREMAN P.C. + +150 East 10th Avenue + +Denver, Colorado 80203 + +Phone: + +Bobbi C. Stemheim + +Law Offices of Bobbi C. 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Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 + +Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 + +Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 + +Attorneys for Ghislaine Maxwell + +## TABLE OF CONTENTS + +| | Page | +|---------------------------------------------------------------------------------|--------------------------------------------------------------------------| +| PRELIMINARY STATEMENT | 1 | +| SUMMARY OF ALLEGATIONS | 3 | +| ARGUMENT | 5 | +| I. All References to Accuser-3 Should Be Stricken as Surplusage | 5 | +| A. | The Indictment Is Insufficient to Allege a Conspiracy as to Accuser-3. 6 | +| B. The Allegations Regarding Accuser-3 Are Irrelevant to the Alleged | | +| Conspiracies | 7 | +| C. | The Allegations Regarding Accuser-3 Are Unduly Prejudicial to Ms. | +| Maxwell. | 9 | +| II. In the Alternative, the Government Should Be Required to Demonstrate the | | +| Admissibility of Evidence Regarding Accuser-3 Pursuant to Fed. R. Evid. 404(b). | 10 | +| CONCLUSION | 11 | + +### TABLE OF AUTHORITIES + +| Cases Grunewald v. United States, | Page(s) | +|-------------------------------------------------------------------------------------|---------| +| 353 U.S. 391 (1957) Stogner v. California, | 8 | +| 539 U.S. 607 (2003) United States v. Benussi, | 7 | +| 608 (2d Cir. 2003) United States v. Curley, | 7 | +| 639 F.3d 50 (2d Cir. 2011) United States v. Greebel, | 10 | +| No. 15-cr-637 (KAM), 2017 WL 3610570 (E.D.N.Y. Aug. 4, 2017) United States v. Hsia, | 5 | +| 24 F. Supp. 2d 14 (D.D.C. 1998) United States v. Scarpa, | 8, 9 | +| 913 F.2d 993 (2d Cir. 1990) Statutes | 5 | +| 18 U.S.C. § 2421 | 3 | +| 18 U.S.C. § 2422 | passim | +| 18 U.S.C. § 2423 | passim | +| 18 U.S.C. § 2424 | 3 | +| 18 U.S.C. § 3283 (1994) | 6, 7 | +| 18 U.S.C. § 3283 (2003) | 7 | +| N.Y. Penal Law § 130.55 Rules | 3 | +| Fed. R. Crim. P. 7(d) | 5 | +| Fed. R. Evid. 404 | passim | + +### Other Authorities + +| Sexual Offences Act 2003 § 9 (Eng.), 2003, c. 42 | 4 | +|----------------------------------------------------------------------------------------|---| +| Telecommunications Act of 1996, PL 104-104, Feb. 8, 1996, Title V, § 508, 110 Stat. 56 | 3 | +| Title XVI, § 160001(g), 108 Stat. 1796 | 6 | + +### PRELIMINARY STATEMENT + +Ghislaine Maxwell respectfully submits this Memorandum in Support of her Motion to Strike Surplusage from the Indictment ("Motion"). + +Although Ms. Maxwell is charged with conspiring to cause individuals to travel in interstate or foreign commerce to engage in unlawful sexual activity, the indictment contains no allegation that Accuser-3 ever traveled.' Moreover, throughout the period alleged in the indictment, Accuser-3 was above the legal age of consent in England, where all alleged conduct as to her took place. Therefore, the Court should strike all allegations regarding Accuser-3 from the indictment, as they are nothing more than a transparent attempt by the government to introduce Accuser-3's testimony as evidence of a conspiracy, when it is at most "other acts" evidence subject to the balancing test required by Fed. R. Evid. 404(b). + +Counts One through Four of the indictment allege that between 1994 and 1997, Ms. Maxwell violated and conspired to violate two separate provisions of the Mann Act: 18 U.S.C. § 2422 (now § 2422(a)), which prohibits the enticement of individuals to travel in interstate or foreign commerce for the purpose of engaging in unlawful sexual activity, and 18 U.S.C. § 2423(a), which prohibits the transportation of individuals under age 18 in interstate or foreign commerce with the intent that they engage in unlawful sexual activity. The substantive Mann Act counts involve Ms. Maxwell's alleged enticement and/or transportation of Accuser-1. + +The indictment alleges that Ms. Maxwell engaged in group sexual encounters with Jeffrey Epstein and Accuser-1 and that, on at least one occasion, Ms. Maxwell enticed or caused Accuser-1 to travel from Florida to New York for the purpose of engaging in such encounters with Epstein. But to do so, it must rely on the accusations of a single individual regarding + +I This individual is described in the indictment as Minor Victim-3. Similarly, we refer to the individuals identified in the indictment as Minor Victim-1 and Minor Victim-2 as Accuser-I and Accuser-2, respectively. + +conduct that allegedly took place more than two decades ago—accusations so vague that they do not even link Ms. Maxwell to the only specific allegation of travel by Accuser-1 in the indictment (see Indictment¶¶ 1lb, 17b). + +To try to bolster its case, the government alleges that Ms. Maxwell was complicit in Epstein's alleged "sexual abuse" of two other individuals, Accuser-2 and Accuser-3, and has included allegations regarding Ms. Maxwell's interactions with these two individuals in the indictment. But the allegations as to Accuser-3 cannot possibly support the charges against Ms. Maxwell: Although the gravamen of a § 2422(a) or § 2423(a) offense is enticing or causing an individual to travel, there is no allegation that Accuser-3 ever traveled—let alone that Ms. Maxwell (or Epstein, for that matter) enticed her to do so or transported her. Moreover, although both § 2422(a) and § 2423(a) require an intent that the traveling individual engage in unlawful sexual activity, the indictment alleges no facts suggesting that Epstein's alleged sexual activity with Accuser-3, who was over the legal age of consent in England at all relevant times, was unlawful. As a result, these allegations serve only to demonstrate a propensity on the part of Ms. Maxwell that will prejudice the jury against her. + +To enable the presentation of evidence regarding Accuser-3, the government claims the alleged "sexual abuse" of Accuser-3 is somehow an "overt act" in furtherance of conspiracies to cause unspecified individuals to travel for the purpose of engaging in unlawful sexual activity. The government's inclusion of these allegations, however, is nothing more than an attempted end-run around its obligations under Fed. R. Evid. 404(b). The "overt act" alleged as to Accuser-3 has nothing to do with the alleged conspiracy. Moreover, the allegations regarding Accuser-3 are unduly prejudicial to Ms. Maxwell. Accordingly, Ms. Maxwell requests that the allegations regarding Accuser-3 be stricken as surplusage, or in the alternative, that the + +government be required to treat any evidence supporting such allegations as Fed. R. Evid. 404(b) evidence, subject to balancing by this Court of its probative value and prejudicial effects. + +## SUMMARY OF ALLEGATIONS + +Counts One through Four of the indictment allege that Ms. Maxwell violated and conspired to violate two separate provisions of the Mann Act, 18 U.S.C. §§ 2421-2424. These counts are based on conduct that occurred at unspecified times between 1994 and 1997. + +Counts Two and Four allege that Ms. Maxwell substantively violated 18 U.S.C. § 2422 (now § 2422(a)) 2 and § 2423(a), respectively, by enticing and causing Accuser-1 to travel from Florida to New York in order to engage in sex acts with Jeffrey Epstein that would violate N.Y. Penal Law § 130.55. Indictment¶¶ 13, 19. The indictment does not charge Ms. Maxwell with a substantive Mann Act violation as to any individual other than Accuser-1, nor does it allege that Ms. Maxwell personally enticed or caused any person other than Accuser-1 to travel in interstate or foreign commerce for any reason. + +Counts One and Three allege that Ms. Maxwell conspired with Epstein "and others" to violate §§ 2422(a) and 2423(a), respectively. Indictment ¶¶ 9, 15. Count One alleges that the object of the § 2422(a) conspiracy was to "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." ld.1 10. Count Three alleges that the object of the § 2423(a) conspiracy was to "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." Id. 1 16. + +2 Prior to February 8, 1996, this provision constituted the entirety of § 2422; it became § 2422(a) as a result of the enactment of additional subsections as of that date. Telecommunications Act of 1996, PL 104-104, Feb. 8, 1996, Title V, § 508, 110 Stat 56. The provision is referred to herein as § 2422(a). + +In addition to the allegations regarding Accuser-1, the indictment includes factual allegations regarding Ms. Maxwell's interactions with two other individuals, Accuser-2 and Accuser-3, some of which are characterized as "overt acts" in furtherance of the two conspiracies. Ms. Maxwell is not alleged, however, to have enticed or otherwise caused either Accuser-2 or Accuser-3 to travel. + +Ms. Maxwell's interactions with Accuser-3 allegedly took place entirely in London, England, where Ms. Maxwell is alleged to have "groomed and befriended" Accuser-3 "between approximately 1994 and 1995." Id. ¶ 7c. Ms. Maxwell allegedly introduced Accuser-3 to Epstein and arranged for "multiple interactions between [Accuser-3] and Epstein," during which Ms. Maxwell "encouraged [Accuser-3] to massage Epstein, knowing that Epstein would engage in sex acts with [Accuser-3] during those massages." Id. + +Although the indictment alleges that Epstein "sexually abused" Accuser-3 during the massages (id.), it does not allege that Epstein's interactions with Accuser-3 were nonconsensual or in violation of any English law. Notably, Ms. Maxwell is not alleged to have met Accuser-3 and introduced her to Epstein until 1994 at the earliest, by which time Accuser-3 had reached age 163—the legal age of consent in England. Sexual Offences Act 2003 § 9 (Eng.), 2003, c. 42. Thus, it appears that the "sexual abuse" of Accuser-3 that the indictment alleges was lawful conduct. + +Nor does the indictment 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, Epstein, or anyone else. Yet Counts One and Three allege that Ms. Maxwell's encouragement of Accuser-3 to provide massages to Epstein in the future was somehow an overt act in furtherance of the alleged + +3 The government has disclosed that Accuser-3 was born in March 1977. + +§ 2422(a) and § 2423(a) conspiracies to cause individuals to travel in interstate or foreign commerce to engage in unlawful sexual activity. Id. ¶¶ 11d, 17d. + +## ARGUMENT + +## I. All References to Accuser-3 Should Be Stricken as Surplusage. + +Under Fed. R. Crim. P. 7(d), "[u]pon the defendant's motion, the court may strike surplusage from the indictment or information." "This rule introduces a means of protecting the defendant against immaterial or irrelevant allegations in an indictment or information, which may, however, be prejudicial." Fed. R. Crim. P. 7(d) Advisory Committee's Note. In the Second Circuit, Fed. R. Crim. P. 7(d) motions may be granted "where the challenged allegations are not relevant to the crime charged and are inflammatory and prejudicial." United States v. Scaipa, 913 F.2d 993, 1013 (2d Cir. 1990) (internal quotations omitted); see United States v. GreebeI, No. 15-cr-637 (KAM), 2017 WL 3610570, at \*2 (E.D.N.Y. Aug. 4, 2017) (striking language stating that defendant "orchestrated four interrelated fraud schemes" where indictment charged him in only two of those schemes). + +The paragraphs of the indictment alleging that Ms. Maxwell was complicit in Epstein's "sexual abuse" of Accuser-3 are irrelevant, inflammatory, and unduly prejudicial. The indictment is plainly insufficient to allege that Ms. Maxwell conspired to entice Accuser-3 to travel, or to transport her in interstate or foreign commerce, let alone with the requisite intent. Moreover, the allegations regarding Accuser-3 have nothing to do with whether Ms. Maxwell conspired to violate § 2422(a) or § 2423(a) with respect to Accuser-1 or Accuser-2. Thus, the only explanation for the inclusion of alleged 20-year-old allegations involving Accuser-3, and the characterization of the alleged conduct as "sexual abuse," is the likelihood that evidence submitted in support of those allegations will have an unduly prejudicial effect and would not survive a balancing analysis under Fed. R. Evid. 404(b). + +## A. The Indictment Is Insufficient to Allege a Conspiracy as to Accuser-3. + +To establish a § 2422(a) conspiracy violation, the government must show that Ms. Maxwell conspired to "knowingly persuade[], induce[], entice[], or coerce[] any individual to travel in interstate or foreign commerce ... to engage in prostitution, or in any sexual activity for which any person can be charged with a criminal offense." 18 U.S.C. § 2422(a) (1996). To establish a § 2423(a) conspiracy claim, the government must prove that Ms. Maxwell conspired to "knowingly transport[] an individual who ha[d] not attained the age of 18 years in interstate or foreign commerce ... with intent that the individual engage in prostitution, or in any sexual activity for which any person can be charged with a criminal offense." 18 U.S.C. § 2423(a) (1994); 18 U.S.C. § 2423 (1986).4 + +The government cannot show that Ms. Maxwell conspired to commit either offense with respect to Accuser-3. There is no allegation that Accuser-3 ever traveled in interstate or foreign commerce, let alone that Ms. Maxwell, Epstein, or anyone else enticed her or otherwise caused her to do so. While the indictment alleges that Ms. Maxwell encouraged Accuser-3 to massage Epstein in England "knowing that Epstein intended to sexually abuse [Accuser-3] during those massages" (Indictment 9¶ I Id, 17d), it alleges no facts connecting those allegations to any contemplated interstate or foreign travel by Accuser-3—for any purpose. The indictment thus does not come close to alleging facts that would establish a conspiracy to violate either § 2422(a) or § 2423(a) as to Accuser-3. + +Moreover, any charge arising out of a conspiracy with respect to Accuser-3 would be time-barred. The government contends that the indictment is timely under 18 U.S.C. § 3283, which, at the time of the alleged offenses, provided that a prosecution involving an "offense + +Section 2423 was amended effective September 13, 1994, to add a subsection (b) and make cosmetic adjustments, immaterial here, to what is now subsection (a). Violent Crime Control and Law Enforcement Act of 1994, PL 103- 322, Sept. 13, 1994, Title XVI, § I60001(g), 108 Stat 1796. + +involving the sexual or physical abuse of a child under the age of 18 years" could be brought until the victim reached age 25. 18 U.S.C. § 3283 (1994). While Congress amended the statute in 2003 to extend the time in which a prosecution could be brought to within the life of the victim, 18 U.S.C. § 3283 (2003), Accuser-3 reached the age of 25 in March 2002, and thus the statute of limitations as to her had expired before the time of the amendment. While Ms. Maxwell contends that § 3283 cannot be applied retroactively at all, and is inapplicable in any event,5 it is black-letter law that retroactive application of a criminal statute of limitations to revive a time-barred claim would violate the Ex Post Facto Clause. Stogner v. California, 539 U.S. 607, 618 (2003). Thus, there can be no prosecution for any conduct alleged as to Accuser-3. + +### B. The Allegations Regarding Accuser-3 Are Irrelevant to the Alleged Conspiracies. + +According to the indictment, the object of the alleged conspiracies was to entice or cause one or more individuals to travel in interstate or foreign commerce in order to engage in unlawful sexual activity. Because, as shown above, the allegations in the indictment are insufficient to allege such a conspiracy as to Accuser-3, the only individuals as to whom the indictment even arguably alleges such a conspiracy are Accuser-1 and Accuser-2. The allegations regarding Accuser-3, however, have nothing to do with any conspiracy as to Accuser-1 or Accuser-2. + +While the government couches the allegations regarding Minor Victim-3 as "overt acts" in furtherance of the conspiracies alleged in Counts One and Three, they are not. 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." United States v. Benussi, 216 F. Supp. 2d 299, 311 (S.D.N.Y. 2002), aff'd sub nom. United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003) + +s See Motion to Dismiss Counts One Through Four of the Indictment as Time-Barred. + +(quoting Grunewald v. United States, 353 U.S. 391, 397 (1957)). Thus, whether Ms. Maxwell's alleged conduct with respect to Minor Victim-3 constituted an overt act in furtherance of the alleged conspiracy depends on the scope of the alleged conspiracy. + +In United States v. Hsia, 24 F. Supp. 2d 14 (D.D.C. 1998), for example, the defendant was charged with conspiracy, and causing false statements to be made to the Federal Election Commission, in connection with an alleged scheme to obtain illegal campaign contributions from foreign donors. The defendant moved to strike references in the indictment to acts of concealment of the alleged conspiracy. The court expressed concern that "the allegations provide little detail about the acts" and that "references to the alleged acts of concealment and cover-up suggest the inclusion of offenses that are not part of the conspiracy charged in the indictment." Id. at 25. Although the court denied the defendant's motion to strike, it ordered a bill of particulars "as to the scope of the alleged conspiratorial agreement and in particular whether and how the acts of concealment alleged in the indictment were within the scope of the conspiracy charged." Id. at 33. The court added that if the bill of particulars confirmed the defendant's assertion that the alleged acts of concealment and cover-up were not within the alleged scope of the conspiratorial agreement, her motion to strike would be granted. Id. at 26. + +Here, the object of the alleged conspiracies—necessarily, under the Mann Act—was not to cause any individual to engage in unlawful sex acts with Epstein, but to cause individuals to travel to do so. The allegations regarding Accuser-3, even if proven, could not have furthered such alleged conspiracies. There is no basis for any reasonable inference that Epstein and Ms. Maxwell's interactions with Accuser-3 in England furthered a conspiracy to cause Accuser-1, Accuser-2, or anyone else to travel. There is no allegation that Accuser-3 even knew Accuser-1 or Accuser-2, or that there is any causal relationship between the alleged incidents involving Accuser-3 in England and those involving Accuser-I and Accuser-2 in the United States. + +To the extent there is any doubt about the scope of the alleged conspiratorial agreement, or how the allegations relating to Accuser-3 are within the scope of that agreement, the Court can resolve the issue by ordering a bill of particulars on these points, as the court did in Hsia. However, if the government cannot articulate how alleged sexual conduct with a person who never traveled falls within the scope of a conspiracy to cause another individual to travel, then allegations concerning Accuser-3 should be stricken. + +# C. The Allegations Regarding Accuser-3 Are Unduly Prejudicial to Ms. Maxwell. + +There can be no legitimate dispute that the allegations regarding Accuser-3 are inflammatory and unduly prejudicial to Ms. Maxwell. The indictment alleges that Epstein "sexually abused" Accuser-3 and that Ms. Maxwell encouraged Accuser-3 to massage Epstein, "knowing that Epstein intended to sexually abuse" Accuser-3. Indictment¶¶ 7c, l Id, I7d. The phrase "sexual abuse" connotes criminal activity, even though the alleged conduct may well have been lawful: Accuser-3 was at or above the legal age of consent in England at all relevant times, and the indictment contains no suggestion that the alleged sexual activity involving Accuser-3 was nonconsensual. Regardless of whether the conduct was lawful or unlawful in England, however, few allegations could be more prejudicial to a defendant than allegations that she participated in the "sexual abuse" of a teenager. The allegations as to Accuser-3, though irrelevant to the government's conspiracy counts, thus create precisely the prejudicial appearance the government seeks. + +Because the allegations as to Accuser-3 are both irrelevant to the charges against Ms. Maxwell and unduly prejudicial, they should be stricken as surplusage. + +### II. In the Alternative, the Government Should Be Required to Demonstrate the Admissibility of Evidence Regarding Accuser-3 Pursuant to Fed. R. Evid. 404(b). + +At a minimum, the government should not be permitted to use the allegations regarding Accuser-3 to perform an end-run around Fed. R. Evid. 404(b). Rather, the government should be required to demonstrate the admissibility under Fed. R. Evid. 404(b) of any evidence regarding Accuser-3. + +Fed. R. Evid. 404(b) "governs the admissibility of evidence of prior or subsequent tad acts'—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 prohibits the admission of such evidence if it `prove[s] the character of a person' to show his propensity to commit the charged act, but permits its admission for other purposes." Id. (quoting Fed. R. Evid. 404(b)). Permissible purposes include "proving motive, opportunity, intent, preparation, plan, knowledge, identity, absence of mistake, or lack of accident." Fed. R. Evid. 404(b)(2). In a criminal case, the rule obligates a prosecutor to (i) "provide reasonable notice of any such evidence that the prosecutor intends to offer at trial, so that the defendant has a fair opportunity to meet it"; (ii) "articulate in the notice the permitted purpose for which the prosecutor intends to offer the evidence and the reasoning that supports the purpose"; and (iii) "do so in writing before trial" unless excused by the court. Fed. R. Evid. 404(b)(3). + +As shown above, evidence regarding Accuser-3 is irrelevant to the conspiracy counts. Thus, to the extent that the government intends to introduce evidence regarding Accuser-3, such evidence is "other acts" evidence, and its admissibility should be litigated under Fed. R. Evid. 404(b). + +#### CONCLUSION + +For the foregoing reasons, Ms. Maxwell respectfully requests that the Court strike all references to Accuser-3 from Paragraph 7 of the indictment, and that the Court strike Paragraphs 7c, I Id, and I7d in their entirety. In the alternative, Ms. Maxwell respectfully requests that the Court require the government to provide notice pursuant to Fed. R. Evid. 404(6)(3) prior to introducing any evidence pertaining to Accuser-3, and that Ms. Maxwell be given an opportunity to litigate the admissibility of any such evidence pursuant to Fed. R. Evid. 404(b). + +Dated: January 25, 2021 New York, New York + +Respectfully submitted, + +/s/ Mark S. Cohen + +Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 + +Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 + +Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 + +Attorneys for Ghislaine Maxwell + +**CERTIFICATE OF SERVICE** + +I hereby certify that on January 25, 2021, I served by email, pursuant Rule 2(B) of the Court's individual practices in criminal cases, the within memorandum and any accompanying exhibits upon the following: + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +U.S. Attorney's Office, SDNY +One Saint Andrew's Plaza +New York, NY 10007 + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +*/s/ Christian Everdell* + +--- \ No newline at end of file diff --git a/marker2/ds9/EFTA00086736/EFTA00086736.metadata.json b/marker2/ds9/EFTA00086736/EFTA00086736.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..17c3f1a84eb9c844751ec7df61f5256a7cbe26de --- /dev/null +++ b/marker2/ds9/EFTA00086736/EFTA00086736.metadata.json @@ -0,0 +1,922 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086736.pdf", + "engine": { + "marker_major": "2", + "marker_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": 26918, + "elapsed_seconds": 3.63, + "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, + 70.47 + ], + [ + 281.419189453125, + 70.47 + ], + [ + 281.419189453125, + 99.7330322265625 + ], + [ + 68.544, + 99.7330322265625 + ] + ] + }, + { + "title": "MEMORANDUM OF GHISLAINE MAXWELL \nIN SUPPORT OF MOTION TO STRIKE SURPLUSAGE \nFROM SUPERSEDING INDICTMENT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 153.612, + 277.02 + ], + [ + 458.4794921875, + 277.02 + ], + [ + 458.4794921875, + 320.30352783203125 + ], + [ + 153.612, + 320.30352783203125 + ] + ] + }, + { + "title": "TABLE OF CONTENTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 238.68, + 71.28 + ], + [ + 374.138671875, + 71.28 + ], + [ + 374.138671875, + 86.853515625 + ], + [ + 238.68, + 86.853515625 + ] + ] + }, + { + "title": "TABLE OF AUTHORITIES", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 229.5, + 71.28 + ], + [ + 383.96685791015625, + 71.28 + ], + [ + 383.96685791015625, + 86.2330322265625 + ], + [ + 229.5, + 86.2330322265625 + ] + ] + }, + { + "title": "Other Authorities", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 166.91473388671875, + 71.28 + ], + [ + 166.91473388671875, + 86.103515625 + ], + [ + 68.544, + 86.103515625 + ] + ] + }, + { + "title": "PRELIMINARY STATEMENT", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 219.70799999999997, + 71.28 + ], + [ + 391.927978515625, + 71.28 + ], + [ + 391.927978515625, + 86.103515625 + ], + [ + 219.70799999999997, + 86.103515625 + ] + ] + }, + { + "title": "SUMMARY OF ALLEGATIONS", + "heading_level": null, + "page_id": 6, + "polygon": [ + [ + 215.42399999999998, + 125.55000000000001 + ], + [ + 397.0373840332031, + 125.55000000000001 + ], + [ + 397.0373840332031, + 140.853515625 + ], + [ + 215.42399999999998, + 140.853515625 + ] + ] + }, + { + "title": "ARGUMENT", + "heading_level": null, + "page_id": 8, + "polygon": [ + [ + 265.608, + 125.55000000000001 + ], + [ + 346.6669616699219, + 125.55000000000001 + ], + [ + 346.6669616699219, + 140.853515625 + ], + [ + 265.608, + 140.853515625 + ] + ] + }, + { + "title": "I. 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"", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00086736" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086752/EFTA00086752.md b/marker2/ds9/EFTA00086752/EFTA00086752.md new file mode 100644 index 0000000000000000000000000000000000000000..cfbbdc389f65c754df9609fc08a77909800fdbc4 --- /dev/null +++ b/marker2/ds9/EFTA00086752/EFTA00086752.md @@ -0,0 +1,90 @@ +From: ' r To: ' " •cl (USANYS)" + +Subject: FW: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera Date: Thu, 31 Dec 2020 00:38:23 +0000 + +Attachments: 2020.12.31 S tt r r on\_Rivera\_and\_Maxwell\_discovery\_and\_counsel\_access\_(v.2).docx; 2020.12.31 ecl re Rivera \_ and\_ Maxwell Jv.3).docx + +This all appears accurate to me and seems fine to file. Any issues from your perspective? + +From: (USANYS) + +Sent: Wednesday, December 30, 2020 5:29 PM + +To: (USANYS) (USANYS) .c ); a; (USANYS) + +Cc: (USANYS) < ;-(USANYS) >; (USANYS) ; (USANYS) .,, (USANYS) 1 + +Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera + +: We are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to explain that the discovery and counsel access accommodations that have been provided to Maxwell and Rivera, respectively, result from the specific circumstances of their cases, the specific requests of their lawyers, and their individual housing circumstances. On all of these factors, there are several important differences, including: + +The Maxwell case has multiple times more discovery than the Rivera case. Hence, the need for such expanded discovery access is greater in the Maxwell case. At the MDC, Maxwell has a unique housing situation, as she is in protective custody outside the general population. She therefore has sole access to a room to use a computer and phone for approximately 13 hours a day. Rivera, by contrast, is housed in the general population. There are approximately 8o other inmates at the MCC in Rivera's unit that use the same VTC room for court appearances, probation interviews, and attorney meetings. By contrast, Maxwell shares access to the MDC VTC room with substantially fewer inmates. The MDC can therefore provide 15 hours of VTC meetings with her attorneys without compromising access for other MDC inmates. The same is not true for Rivera at the MCC. + +Going forward, even though Rivera's counsel have asked (and the Court has ordered) that Rivera receive three hours of laptop access each day, the MCC is now leaving the laptop with him all day long, and only takes it back at night to charge it. Therefore, the MCC is now providing the same amount of electronic discovery access to Rivera that Maxwell receives at the MDC. + +As for providing Rivera with up to 15 hours of VTC access, we will explain that doing so will compromise access for other inmates. If defense counsel expresses a need for additional time, the MCC will continue to find ways to accommodate those requests as best as they can. + +Please let me know if you have any questions or would like to discuss this further. + +Best, + +From: (USANYS) + +Sent: Monday, December 21, 2020 4:42 PM + +To: (USANYS) c.a; (USANYS) (USANYS) (USANYS) cat; ) 1< >, (USANYS) Cc: (USANYS) it ; (USANYS) < > (USANYS) >; (USANYS) , .; (USANYS) 1 + +Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera + +Thanks, Can you keep me posted on what we think will be the substance of the draft declaration when you know (that is, before we are submitting anything on 12/31)? And how much of this is attributable to differences between MCC and MDC, as well as specific differences in their housing situations? + +From: (USANYS) + +Sent: Monday, December 21, 2020 4:35 PM + +To: (USANYS) (USANYS) (USANYS) dc ); °c ›; (USANYS) Cc: (USANYS) 4 4 > (USANYS) (USANYS) 1 a• (USANYS) (USANYS) (USANYS) + +Subject: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera + +I wanted to bring to your attention a recent issue that's surfaced in United States v. Rivera et al., a sex trafficldng case pending before Judge Engelmayer. As I'll describe in more detail below, Judge Engelmayer has asked us to submit a declaration from the BOP explaining why the discovery and counsel access accommodations provided to Ghislaine Maxwell (detained at the MDC outside the general population) cannot be extended to Justin Rivera (detained at the MCC in the general population). + +Justin Rivera was charged in February 2019 with sex trafficking conspiracy. He's been detained at the MCC since April 2019 on consent (he's also serving a state sentence). His trial, which was originally scheduled for April 2019, is expected to start on February 16, 2020. In July 2020, he had new counsel appointed, citing an irreconcilable breakdown with his former counsel. + +Since this fall, Judge Engelmayer has become increasingly frustrated with the MCC's treatment of Rivera. In particular, he's cited their failure to provide Rivera with adequate accommodations to review discovery and meet with his lawyers, who refuse to visit Rivera at the MCC for personal health concerns. We have two court orders in place to address these issues: (1) a laptop order, which requires the MCC to provide Rivera access to a laptop for three hours per day; and (2) a videoconference order, which requires the MCC to make available four hours of videoconferencing each week, in addition to any telephone or videoconference calls obtained through the Federal Defenders. + +At the moment, there's not a concern, at least from Judge Engelmayer, that the amount of time Rivera has for videoconferences and electronic discovery review is insufficient for trial preparation, although defense counsel has stated that they may request more time in the future. However, in a letter last night and during a court conference this morning (transcript attached), defense counsel cited the accommodations that the MDC has provided to Maxwell, describing them as "strikingly different and far superior" to those afforded to Rivera. Defense counsel further suggested that Rivera was being treated differently on account of his race, gender and class. Judge Engelmayer stated that the disparity in access "jumped off the page" and that the optics were "terrible," and asked us toe lain the rationale for the differing treatment. After conferring with and before our conference, we explained our understanding that the disparity comes down to the fact that Maxwell and Rivera have very different housing situations, with Maxwell's situation being more amenable to greater access to electronic discovery review and legal visits. + +Judge Engelmayer asked us to submit a declaration, from an appropriate person at the BOP, explaining in more detail why the accommodations provided to Maxwell cannot be extended to Rivera. + +Based on the recent bail opposition in the Maxwell case, I believe the differences in counsel/discovery access are as follows: + +| Accommodation | Maxwell | Rivera | +|-----------------------------------------------------------------------|---------------------------------------------------|------------------------------------------------------------------------------------------------------------| +| Review of electronic discovery (NB: each defendant has laptop access) | 13 hours per day/7 days per week (91 hours total) | 3 hours per day/7 days per week (21 hours total) | +| Counsel visits (by video) | 3 hours per day/5 days per week (15 hours total) | Four hours per week (plus an additional two hours scheduled through the Federal Defenders) (6 hours total) | + +| Weekend legal calls | As needed | Not available | +|---------------------|-----------|---------------| +|---------------------|-----------|---------------| + +The declaration is due by December 31. Because Judge Engelmayer's request implicates at least two criminal cases, and potentially the ongoing civil litigation with the MCC, we wanted to make sure that you were all aware of this issue. We are also happ to set up a call to discuss this further. In the meantime, we are working with to identify the appropriate declarant and draft an explanation for the Court. + +Best, + +Bhaskaran Assistant United States Attorney United States Attorney's Office for the Southern District of New York One Saint Andrew's Plaza New York NY 10007 Tel: \ No newline at end of file diff --git a/marker2/ds9/EFTA00086752/EFTA00086752.metadata.json b/marker2/ds9/EFTA00086752/EFTA00086752.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7a91deb9a702c1623ba7c61f9588eed91a651bc5 --- /dev/null +++ b/marker2/ds9/EFTA00086752/EFTA00086752.metadata.json @@ -0,0 +1,156 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086752.pdf", + "engine": { + "marker_major": "2", + "marker_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": 9041, + "elapsed_seconds": 2.35, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 88 + ], + [ + "Line", + 36 + ], + [ + "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", + 108 + ], + [ + "Line", + 50 + ], + [ + "Text", + 15 + ], + [ + "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", + 109 + ], + [ + "Line", + 50 + ], + [ + "Text", + 7 + ], + [ + "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": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 14 + ], + [ + "Text", + 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/EFTA00086752" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086756/EFTA00086756.md b/marker2/ds9/EFTA00086756/EFTA00086756.md new file mode 100644 index 0000000000000000000000000000000000000000..575575d58e90cfe171c95698014798c051cdf5de --- /dev/null +++ b/marker2/ds9/EFTA00086756/EFTA00086756.md @@ -0,0 +1,119 @@ +From: ' To: ' (USANYS)" + +Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera + +Date: Thu, 31 Dec 2020 16:57:54 +0000 + +Thanks . Would it be possible to clarify that although Maxwell has access to a social phone, she has the same limited number of minutes for social calls per month as all other inmates? I just don't want to give the misimpression that Maxwell gets extra time for social calls. + +From: (USANYS) Sent: Thursday, December 31, 2020 11:27 AM To: (USANYS) Cc: (USANYS) ca; (USANYS) (USANYS) (USANYS) 1 < (USANYS) ; (USANYS) Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera (USANYS) cM > + +Thanks, I have incorporated your edits and comments. + +>; + +Also, an update. There will be a separate declaration on Maxwell, which I have attached here. The substance is the same as before, with one minor exception — it clarifies that Maxwell has daily access to a social telephone. + +From: (USANYS) c Sent: Thursday, December 31, 2020 10:39 AM To: (USANYS) Cc: (USANYS) ) (USANYS) (USANYS) 1 (USANYS) (USANYS) (USANYS) < M>, (USANYS) ‹ > Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera + +Just a couple small things from me and . Thanks for putting this together. + +From: (USANYS) Sent: Wednesday, December 30, 2020 11:38 PM To: ) Cc: (USANYS) (USANYS) (USANYS) (USANYS) c ) (USANYS) (USANYS) + +Subject: FW: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera + +Hey everyone: Here's the latest draft of our letter and declaration on this issue. We are still confirming a few things, but they shouldn't impact the substance of the Maxwell discussion. There is also a chance that there's a separate declaration from the MDC; if there is, it should contain the same substance re: Maxwell that's in the attached draft. + +Our response is due tomorrow. I'm generally around later this evening or tomorrow if there's anything you'd like to discuss. + +Thanks very much. + +From: (USANYS) + +Sent: Wednesday, December 30, 2020 2:40 PM + +To: (USANYS) c > (USANYS) (USANYS) c ) (USANYS) ) ; , (USANYS) + +Cc: (USANYS) (USANYS) (USANYS) (USANYS) ; (USANYS) 1 + +Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera + +We are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to explain that the discovery and counsel access accommodations that have been provided to Maxwell and Rivera, respectively, result from the specific circumstances of their cases, the specific requests of their lawyers, and their individual housing circumstances. On all of these factors, there are several important differences, including: + +- The Maxwell case has multiple times more discovery than the Rivera case. Hence, the need for such expanded discovery access is greater in the Maxwell case. + +- **At the MDC, Maxwell has a unique housing situation, as she is in protective custody outside the general population. She therefore has sole access to a room to use a computer and phone for approximately 13 hours a day. Rivera, by contrast, is housed in the general population.** +- **There are approximately 8o other inmates at the MCC in Rivera's unit that use the same VTC room for court appearances, probation interviews, and attorney meetings. By contrast, Maxwell shares access to the MDC VTC room with substantially fewer inmates. The MDC can therefore provide 15 hours of VTC meetings with her attorneys without compromising access for other MDC inmates. The same is not true for Rivera at the MCC.** + +**Going forward, even though Rivera's counsel have asked (and the Court has ordered) that Rivera receive three hours of laptop access each day, the MCC is now leaving the laptop with him all day long, and only takes it back at night to charge it. Therefore, the MCC is now providing the same amount of electronic discovery access to Rivera that Maxwell receives at the MDC.** + +**As for providing Rivera with up to 15 hours of VTC access, we will explain that doing so will compromise access for other inmates. If defense counsel expresses a need for additional time, the MCC will continue to find ways to accommodate those requests as best as they can.** + +**Please let me know if you have any questions or would like to discuss this further.** + +**Best,** + +From: (USANYS) + +Sent: Monday, December 21, 2020 4:42 PM + +To: (USANYS) (USANYS) < (USANYS) >; (USANYS) F c >; (USANYS) Cc: (USANYS) (USANYS) ›; (USANYS) (USANYS) >; (USANYS) 1 c > + +Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera + +Thanks, . Can you keep me posted on what we think will be the substance of the draft declaration when you know (that is, before we are submitting anything on 12/31)? And how much of this is attributable to differences between MCC and MDC, as well as specific differences in their housing situations? + +From: (USANYS) + +Sent: Monday, December 21, 2020 4:35 PM + +To: (USANYS) c >.; (USANYS) >; ) < (USANYS) (USANYS) >; (USANYS) Cc: (USANYS) (USANYS) c ›; (USANYS) To: To: Cc: \ No newline at end of file diff --git a/marker2/ds9/EFTA00086761/EFTA00086761.metadata.json b/marker2/ds9/EFTA00086761/EFTA00086761.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ae89d90900840d40fdae92ddcfc995990a91eb33 --- /dev/null +++ b/marker2/ds9/EFTA00086761/EFTA00086761.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086761.pdf", + "engine": { + "marker_major": "2", + "marker_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": 517, + "elapsed_seconds": 0.3, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 18 + ], + [ + "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/EFTA00086761" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086762/EFTA00086762.md b/marker2/ds9/EFTA00086762/EFTA00086762.md new file mode 100644 index 0000000000000000000000000000000000000000..113da50d75d99109ad1227940f4518d0adb82caa --- /dev/null +++ b/marker2/ds9/EFTA00086762/EFTA00086762.md @@ -0,0 +1,57 @@ +To + +Cc: ." 11NYS)" USANYS)" + +Subject: RE: JE FOIA review in SDNY (?) + +Date: Wed, 12 Jun 2019 13:30:13 +0000 + +Importance: Normal + +I don't see a reference to Epstein in our FOR Tracking Database. + +But it wouldn't surprise me if the Department did have a bunch of FOlAs relating to Epstein. + +Sent: vir•a . r e n , 2019 7:45 AM + +From: (USANYS) + +To: (USANYS) + +Cc: (USANYS) + +Subject: Re: JE FOIA review in SDNY (?) + +USANYS)< > + +This does not ring a bell but I would need more specifics to run this down. + +On Jun 12, 2019, at 6:54 AM USANYS) < wrote: + +I'll see if I have anything on my end. + +On Jun 11, 2019, at 10:26 PM, (USANYS) < > wrote: + +Do you know anything about the below? We have a very advanced, very sensitive, and, most importantly, very covert investigation into Epstein. + +Thanks, + +Sent from my iPhone + +Begin forwarded message: + +From: ' )" + +Date: June 11, 2019 at 10:14:12 PM EDT + +To: " (USANYS)" + +Cc: 1 )" + +Subject: RE: JE FOIA review in SDNY (?) + +We heard second-hand from a colleague that our civil division is processing a FOIA request relating to the Epstein investigation (but unclear on specifics). Obviously this is the first we've heard of it, and understandable that there wouldn't be cross-communication since the criminal investigation is still covert (and not widely known even among assistants), but it still is a little puzzling in terms of why such a review would be venued here. Do you who the right person would be in civil to ask about FOIA processes there? We're happy to reach out if that's appropriate, or if you prefer to do it at the supervisor level certainly no objection from us. + +thanks, + +Assistant U.S. Attorney ligi • • f New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00086762/EFTA00086762.metadata.json b/marker2/ds9/EFTA00086762/EFTA00086762.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4be3963d7128321510c3c666442e028a1a6620b9 --- /dev/null +++ b/marker2/ds9/EFTA00086762/EFTA00086762.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086762.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1666, + "elapsed_seconds": 1.38, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 85 + ], + [ + "Line", + 37 + ], + [ + "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", + 13 + ], + [ + "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/EFTA00086762" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086764/EFTA00086764.md b/marker2/ds9/EFTA00086764/EFTA00086764.md new file mode 100644 index 0000000000000000000000000000000000000000..6a399172b070d67fc6bd325c9f4189300c1c39c0 --- /dev/null +++ b/marker2/ds9/EFTA00086764/EFTA00086764.md @@ -0,0 +1,51 @@ +From: + +To: + +Subject: RE: Epstein matter + +Date: Wed, 12 Jun 2019 15:17:15 +0000 + +Importance: Normal + +Good. (Yes, I just raised the issue with Janis). + +From: (USANYS) + +Sent: Wednesday, June 12, 2019 11:16 AM + +Subject: RE: Epstein matter + +Let's wait until next Thursday but in the interim I will meet with Jenn Ranucci if I can, who Janis confirmed to me is the new supervisor and with whom I have a relationship + +From + +Sent: Tuesday, June 11, 2019 5:37 PM + +To: (USANYS) + +Subject: FW: Epstein matter + +What do you want to do? I can talk with him alone, but definitely better if you are there. + +Fro + +Sent: Tuesday, June 11, 2019 5:13 PM + +To: + +Cc: + +Subject: Re: Epstein matter + +I'm in El Salvador, returning Friday night. How does next week look? + +On Jun 11, 2019 2:33 PM wrote: + +Any chance you have time this week for a brief meeting with me and Russell? I'd like to talk about the plan for the Epstein case. + +Thanks, + +Chief, Criminal Division + +torney's Office, SDNY \ No newline at end of file diff --git a/marker2/ds9/EFTA00086764/EFTA00086764.metadata.json b/marker2/ds9/EFTA00086764/EFTA00086764.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9d49a79ce04f2fe404aaad093e41bf19f97dcf89 --- /dev/null +++ b/marker2/ds9/EFTA00086764/EFTA00086764.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086764.pdf", + "engine": { + "marker_major": "2", + "marker_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": 961, + "elapsed_seconds": 1.41, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Text", + 33 + ], + [ + "Line", + 29 + ], + [ + "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/EFTA00086764" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086765/EFTA00086765.md b/marker2/ds9/EFTA00086765/EFTA00086765.md new file mode 100644 index 0000000000000000000000000000000000000000..59036175b9551dbeb9452a119b6fd0b98352abfc --- /dev/null +++ b/marker2/ds9/EFTA00086765/EFTA00086765.md @@ -0,0 +1,41 @@ +To: ' + +Subject: RE: Epstein + +Date: Wed, 12 Jun 2019 15:51:39 +0000 + +Importance: Normal + +Ah got it, didn't realize that — will get in touch with him. Thank you! + +From: + +Sent: Wednesday, June 12, 2019 11:46 AM + +To: (USANYS) < + +Subject: Re: Epstein + +Hi + +The position was just temporary, I was covering for the former supervisor, Watson, who was at our HQ for an 18 month TDY. returned to the NY office and may be reached at: + +(cell). + +Hope you are well, + +On Jun 12, 2019 11:37 AM, ' (USANYS)" wrote: + +Heys! + +Hope you are well and settling into your new position. Wondering if you have some time to meet this week on the Epstein case? + +Thanks, + +Capone + +Chief Public Corruption Unit + +United States Attorney's Office for the + +Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00086765/EFTA00086765.metadata.json b/marker2/ds9/EFTA00086765/EFTA00086765.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..95d2813b6c3d2ad7ada13fcd5e142dea11de4502 --- /dev/null +++ b/marker2/ds9/EFTA00086765/EFTA00086765.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086765.pdf", + "engine": { + "marker_major": "2", + "marker_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": 749, + "elapsed_seconds": 1.16, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Text", + 26 + ], + [ + "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/EFTA00086765" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086766/EFTA00086766.md b/marker2/ds9/EFTA00086766/EFTA00086766.md new file mode 100644 index 0000000000000000000000000000000000000000..a8bfe7f9cd607036ff8dc4c6633273cde6484cde --- /dev/null +++ b/marker2/ds9/EFTA00086766/EFTA00086766.md @@ -0,0 +1,32 @@ +![](_page_0_Picture_85.jpeg) + +*United States Attorney +Southern District of New York* + +*The Silvio J. Mollo Building +One Saint Andrew's Plaza +New York, New York 10007* + +August 9, 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 is 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 + +![]()![]()*Enclosure* \ No newline at end of file diff --git a/marker2/ds9/EFTA00086766/EFTA00086766.metadata.json b/marker2/ds9/EFTA00086766/EFTA00086766.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..744e5d6dfc300bfaa29e1bd8a00e8a0a80377130 --- /dev/null +++ b/marker2/ds9/EFTA00086766/EFTA00086766.metadata.json @@ -0,0 +1,115 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086766.pdf", + "engine": { + "marker_major": "2", + "marker_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": 607, + "elapsed_seconds": 3.48, + "image_assets": [ + "_page_0_Picture_85.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 318.85200000000003, + 25.11 + ], + [ + 462.06000000000006, + 25.11 + ], + [ + 462.06000000000006, + 40.5 + ], + [ + 318.85200000000003, + 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", + 45 + ], + [ + "Text", + 25 + ], + [ + "Line", + 22 + ], + [ + "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/EFTA00086766" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086766/_page_0_Picture_85.jpeg b/marker2/ds9/EFTA00086766/_page_0_Picture_85.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..3793a4daef29bfa3e0b45b1e818a2e6b1239a3a0 --- /dev/null +++ b/marker2/ds9/EFTA00086766/_page_0_Picture_85.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:8d2b40b04ee879b6301235293c08ba6b3ffdf28eff433f7b3645ac7b5da79d6e +size 3417 diff --git a/marker2/ds9/EFTA00086767/EFTA00086767.md b/marker2/ds9/EFTA00086767/EFTA00086767.md new file mode 100644 index 0000000000000000000000000000000000000000..7ec8caa80cab4f9e4ea9dc7f3356b40c93c689cf --- /dev/null +++ b/marker2/ds9/EFTA00086767/EFTA00086767.md @@ -0,0 +1,23 @@ +![](_page_0_Picture_0.jpeg) + +United States Attorney Southern District of New York + +The Silvio J. Malta Building One Saint Andrew's Plaza New York, New York 10007 + +August 9, 2021 + +## VIA FEDERAL EXPRESS + +MDC—Metropolitan Detention Center Legal Department 80 29'h Street Brooklyn, NY 11232 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +The password for the drive containing discovery materials pertinent to Ghislaine Maxwell (02879-509) + +by: + +Very truly yours, + +AUDREY STRAUSS United States Attorney + +Assistant United States Attorneys 2324/2343/2345 \ No newline at end of file diff --git a/marker2/ds9/EFTA00086767/EFTA00086767.metadata.json b/marker2/ds9/EFTA00086767/EFTA00086767.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6aa819fcc4b88ef60a1cf45c054d241912c4500b --- /dev/null +++ b/marker2/ds9/EFTA00086767/EFTA00086767.metadata.json @@ -0,0 +1,111 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086767.pdf", + "engine": { + "marker_major": "2", + "marker_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": 560, + "elapsed_seconds": 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+**Sent:** Thursday, August 12, 2021 10:58 AM +**To:** [REDACTED] (USANYS) [REDACTED] [REDACTED] +[REDACTED] [REDACTED] + +**Subject:** RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and America' + +Sorry – Just getting through the piles of email. I am around for the next hour or so, then later tonight. Anything soon work for you? + +Thx + +--- + +[REDACTED] +*U.S. Department of Justice Attaché - London* + +![](_page_0_Picture_124.jpeg) + +United States Embassy +33 Nine Elms Lane +London SW11 7US + +[REDACTED] + +--- + +**From:** [REDACTED] (USANYS) <[REDACTED] +**Sent:** Thursday, August 12, 2021 1:53 PM +**To:** [REDACTED] (CRM) <[REDACTED] [REDACTED] +[REDACTED] [REDACTED] [REDACTED] +**Cc:** [REDACTED] (CRM) [REDACTED] (CRM) [REDACTED] + +**Subject:** RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and America' + +Hi [REDACTED], + +Thanks, +[REDACTED] + +From: CRM) Sent: Thursday, August 12, 2021 4:03 AM + +To: (USANYS) + +Cc: + +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, 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, + +![](_page_1_Picture_11.jpeg) + +U.S. Department of Justice Attache - London + +![](_page_1_Picture_13.jpeg) + +United States Embassy 33 Nine Elms Lane London SW11 7US + +![](_page_1_Picture_15.jpeg) + +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 ifias 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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What is the best number to reach you? Alternatively we can use the following dial-in when you are ready: + +i mhanks + +From: CRM) + +Sent: Thursday, August 12, 2021 10:58 AM + +To: USANYS + +Subject: RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and America' + +Sorry - Just getting through the piles of email. I am around for the next hour or so, then later tonight. Anything soon work for you? + +Thx + +U.S. Department of Justice Attaché - London + +tage001.png> + +United States Embassy 33 Nine Elms Lane London SWIl 7US + +**Cc:** [REDACTED] (CRM) <[REDACTED]> (CRM) [REDACTED] +**Subject:** RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and America' + +Hi [REDACTED] + +We just tried you. Is there a good time for you to connect this morning? + +Thanks, +[REDACTED] + +--- + +**From:** [REDACTED] (CRM) <[REDACTED]> +**Sent:** Thursday, August 12, 2021 4:03 AM +**To:** [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] + +--- + +U.S. Department of Justice Attaché - London + +![](_page_2_Picture_1.jpeg) + +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. 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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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) < E> Cc: `Ma (USANYS) dc ); Subject: RE: Jeffrey Epstein-Related Touhy Requests + +1 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). > Cc: (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. (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)< I> + +Cc: McEnany, John (USANYS) + +ana (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) ; ana (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 rkaplanPkaplanheckencom 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. + +From: Kochevar, Steven (USANYS) + +Sent: Thursday, January 2, 2020 7:16 PM + +To: + +Cc: McEnany, John (USANYS) IMB (USANYS) a>, (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. Ct. 1944), *aff'd*, 63 N.Y.S.2d 833 (1st Dep't 1946). \ No newline at end of file diff --git a/marker2/ds9/EFTA00086777/EFTA00086777.metadata.json b/marker2/ds9/EFTA00086777/EFTA00086777.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e73a1347c3807a9035d7769fb63883c8e849a8d5 --- /dev/null +++ b/marker2/ds9/EFTA00086777/EFTA00086777.metadata.json @@ -0,0 +1,166 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086777.pdf", + "engine": { + "marker_major": "2", + "marker_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": 13179, + "elapsed_seconds": 6.58, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 101 + ], + [ + "Line", + 40 + ], + [ + "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", + 89 + ], + [ + "Line", + 41 + ], + [ + "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", + 40 + ], + [ + "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": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 109 + ], + [ + "Line", + 51 + ], + [ + "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 + } + }, + { + "page_id": 4, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 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/EFTA00086777" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086782/EFTA00086782.md b/marker2/ds9/EFTA00086782/EFTA00086782.md new file mode 100644 index 0000000000000000000000000000000000000000..fb96fb85e1e292b4153431fc7a9789b861579870 --- /dev/null +++ b/marker2/ds9/EFTA00086782/EFTA00086782.md @@ -0,0 +1,31 @@ +From: ' SANYS)" To: ' (USANYS)" + +Subject: Re: + +Date: Thu, 13 Jun 2019 12:05:14 +0000 + +Importance: Normal + +Got it overnight, will forward now. Hoping to get through most of it today. + +Sent from my iPhone + +> On Jun 13, 2019, at 8:02 AM, (USANYS) Okay, thanks. When you get the Epstein memo, can you send on? I'll let you do this round of edits but would be interested in reading anyway. + +> Sent from my iPhone + +>> On Jun 13, 2019, at 7:51 AM, (USANYS) wrote: + +>> Uwas going to think about what Inwanted to do and get back to me but never did. Will check back in. + +>> + +>> Sent from my iPhone + +>>> On Jun 13, 2019, at 7:17 AM, (USANYS) wrote: + +>>> >>> Where did land on whether' was staying on R Kelly? + +>>> >>> Sent from my iPhone \ No newline at end of file diff --git a/marker2/ds9/EFTA00086782/EFTA00086782.metadata.json b/marker2/ds9/EFTA00086782/EFTA00086782.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..870e4935eb1862f8334ec4ddbaaf614458075ce5 --- /dev/null +++ b/marker2/ds9/EFTA00086782/EFTA00086782.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086782.pdf", + "engine": { + "marker_major": "2", + "marker_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": 742, + "elapsed_seconds": 1.05, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Text", + 23 + ], + [ + "Line", + 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/EFTA00086782" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086783/EFTA00086783.md b/marker2/ds9/EFTA00086783/EFTA00086783.md new file mode 100644 index 0000000000000000000000000000000000000000..61f8e153d1ecfaa77acea8268b19590857d57af5 --- /dev/null +++ b/marker2/ds9/EFTA00086783/EFTA00086783.md @@ -0,0 +1,31 @@ +From: 'USANYS)" + +To: "Strauss, Audrey (USANYS)" + +Subject: RE: Vetting Consults of SCO Records with USAOs/prosecuting offices + +Date: Thu, 13 Jun 2019 16:14:06 +0000 + +Importance: Normal + +Sounds good. I did have a call with on Epstein and advised him yesterday. I told him we would work on an updated memo to reflect the new posture. + +From:(USANYS) + +Sent: Thursda June 13, 2019 12:11 PM + +To: (USANYS) + +Subject: RE: Vetting Consults of SCO Records with USAOs/prosecuting offices + +let's touch base today; I will report conversation with. + +I do need to tell her where we are on Epstein + +![](_page_0_Picture_12.jpeg) + +![](_page_1_Picture_0.jpeg) + +![](_page_2_Picture_0.jpeg) + +![](_page_3_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00086783/EFTA00086783.metadata.json b/marker2/ds9/EFTA00086783/EFTA00086783.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..42037b64bf9c9ff57069f490553c4a7dfcbecbbc --- /dev/null +++ b/marker2/ds9/EFTA00086783/EFTA00086783.metadata.json @@ -0,0 +1,153 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086783.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + 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b/marker2/ds9/EFTA00086787/EFTA00086787.md @@ -0,0 +1,23 @@ +To:" + +Cc: + +Subject: Re: Draft Indictment + +Date: Fri, 14 Jun 2019 02:19:35 +0000 + +Importance: Normal + +Thankiellei Let's chat tomorrow — I do think this is too sparse. I understand the concerns and they are right ones, but more needs to be done to (i) instill public confidence in the significance and seriousness of this case in light of the prior history: and (ii) relatedly, to give Geoff more to work with at a press conference to further that end. It is a balance, and there are definitely steps we should take to protect the victims (esp those who remain truly anonymous), but I think we'll need to bulk up a bit. + +Sent from my iPhone + +On Jun 13, 2019, at 9:47 PM, ) < > wrote: + +Attached is a draft indictment for your review. We tried to keep the facts sparse, both to protect the victims and to avoid publicizing details that will help us vet new witnesses later on if the details remain confidential. + +Thanks— + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 + +<2019-06-13, Epstein Indictment.docx> \ No newline at end of file diff --git a/marker2/ds9/EFTA00086787/EFTA00086787.metadata.json b/marker2/ds9/EFTA00086787/EFTA00086787.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d7ba213a0d782f4b0685f798ba8cfb7a2b6466de --- /dev/null +++ b/marker2/ds9/EFTA00086787/EFTA00086787.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086787.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1063, + "elapsed_seconds": 0.86, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "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/EFTA00086787" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086788/EFTA00086788.md b/marker2/ds9/EFTA00086788/EFTA00086788.md new file mode 100644 index 0000000000000000000000000000000000000000..d6f62bff07a75377130d293710ca9615f2d7a483 --- /dev/null +++ b/marker2/ds9/EFTA00086788/EFTA00086788.md @@ -0,0 +1,41 @@ +To: ' (USANYS)" < + +Subject: Re: Draft Indictment + +Date: Fri, 14 Jun 2019 02:35:42 +0000 + +Importance: Normal + +I agree with this. + +Sent from my iPhone + +On Jun 13, 2019, at 10:19 PM, (USANYS) < > wrote: + +Sent from my iPhone + +Begin forwarded message: + +From: ' (USANYS)" + +Date: Jun, I A. 2011) :ii l(1: 19:35 PM EDT + +To:" + +Cc: ' )11 + +Subject: Re: Draft Indictment + +Thank'''. Let's chat tomorrow — I do think this is too sparse. I understand the concerns and they are right ones, but more needs to be done to (i) instill public confidence in the significance and seriousness of this case in light of the prior history: and (ii) relatedly, to give Geoff more to work with at a press conference to further that end. It is a balance, and there are definitely steps we should take to protect the victims (esp those who remain truly anonymous), but I think we'll need to bulk up a bit. + +Sent from my iPhone + +On Jun 13, 2019, at 9:47 PM, wrote: + +Attached is a draft indictment for your review. We tried to keep the facts sparse, both to protect the victims and to avoid publicizing details that will help us vet new witnesses later on if the details remain confidential. + +Thanks— + +Assistant United States Attorney Southern District of New York + +C019-06-13, Epstein Indictment.docx> \ No newline at end of file diff --git a/marker2/ds9/EFTA00086788/EFTA00086788.metadata.json b/marker2/ds9/EFTA00086788/EFTA00086788.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2bc07133c112bf1d4c47725a5fe21453c51083ed --- /dev/null +++ b/marker2/ds9/EFTA00086788/EFTA00086788.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086788.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1269, + "elapsed_seconds": 1.15, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "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", + 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/EFTA00086788" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086790/EFTA00086790.md b/marker2/ds9/EFTA00086790/EFTA00086790.md new file mode 100644 index 0000000000000000000000000000000000000000..af49c169f7e4f3a214610a1c9e1e69bc3fbb05aa --- /dev/null +++ b/marker2/ds9/EFTA00086790/EFTA00086790.md @@ -0,0 +1,37 @@ +From: " < + +To: " (USANYS)" + +Cc: ' " • + +Subject: RE: Draft Indictment + +Date: Fri, 14 Jun 2019 03:04:13 +0000 + +Importance: Normal + +Understood, and happy to discuss-are you in tomorrow? + +From: (USANYS) + +Sent: Thursday, June 13, 2019 10:20 PM + +To: + +Cc: + +Subject: Re: Draft Indictment + +Thanks . Let's chat tomorrow — I do think this is too sparse. I understand the concerns and they are right ones, but more needs to be done to (i) instill public confidence in the significance and seriousness of this case in light of the prior history: and (ii) relatedly, to give Geoff more to work with at a press conference to further that end. It is a balance, and there are definitely steps we should take to protect the victims (esp those who remain truly anonymous), but I think we'll need to bulk up a bit. + +Sent from my iPhone + +On Jun 13, 2019, at 9:47 PM, < > wrote: + +Attached is a draft indictment for your review. We tried to keep the facts sparse, both to protect the victims and to avoid publicizing details that will help us vet new witnesses later on if the details remain confidential. + +Thanks— + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 + +<2019-06-13, Epstein Indictment.docx> \ No newline at end of file diff --git a/marker2/ds9/EFTA00086790/EFTA00086790.metadata.json b/marker2/ds9/EFTA00086790/EFTA00086790.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0b039efc3a481cf453e51b11e1651b6637429d24 --- /dev/null +++ b/marker2/ds9/EFTA00086790/EFTA00086790.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086790.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1238, + "elapsed_seconds": 0.93, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Line", + 28 + ], + [ + "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/EFTA00086790" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086791/EFTA00086791.md b/marker2/ds9/EFTA00086791/EFTA00086791.md new file mode 100644 index 0000000000000000000000000000000000000000..003505e5d33bff8b82c94d6181ef5f542d38e70a --- /dev/null +++ b/marker2/ds9/EFTA00086791/EFTA00086791.md @@ -0,0 +1,41 @@ +To:" "< + +Cc: ' " + +Subject: Re: Draft Indictment + +Date: Fri, 14 Jun 2019 03:13:01 +0000 + +Importance: Normal + +Yes — in the morning I'll put on paper or email an outline of what I'm thinking and then we can chat. + +Sent from my iPhone + +On Jun 13, 2019, at 11:04 PM, ) < > wrote: + +Understood, and happy to discuss—are you in tomorrow? + +From: (USANYS) < + +Sent: Thursday, June 13, 2019 10:20 PM + +To: + +Cc: >; + +Subject: Re: Draft Indictment + +Thank\_ Let's chat tomorrow — I do think this is too sparse. I understand the concerns and they are right ones, but more needs to be done to (i) instill public confidence in the significance and seriousness of this case in light of the prior history: and (ii) relatedly, to give Geoff more to work with at a press conference to further that end. It is a balance, and there are definitely steps we should take to protect the victims (esp those who remain truly anonymous), but I think we'll need to bulk up a bit. + +Sent from my iPhone + +On Jun 13, 2019, at 9:47 PM, ) < > wrote: + +Attached is a draft indictment for your review. We tried to keep the facts sparse, both to protect the victims and to avoid publicizing details that will help us vet new witnesses later on if the details remain confidential. + +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/EFTA00086791/EFTA00086791.metadata.json b/marker2/ds9/EFTA00086791/EFTA00086791.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9053cee555de3e4709f787f74afbe97d1509e15c --- /dev/null +++ b/marker2/ds9/EFTA00086791/EFTA00086791.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086791.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1.05, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Line", + 32 + ], + [ + "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", + 3 + ], + [ + "Line", + 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/EFTA00086791" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086793/EFTA00086793.md b/marker2/ds9/EFTA00086793/EFTA00086793.md new file mode 100644 index 0000000000000000000000000000000000000000..b99d51d14ed74eb208294168c6eb348b424366b5 --- /dev/null +++ b/marker2/ds9/EFTA00086793/EFTA00086793.md @@ -0,0 +1,61 @@ +To: "-(USANYS)" < + +Subject: RE: Draft Indictment + +Date: Fri, 14 Jun 2019 13:51:03 +0000 + +Importance: Normal + +Also, on Count 1, are we sure we can charge a single count covering all conduct? I presume we plan to supersede, so this may be moot, but it'd be embarrassing to stumble out of the gate if we have to charge each person trafficked as a separate substantive... + +From: (USANYS) + +Sent: Thursday, June 13, 2019 10:57 PM + +To: (USANYS) + +Subject: Re: Draft Indictment + +Good — you may have to be the one to help get it there. Will loop you in if chain continues. + +Sent from my iPhone + +On Jun 13, 2019, at 10:35 PM, (USANYS) < > wrote: + +I agree with this. + +Sent from my iPhone + +On Jun 13, 2019, at 10:19 PM, (USANYS) c > wrote: + +Sent from my iPhone + +Begin forwarded message: + +From: (USANYS)" + +Date: June 13, 2019 at 10:19:35 PM EDT + +To:' + +Cc: II" 1' + +Subject: Re: Draft Indictment + +Thanks Let's chat tomorrow - I do think this is too sparse. I understand the concerns and they are right ones, but more needs to be done to (i) instill public confidence in the significance and seriousness of this case in light of the prior history: and (ii) relatedly, to give Geoff more to work with at a press conference to further that end. It is a balance, and there are definitely steps we should take to protect the victims (esp those who remain truly anonymous), but I think we'll need to bulk up a bit. + +Sent from my iPhone + +Attached is a draft indictment for your review. We tried to keep the facts sparse, both to protect the victims and to avoid publicizing details that will help us vet new witnesses later on if the details remain confidential. + +Thanks— + +Assistant United States Attorney + +Southern District of New York + +One Saint Andrew's Plaza + +New York, NY 10007 + +<2019-06-13, Epstein Indictment.docx> \ No newline at end of file diff --git a/marker2/ds9/EFTA00086793/EFTA00086793.metadata.json b/marker2/ds9/EFTA00086793/EFTA00086793.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8bf9a4b0472e7c6ad966d48823cfbf0fa2139432 --- /dev/null +++ b/marker2/ds9/EFTA00086793/EFTA00086793.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086793.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1798, + "elapsed_seconds": 1.32, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 34 + ], + [ + "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", + 17 + ], + [ + "Text", + 10 + ], + [ + "Line", + 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/EFTA00086793" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086795/EFTA00086795.md b/marker2/ds9/EFTA00086795/EFTA00086795.md new file mode 100644 index 0000000000000000000000000000000000000000..89593349df695c2de4d6d2b1b31df75fc385bb62 --- /dev/null +++ b/marker2/ds9/EFTA00086795/EFTA00086795.md @@ -0,0 +1,69 @@ +From: ' (USANYS)" ci + +To: ' (USANYS)" C + +Subject: RE: Draft Indictment + +Date: Fri, 14 Jun 2019 13:52:36 +0000 + +Importance: Normal + +I went to speak t about that and the option of charging it that way and superseding later — it is much preferable to it this way if we can because we do not want to charge a single victim count — both not to put it all onMi and to not suggest our case is that narrow. + +gut is that we can, but in my comments I asked the team to do some research on the unit of prosecution. + +From: (USANYS) < + +Sent: Friday, June 14, 2019 9:51 AM + +To: (USANYS) + +Subject: RE: Draft Indictment + +Also, on Count 1, are we sure we can charge a single count covering all conduct? I presume we plan to supersede, so this may be moot, but it'd be embarrassing to stumble out of the gate if we have to charge each person trafficked as a separate substantive... + +From: (USANYS) + +Sent: Thursday, June 13, 2019 10:57 PM + +To: (USANYS) + +Subject: Re: Draft Indictment + +Good — you may have to be the one to help get it there. Will loop you in if chain continues. + +Sent from my iPhone + +On Jun 13, 2019, at 10:35 PM, (USANYS) c > wrote: + +I agree with this. + +Sent from my iPhone + +On Jun 13, 2019, at 10:19 PM, (USANYS) c > wrote: + +Sent from my iPhone + +Begin forwarded message: + +From: " (USANYS)" < + +Date: June 13, 2019 at 10:19:35 PM EDT + +To:' " + +Cc: ' " + +Thanks Let's chat tomorrow — I do think this is too sparse. I understand the concerns and they are right ones, but more needs to be done to (i) instill public confidence in the significance and seriousness of this case in light of the prior history: and (ii) relatedly, to give Geoff more to work with at a press conference to further that end. It is a balance, and there are definitely steps we should take to protect the victims (esp those who remain truly anonymous), but I think we'll need to bulk up a bit. + +Sent from my iPhone + +On Jun 13, 2019, at 9:47 PM, > wrote: + +Attached is a draft indictment for your review. We tried to keep the facts sparse, both to protect the victims and to avoid publicizing details that will help us vet new witnesses later on if the details remain confidential. + +Thanks— + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 + +<2019-06-13, Epstein Indictment.docx> \ No newline at end of file diff --git a/marker2/ds9/EFTA00086795/EFTA00086795.metadata.json b/marker2/ds9/EFTA00086795/EFTA00086795.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e22c9b35a542036e18323d527f188428d96af130 --- /dev/null +++ b/marker2/ds9/EFTA00086795/EFTA00086795.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086795.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2302, + "elapsed_seconds": 1.41, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 34 + ], + [ + "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", + 31 + ], + [ + "Line", + 16 + ], + [ + "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/EFTA00086795" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086797/EFTA00086797.md b/marker2/ds9/EFTA00086797/EFTA00086797.md new file mode 100644 index 0000000000000000000000000000000000000000..0f4a1800b5ef4740a895ba0a6f8db5852eef7a13 --- /dev/null +++ b/marker2/ds9/EFTA00086797/EFTA00086797.md @@ -0,0 +1,75 @@ +To: ' (USANYS)" + +Subject: RE: Draft Indictment + +Date: Fri, 14 Jun 2019 13:57:20 +0000 + +Importance: Normal + +Yes — finishing up within the hour. + +From: (USANYS) + +Sent: Friday, June 14, 2019 9:54 AM + +To: (USANYS) + +Subject: RE: Draft Indictment + +Yeah, I was going to make the same research suggestion. Can you send me your comments when you can? Assuming I'm doing the next round want to make sure I understand yours so I can ensure team addressed them. + +From: (USANYS) + +Sent: Friday, June 14, 2019 9:53 AM + +To: (USANYS) + +Subject: RE: Draft Indictment + +I went to speak to about that and the option of charging it that way and superseding later — it is much preferable to it this way if we can because we do not want to charge a single victim count — both not to put it all on and to not suggest our case is that narrow. + +M, gut is that we can, but in my comments I asked the team to do some research on the unit of prosecution. + +From: (USANYS) c + +Sent: Friday, June 14, 2019 9:51 AM + +To: (USANYS) + +Subject: RE: Draft Indictment + +Also, on Count 1, are we sure we can charge a single count covering all conduct? I presume we plan to supersede, so this may be moot, but it'd be embarrassing to stumble out of the gate if we have to charge each person trafficked as a separate substantive... + +From: (USANYS) + +Sent: Thursday, June 13, 2019 10:57 PM + +To: (USANYS) + +Subject: Re: Draft Indictment + +Good — you may have to be the one to help get it there. Will loop you in if chain continues. + +Sent from my iPhone + +On Jun 13, 2019, at 10:35 PM, (USANYS) < > wrote: + +Sent from my iPhone + +Begin forwarded message: + +From: ' (USANYS)" Date: June 13, 2019 at 10:19:35 PM EDT To: ' " Cc: ' r< Subject: Re: Draft Indictment + +Thanks Let's chat tomorrow — I do think this is too sparse. I understand the concerns and they are right ones, but more needs to be done to (i) instill public confidence in the significance and seriousness of this case in light of the prior history: and (ii) relatedly, to give Geoff more to work with at a press conference to further that end. It is a balance, and there are definitely steps we should take to protect the victims (esp those who remain truly anonymous), but I think we'll need to bulk up a bit. + +Sent from my iPhone + +On Jun 13, 2019, at 9:47 PM, > wrote: + +Attached is a draft indictment for your review. We tried to keep the facts sparse, both to protect the victims and to avoid publicizing details that will help us vet new witnesses later on if the details remain confidential. + +Thanks— + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 + +<2019-06-13, Epstein Indictment.docx> \ No newline at end of file diff --git a/marker2/ds9/EFTA00086797/EFTA00086797.metadata.json b/marker2/ds9/EFTA00086797/EFTA00086797.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2f0bf1c490646ff7e4459b8341847c89d124574f --- /dev/null +++ b/marker2/ds9/EFTA00086797/EFTA00086797.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086797.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2657, + "elapsed_seconds": 1.51, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 37 + ], + [ + "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", + 48 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00086797" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086799/EFTA00086799.md b/marker2/ds9/EFTA00086799/EFTA00086799.md new file mode 100644 index 0000000000000000000000000000000000000000..df263e3c3ccd227b74a178556ed508975c392e6d --- /dev/null +++ b/marker2/ds9/EFTA00086799/EFTA00086799.md @@ -0,0 +1,55 @@ +To: cM > + +Cc: + +Subject: Re: Draft Indictment + +From: ' "cl + +To: (USANYS)" + +Cc: al + +Subject: RE: Draft Indictment + +Date: Fri, 14 Jun 2019 17:10:40 +0000 + +Importance: Normal + +Hi —I'm sure you're juggling a fair amount before you head out, but just wanted to check in on this. We're around this afternoon to take a look at anything or discuss if that would be helpful. Thanks. + +From: (USANYS) + +Sent: Thursday, June 13, 2019 11:13 PM + +To: + +Cc: + +Subject: Re: Draft Indictment + +Yes — in the morning I'll put on paper or email an outline of what I'm thinking and then we can chat. + +Sent from my iPhone + +On Jun 13, 2019, at 11:04 PM, < > wrote: + +Understood, and happy to discuss—are you in tomorrow? + +From: (USANYS) + +Sent: Thursday, June 13, 2019 10:20 PM + +Thanks . Let's chat tomorrow — I do think this is too sparse. I understand the concerns and they are right ones, but more needs to be done to (i) instill public confidence in the significance and seriousness of this case in light of the prior history: and (ii) relatedly, to give Geoff more to work with at a press conference to further that end. It is a balance, and there are definitely steps we should take to protect the victims (esp those who remain truly anonymous), but I think we'll need to bulk up a bit. + +Sent from my iPhone + +On Jun 13, 2019, at 9:47 PM, ) <-> wrote: + +Attached is a draft indictment for your review. We tried to keep the facts sparse, both to protect the victims and to avoid publicizing details that will help us vet new witnesses later on if the details remain confidential. + +Thanks— + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 + +<2019-06-13, Epstein Indictment.docx> \ No newline at end of file diff --git a/marker2/ds9/EFTA00086799/EFTA00086799.metadata.json b/marker2/ds9/EFTA00086799/EFTA00086799.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..21598ee464587d6bdec1dff35b16e4d01c6d692f --- /dev/null +++ b/marker2/ds9/EFTA00086799/EFTA00086799.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086799.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1707, + "elapsed_seconds": 1.26, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 72 + ], + [ + "Line", + 34 + ], + [ + "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", + 11 + ], + [ + "Line", + 6 + ], + [ + "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/EFTA00086799" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086801/EFTA00086801.md b/marker2/ds9/EFTA00086801/EFTA00086801.md new file mode 100644 index 0000000000000000000000000000000000000000..ed653f580e7c7b5e39219dd867cf9c95c97b9169 --- /dev/null +++ b/marker2/ds9/EFTA00086801/EFTA00086801.md @@ -0,0 +1,33 @@ +**To:** [REDACTED] + +**Subject:** RE: Vacation + +**Date:** Fri, 14 Jun 2019 20:41:01 +0000 + +**Importance:** Normal + +--- + +Have a great time! + +--- + +**From:** [REDACTED] (USANYS) <[REDACTED]> + +**Sent:** Friday, June 14, 2019 4:38 PM + +[REDACTED] + +cc: [REDACTED] (USANYS) <[REDACTED]> + +**Subject:** Vacation + +Hi all, + +I am heading to Bermuda with my family tomorrow morning, and will be back in the office next Thursday. As I think you know [REDACTED] is now back. (As an FYI, I will also likely be out the two days following July 4th). + +You will likely have a draft Epstein prosecution memo and indictment before I return. + +Have a great weekend! + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00086801/EFTA00086801.metadata.json b/marker2/ds9/EFTA00086801/EFTA00086801.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..81318c7acdb0f203813e213d42921c456f5b1aab --- /dev/null +++ b/marker2/ds9/EFTA00086801/EFTA00086801.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086801.pdf", + "engine": { + "marker_major": "2", + "marker_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": 662, + "elapsed_seconds": 3.55, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 30 + ], + [ + "Span", + 29 + ], + [ + "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/EFTA00086801" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086802/EFTA00086802.md b/marker2/ds9/EFTA00086802/EFTA00086802.md new file mode 100644 index 0000000000000000000000000000000000000000..08e5180ab0374b630679daa146a9e657db8ada22 --- /dev/null +++ b/marker2/ds9/EFTA00086802/EFTA00086802.md @@ -0,0 +1,702 @@ +# IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN + +GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, + +PLAINTIFF, + +V. + +ESTATE OF JEFFREY E. EPSTEIN, THE 1953 TRUST, PLAN D, LLC; GREAT ST. JIM, LLC; NAUTILUS, INC.; HYPERION AIR, LLC; POPLAR, INC., JOHN AND JANE DOES + +DEFENDANTS, + +Case No.: + +ACTION FOR DAMAGES + +JURY TRIAL DEMANDED + +01 + +#### COMPLAINT + +COMES NOW, the Government of the United States Virgin Islands ("Government") and files this Complaint against the above-named Defendants and in support thereof, would show unto the Court as follows: + +#### JURISDICTION AND PARTIES + +- 1. The Attorney General of the United States Virgin Islands (herein after "Virgin Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands, pursuant to 3 V.I.C. § 114 and her statutory authority to enforce the laws of the Virgin Islands, and advocate for the public interest, safety, health and well-being of persons in the Virgin Islands. +- 2. This Court has subject matter jurisdiction over this civil matter pursuant to 4 V.I.C. § 76 and 14 V.I.C. § 607. + - 3. This Court has personal jurisdiction over the parties pursuant to 5 V.I.C. § 4903. + +4. The Virgin Islands is an unincorporated territory of the United States. It consists of St. Thomas, St. Croix, St. John, and Water Island, and more than 40 surrounding islands and Cays, some of which are privately owned. Among these privately owned islands are Little St. James and Great St. James. + +5. Jeffrey E. Epstein ("Epstein") was aresident of the Virgin Islands and he maintained a residence on Little St. James, which he acquired in 1998 and in 2016 he also purchased Great St. James. + +6. Epstein registered as a sex offender in the Virgin Islands in 2010. He was aTier 1 offender under Virgin Islands law based upon his Florida conviction of procuring a minor for prostitution. As a Tier I offender, Epstein was required to register annually with the Virgin Islands Department of Justice ("VIDOJ") and give advance notice of his travel to and from the Virgin Islands. Epstein was also subject to random address verification by VIDOJ. + +7. Epstein was found dead on August 10, 2019 while in custody in New York for sex crimes. + +8. Defendant, Estate of Jeffrey E. Epstein ("The Estate"), created upon Epstein's death, is domiciled in the Virgin Islands. On August 15, 2019, the Executors of The Estate, Darren K. Indyke and Richard D. Kahn, filed aPetition for Probate and Letters Testamentary which included Epstein's last will and testament with the Probate Division of the Superior Court of the Virgin Islands. + +9. The Petition reports the value of the real and personal property in The Estate located in the Virgin Islands at \$577,672,654.00 dollars. + +10. According to the Petition, the assets in the Virgin Islands thus far includes: + +- b. \$127 million in fixed income and equity investments; +- c. \$195 million in hedge fund and private equity investments; and +- d. \$18.5 million in planes, boats, and automobiles. + +The Estate has not yet valued his fine arts, antiques, and other valuables. + +1I . The Estate also includes shares of various corporate entities which hold residences and real property used by Epstein, namely: + +- a. Brownstone in New York City valued at \$56 million; +- b. Ranch in New Mexico valued at \$72 million; +- c. Gated home in Palm Beach, Florida, valued at \$12 million; +- d. Seven units in an apartment building in Paris, valued at \$8 million; and +- e. Great St. James and Little St. James, collectively valued at \$86 million. + +12. The Estate is responsible to pay damages for the acts committed by Epstein and the Epstein Enterprise described below. + +13. Defendant, The 1953 Trust ("The Trust") was created by Epstein, who "amended and restated" its terms only two days before his suicide. That same day, Epstein revised his Last Will and Testament, transferring all of his "property, real and personal, wherever situated" to The Trust. + +14. The Trust also contains Epstein's financial assets and is also responsible to pay damages for the acts committed by Epstein and the Epstein Enterprise described below. The Trust's administrators, Darren K. Indyke and Richard D. Kahn, filed aCertificate of Trust in the Superior Court of the Virgin Islands for The Trust on August 26, 2019. + +IS. Epstein maintained adeliberately complex web of Virgin Islands corporations, limited liability companies, foundations, and other entities, not all of which are yet known to the + +Government of the Virgin Islands, through which he carried out and concealed his criminal conduct. + +16. Epstein regularly created new entities in the territory and transferred properties and funds between them in order to preserve and shield Epstein's assets and to facilitate and conceal the unlawful acts described in this Complaint. + +17. These entities held properties, including Little St. James and Great St. James, at which Epstein trafficked and sexually abused women and underage girls. Epstein owned and arranged for private planes, helicopters, boat and automobiles to transport victims to, from, and within the Virgin Islands, and provided money to pay these young women and underage girls. + +18. Epstein sat at the hub of this web, serving as president, member, manager, or director of each of the entities and, upon information and belief, directing their activities. + +19. Defendant, Nautilus, Inc., is acorporation established and organized under the laws of the Virgin Islands. It was incorporated on November 22, 2011. + +20. According to records of the Virgin Islands Recorder of Deeds, Nautilus, Inc. owns Little St. James, a/k/a Parcel Number 109803010100, a parcel of 3.1 million square feet valued at \$3.2 million, with buildings and improvements valued at \$4 million. + +21. Epstein was president and director of Nautilus, Inc., which corporate filings describe as "holding property for personal use." Darren Indyke and Richard Kahn, Executors of the Estate, are the secretary and treasurer of Nautilus, Inc., respectively. The Estate values Epstein's holdings of Nautilus, Inc., which holds title to Little St. James at \$63.9 million. + +22. A deed recorded with the Virgin Islands Recorder of Deeds on December 30, 2011 reflects that the property was transferred from aDelaware entity, L.S.J., LLC, to Nautilus, Inc. for "TEN DOLLARS (\$10.00) and other good and valuable consideration." The quitclaim deed lists Jeffrey Epstein as the sole member of L.S.J., LLC, which it acquired Little Saint James via a warranty deed dated April 27, 1998. + +23. As described below, Epstein engaged in apattern and practice of trafficking and sexually abusing young women and female children on this private, secluded island of Little St. James where Epstein and his associates could avoid detection of their illegal activity from Virgin Islands and federal law enforcement and prevent these young women and underage girls from leaving freely and escaping the abuse. + +24. Thus, Nautilus, Inc. participated in carrying out, facilitating and concealing Epstein's crimes, hence Little St. James became an instrumentality of those crimes. + +25. Defendant, Great St. Jim, LLC, is alimited liability company established and organized under the laws of the Virgin Islands. Great St. Jim, LLC was organized on October 26, 2015. Great St. Jim, LLC, according to records of the Virgin Islands Recorder of Deeds, owns at least three properties that make up Great St. James acquired on January 28, 2016: Parcel Number 109801010100, consisting of 3.5 million square feet and valued at \$17.5 million; Parcel Number 109801010200, consisting of 450,000 square feet of land, valued at \$2.8 million; and Parcel Number 109801010300, 1.2 million square feet of land, valued at \$2.7 million. According to a warranty deed filed with the Virgin Islands Recorder of Deeds, Epstein, through Great St. Jim, LLC, acquired the last two parcels for \$5 million. + +26. Epstein is listed as manager and amember of Great St. Jim, LLC and the nature of its business is described as "holding assets." + +27. Upon information and belief, Epstein purchased these Great St. James properties the island with closest proximity to Little St. James—to further shield his conduct on Little St. James from view, prevent his detection by law enforcement or the public, and allow him to + +continue and conceal his criminal enterprise. Epstein's significant investment in the purchase of Great St. James demonstrates his intent to expand his illegal operation in the Virgin Islands for years to come. Thus, Great St. Jim, LLC participated in carrying out, concealing, facilitating and continuing Epstein's crimes, and Great St. James became an instrumentality of those crimes. + +28. Defendant, Poplar, Inc., is acorporation established and organized under the laws of the Virgin Islands. Poplar, Inc. was incorporated on November 22,2011. Epstein was president and director of Poplar, Inc., and its purpose was described in corporate filings as "holding property for personal use." Darren Indyke and Richard Kahn, Executors of the Estate, are secretary and treasurer of Poplar, Inc., respectively. + +29. A certificate of incumbency provided to the Department of Planning and Natural Resources ("DPNR") also lists Epstein as president of Poplar, Inc. and expressly authorizes the incorporators to conduct "transactions related to permitting matters submitted on behalf of Great St. Jim, LLC." + +30. Poplar, Inc. is listed as the signatory for the 2017 Annual Report for Great St. Jim, LLC, and the signature appears to be Epstein's. The Petition for Probate and Letters Testamentary filed by The Estate lists Poplar, Inc. as holding title to Great St. James. Thus, Poplar, Inc. participated in carrying out, concealing, facilitating and continuing Epstein's crimes. + +31. Defendant, Plan D, LLC is alimited liability company established and organized under the laws of the Virgin Islands. In its original Articles of Organization, filed October 19, 2012, and Annual Report filings, Epstein's pilot, Larry Visoski, was listed as Plan D, LLC's sole manager/member. However, the July 31,2019 Annual Report revealed Epstein as the principal behind Plan D, LLC. + +32. Upon information and belief, Plan D, LLC owns one or more of the airplanes and helicopters that Epstein used to transport young women and children to and from the Virgin Islands to carry out the criminal pattern of activity described below. Among the airplanes owned by Plan D, LLC is a Gulfstream with N-number N212JE. Flight logs and travel notices indicate that Epstein used this plane to traffic and transport and young women and underage girls to the Virgin Islands. + +33. Defendant, Hyperion Air, LLC is alimited liability company established and organized under the laws of the Virgin Islands on October 19, 2012. Jeffrey Epstein is a manager/member of Hyperion Air, LLC, along with his pilot, Larry Visoski. The purpose of Hyperion Air, LLC is listed in its Annual Report as "holding assets." + +34. Hyperion Air, LLC is the registered owner of aBell helicopter with N-number N331JE and a Keystone helicopter with N-number N722JE. Upon information and belief, Epstein used these helicopters to transport young women and underage girls between St. Thomas and Little St. James. + +35. John and Jane Does represent individuals and entities whose identities or involvement with Epstein are currently unknown. The Government of the Virgin Islands will amend the Complaint to add these individuals and entities when discovered. + +36. The Attorney General brings this action to seek all remedies available to the Government of the Virgin Islands in enforcing its laws and protecting the public interest and public safety. These claims are distinct from, and are not intended to supplant, the claims of victims who were unconscionably harmed by Jeffrey Epstein and his associates. + +#### FACTUAL ALLEGATIONS + +# A. The Conduct of the "Epstein Enterprise" in the Virgin Islands + +37. Epstein and his associates, including Defendants, identified and recruited female victims, including children, and transported them to the Virgin Islands where they were abused and injured. Epstein, through and in association with Defendants, trafficked, raped, sexually assaulted and held captive underage girls and young women at his properties in the Virgin Islands. + +38. Epstein created anetwork of companies and individuals who participated in and conspired with him in a pattern of criminal activity related to the sex trafficking, forced labor, sexual assault, child abuse, and sexual servitude of these young women and children. Epstein and his associates trafficked underage girls to the Virgin Islands, held them captive, and sexually abused them, causing them grave physical, mental, and emotional injury. + +39. To accomplish his illegal ends, Epstein formed an association in fact with multiple Defendants and others (both companies and individuals) who were willing to participate in, facilitate, and conceal Epstein's criminal activity in exchange for Epstein's bestowal of financial and other benefits, including sexual services and forced labor from victims. + +40. This illicit association of Epstein, Defendants, and his associates constitutes what is referred to herein as the "Epstein Enterprise." Epstein's associates in the Epstein Enterprise, including, but not limited to, those named as Defendants knowingly facilitated, participated in, and concealed Epstein's illegal conduct. + +41. Epstein used his wealth and power to create the Epstein Enterprise which engaged in a pattern of criminal activity in the Virgin Islands by repeatedly procuring and subjecting underage girls and young women to unlawful sexual conduct, sex trafficking, and forced labor. + +42. The Epstein Enterprise engaged in apattern of criminal activity in the Virgin Islands (and elsewhere) with the criminal purpose and goal of placing a steady supply of vulnerable female children and young women into sexual servitude in service of Epstein's desires, and those of his associates. The Epstein Enterprise maintained and made available young women and underage girls for the purpose of engaging them in forced labor and sexual activities and used coercion and deception to procure, abuse, and harbor its victims. + +43. Flight logs and other sources establish that between 2001 and 2019 the Epstein Enterprise transported underage girls and young women to the Virgin Islands, who were then taken via helicopter or private vessel to Little St. James where they were then deceptively subjected to sexual servitude, forced to engage in sexual acts and coerced into commercial sexual activity and forced labor. + +44. In furtherance of its criminal activities, the Epstein Enterprise used its aircraft to transport the young women and underage girls to the Virgin Islands for purposes of sexual abuse and exploitation. + +45. The Epstein Enterprise facilitated and participated in the sexual molestation and exploitation of numerous girls between the age of 12 and 17 years old. + +46. On the pretext of providing modeling opportunities, careers and contracts, associates of the Epstein Enterprise, funded by the Epstein Enterprise, lured and recruited young women and underage girls to travel to locations including the Virgin Islands where, upon information and belief, based on the pattern and practice of the Epstein Enterprise, they were sexually abused and exploited. + +47. Associates in the Epstein Enterprise recruited both victims and abusers into the Epstein Enterprise, participated in sexual acts of rape and abuse of minors and witnessed Epstein and others engage in sexual acts with children. + +48. As recent as 2018, air traffic controllers and other airport personnel reported seeing Epstein leave his plane with young girls some of whom appeared to be between the age of II and 18 years. + +49. Upon information and belief, based on Epstein's pattern of trafficking and sexually abusing young girls, the Epstein Enterprise trafficked and abused these girls, and others, in the Virgin Islands through 2018. + +50. When sued in civil court for committing sex trafficking and sex crimes, Epstein never denied engaging in sexual acts with underage females and procuring underage females for prostitution, but instead consistently invoked his Fifth Amendment privilege against selfincrimination. + +51. Upon information and belief, the Epstein Enterprise kept a computerized list of underage girls who were in or proximate to the Virgin Islands, and able to be transported to Epstein's residence at Little St. James in the Virgin Islands. + +52. The Epstein Enterprise engaged in apattern of criminal conduct by trafficking children and young women and placing them in sexual servitude and forced labor in the Virgin Islands. The Epstein Enterprise repeatedly violated 14 V.I.C. §§ 133 to 138, which prohibit trafficking and sexual abuse. The Epstein Enterprise also repeatedly violated laws against child abuse and neglect, including 14 V.I.C. § 505, which defines the crime of child abuse as knowingly or recklessly causing "a child to suffer physical, mental, or emotional injury," or causing a child to be placed in asituation where such injury is foreseeable, and 14 V.I.C. § 506, which applies, as + +here, where the child suffers serious physical, mental, or emotional injury as aresult of that abuse. The harm to Epstein's victims was both fully foreseeable and deeply damaging. + +53. The Epstein Enterprise knowingly recruited, transported, transferred, harbored, received, procured, obtained, isolated, maintained, and enticed young women and girls to engage in forced labor (such as providing massages) and, ultimately, sexual servitude at his little St. James residence. + +54. A 15 year old victim was forced into sexual acts with Epstein and others and then attempted to escape by swimming off the Little St. James island. Epstein and others organized a search party that located her and kept her captive by, among other things, confiscating her passport. + +55. Another victim, who was first engaged in provide massages to Epstein, was then forced to perform sexual acts at Little St. James in the Virgin Islands. When she attempted to escape from the "private island," Epstein and asearch party found her, returned her to his house, and suggested physical restraint or harm if she failed to cooperate. + +56. The Epstein Enterprise deceptively lured underage girls and women into its sex trafficking ring with money and promises of employment, career opportunities and school assistance. The Epstein Enterprise preyed on their financial and other vulnerabilities, and promised victims money, shelter, gifts, employment, tuition and other items of value. For example, participants in the Epstein Enterprise targeted young and underage females under the pretext that they would be paid substantially merely to provide massages to him and others. However, once drawn in, victims were then pressured and coerced to engage in sexual acts. + +57. The Epstein Enterprise forced underage victims to recruit others to perform services and engage in sexual acts—a trafficking pyramid scheme. + +58. The Epstein Enterprise paid girls for each "meeting," with additional money if they brought additional girls. Epstein reportedly required three meetings per day. + +59. The Epstein Enterprise used the term "work" as acode for sexual abuse, and, upon information and belief, reportedly kept computer records of the contact information for the victims. + +60. Consistent with his creation and use of acomplex web of entities to carry out and conceal the criminal trafficking enterprise in the Virgin Islands, the Epstein Enterprise sometimes paid young women and underage girls he exploited and trafficked through his charitable foundations. + +61. Once the girls and women were recruited, participants in the Epstein Enterprise enforced their sexual servitude of victims by coercion, including but not limited to, confiscating passports, controlling and extinguishing external communications, and threatening violence. They also made fraudulent statements to family members of victims, claiming victims were being well cared for and supported financially in college and other educational opportunities. + +62. The Epstein Enterprise transported, held, sexually abused, trafficked, and concealed women and children at his property in the Virgin Islands dozens of times over nearly two decades. + +# B. The "Epstein Enterprise" Abused Privileges of Residency to Carry out its Criminal Scheme + +63. The Epstein Enterprise in 1998 acquired Little St. James in the Virgin Islands as the perfect hideaway and haven for trafficking young women and underage girls for sexual servitude, child abuse and sexual assault. Little St. James is asecluded, private island, nearly two miles from St. Thomas with no other residents. It can be visited only by private boat or helicopter; no public or commercial transportation is available to carry persons on or off the island, and no + +bridge connects the island to St. Thomas. Epstein had easy access to Little St. James from the private airfield on St. Thomas, only 10 minutes away by his private helicopter, but the women and children he trafficked, abused, and held there were not able to leave without his permission and assistance, as it was too far and dangerous to swim to St. Thomas. + +64. In 2016, upon information and belief, using a straw purchaser to hide Epstein's identity, the Epstein Enterprise acquired Great St. James, the nearest island to Little St. James. By then, Epstein was a convicted sex offender. Upon information and belief, the Epstein Enterprise purchased the island for more than \$20 million because its participants wanted to ensure that the island did not become a base from which others could view their activities or visitors. By acquiring ownership and control of Great St. James to the exclusion of others, the Epstein Enterprise created additional bathers to prevent those held involuntarily on Little St. James from escaping or obtaining help from others. + +65. Great St. James and Little St. James are environmentally sensitive locations, with native coral and wildlife protected by federal and territorial law and enforcement authorities. The Department of Planning and Natural Resources ("DPNR") regulates and monitors construction in the Coastal Zone to protect, maintain and manage the precious natural resources of the Virgin Islands. Under its authority, DPNR repeatedly issued citations and assessed thousands of dollars of fines for violations of the Virgin Islands construction code and environmental protection laws on both Little St. James and Great St. James—significant penalties to the agency and to the average resident of the Virgin Islands. But because of Epstein's enormous wealth, these fines had little effect in curbing or stopping the Epstein Enterprise's unlawful conduct or conforming its activities to the law. + +66. As a result of illegal construction activity of the Epstein Enterprise, the Virgin Islands has incurred, and will incur, significant expenses to remove the illegal construction or remediate its effects on natural resources in and around Little St. James and Great St. James. The extent of the potential environmental damage is unknown at this time as the illegal construction has not been removed or remediated. + +67. The Epstein Enterprise continues to attempt to prevent or limit DPNR authorities from conducting random inspections on the Little St. James and Great St. James necessary to comply with Virgin Islands law. + +68. The Epstein Enterprise's violation of the construction and environmental laws was part of a pattern of behavior in flouting the laws of the Virgin Islands and holding itself above the law. Upon information and belief, as described above, the Epstein Enterprise undertook construction at Great St. James after 2016 to continue the scheme to carry out and conceal his trafficking and sexual abuse of young women and children in the Virgin Islands. These actions are also indicative of the Epstein Enterprise's disregard for Virgin Islands' law. The Epstein Enterprise used the Virgin Islands' land, resources, people, and laws for its illicit purposes. Rather than participating lawfully in this community, the Epstein Enterprise took advantage of the secluded nature of the islands in furtherance of its crimes. + +69. As a result of its deplorable and unlawful conduct, the Epstein Enterprise has subjected the Virgin Islands to public portrayals as ahiding place for human trafficking and sex crimes. + +# C. The "Epstein Enterprise" Fraudulently Concealed its Conduct + +70. The Epstein Enterprise fraudulently concealed its actions to prevent detection by the Government of the Virgin Islands. + +71. The secluded properties at Little St. James and Great St. James were repeatedly used by the Epstein Enterprise as the locations for unlawfully soliciting, transporting, transferring, harboring, receiving, providing, isolating, patronizing, maintaining, deceiving, coercing, and sexually abusing young women and children and concealing these crimes. + +72. The Epstein Enterprise was able to hide the trafficking ring from law enforcement, despite the fact that Epstein was aregistered sex offender. Given the isolation of the Little St. James and Great St. James and the nature of the crimes and of the victims targeted by the Epstein Enterprise, the activities of the Epstein Enterprise were not readily detectable. Moreover, Epstein's great wealth and power likely made witnesses reluctant to report their observations to the local law enforcement. + +73. Upon information and belief, the Epstein Enterprise prevented its employees from cooperating with law enforcement. Employees and others were required to sign confidentiality agreements that prohibited them from speaking to or sharing information with law enforcement. If they were contacted by law enforcement they were to notify the Epstein Enterprise and be represented by Epstein's counsel. + +74. The employees were directed not to communicate or interact with guests visiting Little St. James and were also directed not to disclose to anyone events that occurred on the island. + +75. Monitoring asex offender with his own private islands and the resources to fly victims in and out on private planes and helicopters presented unique challenges and allowed the Epstein Enterprise to limit scrutiny by the Government of the Virgin Islands. + +76. Sexual Offender Registration and Community Protection Act ("SORCPA") 14 V.I.C. § 1721, et. seq. requires sex offenders registered in the Virgin Islands to make periodic inperson appearances to verify and update their registration information. + +77. Epstein renewed his registration each year in the Virgin Islands. In addition, beyond this statutory requirement, the Virgin Islands periodically visited—or attempted to visit— Little St. James to conduct additional address verifications. + +78. At his last verification in July 2018, Epstein refused to permit Virgin Islands Department of Justice Investigators, assisted by United States Marshals, to enter Little St. James beyond its dock, claiming that the dock was his "front door." Instead, Epstein arranged to be met at his office on St. Thomas. + +79. Epstein also misled the Government regarding his travel plans. On March 19, 2019, the Virgin Islands was notified that Epstein would be traveling to France for 10 days on the private plane owned by Plan D, LLC. His notification form did not disclose travel to any other countries. It was later discovered by law enforcement authorities that Epstein also travelled to Vienna and Monaco during that trip. + +80. Similarly, the Epstein Enterprise sought to prevent DPNR from conducting routine site visits to inspect unpermitted and potentially damaging construction activity on Great St. James. The Epstein Enterprise repeatedly objected to DPNR's inspections referring to them as "invasions" of Epstein's constitutional right to privacy in his home, which he described defined as the entire island. These DPNR inspections are required for all construction and Virgin Islands residents are + +required to cooperate with the inspections to assure compliance with the law throughout the construction phases. + +81. These efforts represent Epstein Enterprise's intent to conceal its unlawful activity on Little St. James and Great St. James. + +82. The Epstein Enterprise also created numerous corporations and limited liability companies in the Virgin Islands to help conceal its unlawful activity. Most of these companies were created in 2011 and 2012, soon after Epstein registered as a sex offender in the Virgin Islands. + +83. Epstein's pilot, Larry Visoski is identified as member or co-member in companies that serviced and maintained the planes that the Epstein Enterprise used to traffick young women and children — Freedom Air Petroleum, LLC (registered November 28, 2011 to hold assets); and JEGE, LLC (registered October 19, 2012 to hold assets). + +84. Other Epstein entities include LSJ Employees, LLC (registered October 27, 2011 to provide services); Southern Financial, LLC (registered February 25, 2013 to provide services) and LSJ Emergency, LLC (registered December 2, 2015 to provide services). + +85. Some of these companies held considerable assets: Financial Informatics, Inc. (incorporated November 18, 2011, also known as Southern Trust Company, Inc.) had assets of approximately \$391 million in 2015; and Financial Trust Company, Inc. (incorporated November 6, 1998) had assets of \$212 million when it publicly filed its last balance sheet in 2012. + +86. Though often absent in the original incorporation or registration documents or annual filings, Epstein ultimately appeared as president, director, manager, or sole member of each of these companies. Upon information and belief, the purpose of this complex array of corporate entities—some of which may still be discovered—was to allow Epstein to shelter his assets in order to fund, carry out, and conceal his identity and pattern of criminal conduct. + +87. The Estate continues to engage in acourse of conduct aimed at concealing the criminal activities of the Epstein Enterprise. On November 24, 2019, Epstein's Estate filed an Expedited Motion for Establishment of aVoluntary Claims Resolution Program in the Superior Court of the Virgin Islands. ("Motion"). According to the Motion, the proposed program was to be designed to "establish an independent and voluntary claims resolution program for purposes of resolving sexual abuse claims against Jeffrey E. Epstein." (Motion, at I ). + +88. The program proposed by the Estate, whose executors are trustees of The 1953 Trust and officers in at least two Epstein entities, imposes confidentiality requirements and requires any claimant accepting an award under the program to sacrifice any other claims against "any person or entity arising from or related to Mr. Epstein's conduct." (Motion, at 5). It acts to conceal the criminal activities of the Epstein Enterprise and shield its participants from liability and accountability for the injury they caused to the victims. + +89. Two days before his death, Epstein amended The Trust and his Last Will and Testament. Upon information and belief, he did so, as part of apattern and ongoing effort to conceal and shield his assets from potential recovery by claimants. + +# D. The "Epstein Enterprise" Violated Numerous Virgin Islands Laws + +90. The pattern of criminal activity engaged in by Epstein and other participants in the Epstein Enterprise violated 14 V.I.C. §§ 605 and 607 of the Criminally Influenced and Corrupt Organizations Act ("CICO"). + +91. The Epstein Enterprise also violated Title 14, Chapter 3A, The Virgin Islands Uniform Prevention of and Remedies for Human Trafficking Act relating to Trafficking of Persons; Title 14, Chapter 24, relating to Child Protection and Child Abuse and Neglect; Title 14, + +Chapter 81, relating to Prostitution and Related Offenses; Title IS, Chapter 85, relating to Rape and Sexual Assault and other related offenses, as well as other Virgin Islands laws. + +92. The Epstein Enterprise violated Virgin Islands laws by engaging in the human trafficking of underage girls and young women and commercial sex with young women and underage girls by force, fraud, enticement, or coercion, which serve as predicates to the Epstein Enterprise's violations of CICO. + +93. Certain participants who recruited young women and underage girls to be trafficked and forced into sexual servitude themselves were sexually trafficked and abused by the Epstein Enterprise and may be afforded the protections of 14 V.I.C. § 145. + +94. Specifically, Plan D, LLC knowingly and intentionally facilitated the trafficking scheme by flying underage girls and young women into the Virgin Islands to be delivered into sexual servitude. Plan D, LLC repeatedly made flights from the mainland to St. Thomas with Epstein and underage girls and young women for the purpose of engaging in sexual activity on Little St. James. On some occasions, they would transport Epstein and female children by helicopter to Little St. James. On other occasions, Epstein and the young women and girls would be transported by boat. + +95. Great St. Jim, LLC and Nautilus, Inc. knowingly participated in the Epstein Enterprise and facilitated the trafficking and sexual servitude of young women and underage girls by providing the secluded properties at, from, or to which Epstein and his associates were able to transport, transfer, receive, maintain, isolate, harbor, provide, entice, deceive, coerce, and sexually abuse underage girls and young women. + +96. The Epstein Enterprise engaged in acontinuing course of unlawful conduct. + +97. After Epstein's suicide, the Epstein Enterprise continued to exist as each of the participants continued to conspire to prevent detection of the breadth and scope of the Epstein Enterprise's criminal wrongdoing and to prevent accountability. These conspiratorial acts are ongoing. + +98. The conduct of the Epstein Enterprise offends the core purpose of the Virgin Islands Uniform Prevention of and Remedies for Human Trafficking Act, 14 V.I.C. §131 et seq, and violates CICO, enacted to "curtail criminal activity and lessen its economic and political power in the Territory of the Virgin Islands by establishing new penal prohibitions and providing to law enforcement and the victims of criminal activity new civil sanctions and remedies." 14 V.I.C. § 601. + +99. The Epstein Enterprise is an illicit enterprise within the meaning of 14 V.I.C. §§ 604 and 605. + +100. The Government is entitled to recover civil penalties, damages and other remedies and to extinguish and recoup from the Epstein Enterprise any and all financial and other benefits, and any personal and real property that was used during the course of, or intended for use in the course of the conduct or criminal activity in violation of the laws of the Virgin Islands. The Government is entitled to obtain through divestiture, forfeiture, or other equitable relief all properties and instrumentalities used by the Epstein Enterprise in the criminal pattern of trafficking and sexual abuse in the Virgin Islands, including but not limited to, Great St. James and Little St. James, and all other remedies and penalties permitted by law in the interest of justice. + +#### COUNT ONE Human Trafficking — Trafficking an Individual Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"), 14 V.I.C. § 600 et seq.; and 14 V.I.0 §133 + +101. The Government restates and realleges paragraphs I to 100 of this Complaint as if fully set forth herein. + +102. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. + +103. The Epstein Enterprise engaged in two or more occasions of conduct that constitutes criminal predicate acts as defined by CICO, including, but not limited to, knowingly recruiting, transporting, transferring, harboring, receiving, providing, obtaining, isolating, maintaining, or enticing female children and young women in the furtherance and performance of forced labor, sexual servitude and commercial sexual activity in violation of Virgin Islands laws codified in 14 V.I.C. §§ 133-138. + +104. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. + +105. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. + +106. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14V.I.C. §600 et seq. + +#### COUNT TWO Human Trafficking — Trafficking an Individual Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act 14 V.I.C. § 600 et seq. and 14 V.I.0 §133 + +107. The Government restates and realleges paragraphs 1-106 of this Complaint as if fully set forth herein. + +108. At all times material herein, each Defendant joined in aconspiracy to violate laws prohibiting human trafficking. + +109. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by recruiting, transporting, transferring, harboring, receiving, providing, obtaining, isolating, maintaining or enticing female children and young women in the furtherance and performance of forced labor, sexual servitude and commercial sexual activity in violation of Virgin Islands laws codified in 14 V.1.C. § 133 -138. + +110. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the U.S. Virgin Islands. + +111. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §604(j). + +112. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14V.I.C. §600 et seq. + +#### COUNT THREE Human Trafficking — Forced Labor Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"), 14V.I.C. § 600 et seq.; and 14 V.I.0 §134 + +113. The Government restates and realleges paragraphs 1-112 of this Complaint as if fully set forth herein, + +114. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. + +115. The Epstein Enterprise engaged in two or more occasions of conduct that constitutes criminal predicate acts as defined by CICO, including, but not limited to, knowingly using coercion to compel underage girls and young women to provide labor or services by forced labor in violation of 14 V.I.C. § 134. + +116. The Epstein Enterprise knowingly provided or obtained the labor services of individuals by means of force, threats of force, physical restraint, and/or threats of physical restraint; by means of serious harm or threats of serious harm; by means of abuse or threatened abuse of law or legal processes; and by means of the Epstein Enterprise with the intent to cause individuals to believe that, if individuals did not perform such labor or services, individuals would suffer serious harm or physical restraint. + +117. Defendants through a pattern of criminal activity directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. + +118. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. + +119. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. + +120. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. + +#### COUNT FOUR Human Trafficking — Forced Labor Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14V.I.C. § 600 et seq.; and 14 V.I.0 §134 + +121. The Government restates and realleges paragraphs 1-120 of this Complaint as if fully set forth herein. + +122. At all times material herein, each Defendant joined in aconspiracy to violate laws prohibiting human trafficking. + +123. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by knowingly using coercion to compel underage girls and young women to provide labor or services by forced labor in violation of 14 V.I.C. § 134. + +124. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the U.S. Virgin Islands. + +125. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §604(j). + +126. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14V.I.C. §600 es seq. + +#### COUNT FIVE Human Trafficking — Sexual Servitude Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"), 14V.I.C. § 600 et seq.; 14 V.I.0 §135 + +127. The Government restates and realleges paragraphs 1-126 of this Complaint as if fully set forth herein. + +128. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. + +129. The Epstein Enterprise engaged in two or more occasions of conduct that constitutes criminal predicate acts as defined by CICO, including, but not limited to, knowingly maintaining or making available minors for the purpose of engaging the minors in commercial sexual activities or using coercion or deception to force young women to engage in commercial sexual activity in violation of 14 V.I.C. § 135. + +130. On the pretext of providing modeling opportunities, careers and contracts, Defendants facilitated the transporting or recruiting of young women and girls or lured and recruited young women and underage girls to travel to the Virgin Islands where they engaged in sexual acts with Epstein and others. In some instances, young women and underage girls were given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and others. + +131. Defendants through a pattern of criminal activity directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. + +132. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. + +133. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. + +134. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14V.I.C. §600 et seq. + +#### COUNT SIX Human Trafficking— Sexual Servitude Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act 14V.I.C. § 600 et seq.; 14 V.I.0 §135 + +135. The Government restates and realleges paragraphs 1-134 of this Complaint as if fully set forth herein. + +136. At all times material herein, each Defendant joined in aconspiracy to violate laws prohibiting human trafficking. + +137. Each Defendant engaged in acts that revealed its intent to join the criminal conspiracy by knowingly maintaining or making available minors for the purpose of engaging the minors in commercial sexual activities or using coercion or deception to force young women to engage in commercial sexual activity in violation of 14 V.I.C. § 135. + +138. On the pretext of providing modeling opportunities, careers and contracts, Defendants facilitated the transporting or recruiting of young women and girls or lured and recruited young women and underage girls to travel to the Virgin Islands where they engaged in sexual acts with Epstein and others. In some instances, young women and underage girls were + +given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and others. + +139. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the U.S. Virgin Islands. + +140. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §604(j). + +141. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14V.I.C. §600 el seq. + +#### COUNT SEVEN Human Trafficking — Patronizing Minors and Victims of Sexual Servitude Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"), 14 V.I.C. § 600 et seq.; 14 V.I.0 §§ 136-37 + +142. The Government restates and realleges paragraphs 1-141 of this Complaint as if fully set forth herein. + +143. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. + +144. The Epstein Enterprise engaged in two or more occasions of conduct that constitutes criminal predicate acts as defined by CICO, including, but not limited to, knowingly giving, agreeing to give, or offering to give items of value to young women and minors so that the young women and minors would engage in commercial sexual activity with Epstein, other Defendants, and other individuals in violation of 14 V.I.C. §§ 136-137. + +145. In some instances, young women and underage girls were given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and others. + +146. Defendants through a pattern of criminal activity directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. + +147. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. + +148. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. + +149. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO 14V.I.C. §600 et seq. + +#### COUNT EIGHT Human Trafficking — Patronizing Minors and Victims of Sexual Servitude Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act 14 V.I.C. § 600 a seq.; 14 V.I.0 §§ 136-37 + +150. The Government restates and realleges paragraphs 1-149 of this Complaint as if fully set forth herein. + +151. At all times material herein, each Defendant joined in aconspiracy to violate laws prohibiting human trafficking. + +152. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by knowingly giving, agreeing to give, or offering to give items of value to young women and minors so that the young women and minors would engage in commercial sexual activity with Epstein, other Defendants, and other individuals in violation of 14 V.I.C. §§ 136-137. + +153. In some instances, young women and underage girls were given scholarships, money, gifts or other items of value in exchange for engaging in sexual acts with Epstein and others. + +154. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the U.S. Virgin Islands. + +155. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise; human trafficking, forced labor, and sexual servitude. + +156. At all times material herein, Defendants engaged in said pattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO 14V.I.C. §600 et seq. + +#### COUNT NINE Child Abuse and Neglect Violation of the Criminally Influenced and Corrupt Organization Act ("CICO"), 14V.I.C. § 600 et seq.; 14 V.I.0 §§ 505, 506 and 507 + +157. The Government restates and realleges paragraphs 1-156 of this Complaint as if fully set forth herein. + +158. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. + +159. The Epstein Enterprise engaged in two or more occasions of conduct that constitutes criminal predicate acts as defined by CICO, including, but not limited to, knowingly or recklessly causing a child to suffer physical, mental or emotional injury, or knowingly or recklessly causing a child to be placed in asituation where it is reasonably foreseeable that such child may suffer physical, mental or emotional injury, in violation Virgin Islands criminal laws prohibiting Child Abuse and Neglect in Title 14 V.I.C. § 500 et. seq. + +160. As a result of the Epstein Enterprise's actions numerous young girls suffered serious physical, mental and emotional injury. + +161. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. + +162. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. + +163. At all times material herein, Defendants engaged in apattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. l4 V.I.C. §600 et seq. + +#### COUNT TEN + +# Child Abuse and Neglect + +### Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14V.I.C. § 600 et seq.; 14 V.I.0 §§ 505, 506 and 507 + +164. The Government restates and realleges paragraphs 1-163 of this Complaint as if fully set forth herein. + +165. At all times material herein, each Defendant joined in aconspiracy to violate laws prohibiting child abuse and neglect. + +166. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy as they knowingly or recklessly caused achild to suffer physical, mental or emotional injury, or knowingly or recklessly caused achild to be placed in asituation where it is reasonably foreseeable that such child may suffer physical, mental or emotional injury, in violation Virgin Islands criminal laws prohibiting Child Abuse and Neglect in Title 14 V.I.C. § 500 et seq. + +167. As a result of Defendants' actions, numerous young girls suffered serious physical, mental and emotional injury. + +168. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls in knowing or reckless disregard of the laws of the U.S. Virgin Islands. + +169. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §604(j). + +170. At all times material herein, Defendants engaged in apattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14V.I.C. §600 et seq. + +#### COUNT ELEVEN Aggravated Rape Violation of the Criminally Influenced and Corrupt Organization Act ("CICO"), 14V.I.C. § 600 et seq.; 14 V.I.0 § 1700a + +171. The Government restates and realleges paragraphs 1-170 of this Complaint as if fully set forth herein. + +172. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. + +173. The Epstein Enterprise engaged in two or more occasions of conduct that constitutes criminal predicate acts as defined by CICO, including, but not limited to, conduct that constituted or facilitated the rape of minors by force, intimidation, or the perpetrator's position of authority over the victim. + +174. Epstein and others, using force or intimidation, engaged in sexual intercourse with underage girls without their consent in violation of 14 V.I.C. § I 700a. + +175. As a result of the Epstein Enterprise's actions, numerous underage girls suffered serious physical, mental and emotional injury. + +176. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. + +177. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. + +178. At all times material herein, Defendants engaged in apattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14V.I.C. §600 et seq. + +#### COUNT TWELVE Aggravated Rape Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14V.I.C. § 600 et seq.; 14 V.I.0 § 1700a + +179. The Government restates and realleges paragraphs 1-178 of this Complaint as if fully set forth herein. + +180. At all times material herein, each Defendant joined in aconspiracy to violate laws prohibiting aggravated rape. + +181. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by engaging in conduct that constituted or facilitated the rape of minors by force, intimidation, or the perpetrator's position of authority over the victim. + +182. Epstein and others, using force or intimidation, engaged in sexual intercourse with underage girls without their consent in violation of 14 V.I.C. § 1700a. + +183. As a result of Defendants' actions, numerous underage girls suffered serious physical, mental and emotional injury. + +184. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the U.S. Virgin Islands. + +185. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §604(j). + +186. At all times material herein, Defendants engaged in apattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14V.I.C. §600 et seq. + +#### COUNT THIRTEEN Rape in the Second Degree Violation of the Criminally Influenced and Corrupt Organization Act ("CICO"), 14 V.I.C. § 600 et seq.; 14 V.I.0 § 1702 + +187. The Government restates and realleges paragraphs 1- 186 of this Complaint as if fully set forth herein. + +188. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. + +189. The Epstein Enterprise engaged in two or more occasions of conduct that constitutes criminal predicate acts as defined by CICO, including, but not limited to, conduct that constituted or facilitated the rape of girls under 18 years of age. + +190. Epstein and others who engaged in rape were over 18 years old at the time of the incidents. + +191. As a result of the Epstein Enterprise's actions, numerous minors suffered serious physical, mental and emotional injury. + +192. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. + +193. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. + +194. At all times material herein, Defendants engaged in apattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. + +#### COUNT FOURTEEN Rape in the Second Degree Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. § 600 et seq.; 14 V.I.0 § 1702 + +195. The Government restates and realleges paragraphs 1-194 of this Complaint as if fully set forth herein. + +196. At all times material herein, each Defendant joined in aconspiracy to violate laws prohibiting rape in the second degree. + +197. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by engaging in conduct that constituted or facilitated the rape of girls under 18 years of age. + +198. Epstein and others who engaged in rape were over 18 years old at the time of the incidents. + +199. As a result of Defendants' actions, numerous minors suffered serious physical, mental and emotional injury. + +200. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the U.S. Virgin Islands. + +201. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §604(j). + +202. At all times material herein, Defendants engaged in apattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14 V.I.C. §600 et seq. + +#### COUNT FIFTEEN Unlawful Sexual Contact in the First or Second Degree Violation of the Criminally Influenced and Corrupt Organization Act ("CICO"), 14 V.I.C. § 600 et seq.; 14 V.I.0 §§ 1708 and 1709 + +203. The Government restates and realleges paragraphs 1- 202 of this Complaint as if as if fully set forth herein. + +204. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. + +205. The Epstein Enterprise engaged in two or more occasions of conduct that constitutes criminal predicate acts as defined by CICO, including, but not limited to, using or facilitating the use of force or coercion to accomplish sexual contact or engaging in sexual contact with a minor between 13 and 16 years of age. + +206. Epstein and others who engaged in the sexual contact were over 18 years old at the time of the incidents. + +207. As a result of the Epstein Enterprise's actions numerous young women and minors suffered serious physical, mental and emotional injury. + +208. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. + +209. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. 210. At all times material herein, Defendants engaged in apattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO 14V.I.C. §600 es seq. COUNT SIXTEEN Unlawful Sexual Contact in the First or Second Degree Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. § 600 et seq.; 14 V.I.0 §§ 1708 and 1709 211. The Government restates and realleges paragraphs 1 - 210 of this Complaint as if as if fully set forth herein. 212. At all times material herein, each Defendant joined in aconspiracy to violate laws prohibiting unlawful sexual contact. 213. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by using or facilitating the use of force or coercion to accomplish sexual contact or engaging in sexual contact with aminor between 13 and 16 years of age. 214. Epstein and others who engaged in the sexual contact were over 18 years old at the time of the incidents. 215. As a result of Defendants' actions, numerous young women and minors suffered serious physical, mental and emotional injury. 216. Defendants knowingly benefited financially and/or obtained other non-financial + +value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of minor girls and young women in knowing or reckless disregard of the laws of the U.S. Virgin Islands. + +217. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §604(j). + +218. At all times material herein, Defendants engaged in apattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO 14 V.I.C. §600 et seq. + +#### COUNT SEVENTEEN Prostitution and Keeping House of Prostitution Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"), 14V.I.C. § 600 et seq.: 14 V.I.C. §§ 1622, 1624 + +219. The Government restates and realleges paragraphs 1 - 218 of this Complaint as if fully set forth herein. + +220. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. + +221. The Epstein Enterprise engaged in two or more occasions of conduct that constitutes criminal predicate acts as defined by CICO, including the engaging in or facilitating the knowing and/or reckless abuse of minors through the acts alleged herein. + +222. The Epstein Enterprise knowingly persuaded, induced, enticed, and/or coerced young women and children to travel to the Virgin Islands to engage in prostitution and/or sexual activity, and/or attempted to do the same. + +223. The Epstein Enterprise kept, maintained, and/or permitted his property at Little St. James to be used for the purpose of prostitution, lewdness or assignation with knowledge or reasonable cause to know the same. + +224. The Epstein Enterprise received or offered or agreed to receive women and children at his property at Little St. James for the purposes of prostitution, lewdness or assignation, and/or permitted young women and children to remain there for such purposes. + +225. The Epstein Enterprise directed, took, transported, and or offered or agreed to take or transport young women and children to Little St. James with the knowledge or reasonable cause to know that the purpose of such directing, taking or transporting was prostitution, lewdness or assignation. + +226. The Epstein Enterprise knew or should reasonably have known that some of the individuals that were the subjects of the actions described in this Count were minors. + +227. As a result of Defendants' actions, numerous young women and minors suffered serious physical, mental and emotional injury. + +228. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. + +229. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. + +230. At all times material herein, Defendants engaged in apattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14V.I.C. §600 et seq. + +#### COUNT EIGHTEEN Prostitution and Keeping House of Prostitution Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14V.I.C. § 600 et seq.: 14 V.I.C. §§ 1622, 1624. + +231. The Government restates and realleges paragraph 1 - 230 of this Complaint as if fully set forth herein. + +232. At all times material herein, each Defendant joined aconspiracy to laws against prostitution. + +233. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy by engaging in or facilitating the persuasion, inducement, enticement or coercion of young women and children to travel to the Virgin Islands to engage in prostitution and/or sexual activity, and/or attempted to do the same; keeping, maintaining, and/or permitting Epstein's property at Little St. James, to be used for the purpose of prostitution, lewdness or assignation with knowledge or reasonable cause to know the same; receiving, offering, or agreeing to receive individuals at his property at Little St. James for the purposes of prostitution, lewdness or assignation, and/or permitted young women and children to remain there for such purposes; and directing, taking, transporting, and/or offering or agreeing to take or transport young women and children to Little St. James with the knowledge or reasonable cause to know that the purpose of such directing, taking or transporting was prostitution, lewdness or assignation, in violation of 14 V.I.C. §§ 1622 and 1624. + +234. Defendants knew or should reasonably have known that some of the individuals that were the subjects of the actions described in this Count were minors. + +235. As a result of Defendants' actions numerous young women and minors suffered serious physical, mental and emotional injury. + +236. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the U.S. Virgin Islands. + +237. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §604(j). + +238. At all times material herein, Defendants engaged in apattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14V.I.C. §600 et seq. + +#### COUNT NINETEEN Sex Offender Registry + +# Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"), 14V.I.C. § 600 et seq.: 14 V.I.C. § 1721 et seq. + +239. The Government restates and realleges paragraphs 1- 238 of this Complaint as if fully set forth herein. + +240. Epstein was required to, and did, register under the Virgin Islands Sexual Offender Registration and Community Protection Act ("SORCPA") codified at 14 V.I.C. § 1721 et seq. + +241. SORCPA requires registered offenders to provide information relating to intended travel in foreign commerce. + +242. On at least two occasions, Epstein traveled to Vienna and Monaco without disclosing that travel to the Virgin Islands sex offender registry. + +243. Epstein's failure to disclose this travel before, during, or even after his travel was knowing. + +244. Epstein's violation SORPCA was part of apattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise. 14 V.I.C. §604(j). + +#### COUNT TWENTY Fraudulent Conveyance + +# Violation of the Criminally Influenced and Corrupt Organizations Act ("CICO"), 14 V.I.C. § 600 et seq.: 14 V.I.C. §§ 832-833 + +245. The Government restates and realleges paragraphs 1- 244 of this Complaint as if fully set forth herein. + +246. At all times material herein, each Defendant directly and indirectly participated in or associated with the Epstein Enterprise, an illicit enterprise. + +247. Each Defendant engaged in two or more occasions of conduct that constitutes criminal predicate acts as defined by CICO, including, but not limited to transferring assets to and between various entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder or delay claims against them. + +248. Upon information and belief, in an effort to defeat the claims of creditors and avoid the oversight of the court probating his estate, Epstein, days before his death, transferred significant assets, including assets held by other Defendants, into The 1953 Trust. + +249. At the time of these transfers, Epstein had numerous actions pending against him related to his trafficking and sexual assaults seeking financial judgments. + +250. Through these transfers, Epstein and the Epstein Enterprise fraudulently removed property and effects beyond the jurisdiction of the probate court. + +251. Epstein and the Epstein Enterprise were parties to the fraudulent conveyance of the property, real or personal, and/or the interests or rights arising out of property, contracts, or conveyances of Epstein and the Epstein Enterprise. + +252. Epstein and the Epstein Enterprise acted with the intent to defeat, hinder, or delay creditors and claimants, including the Government of the Virgin Islands, in collecting on their judgements, debts and demands. + +253. Defendants through a pattern of criminal activity acquired and maintained, directly or indirectly, an interest in or control of the Epstein Enterprise or real property. + +254. Defendants benefited, directly and indirectly, from the pattern of criminal activity conducted by the Epstein Enterprise. + +255. At all times material herein, Defendants engaged in apattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14V.I.C. §600 et seq. + +### COUNT TWENTY-ONE Fraudulent Conveyance Conspiracy to Violate the Criminally Influenced and Corrupt Organizations Act, 14 V.I.C. § 600 et seq.: 14 V.I.C. §§ 832-833 + +256. The Government restates and realleges paragraphs I to 255 of this Complaint as if fully set forth herein. + +257. At all times material herein, each Defendant joined in aconspiracy to commit fraudulent conveyances. + +258. Each Defendant engaged in acts that revealed its intent to join and participate in the criminal conspiracy, including, but not limited to, transferring assets to and between various entities controlled by Epstein and the Epstein Enterprise to avoid, defeat, hinder or delay claims against them. + +259. Upon information and belief, in an effort to defeat the claims of creditors and avoid the oversight of the court probating his estate, Epstein, days before his death, transferred significant assets, including assets held by other Defendants, into The 1953 Trust. + +260. At the time of this transfer, Epstein had numerous actions pending against him related to his trafficking and sexual assaults seeking financial judgments. + +261. Through this transfer, Epstein and the Epstein Enterprise fraudulently removed property and effects beyond the jurisdiction of the probate court. + +262. Epstein and the Epstein Enterprise were parties to the fraudulent conveyance of the property, real or personal, and/or the interests or rights arising out of property, contracts, or conveyances of Epstein and the Epstein Enterprise. + +263. Epstein and the Epstein Enterprise acted with the intent to defeat, hinder, or delay the Government of the Virgin Islands and other creditors and claimants to collect on their judgements, debts and demands. + +264. Defendants knowingly benefited financially and/or obtained other non-financial value from participation in the Epstein Enterprise, which has engaged in human trafficking, forced labor, sexual servitude and commercial sexual activity of girls and young women in knowing or reckless disregard of the laws of the U.S. Virgin Islands. + +265. At all times material herein, each Defendant conspired with Epstein and other Defendants to fulfill the primary criminal purposes of the Epstein Enterprise: human trafficking, forced labor, and sexual servitude. 14 V.I.C. §604(j). + +266. At all times material herein, Defendants engaged in apattern of criminal activity that was not isolated but was related to the affairs of the Epstein Enterprise in violation of CICO. 14V.I.C. §600 et seq. + +#### COUNT TWENTY-TWO Civil Conspiracy + +267. The Government restates and realleges paragraphs I - 266 of this Complaint as if fully set forth herein. + +268. Defendants acted in concert and joined with others to perform the wrongful acts identified in Counts 1 to 13, among others, concealing the sexual abuse of minor females by unlawful means. + +269. Each co-conspirator knew, or in the exercise of reasonable care should have known, about the conduct of the others and about the common unlawful scheme. + +270. These unlawful acts could not have been carried to the length and extent accomplished without the common understanding shared by Epstein and the Epstein Enterprise Defendants. + +271. Each of the Defendants had aduty to report, stop or terminate the wrongful conduct, but instead each Defendant concealed, assisted and furthered the wrongful acts by use of civil conspiracy. + +272. As a direct and proximate result of Defendants' conspiracy, the Virgin Island has been injured. + +273. Each co-conspirator is jointly and severally liable for the acts alleged herein. + +#### Notice of Allegation of PUNITIVE DAMAGES + +274. The purpose of punitive damages in the common law is to punish the defendant for outrageous conduct that is reckless or intentional and to deter others from engaging in such conduct in the future. + +275. This Complaint describes intentional conduct so egregious, persistent, and injurious that it shocks the conscience and offends acivilized society. + +276. Punitive damages are especially important in the case of persons or companies that have money, assets, and power that mere fines, penalties, and economic damages are simply not sufficient. + +277. At all times material herein, Epstein and the Epstein Enterprise engaged repeatedly in wrongful acts which were intentional and outrageous. The Government gives notice that it intends to pursue the possibility of punitive damages in any jury verdict. + +#### PRAYER FOR RELIEF + +WHEREFORE, the Government respectfully requests that the Court: + +A. Enter a judgment in favor of the Government and against Defendants on all counts; + +B. Declare that Defendants, through the Epstein Enterprise, have engaged in apattern of criminal activity in the Virgin Islands including but not limited to human trafficking, forced labor and sexual servitude of female children and young women, unlawful sexual contact, child sexual abuse, child abuse and neglect, rape, prostitution and other offenses related offenses, and civil conspiracy.; + +C. Pursuant to 14 V.I.C. § 610, enforce and maintain the criminal activity liens the Government is filing contemporaneously with this lawsuit, or shall file in connection with this action; + +D. Pursuant to 14 V.I.C. § 607(a)(1) and 14 V.I.C. § 141, issue an order forfeiting and divesting in favor of the Government of the Virgin Islands all of Defendants' interests in any real and personal property within the territory of the U.S. Virgin Islands used to facilitate the criminal enterprise carried out by the Epstein Enterprise, including but not limited to Little St. James Island and Greater St. James Island . + +E. Issue an order forfeiting to the Government of the Virgin Islands any proceeds or funds obtained by Defendants, whether directly or indirectly, during the course of the criminal activity of the Epstein Enterprise; + +F. Pursuant to 14 V.I.C. § 607(a)(1), require Defendants to divest themselves of any real property or other interests in favor of the Government of the Virgin Islands used to further the goals of the Epstein Enterprise; + +G. Pursuant to 14 V.I.C. § 607(a)(3) and (5), order the dissolution of the Epstein Enterprise, including but not limited to, order the dissolution of the corporate Defendants; + +H. Pursuant to 14 V.I.C. § 607(a)(2) enter an injunction to prevent the further criminal conduct, and concealment of the criminal conduct, by the Epstein Enterprise; + +I. Pursuant to 14 V.I.C. § 607(a)(4), order the revocation of any and all licenses, permits and approvals that had been granted by any agency of the Territory, and require the repayment of any tax benefits that had been bestowed on any Defendant; + +J. Pursuant to 14 V.I.C. § 607(a)(6)(e), award the Government the maximum civil penalty for each and every violation of law committed by the Epstein Enterprise; + +K. Pursuant to 14 V.I.C. § 607, award treble damages and all other available remedies, including attorneys' fees and costs; + +L. Award compensatory and punitive damages for Defendants' civil conspiracy; + +M. Void the transfer of assets as fraudulently conveyed to the The 1953 Trust; + +N. Award such equitable relief, including disgorgement of all ill-gotten gains, as may be just and proper and appropriate, pursuant to 14 14 V.I.C. § 608(c)(4), to protect the rights of victims and innocent persons in the interest of justice and consistent with the purposes of CICO; + +O. Assess and award ajudgment in favor of the Government and against the Defendants for attorneys' fees and costs and pre- and post-judgment interest; and + +P. Award any and all other relief this Court deems appropriate. + +The Government demands ajury trial on all issues so triable. + +RESPECTFULLY SUBMITTED, + +#### Dated: January 15, 2020 GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS + +![](_page_47_Picture_11.jpeg) + +V.I. Department of Justice Office of the Attorney General 34-38 Kronprindsens Gade GERS Building, 2nd Floor St. Thomas, U.S.V.I. 00802 Telephone: + +RECEIVED +20 JAN 15 PM 1:01 \ No newline at end of file diff --git a/marker2/ds9/EFTA00086802/EFTA00086802.metadata.json b/marker2/ds9/EFTA00086802/EFTA00086802.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..dc4d6fc753a46afe412337a2cfecfb6429d6ecab --- /dev/null +++ b/marker2/ds9/EFTA00086802/EFTA00086802.metadata.json @@ -0,0 +1,2664 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086802.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 49, + "chars": 79519, + "elapsed_seconds": 16.43, + "image_assets": [ + "_page_47_Picture_11.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS \nDIVISION OF ST. 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I.:verde!' + +![](_page_0_Picture_6.jpeg) + +July 6, 2020 + +## VIA ECF + +The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse + +![](_page_0_Picture_10.jpeg) + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Dear Judge Nathan: + +On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter in response to the Court's order from earlier today regarding the scheduling of the arraignment, initial appearance, and bail hearing in this matter. We have been attempting to contact our client at the Metropolitan Detention Center; we were able to speak to her for the first time today just before 9:00pm this evening. She has agreed to waive her physical presence for these proceedings. + +As directed by the Court, we have met and conferred with the Government regarding scheduling. All parties will be able to proceed remotely on the morning of July 14, 2020. The defense will not be able to proceed on July 9, 2020. + +We will meet and confer further with the Government tomorrow regarding a proposed briefing schedule and anticipate providing a joint proposed briefing schedule for the Court's consideration by the end of the day. + +Respectfully submitted, + +Is/ Mark S. Cohen + +Mark S. Cohen sin + +![](_page_0_Picture_20.jpeg) + +The Honorable Alison J. 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Present for the interview was attorney -• along with AUSA AUSA Detective , and Special Agent . After being advised of the identity of the above listed individuals and the nature of the interview, provided the following information: + +has lived back and forth between Europe and New York. has worked in real estate for six year and has her own jewelry design company, for the past three years. grew up in Italy outside Venice, where she attended school. When was between 22 to 24 years old, she came to New York to learn English and studied fashion. started modeling and casting work for a good agency. Her booker, ANDREW LNU, was casting for Victoria's Secret. Her booker recommended her to a man to go to a casting. went to JEFFREY EPSTEIN's house with her book. saw many girls living there at the house. A woman, who thought may have been a sister but was not sure, told her, "Oh you have to be nice to him; he's going to help you a lot". EPSTEIN's house was on the Upper East Side on maybe 72nd street; it was a big house. This was maybe in the winter/March of 2004. described a woman as having short dark hair and thought this to be GHISLAINE MAXWELL. This woman introduced to EPSTEIN and told her, "Be nice, he's important". This woman walked her up the stairs. Once there when it was just the two of them, and EPSTEIN talked. did not remember what the two of them talked about. EPSTEIN made realize she was not there for a casting. said, "It was a sexual thing; it was harassment.". + +did not remember EPSTEIN saying much, but remembered him being aggressive with her. EPSTEIN pushed to the door, came up to her, touched her face and touched her all over, her vagina in particular. + +Investigation on 09/12/2019 at New York, New York, United States (In Person) + +This document contains neither recommendations nor conclusions of the FBI. It is the p +**To:** "[REDACTED]" <[REDACTED]> +**Cc:** "[REDACTED]" <[REDACTED]> + +**Subject:** Re: Call re Epstein case + +**Date:** Wed, 29 Apr 2020 19:05:59 +0000 + +--- + +Sounds great thanks + +Sent from my iPhone + +On Apr 29, 2020, at 3:04 PM, [REDACTED] <[REDACTED]> wrote: + +Same + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Wednesday, April 29, 2020 15:04 +**To:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** FW: Call re Epstein case + +Good for me – work for you guys? + +--- + +**From:** [REDACTED] (USANYS) 3 <[REDACTED]> +**Sent:** Wednesday, April 29, 2020 3:03 PM +**To:** [REDACTED] <[REDACTED]> +**Cc:** [REDACTED], [REDACTED] 1 <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]> +**Subject:** RE: Call re Epstein case + +Sure – how's 4:30? + +[REDACTED] + +United States Attorney's Office +Southern District of New York + +[REDACTED] + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Wednesday, April 29, 2020 2:15 PM +**To:** [REDACTED] (USANYS) 3 <[REDACTED]> +**Cc:** [REDACTED], [REDACTED] 1 <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]> +**Subject:** Call re Epstein case + +Hi [REDACTED], + +Thanks very much, \ No newline at end of file diff --git a/marker2/ds9/EFTA00086888/EFTA00086888.metadata.json b/marker2/ds9/EFTA00086888/EFTA00086888.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8c6627005cba3d3a3b010e80c00cca81cbb22daa --- /dev/null +++ b/marker2/ds9/EFTA00086888/EFTA00086888.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086888.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1224, + "elapsed_seconds": 5.68, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 36 + ], + [ + "Text", + 35 + ], + [ + "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 + ], + [ + "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/EFTA00086888" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086890/EFTA00086890.md b/marker2/ds9/EFTA00086890/EFTA00086890.md new file mode 100644 index 0000000000000000000000000000000000000000..703136f21479edb8ad0842544c68d1ec7f9fdeda --- /dev/null +++ b/marker2/ds9/EFTA00086890/EFTA00086890.md @@ -0,0 +1,261 @@ +From: To: (USANYS [Contractor]" Cc: ' fiNYS)" (USANYS) [Contractor]" (USANYS) (USANYS)" + +Subject: RE: Fedex + +Date: Thu, 05 Aug 2021 14:51:38 +0000 + +Attachments: 2021.08.05\_Maxwell Discoyery\_Letter.docx + +Inline-Images: imageO0I.jpg + +Absolutelyl It has been saved to the subpoena returns folder here, and stamped/added to the pending Nineteenth Production folder on the shared. I've updated the cover letter (attached) and index to reflect this addition. If there are any edits to be made, I'm happy to do so. + +Thanks so much! + +From: (USANYS) < > Sent: Thursday, August 5, 2021 10:40 AM To: (USANYS) [Contractor] Cc: (USANYS) (USANYS) (USANYS) [Contractor] > + +Subject: FW: Fedex + +Importance: High + +Hi team, + +Could you please add this to the subpoena folder and the next discovery production? Thank you. + +From: Tracy Chapell < Sent: Thursday, August 5, 2021 9:49 AM To: (MANN 4: .=>, (USANYS) Cc: (USANYS) aa (USANYS) + +Subject: RE: Fedex + +Importance: High + +Good morning, + +Sorry for the late response. Our IT team was not able to go back past 2007. I am attaching a spreadsheet with the shipments on his account from 2007 - 2020 for your review. Please let me know if you have any questions or need anything further. + +Thank you, + +Tracy Chapell Senior Paralegal + +![](_page_1_Picture_0.jpeg) + +From: + +Sent: Friday, July 30, 2021 8:46 AM + +To: Tracy Chapell c M> (USANYS) > + +Cc: (USANYS) Ca. (USANYS) > + +Subject: [EXTERNAL] RE: Fedex + +3620 Hack Cross Road + +Building 8, 3rd Floor + +Mem his, TN 38125 + +(t) + +Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown or suspicious origin. + +Hi Tracy, + +Thank for your help with this inquiry. We're not sure whether this would have been the same account number during the time period we're looking at, but the account number we have is 1144-2081-6. More broadly, we are searching for any accounts or data associated with Ghislaine Maxwell or Jeffrey Epstein. + +Thank you, + +From: Tracy Chapell < + +Sent: Friday, July 30, 2021 9:40 AM + +To: + +Cc: + +Subject: RE: Fedex + +Importance: High + +Do you have a FedEx Express account number? I am going to reach out to IT and see what they can find or have. + +Thank you, + +Tracy Chapell + +Senior Paralegal + +![](_page_1_Picture_26.jpeg) + +Federal Express Corporation + +Legal Department + +3620 Hack Cross Road + +Building 8, 3rd Floor + +Mem his, TN 38125 + +From: Sent: Thursday, July 29, 2021 5:02 PM To: Tracy Chapell Cc: Subject: [EXTERNAL] RE: Fedex c M> + +Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown or suspicious origin. + +Hi Tracy, + +I hope all's well. Do you have a few minutes to talk tomorrow? We'd like to follow up on something with you. + +Thanks, + +From: Tracy Chapell Sent: Friday, July 16, 2021 10:11 AM To: (USANYS) Subject: RE: Fedex + +Good morning, + +Sorry for my late response. I have been out of the office all week. I can testify if need be. Let me know if you need anything further. + +Thank you, + +Tracy Chapell Senior Paralegal + +![](_page_2_Picture_10.jpeg) + +Federal Express Corporation Legal Department 3620 Hack Cross Road Building B, 3rd Floor Memphis, TN 38125 (t) + +From: (USANYS) Sent: Tuesday, July 13, 2021 2:34 PM To: Tracy Chapell Cc: (USANYS) Subject: [EXTERNAL] RE: Fedex + +Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown or suspicious origin. + +Thanks, Tracy. We'd like to identify a records custodian who could testify, in the event that it would be necessary. + +From: Tracy Chapell < + +Sent: Wednesday, July 7, 2021 11:07 AM + +To: (USANYS) + +Cc: (USANYS) + +Subject: RE: Fedex + +Good morning, + +Please see attached. Let me know if you need anything further. + +Thank you, + +Tracy Chapell + +Senior Paralegal + +![](_page_3_Picture_11.jpeg) + +Legal Department + +3620 Hack Cross Road + +Building B, 3rd Floor + +Memphis, TN 38125 + +(t) + +From: (USANYS) < + +Sent: Tuesday, July 6, 2021 12:33 PM + +To: Tracy Chapell + +Cc: (USANYS) + +Subject: (EXTERNAL) RE: Fedex + +Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown or suspicious origin. + +Hi Tracy, + +We'd like someone to sign an affidavit for now, but we'd also like to identify someone who could testify at trial if need be. The trial is for Ghislaine Maxwell, scheduled to start in New York in November. + +I've attached a proposed declaration, though if FedEx has its own standard format, that will likely work too. + +Thanks, + +From: Tracy Chapell + +Sent: Tuesday, July 6, 2021 10:49 AM + +To: + +I have reviewed the records and they seem to be our records. Are you needing someone to sign an affidavit or appear in person at trial? (is this "the" Jeffrey Epstein?) + +Thank you, + +Tracy Chapell + +Senior Paralegal + +![](_page_4_Picture_5.jpeg) + +Federal Express Corporation + +Legal Department + +3620 Hack Cross Road + +Building B, 3rd Floor + +Memphis, TN 38125 + +From: (USANYS) + +Sent: Tuesday, July 6, 2021 9:25 AM + +To: Tracy Chapell + +Cc: (USANYS) + +Subject: (EXTERNAL] RE: Fedex + +Caution! This email originated outside of FedEx. Please do not open attachments or click links from an unknown or suspicious origin. + +Hi Tracy, + +I hope you had a nice weekend, and thanks again for the call last week. I've attached the FedEx records for which we are looking for a records custodian. According to a log, the U.S. Attorney's Office for the Southern District of Florida sent FedEx a subpoena in February 2008, and the FedEx point of contact was Tracy Ferrara. If we find any front matter, like an internal tracking number, we'll let you know. + +Thanks again for your assistance with this. Please let me know if you have any questions. + +Assistant United States Attorney + +Southern District of New York + +1 Saint Andrews Plaza + +New York, New York 10007 + +Sent: Friday, July 2, 2021 11:08 AM + +To: (CTR) + +Subject: RE: Fedex + +Thanks, M! + +Tracy, would you mind giving me a call when you have a chance? My number + +Thanks, + +From: (CTR) + +Sent: Friday, July 2, 2021 11:05 AM + +To: (USANYS) < > + +Subject: Fedex + +Hi Tracy, + +You have been extremely helpful in the past with me I was hoping you can lend assistance to the assistant United States attorney, I'm working with. is ccd on this email, if you want to reply and see what she can help with. + +Thank you in advance for al your help, + +Sent with BlackBerry Work + +(www.blackberry.com) \ No newline at end of file diff --git a/marker2/ds9/EFTA00086890/EFTA00086890.metadata.json b/marker2/ds9/EFTA00086890/EFTA00086890.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1e077c38bad40185cda0c03083ad854b2fdedfc1 --- /dev/null +++ b/marker2/ds9/EFTA00086890/EFTA00086890.metadata.json @@ -0,0 +1,222 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086890.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + 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I'll need to meet with Mon August 16th at fpm and August 17th at 10am. + +One special request: would it be possible to please make sure that Mstays at a different hotel than who will be coming up that same week? I'd like to avoid them running into each other if possible. + +Thanks so much, \ No newline at end of file diff --git a/marker2/ds9/EFTA00086896/EFTA00086896.metadata.json b/marker2/ds9/EFTA00086896/EFTA00086896.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..55caca4202f9afb6cbd3c915f565afe6a3af30be --- /dev/null +++ b/marker2/ds9/EFTA00086896/EFTA00086896.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086896.pdf", + "engine": { + "marker_major": "2", + "marker_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": 526, + "elapsed_seconds": 0.51, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 30 + ], + [ + "Line", + 13 + ], + [ + "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/EFTA00086896" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086897/EFTA00086897.md b/marker2/ds9/EFTA00086897/EFTA00086897.md new file mode 100644 index 0000000000000000000000000000000000000000..cafff79a7121d22f96665a1ae6e612ac71996e40 --- /dev/null +++ b/marker2/ds9/EFTA00086897/EFTA00086897.md @@ -0,0 +1,63 @@ +To: + +Cc: + +Subject: Fwd: UK / US Contact Details + +Date: Wed, 11 Dec 2019 12:24:43 +0000 + +Attachments: ATT00001.htm; ATT00002.htm; ATT00003.htm; ATT00004.htm; ATT00005.htm; AMENDED\_Ietter\_to\_United\_States\_Attomey.pdf; ATT00006.htm; image001.png + +Inline-Images: image002.jpg; image003.png; image005jpg; image003(1).png + +Sent from my iPhone + +Begin forwarded message: + +Front: + +Date: December 11, 2019 at 6:43:48 AM EST + +To:" + +Subject: Fwd: RE: UK / US Contact Details + +Good morning M. See below. + +Forwarded message + +From: + +Date: Dec 11, 2019 5:09 AM + +Subject: RE: UK / US Contact Details + +To: ' + +Cc: + +Sir, + +Apologies for this mix-up, I had slightly out of date information. + +The correct solicitor details are as shown on this attached, amended letter. I hope this has not caused issues for you. + +Thanks, + +■ + +**Detective** + +**Staff** Officer to De ut Assistant Commissioner (Specialist Operations) + +![](_page_1_Picture_1.jpeg) + +![](_page_1_Picture_2.jpeg) + +![](_page_1_Picture_5.jpeg) + +![](_page_1_Picture_3.jpeg) + +![](_page_1_Picture_4.jpeg) + +![](_page_1_Picture_6.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00086897/EFTA00086897.metadata.json b/marker2/ds9/EFTA00086897/EFTA00086897.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6d1019ea634dbcdd7e210f8bfa621fc66093f8d7 --- /dev/null +++ b/marker2/ds9/EFTA00086897/EFTA00086897.metadata.json @@ -0,0 +1,95 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086897.pdf", + "engine": { + "marker_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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b/marker2/ds9/EFTA00086900/EFTA00086900.md new file mode 100644 index 0000000000000000000000000000000000000000..80a7532146d2c559a7fc4aed5194490859e201eb --- /dev/null +++ b/marker2/ds9/EFTA00086900/EFTA00086900.md @@ -0,0 +1 @@ +NOTICE - This email and any attachments are solely for the intended recipient and may be confidential. If you have received this email in error, please notify the sender and delete it from your system. Do not use, copy or disclose the information contained in this email or in any attachment without the permission of the sender. Metropolitan Police Service (MPS) communication systems are monitored to the extent permitted by law and any email and/or attachments may be read by monitoring staff. Only specified personnel are authorised to conclude binding agreements on behalf of the MPS by email and no responsibility is accepted for unauthorised agreements reached with other personnel. While reasonable precautions have been taken to ensure no viruses are present in this email, its security and that of any attachments cannot be guaranteed. \ No newline at end of file diff --git a/marker2/ds9/EFTA00086900/EFTA00086900.metadata.json b/marker2/ds9/EFTA00086900/EFTA00086900.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a193be54f7e2b5fedefa1151e8ac99d340ff6081 --- /dev/null +++ b/marker2/ds9/EFTA00086900/EFTA00086900.metadata.json @@ -0,0 +1,46 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086900.pdf", + "engine": { + "marker_major": "2", + "marker_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": 845, + "elapsed_seconds": 2.91, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 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/EFTA00086900" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086901/EFTA00086901.md b/marker2/ds9/EFTA00086901/EFTA00086901.md new file mode 100644 index 0000000000000000000000000000000000000000..7ebb1467ca3bdeb4adc073d82c99c13cb3264c7e --- /dev/null +++ b/marker2/ds9/EFTA00086901/EFTA00086901.md @@ -0,0 +1,55 @@ +![](_page_0_Picture_115.jpeg) + +**METROPOLITAN +POLICE** + +Geoffrey S. Berman +United States Attorney +Southern District of New York + +**Deputy Assistant Commissioner +Specialist Operations Headquarters** + +New Scotland Yard +1 - 8 Richmond Terrace +Victoria Embankment +London +SW1A 2JL + +Telephone: [REDACTED] + +Email: [REDACTED] + +Reference: 53/DACSO/2019/RW + +11th December 2019 + +**PLEASE NOTE AMENDMENT BELOW AND DISREGARD LETTER SENT 9TH DECEMBER 2019** + +Dear Mr. Berman, + +I am writing regarding your investigation into the allegations of sexual exploitation and abuse by Jeffrey Epstein as detailed in the case of *United States v. Jeffrey Epstein*, 19 Cr. 490 (RMB). + +I have been advised that US Embassy representatives in London have made contact with Metropolitan Police Colleagues on your behalf, requesting the contact details for the solicitor for HRH The Duke of York, Prince Andrew. These contact details are: + +Gary Bloxsome +Blackfords LLP +15 Old Bailey +London EC4M 7EF + +[REDACTED] + +[REDACTED] + +[REDACTED] + +The above is supplied for your information. + +Yours sincerely, + +[REDACTED] + +[REDACTED] + +Deputy Assistant Commissioner – Specialist Operations +Metropolitan Police Service \ No newline at end of file diff --git a/marker2/ds9/EFTA00086901/EFTA00086901.metadata.json b/marker2/ds9/EFTA00086901/EFTA00086901.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1d9cfd5be86c2b01d6aaad8121bfcc87b3341371 --- /dev/null +++ b/marker2/ds9/EFTA00086901/EFTA00086901.metadata.json @@ -0,0 +1,88 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086901.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1220, + "elapsed_seconds": 5.4, + "image_assets": [ + "_page_0_Picture_115.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "PLEASE NOTE AMENDMENT BELOW AND DISREGARD LETTER SENT 9 TH DECEMBER 2019", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 67.83, + 326.698 + ], + [ + 470.05, + 326.698 + ], + [ + 470.05, + 339.628 + ], + [ + 67.83, + 339.628 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Text", + 33 + ], + [ + "Line", + 32 + ], + [ + "SectionHeader", + 4 + ], + [ + "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/EFTA00086901" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086901/_page_0_Picture_115.jpeg b/marker2/ds9/EFTA00086901/_page_0_Picture_115.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..35fcf82cf4d8ca71722aa1cbf810dde8c22bf17f --- /dev/null +++ b/marker2/ds9/EFTA00086901/_page_0_Picture_115.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:48ff97aadb3c9c0864ded46f7398107b46910dcf3640d163853672d9f92ecc55 +size 4067 diff --git a/marker2/ds9/EFTA00086902/EFTA00086902.md b/marker2/ds9/EFTA00086902/EFTA00086902.md new file mode 100644 index 0000000000000000000000000000000000000000..729b946edc40a749f9b61ab934c27208444a38a0 --- /dev/null +++ b/marker2/ds9/EFTA00086902/EFTA00086902.md @@ -0,0 +1,27 @@ +![](_page_0_Picture_2.jpeg) + +Date of entry 09/05/2019 + +On September 3, 2019, , inmate at the Metropolitan Correctional Center (MCC), was interviewed at the Southern District of New York, 500 Pearl Street, New York, NY. In attendance at the interview were FBI Special Agent (SA) Office of the Inspector General (OIG) SA , Assistant United States Attorney (AUSA) , and attorneys, was advised of his rights and also that it is a separate crime to lie to a federal agent. acknowledged what he was advised of and was willing to proceed with the interview. After being advised of the identity of the interviewing investigators and the nature of the interview, -provided the following information: + +has been at MCC in the Special Housing Unit (SHU) L Tier since August 2, 2019. His cell is the first cell on the left and he is able to see all the cells on the right side in L Tier. can also see G and H Tier along with the middle portion of the multi-purpose room in the SHU from his cell. usually goes to sleep around 11pm or 12am. /f he gets to sleep during the day, he will then go to bed around 3am. stated that he is always up for breakfast which is around 6:10am. will sometimes wake up when the count is conducted because he can hear the keys. + +On the morning that JEFFREY EPSTEIN was found unresponsive in his cell, said that he saw a Guard, who he described as a black male, on the shorter side heightwise, and had close cut hair, knock on EPSTEIN's cell door. The Guard looked into the cell and then entered the cell. When the Guard opened the door, could only see EPSTEIN's legs from the knee down but could tell that he was laying down on his back because his feet were pointed upward. could only see this portion of EPSTEIN because EPSTEIN always slept on the floor to the right side of the cell. + +The Guard bent down to shake EPSTEIN and was saying "Epstein. Epstein.". + +Investipticmon 09/03/2019 m 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. + +Comthwthon of FD-302 of (U) Interview of a 09/03/2019 ,page 2 of 2 + +The Guard then tried to pick up EPSTEIN from behind, with his arms wrapped around EPSTEIN. Both the Guard and EPSTEIN fell back to the floor, with EPSTEIN falling to the side of the Guard. stated that once the two fell, he could then see EPSTEIN. The Guard then started giving EPSTEIN chest compressions and mouth-to-mouth. At this point the Guard said "Fuck!" and asked the female Guard, who was standing near the L Tier gate, if she had pressed the button. The female Guard said "Yeah, a long time ago." + +A Lieutenant then came in and also a male nurse who tried to revive EPSTEIN. However, EPSTEIN was not responsive because, according to , EPSTEIN was already dead. said that EPSTEIN looked dead when he fell with the Guard after the Guard tried to pick him up. + +said that personnel were having trouble getting EPSTEIN onto the stretcher because EPSTEIN was basically dead weight. When they did get him on the stretcher, EPSTEIN still had on headphones. stated that EPSTEIN did not have any marks around his neck and he didn't see a rope around EPSTEIN's neck. At this point, woke up his cellmate who then took a look at what was happening. cellmate made a comment that EPSTEIN didn't hang himself because he didn't have the typical injuries. -• at some point, saw a male come out of EPSTEIN's cell with a sheet that had a loop and knot. + +After this, MCC personnel, to include Lieutenant , started to cover up the windows to the cells on L Tier. They also brought dividers to block views from his cell and the camera. + +The day before EPSTEIN died, EPSTEIN and his cellmate left at the same time that morning. EPSTEIN was with his lawyers all day, as usual. However, when he was brought back to the SHU that night, the guards took him up to J Tier before they brought him back to his cell. 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Also present for the interview was Office of Inspector General (OIG) Special Agent (SA) and Federal Bureau of Investigation (FBI) SA . After being advised of the identities of the interviewing personnel, and the nature of the interview, voluntarily provided the following information: + +Prior to employment with the Bureau of Prisons (BOP), \_was a paralegal at Law Firm. He worked litigation, pro bono, mergers and acquisitions for approximately ten years. also been an enlisted NAVY Reservist for the last twenty years. was employed as a Corrections Officer with BOP in June the Metropolitan Detention Center, hereinafter referred to as MDC. transitioned to the BOP Metropolitan Corrections Center, hereinafter referred to as MCC, on He was later promoted to the rank of Lieutenant on + +the Special Housing Unit's, hereinafter referred to as SHU, Lieutenant for approximately 90 days since Lieutenants rotate throughout MCC every 90 days. Accoring to\_ his duties and responsibilities were as follows: + +- Control max wing (10 South) and oversee the regular SHU +- Supervise employees +- Control moves +- Oversee Segregation Reviews, hereinafter referred to as SROs + +Investigation on 08/29/2019 at New York, New York, United States (In Person) + +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 not to be distributed outside your agency. + +Continuation a FD-302 of ( U ) Interview of a 08/29/2019 ,Page 2 of 3 + +- Ensure inmates are given "what they have coming" + +- "A lot" + +is generally the Monday - Friday 6 a.m. - 2 p.m. shift supervisor. + +\_advised that there is mandatory quarterly training in the SHU program for BOP emnployees. He also reviews 292 Forms which track an inmate's meals, recreation, medical attention, and showers. 292 Forms populate the BOP system, BOPware. Every SHU inmate has an associated 292 Form as long as they're in the SHU population. Once they rotate to another population the form is invalid and no longer exists. Medical personnel visit the SHU twice a day for rounds in the mornings and evenings. regularly audits 292 Forms from the previous day. + +advised that accountability of inmates is important. He never caught anyone intentionally not doing their job. also reviews "round forms" and searches for red flags. These could be missing spaces, missing signatures, etc. /f caught, approaches the individual and requests an explanation. + +the SHU Lieutenant when EPSTEIN was assigned. EPSTEIN wasn't originally in the SHU. advised EPSTEIN was in 10S lower, this population is for inmates not on 10S but high profile. EPSTEIN was assigned to cell 201 in the SHU. During their first encounter, EPSTEIN asked "am I going to get out of here?". remembers EPSTEIN frequenting the attorney conference area for long periods of time. + +advised that at one point during the beginning, at a meeting with MCC executive management, they wanted to house EPSTEIN with a bunkie. doesn't recall exactly who requested this action however he remembers they were trying to identify an inmate. Ultimately, they decided to house EPSTEIN with wasn't asked for his input and followed executive management orders. There was an incident on 07/23/2019 between the two, but it didn't occur oa shift. He heard about it the next day. Lieutenant completed the 583 packet, which included memos and photos resulting from the incident. + +recalls interacting with EPSTEIN on watch. EPSTEIN stated "I don't want to be here" and "I'm not going to hurt myself". fl lso remembers + +Comthwthon of FD-302 of (U) Interview of a 08/29/2019 ,page 3 of 3 + +feeding EPSTEIN. + +The BOP psychologist said that EPSTEIN must be housed with a cell mate when he returned to the SHU. provided cell mate recommendations but they were still deciding on an individual when left the institution that night. makers chose called to ensure that he received a bunkie. BOP decision- + +remembers EPSTEIN requesting to make a phone call to his daughter. doesn't do phone calls because he is unaware of every inmate's restricted contact list. + +informed his direct subordinate that EPSTEIN needed another bunkie. They were short staffed that day. replied with "III, I got it". The next morning he had a bunkie. Inmates receive bunkies when they come off suicide watch. It's common practice in BOP. This is clearly communicated in suicide watch training, it's posted throughout the area, and it's also institutional knowledge. + +EPSTEIN had a bunkie on 08/08/2019. is unaware of anything other than that because he wasn't working. EPSTEIN's bunkie when left work. EPSTEIN was down in an attorney conference as well. communicated the message regarding a bunkie t o didn't speak to anyone else about it because he expected to disseminate it to his subordinates. There were no other emails, or communications, regarding the matter. The message was spread by word of mouth. + +advised that Corrections Officer and Corrections Officer know that inmates on suicide watch are housed with a bunkie. If EPSTEIN were spotted alone in his cell, expects that it would be reported to the shift supervisor. 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Also present during the interview was DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL (DOJ-OIG) Special Agent- -. After being advised of the identities of the interviewing Agents, that the interview was voluntary, and that lying to a federal agent is a crime, provided the following information: + +has worked for the BUREAU OF PRISONS (BOP) since 1994 with one break in service. plans on retiring in approximately 7 months. + +by him. account. confirmed that the email sent from as composed was not aware of anyone else having access to his email + +obtained the name of DOJ-OIG employee from another BOP employee, works in the Community Corrections Department at the METROPOLITAN DETENTION CENTER (MDC) in Brooklyn, New York. sent an email asking for the name of a DOJ-OIG employee he could contact to make the complaint. met while working at the FEDERAL CORRECTIONAL INSTITUTE, DANBURY in Danbury, Connecticut around 2000. + +' current post at the METROPOLITAN CORRECTIONAL CENTER (MCC) is at the rear gate. has worked there for several months. Some of primary responsibilities at the rear gate are to check vehicles making deliveries for any contraband, scan in packages, and to check the gate passes of inmates who have them. has an office at his post but spends most of his time moving around. + +BOP inmate has a gate pass, meaning can enter and exit + +Investigation on 08/28/2019 m 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 nor to be distributed outside your agency. + +Comthwthon of FD-302 of (U) Interview of a 08/28/2019 ,page 2 of 3 + +MCC to complete whatever task is assigned. also helps other inmates with their jobs. Typically leaves through the lobby to the Warden's complex and performs janitorial duties there. started this job approximately three weeks ago. has frequent interactions with because or exits the gate. these interactions. has to check gate pass every time would usually make small talk with enters during + +On or about August 15, 2019, at approximately 10:30am, approached ' post at the rear gate with approximately three large bags of shredded paper. told that "They are shredding everything back there." said there was a white man with a Southern accent who was involved in the document shredding. was unfamiliar with anyone at MCC that fit that description. surmised that since he did not know who the white man with the Southern accent was, he must have been part of the BOP After Action team related to the JEFFREY EPSTEIN suicide. told he heard someone say, "Make sure you get that box over there too." thought he remembered telling him that someone asked to help shred documents as well. did not know for certain where the shredded documents originated from. Shredded documents are thrown out on a fairly regular basis through ' post at the rear gate, but thought that there were more shredded documents than usual during this incident. also told that thought this was more than the usual amount. saw a few days later with additional shredded paper to throw out. + +never witnessed anyone physically shredding documents. never looked through the shredded documents that threw out. No one told that the shredded documents were related to EPSTEIN. No one told that the BOP After Action Team looking into the EPSTEIN suicide was shredding documents. + +is still posted at the rear gate as his primary job. + +called someone at the FBI on or about August 23, 2019 to file a report about this incident. He spoke with a female, but could not remember what office or number he called. + +Continuation of FD-302 of ( 13 ) Interview of .on 08/28/2019 ,Page 3 of 3 + +that EPSTEIN should be confined in the 10 South wing of MCC. \ No newline at end of file diff --git a/marker2/ds9/EFTA00086907/EFTA00086907.metadata.json b/marker2/ds9/EFTA00086907/EFTA00086907.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ee42cc42ba9bedccde37d34b0146fb90d13f73f3 --- /dev/null +++ b/marker2/ds9/EFTA00086907/EFTA00086907.metadata.json @@ -0,0 +1,160 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086907.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3992, + "elapsed_seconds": 0.93, + "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", + 40 + ], + [ + "Text", + 12 + ], + [ + "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", + 86 + ], + [ + "Line", + 42 + ], + [ + "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": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 15 + ], + [ + "Line", + 5 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00086907" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086907/_page_0_Picture_3.jpeg b/marker2/ds9/EFTA00086907/_page_0_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..fa3883c59264e18e6a03164a0f33ffc1d8c99ba7 --- /dev/null +++ b/marker2/ds9/EFTA00086907/_page_0_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:04a9c9d54ce27230a25fde49f474af6e044a6d1040a904c62b32082cbdd4a1a6 +size 4849 diff --git a/marker2/ds9/EFTA00086910/EFTA00086910.md b/marker2/ds9/EFTA00086910/EFTA00086910.md new file mode 100644 index 0000000000000000000000000000000000000000..c1197d33e8938173877520abeb16d66ca6ba5442 --- /dev/null +++ b/marker2/ds9/EFTA00086910/EFTA00086910.md @@ -0,0 +1,33 @@ +## FORDHAM + +University + +Lincoln Center, 150 West 62nd S + +Bruce A. Green Louis Stein Chair + +![](_page_0_Picture_5.jpeg) + +0, 2019 + +Hon. Richard M. Berman U.S. District Court for the Southern District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 + +re: United States v. Epstein. I :19-cr-00490-RMB + +Dear Judge Berman: + +School of Law + +Phone: 2124366851 Fax: 212-636-6899 bgreen@law.fordhain.edu + +![](_page_0_Picture_10.jpeg) + +Yesterday, I was provided a partial transcript of the August 27, 2019 hearing in the abovecaptioned case, and I am writing to clarify the record. + +As you know, I co-authored a New York Law Journal article before the hearing. The transcript quotes the court, in pertinent part, as follows with reference to me and the article: "On a somewhat more serious note, don't quote me on this, but it is my understanding that one of the authors of that article is himself counsel in one of the Epstein-related cases. I was surprised to learn that very recently. I'm certain it is true. I was also surprised that that aspect was not disclosed in the Law Journal." Later in the hearing, attorney David Boies made comments consistent with those of the court. + +Just to clear up the evident misunderstanding: I have never been counsel to Epstein or his estate or to anyone in an Epstein-related case. I did serve as an expert witness, by way of e t declaration, in support of Professor Dershowitz's motion to disqualify Mr. Boies and his law firm i v. Dershowitz, 1:19-cv-03377 (SDNY), a pending defamation case that might be described as "Epsteinrelated." My work as an expert witness, which concluded in June, did not involve my representation of, or advocacy on behalf of, Professor Dershowitz. I did not serve as counsel or as an advocate on anyone's behalf in co-authoring the law journal article. + +Very truly yours, + +Bruce A. Green \ No newline at end of file diff --git a/marker2/ds9/EFTA00086910/EFTA00086910.metadata.json b/marker2/ds9/EFTA00086910/EFTA00086910.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..995190d0e3f8941b4ef696a63eeb6937a1c41889 --- /dev/null +++ b/marker2/ds9/EFTA00086910/EFTA00086910.metadata.json @@ -0,0 +1,97 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086910.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1899, + "elapsed_seconds": 0.99, + "image_assets": [ + "_page_0_Picture_5.jpeg", + "_page_0_Picture_10.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FORDHAM", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 52.63199999999999, + 52.650000000000006 + ], + [ + 161.80874633789062, + 52.650000000000006 + ], + [ + 161.80874633789062, + 74.41876220703125 + ], + [ + 52.63199999999999, + 74.41876220703125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 85 + ], + [ + "Line", + 41 + ], + [ + "Text", + 15 + ], + [ + "Picture", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 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/EFTA00086910" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086910/_page_0_Picture_10.jpeg b/marker2/ds9/EFTA00086910/_page_0_Picture_10.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..22112faf8409c1b3d2f63cdec8385e340c01934a --- /dev/null +++ b/marker2/ds9/EFTA00086910/_page_0_Picture_10.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:09f1121141c42fb381dd75aaf41beddd22bdef4c7abe3a0706eca263ad5f72d2 +size 17712 diff --git a/marker2/ds9/EFTA00086910/_page_0_Picture_5.jpeg b/marker2/ds9/EFTA00086910/_page_0_Picture_5.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..5e6ef8693fbbef4f1316068f2f1b2ba3eb7199b5 --- /dev/null +++ b/marker2/ds9/EFTA00086910/_page_0_Picture_5.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:394dcf9db1f4cc620b5e2d904919d97cae1b1f9cd3b79323e5beef60576e606e +size 22865 diff --git a/marker2/ds9/EFTA00086911/EFTA00086911.md b/marker2/ds9/EFTA00086911/EFTA00086911.md new file mode 100644 index 0000000000000000000000000000000000000000..5d7893dbc0b000e92a3c0d05a700845e4b971f77 --- /dev/null +++ b/marker2/ds9/EFTA00086911/EFTA00086911.md @@ -0,0 +1,31 @@ +UNITED STATES COURTHOUSE + +500 PEARL STREET + +NEW YORK, NEW YORK 10007 + +(212)8084715 + +CHAMBERS OF RICHARD M. BERMAN UNITED STATES DISTRICT JUDGE + +> Bruce A. Green Louis Stein Chair Fordharn University School of Law 150 West 62"d Street Room 7-168 New York City, NY 10023 + +Dear Professor Green, + +![](_page_0_Picture_8.jpeg) + +September 4, 2019 + +Thank you for your letter of August 30, 2019.1 appreciate your taking the time to clarify the record. + +I learned that you had been "retained to provide opinions as an expert on legal ethics" in owing the August 27, 2019 public hearing in US v. Epstein. I learned of your role in theme case by reading your affidavit, dated June 7, 2019, which includes your legal ethics opinion that David Boies should be di ualified from representing Ms. in that matter. As you are aware, both Mr. Boles and Ms. were invited to testify at the August 27, 2019 hearing. + +ain surprised that your advocacy of Mr. Boles' disqualification from representing Ms.. Lirint(in a case obviously related to US v. Epstein) was not disclosed simultaneously with your August 26, 2019 Law Journal opinion piece entitled "The Judge in Epstein's Case Should Not Turn the Dismissal Into a Drama for the Victims." I am also surprised that you would find the August 27, 2019 public hearing to be an inappropriate occasion for transparency in light of Federal Rule of Criminal Procedure 57 and the Crime Victims' Rights Act, 18 U.S.C. § 3771. You wrote: "This is an odd moment for transparency in a criminal case." + +Finally, it is unfortunate that your opinion piece may have been construed as an effort to chill Ms. a and Mr. Boies' right to be heard under 18 U.S.C. § 3771 at the August 27, 2019 public hearing. You wrote: "[W]hatever informational interests the victims may have would be served by affording them a chance to attend the hearing, not by giving them a speaking role." + +Sincerely. + +Richard M. Berman U.S.D.J. + +cc: A ey; Martin G. Weinberg, Esq.; Reid Weingarten, Esq.; David Boies, Esq. \ No newline at end of file diff --git a/marker2/ds9/EFTA00086911/EFTA00086911.metadata.json b/marker2/ds9/EFTA00086911/EFTA00086911.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0d979163210dfb9ed74ab591584af593e6b56601 --- /dev/null +++ b/marker2/ds9/EFTA00086911/EFTA00086911.metadata.json @@ -0,0 +1,153 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086911.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2004, + "elapsed_seconds": 0.9, + "image_assets": [ + "_page_0_Picture_8.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 208.692, + 24.299999999999997 + ], + [ + 401.97998046875, + 24.299999999999997 + ], + [ + 401.97998046875, + 37.11590576171875 + ], + [ + 208.692, + 37.11590576171875 + ] + ] + }, + { + "title": "SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 212.36399999999998, + 36.45 + ], + [ + 396.4984436035156, + 36.45 + ], + [ + 396.4984436035156, + 47.98590087890625 + ], + [ + 212.36399999999998, + 47.98590087890625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 92 + ], + [ + "Line", + 40 + ], + [ + "Text", + 11 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 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": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 13 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 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/EFTA00086911" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086911/_page_0_Picture_8.jpeg b/marker2/ds9/EFTA00086911/_page_0_Picture_8.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..9fd8010ada7e70471de014900e747659620e1cfb --- /dev/null +++ b/marker2/ds9/EFTA00086911/_page_0_Picture_8.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:358fadaa717542da0a05bae7fa068dcb4d628daa3b53cbe141531cb239f1e1de +size 21830 diff --git a/marker2/ds9/EFTA00086913/EFTA00086913.md b/marker2/ds9/EFTA00086913/EFTA00086913.md new file mode 100644 index 0000000000000000000000000000000000000000..709f81418d1591a6d1b7e06165282bd4a3301325 --- /dev/null +++ b/marker2/ds9/EFTA00086913/EFTA00086913.md @@ -0,0 +1,81 @@ +From: ' (USANYS)" To: "-(USANYS Contractor (USANYS) [Contractor " [Contractor]" Cc: ' " (USANYS) + +Subject: FW: Following up re outstanding GM items + +Date: Wed, 23 Dec 2020 01:54:46 +0000 + +Attachments: + +From: ME,IME > + +Sent: Tuesday, December 22, 2020 5:23 PM + +To: ) < >; MB (NY) (F8I)< > + +Cc: < >; (USANYS) > + +Subject: Re: Following up re outstanding GM items + +Pretty sure you have notes but either way here is another copy. + +Detective + +NYPD / FBI + +Child Exploitation Human Trafficking Task Force + +Office: + +Cell: + +Fax: + +From: M, + +Sent:Tuesday, December 22, 2020 5:21 PM + +To: ) (NY) (FBI) < > + +Cc: (USANYS) + +Subject: Re: Following up re outstanding GM 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. + +## Child Exploitation Human Trafficking Task Force + +Office: + +Cell: + +Fax: + +From: + +Sent: Tuesday, December 22, 2020 11:32 AM + +To: =, • (NY) (FBI) ; + +Cc: (USANYS) < + +Subject: Following up re outstanding GM items + +Hi and M, + +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 materials to play; and +- Setting up a call with + +Thanks very much, + +Assistant United States Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00086913/EFTA00086913.metadata.json b/marker2/ds9/EFTA00086913/EFTA00086913.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ad913d9f182f208091601c4f8cf588cf9c3577fb --- /dev/null +++ b/marker2/ds9/EFTA00086913/EFTA00086913.metadata.json @@ -0,0 +1,128 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086913.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2236, + "elapsed_seconds": 1.15, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Child Exploitation Human Trafficking Task Force", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.823999999999998, + 56.7 + ], + [ + 302.0596923828125, + 56.7 + ], + [ + 302.0596923828125, + 69.66 + ], + [ + 31.823999999999998, + 69.66 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 86 + ], + [ + "Line", + 39 + ], + [ + "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 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Line", + 23 + ], + [ + "Text", + 19 + ], + [ + "ListItem", + 4 + ], + [ + "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/EFTA00086913" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086915/EFTA00086915.md b/marker2/ds9/EFTA00086915/EFTA00086915.md new file mode 100644 index 0000000000000000000000000000000000000000..94b3139092cdabf52a205bf109ff792d30113ebe --- /dev/null +++ b/marker2/ds9/EFTA00086915/EFTA00086915.md @@ -0,0 +1,169 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +United States of America, + +—v— + +Ghislaine Maxwell, + +Defendant. + +20-CR-330 (MN) + +OPINION AND ORDER + +ALISON J. NATHAN, District Judge: + +Defendant Ghislaine Maxwell has been indicted by a grand jury on charges of conspiracy to entice minors to travel to engage in illegal sex acts, in violation of 18 U.S.C. § 371; enticing a minor to travel to engage in illegal sex acts, in violation of 18 U.S.C. §§ 2422 and 2; conspiracy to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371; transporting minors to participate in illegal sex acts, in violation of 18 U.S.C. §§ 2423 and 2; and two charges of perjury, in violation of 18 U.S.C. § 1623. The Court held a lengthy bail hearing on July 14, 2020. After extensive briefing and argument at the hearing, the Court concluded that the Defendant was a clear risk of flight and that no conditions or combination of conditions would ensure her appearance. Bail was therefore denied. + +The Defendant has now filed a renewed motion for release on bail pending trial, which the Government opposes. In her renewed motion, the Defendant attempts to respond to the reasons that the Court provided in denying bail and proposes a substantially larger bail package. But by and large, the arguments presented either were made at the initial bail hearing or could have been made then. In any event, the new information provided in the renewed application only solidifies the Court's view that the Defendant plainly poses a risk of flight and that no + +combination of conditions can ensure her appearance. This is so because: the charges, which carry a presumption of detention, are serious and carry lengthy terms of imprisonment if convicted; the evidence proffered by the Government, including multiple corroborating and corroborated witnesses, is strong; the Defendant has substantial resources and foreign ties (including citizenship in a country that does not extradite its citizens); and the Defendant, who lived in hiding and apart from the family to whom she now asserts important ties, has not been fully candid about her financial situation. Thus, for substantially the same reasons that the Court denied the Defendant's first motion for release on July 14, 2020, the Court DENIES the Defendant's renewed motion for release on bail.' + +### I. Background + +On June 29, 2020, a grand jury in the Southern District of New York returned a six-count Indictment against the Defendant, charging her with facilitating Jeffrey Epstein's sexual abuse of multiple minor victims between approximately 1994 and 1997. See Dkt. No. 1. On July 2, 2020, the Indictment was unsealed, and that same day, the Defendant was arrested in New Hampshire. On July 8, 2020, the Government filed a Superseding Indictment, which contained only small ministerial corrections. Dkt. No. 17. + +On July 14, 2020, this Court held a hearing regarding the Defendant's request for bail. After a thorough consideration of all of the Defendant's arguments and of the factors set forth in 18 U.S.C. § 3142(g), the Court concluded that no conditions or combination of conditions could reasonably assure the Defendant's appearance, determining as a result that the Defendant was a flight risk and that detention without bail was warranted under 18 U.S.C. § 3142(e)(1). The + +&#x27; This Opinion & Order will be temporarily sealed in order to allow the parties to propose redactions to sensitive or confidential information. + +Defendant did not appeal the Court's determination that detention was required, and she has been incarcerated at the Metropolitan Detention Center since that time. + +#### IL Legal Standard + +Pretrial detainees have a right to bail under the Eighth Amendment to the United States Constitution, which prohibits the imposition of "[e]xcessive bail," and under the Bail Reform Act, 18 U.S.C. § 3141, et seq. The Bail Reform Act requires the Court to release a defendant "subject to the least restrictive further condition, or combination of conditions, that [it] determines will reasonably assure the appearance of the person as required and the safety of any other person and the community." 18 U.S.C. § 3142(c)(1)(B). Only if, after considering the factors set forth in 18 U.S.C. § 3I42(g), the Court concludes 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," may the Court order that the defendant be held without bail. 18 U.S.C. § 3142(e)(1). + +If there is probable cause to find that the defendant committed an offense specifically enumerated in § 3142(e)(3), a rebuttable presumption arises "that no condition or combination of conditions will reasonably assure" the defendant's appearance or the safety of the community or others. 18 U.S.C. § 3142(e)(3). In such circumstances, "the defendant `bears a limited burden of production . . . to rebut that presumption by coming forward with evidence that he does not pose a danger to the community or 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)); see also United States v. Rodriguez, 950 F.2d 85, 88 (2d Cir. 1991) ("[A] defendant must introduce some evidence contrary to the presumed fact in order to rebut the presumption."). Nonetheless, "'the government retains the ultimate burden of persuasion by clear and convincing evidence that the + +defendant presents a danger to the community,' and `by the lesser standard of a preponderance of the evidence that the defendant presents a risk of flight.'" English, 629 F.3d at 319 (quoting Mercedes, 254 F.3d at 436); see also United States v. Manly., 782 F.2d 1141, 1144 (2d Cir. 1986) ("The government retains the burden of persuasion [in a presumption case]."). Even when "a defendant has met his burden of production," however, "the presumption favoring detention does not disappear entirely, but remains a factor to be considered among those weighed by the district court." United States v. Mattis, 963 F.3d 285, 290-91 (2d Cir. 2020). + +After a court has made an initial determination that no conditions of release can reasonably assure the appearance of the Defendant as required, the Court may reopen the bail hearing if "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 pretrial detention is warranted. 18 U.S.C. § 3142(0. But the Court is not required to reopen the hearing or to conduct another hearing if it determines that any new information would not have a material bearing on the issue. See United States v. Raniere, No. 18-CR-2041 (NGG) (VMS), 2018 WL 6344202, at \*2 n.7 (E.D.N.Y. Dec. 5, 2018) (noting that "[a]s the court has already held one detention hearing, it need not hold another" the standards set forth in 18 U.S.C. § 3142(0(2) are met); United States v. Havens, 487 F. Supp. 2d 335, 339 (W.D.N.Y. 2007) (electing not to reopen a detention hearing because the new information would not have changed the court's decision to detain the defendant until trial). + +### III. Discussion + +The Defendant bases her renewed motion for bail on both 18 U.S.C. § 3142(0 and the Court's inherent powers to review its own bail decisions. See Def. Mot. at 7-9. As already noted, § 3142(0 provides that a bail hearing "may be reopened ... at any time before trial 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 whether there are conditions of release that will reasonably assure the appearance of such person as required and the safety of any other person and the community." A court may also revisit its own decision pursuant to its inherent authority, even where the circumstances do not match § 3142(0's statutory text. See, e.g., United States v. Rowe, No. 02-CR-756 (LMM), 2003 WL 21196846, at \*1 (S.D.N.Y. May 21, 2003) (noting 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. Petrov, No. 15-CR-66 (LTS), 2015 WL 11022886, at \*3 (S.D.N.Y. Mar. 26, 2015) (noting the "Court's inherent authority for reconsideration of the Court's previous bail decision"). + +In line with this, the Defendant's new motion aims to address the reasons that the Court provided when it originally determined that no conditions could reasonably assure her appearance and that pretrial detention was warranted. First, the Defendant proposes a more expansive set of bail conditions that she claims addresses any concerns regarding risk of flight. The newly proposed conditions include a \$28.5 million bail package, which consists of a \$22.5 million personal recognizance bond co-signed by the Defendant and her spouse and secured by approximately \$8 million in property and \$500,000 in cash, along with six additional bonds five co-signed by the Defendant's friends and family members and the sixth posted by the security company that would provide security services to the Defendant if she were granted bail and transferred to home confinement. See Def. Mot. at 2. The proposed conditions also provide that the Defendant would be released to the custody of a family member, who would serve as her third-party custodian under 18 U.S.C. § 3142(c)(1)(B)(i); that she would be placed in home confinement with GPS monitoring and that her travel would be restricted to the Southern and Eastern Districts of New York and would be limited to appearances in Court, meetings with + +counsel, medical visits, and upon approval by the Court or Pretrial Services. hi. at 2-3. + +Furthermore, the Defendant would have on-premises security guards that she would pay for who would prevent her from leaving the residence at any time without prior approval by the Court or Pretrial Services and who would escort her when she is authorized to leave. Id. at 3. + +The motion also presents new information that, according to the Defendant, addresses the concerns that the Court articulated when it determined that detention was warranted. This newly presented information, most of which was available to the Defendant at the time of the initial bail hearing, includes evidence of the Defendant's family ties in the United States, see Def. Mot. at 10-14; a detailed financial report that provides a more comprehensive outlook on the Defendant's financial conditions and assets, see id. at 15-18; evidence that according to her rebuts the Government's original contention that she attempted to evade law enforcement prior to her arrest, see id. at 18-25; waivers of her right to contest extradition from the United Kingdom and France, along with expert opinions claiming that the Defendant would not be able to resist extradition if she were to execute the waivers, see id. at 25-29; and evidence that she argues lays bare the weakness of the Government's case against her, see id. at 30-34. + +Finally, the Defendant argues that the conditions of her confinement, including as a result of the COVID-19 pandemic, present an additional factor favoring release. She claims that the conditions imposed are punitive and that those conditions interfere with her ability to participate in her defense, and she asserts that these factors further militate in favor of release. See id. at 34- 38. + +Having carefully considered all of the Defendant's arguments, the Court again concludes that no conditions or combination of conditions could reasonably assure her appearance and that + +detention without bail is warranted under 18 U.S.C. § 3142(e)(I). The Court accordingly denies Defendant's request to reopen the original bail hearing and denies her renewed motion for bail. + +# A. The presumption in favor of detention applies + +The Court is required to presume that no condition or combination of conditions of pretrial release will reasonably assure the Defendant's appearance. The Bail Reform Act provides that if a defendant is charged with committing an offense involving a minor victim under 18 U.S.C. §§ 2422 or 2423, "it shall be presumed that no condition or combination of conditions will reasonably assure the appearance of the person as required and the safety of the community if the judicial officer finds that there is probable cause to believe that the person committed." 18 U.S.C. § 3142(e)(3)(E). The Defendant's indictment by a grand jury suffices to establish that there is probable cause to believe that she committed the offenses charged in the indictment. See, e.g., United States v. Contreras, 776 F.2d 51, 53-54 (2d Cir. 1985) (noting that that an indictment returned by a properly constituted grand jury "conclusively determines the existence of probable cause" and that "the return of an indictment eliminates the need for a preliminary examination at which a probable cause finding is made by a judicial officer pursuant to Rule 5(c) of the Federal Rules of Criminal Procedure." (citations omitted)). In light of the crimes charged in the indictment, the Court begins with the presumption that no condition or combination of conditions of pretrial release will reasonably assure the Defendant's appearance. + +When the presumption applies, the Defendant bears a limited burden of production "tending to counter the § 3142(e) presumption of flight," Contreras, 776 F.2d at 53 n.1. The Defendant's burden of production only requires that she "introduce a certain amount of evidence contrary to the presumed fact." United States v. Jessup, 757 F.2d 378, 380 (1st Cir. 1985), + +abrogated on other grounds by United States v. O'Brien, 895 F.2d 810 (1st Cir. 1990). That burden is "limited." United States v. Mercedes, 254 F.3d 433, 436 (2d Cir. 2001). The Defendant's proffer of evidence and information—including information relating to her financial conditions and her family ties to the United States, among other things-satisfies this limited burden. As the Court discussed at the July 14, 2020 hearing, these factors bear on the question of whether the Defendant poses a flight risk. And the evidence she advances in her renewed motion for bail reasonably disputes the presumption that she poses a flight risk. In that sense, this evidence is relevant to the ultimate determination and satisfies the relatively low threshold imposed by the burden of production. + +The presumption of flight does not disappear entirely, however, and it "remains a factor to be considered among those weighed by the district court." United States v. Mercedes, 254 F.3d 433, 436 (2d Cir. 2001) (quoting Martir, 782 F.2d at 1144). As a result, "[a] judicial officer conducting a detention hearing should, even after a defendant has come forward with rebuttal evidence, continue to give the presumption of flight some weight by keeping in mind that Congress has found that these offenders pose special risks of flight, and that `a strong probability arises' that no form of conditional release will be adequate to secure their appearance." Martir, 782 F.2d at 1144 (citation omitted). + +# B. The new information does not alter the Court's initial determination + +When determining whether there are conditions of release that will reasonably assure the appearance of the person as required, courts are required to consider the factors outlined in 18 U.S.C. § 3142(g). Thus, the Court considers (1) the nature and circumstances of the offense charged, including whether the offense involves a minor victim, (2) the weight of the evidence, (3) the defendant's history and characteristics, and (4) the nature and seriousness of the danger to any person or the community posed by pre-trial release. See Mercedes, 254 F.3d at 436; see also 18 U.S.C. § 3142(g). + +At the July 14, 2020 bail hearing, the Court considered these factors before concluding that no conditions of release could reasonably assure the appearance of the person as required. And the first and fourth factors remain unchanged. As already noted, the Defendant is charged with offenses involving minor victims, and it is undisputed that the nature and circumstances of the offenses charged in the Superseding Indictment weighs in favor of continued detention. On the other hand, the Government has not advanced any evidence that the Defendant poses a danger to any person or to the community, a factor that weighs against detention. The Defendant's arguments therefore focus on the second and third factors. + +As explained below, neither the arguments put forth in the Defendant's renewed motion for bail nor the evidence she submitted in conjunction with her motion rebut the Court's conclusions, and the Court continues to find, after again applying these factors, that no conditions of release will reasonably assure the Defendant's appearance at future proceedings. + +# 1. The Weight of the Evidence + +The Court will address the strength of the Government's case first. The Defendant argues that the Government lacks any meaningful documentary corroboration of the witness testimony and that the discovery produced to date has included only a "small number of documents from the time period of the conspiracy." Def. Mot. at 5. And she claims, as a result, that the Government overstated the strength of its case in advance of the July 14, 2020 bail hearing. See id. at 30-33. So she argues that the second § 3142(g) factor supports release. + +The Court disagrees. Arguing that the case against her "is based almost exclusively on the recollections of the three accusers, who remain unidentified," the Defendant contends that the weight of the evidence is weak. Def. Reply at 2. But she too easily discredits the witness testimony. According to the Government, and as reflected in the indictment, it 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 Gov't Opp'n at 10; see also Dkt. No. 17, SI Superseding Indictment, ¶¶ 7, II, 13, 17. Moreover, the Government proffers that additional evidence, including flight records and other witnesses' corroborating testimony, will further support the main witnesses' testimony and link the Defendant to Epstein's conduct. Gov't Opp'n at 10-11. And while the Defendant contends that much of this evidence focuses on Epstein, not the Defendant, the nature of the conspiracy charge (along with the evidence linking the Defendant to Epstein) renders this evidence relevant to the Government's charges against her. As the Court stated in the July 14,2020 hearing, although the Court does not prejudge the merits of the Government's case or of the Defendant's defenses, for purposes of the bail determination stage, the Government's proffered case against the Defendant remains strong. See Dkt. No. 93 ("Tr.") at 83:4-83:10. The Court again concludes that the Defendant's awareness of the potential strength of the government's case against her creates a risk of flight, and none of the Defendant's new arguments meaningfully alter that conclusion. As a result, the second factor supports detention. + +# 2. The Defendant's History and Characteristics + +At the July 14,2020 bail hearing, the Court determined that the Defendant was a flight risk in part because of her substantial international ties, including multiple foreign citizenships and familial and personal connections abroad and her ownership of at least one foreign property of significant value. See Tr. at 83:13-83:18. And the Court further noted that the Defendant's extraordinary financial resources could provide her the means to flee the country even despite + +COVID-I9 related travel restrictions. Id. at 83:21-83:25. The Court also observed that the Defendant had family and personal connections to the United States but concluded that the absence of any dependents, significant family ties, or employment in the United States also supported the conclusion that flight would not pose an insurmountable burden for her. Id. at 84:4-84:9. While the Defendant's renewed motion for bail addresses some of these factors, it does not alter the Court's conclusion. + +The first few considerations remain relatively unchanged. The Defendant continues to have substantial international ties and multiple foreign citizenships, and she continues to have familial and personal connections abroad. None of the evidence presented in support of the present motion fundamentally alters those conclusions. To address the Court's concern that the Defendant's French citizenship presented the opportunity that she could flee to France and that she would be able to resist extradition on that basis, see Tr. at 83:1843:20, the Defendant now offers to waive her right to extradition from both the United Kingdom and France, along with expert opinions reports claiming that such waivers would likely make it possible to resist an extradition request from the United States to either country. See Def. Mot., Exs. T, U, V. As the Government points out in its brief, however, the legal weight of the waivers is, at best, contested. The French Ministry of Justice, for instance, indicated in a letter submitted in conjunction to the Government's opposition that the French Code of Criminal Procedure "absolutely prohibits" the extradition of a French national. See Gov't Opp'n, Ex. B. And while the Defendant's own expert attempts to rebut the Ministry of Justice's letter, see Def. Reply, Ex. A, even the Defendant's own experts use probabilistic, rather than absolute, language, leaving open the possibility that extradition would be blocked. See, e.g., Def. Mot., Ex. U at 2 ("On the basis of the information currently known, it is highly unlikely that Ghislaine Maxwell would be able + +successfully to resist extradition to the United States in relation to the charges in the superseding indictment dated 7 July 2020."); Def. Mot., Ex. V ¶ 76 ("It would ... become a matter for the French government to decide on whether or not to issue an extradition decree against Ms. Ghislaine Maxwell."); id. ¶ 77 ("[I]t is highly unlikely that the French government would refuse to issue and execute an extradition decree against Ms Maxwell. . . ."). Nor has the Defendant presented any cases where courts addressed the question of whether an anticipatory waiver of extradition is enforceable; while she cites cases where defendants offered to waive extradition, the reasoning in those cases turned on other factors and the courts did not dwell on the enforceability of such waivers. See, e.g., United States v. Cirillo, No. 99-1514, 1999 WL 1456536, at \*2 (3d Cir. July 13, 1999); United States v. Salvagno, 314 F. Supp. 2d 115, 119 (N.D.N.Y. 2004); United States v. Karni, 298 F. Supp. 2d 129, 132-33 (D.D.C. 2004); United States v. Chen, 820 F. Supp. 1205, 1212 (N.D. Cal. 1992). In those cases, the courts included such waivers as one among several conditions of release, but they did not make any express determination that such waivers are enforceable. On the other hand, some courts have expressly opined that such waivers are unenforceable. See, e.g., United States v. Epstein, 425 F. Supp. 3d 306, 325 (S.D.N.Y. 2019) (describing the "Defense proposal to give advance consent to extradition and waiver of extradition rights" as "an empty gesture."); United States v. Morrison, No. 16-MR-118, 2016 WL 7421924, at \*4 (W.D.N.Y. Dec. 23, 2016) ("Although the defendants have signed a waiver of extradition, such a waiver may not become valid until an extradition request is pending in Canada and may be subject to withdrawal."); United States v. Stroh, No. 396-CR-139 (AHN), 2000 WL 1832956, at \*5 (D. Conn. Nov. 3, 2000) ("[I]t appears that there is a substantial legal question as to whether any country to which he fled would enforce any waiver of extradition signed under the circumstances presented in this case. At any event, + +extradition from Israel (or any other country) would be, at best, a difficult and lengthy process and, at worst, impossible."). + +Having carefully reviewed the experts' reports and the cases cited by the Defendant,2 the Court's analysis of the relationship between the Defendant's French citizenship and the risk of flight remains fundamentally unchanged. Its reasoning is guided in part by the substantial legal questions regarding the legal weight of anticipatory extradition waivers and the likelihood that any extradition would be a difficult and lengthy process (including, for instance, the likelihood that the Defendant would contest the validity of those waivers and the duration it would take to resolve those legal disputes). The likelihood that the Defendant would be able to frustrate any extradition requests—even if she were correct that she would be unable to stop extradition entirely—weighs strongly in favor of detention. + +In addition, the Defendant's extraordinary financial resources also continue to provide her the means to flee the country and to do so undetected. To be sure, this factor alone does not by itself justify continued detention. But as the Court noted at the initial bail hearing, the Defendant's financial resources, in combination with her substantial international ties and foreign connections and her experience avoiding detection (whether from the government, the press, or otherwise), do bear significantly on the flight risk analysis. See Tr. at 88:6-88:23 (distinguishing this case from United States v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018), + +2 The Defendant also argues that "a defendant's waiver of the right to appeal an extradition order has been recognized as an indication of the defendant's intent not to flee." Def. Mot. at 27 (citing United States v. Khashoggi, 717 F. Supp. 1048, 1052 (S.D.N.Y. 1989)). The Court places little weight on this argument. Under the Defendant's theory, a defendant could strategically offer to waive the right to extradition while intending to resist any subsequent extradition that might result. The Court is unpersuaded. + +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)). + +The Court's concerns regarding the absence of any dependents, significant family ties, or employment in the United States, meanwhile, apply with somewhat less force in light of the evidence submitted in support of this motion. See id. at 84:4-84:9. The Defendant has submitted a litany of letters of support written by friends and family members. See Def. Mot., Exs. A—N, W—X. These letters, according to the Defendant, support her claim that she has significant ties to the United States and attest to the Defendant's character. The Defendant places particular emphasis on the letter written by her spouse, whose identity and connection to the Defendant was withheld from the Court at the initial bail hearing. See Def. Mot. at 11-13. In that letter, her spouse expounds on the lives they led before her arrest, noting in particular that the Government's characterization of the Defendant's "transient" lifestyle, Dkt. No. 4 at 9, was belied by the "quiet family life" that they had enjoyed. Def. Mot. at 11; see also Def. Mot, Ex. A 4-5. Other letters similarly highlight that the Defendant's family and affective ties in the United States are stronger than was originally presented to the Court in the initial bail hearing. + +These letters substantiate the Defendant's claim that she has important ties to people in the United States, but they leave unaltered the Court's conclusion that flight would not pose an insurmountable burden for the Defendant. Among other things, the Defendant now argues that her newly revealed relationship with her spouse signals her deep affective ties in the country, but at the time she was arrested, she was not living with him and claimed to be getting divorced. See Pretrial Services Report at 3. Indeed, she does not propose to live with him were she to be released on bail, undercutting her argument that that relationship would create an insurmountable burden to her fleeing. Furthermore, the fact that she has friends and family in the United States + +does not mean that those people would be unable to visit her were she to flee to another country. In addition, the Defendant continues to lack any employment ties to the United States—another factor weighing in favor of detention. Furthermore, it is apparent from the letters that the Defendant has significant ties to family and friends abroad. In light of this, nothing in the renewed motion for bail alters the Court's fundamental conclusion that flight would not pose an insurmountable burden to the Defendant. + +Other factors that similarly speak to the Defendant's history and characteristics weigh in favor of detention. Most notably, the Defendant's pattern of providing incomplete or erroneous information to the Court or to Pretrial Services bears significantly on the Court's application of the third factor to the present case. Among other things, in July 2020 the Defendant represented to Pretrial Services that she possessed around \$3.5 million worth of assets (while leaving out her spouse's assets and assets that had been transferred to trust accounts) and the representation that the New Hampshire property was owned by a corporation and that she was "just able to stay there." See Pretrial Services Report at 2. The Defendant now claims that she "was detained at the time and had no access to her financial records and was trying to piece together these numbers from memory. According to the Macalvins report, [the financial figures] are a close approximation of the value of the assets that Ms. Maxwell held in her own name at the time of her arrest.... For the reasons already discussed, Ms. Maxwell was reluctant to discuss anything about her [spouse] and expressed that to Pretrial Services." Def. Mot. at 16 n.5. Even if the Defendant was unable to provide an exact number, however, the difference between the number she originally reported to Pretrial Services and the number now presented to the Court in the Macalvins report, a report on the Defendant's finances prepared by a prominent accounting firm for purposes of this motion, see Def. Mot., Ex. O, makes it unlikely that the misrepresentation + +was the result of the Defendant's misestimation rather than misdirection. And while the Defendant's concerns regarding her spouse's privacy are not insignificant, she fails to furnish any explanation as to why those concerns led her to misrepresent key facts to Pretrial Services and, by extension, the Court. In sum, the evidence of a lack of candor is, if anything, stronger now than in July 2020, as it is clear to the Court that the Defendant's representations to Pretrial Services were woefully incomplete. That lack of candor raises significant concerns as to whether the Court has now been provided a full and accurate picture of her finances and as to the Defendant's willingness to abide by any set of conditions of release. + +For the reasons stated above, the Court concludes that the third factor continues to weigh in favor of detention. + +# C. Pretrial detention continues to be warranted + +In light of the reasons stated above, the Government has again met its burden of persuasion by "a preponderance of the evidence that the defendant presents a risk of flight." English, 629 F.3d at 319 (quoting Mercedes, 254 F.3d at 436). Taking the § 3142(g) factors into account, the Court concludes that the presumption in favor of detention, the nature and characteristics of the charged offenses, the weight of the evidence, and the history and characteristics of the Defendant all weigh in favor of detention. Along similar lines, the Government has also shown, and the Court concludes for the reasons outlined below, that the Defendant's proposed bail package cannot reasonably assure her appearance. Thus, the Court's original conclusion that the Defendant poses a flight risk and that no set of conditions can reasonably assure her future appearance remains unaltered. + +As already noted, the Defendant now proposes a \$28.5 million bail package, which includes a \$22.5 million personal recognizance bond co-signed by the Defendant and her spouse and secured by approximately \$8 million in property and \$500,000 in cash, along with six additional bonds—five co-signed by the Defendant's friends and family members and the sixth posted by the security company that would provide security services to the Defendant if she were granted bail and transferred to home confinement. See Def. Mot. at 2. At the initial hearing, the Court noted that the opaqueness of the Defendant's finances rendered it difficult to set financial bail conditions that could reasonably assure her appearance in court. The financial information that the Defendant presented to the Court at the initial bail hearing was undisputedly incomplete, and as the Court noted, the Court lacked "a clear picture of Ms. Maxwell's finances and the resources available to her." Tr. at 86-87. + +The Defendant has now presented to the Court what is perhaps a more thorough report on her finances prepared by Macalvins, an accounting firm in the United Kingdom. Macalvins analyzed the Defendant's assets and finances for the past five years, basing its analysis on, among other things, bank statements, tax returns, and FBAR filings, providing a summary of the assets held by the Defendant and her spouse as well as the assets held in trust for the benefit of the Defendant for the period stemming from 2015 to 2020. See Def. Mot., Ex. O. In addition, the Defendant retained a Certified Fraud Examiner and a former IRS Special Agent, who reviewed the Macalvins report and the underlying documents and determined that report accurately represents the assets held by the Defendant and her spouse. See Def. Mot., Ex. P. The Defendant's new bail proposal is based on the numbers derived from the Macalvins report. + +But even assuming that the financial report provides an accurate analysis of the Defendant's finances, the Court is unpersuaded by her argument that the bail package reasonably assures her appearance. As the Government argues, the bail package would leave unrestrained + +millions of dollars and other assets that she could sell in order to support herself. See Gov't Opp'n at 23. Furthermore, the proposed bond is only partially secured. Taking into account the vast amounts of wealth left relatively unrestrained by the bail package, that amount, standing alone, cannot reasonably assure that she would appear before the Court. Nor is the Court's conclusion altered by the fact that a number of third parties have pledged to support her bond; the amount of wealth that she would retain were she to flee, in addition to contingent assets and future income streams that are not accounted for in the bail package, would plausibly enable her to compensate them, in part or in full, for their losses. And while the Defendant argues that she has procured "significant loans on the basis of a negative pledge" over a property and that \$4 million is invested in an "illiquid hedge fund that could only be liquidated with considerable difficulty," see Def. Reply at 6, these arguments do not alter the Court's ultimate conclusion that the financial package does not meaningfully mitigate the possibility of flight. + +The proposed conditions also provide that the Defendant would be released to the custody of a family member, who would serve as the Defendant's third-party custodian under 18 U.S.C. § 3142(c)(1)(3)(i); that the Defendant would be placed in home confinement with GPS monitoring and that her travel would be restricted to the Southern and Eastern Districts of New York and would be limited to appearances in Court, meetings with counsel, medical visits, and upon approval by the Court or Pretrial Services; that she would be under the strict supervision of Pretrial Services; and that she would surrender all travel documents. Id. at 2-3. Furthermore, the Defendant would have on-premises security guards who would prevent her from leaving the residence at any time without prior approval by the Court or Pretrial Services and who would escort her when she is authorized to leave. Id. at 3. + +None of these conditions would reasonably assure the Defendant's appearance. Here, too, the Court's original determination applies with equal force. As the Court noted at the original hearing, the Defendant has demonstrated an extraordinary capacity to evade detection, "[e)ven in the face of what the Defense has acknowledged to be extreme and unusual efforts to locate her." Tr. at 87:4-87:19. Indeed, regardless of whether the Defendant sought to evade the press, rather than law enforcement, in the months leading up to her arrest, her sophistication in evading detection reveals the futility of relying on any conditions, including GPS monitoring, restrictive home confinement, and private security guards, to secure her appearance. See Tr. at 87:4-88:2. As other courts have observed, "home detention with electronic monitoring does not prevent flight; at best, it limits a fleeing defendant's head start." United States v. Zarger, No. 00- CR-773-S-1 (JG), 2000 WL 1134364, at \*I (E.D.N.Y. Aug. 4, 2000). Furthermore, while the Defendant now represents that she would be released to the custody of a family member, who would serve as the Defendant's third-party custodian under 18 U.S.C. § 3142(c)(1)(B)(i), and that she secured a residence in the Eastern District of New York, see Def. Mot. at 3, that does not outweigh the other significant factors weighing in favor of detention. And finally, the Defendant's argument that private security guards could ensure her appearance at future proceedings runs afoul of the Bail Reform Act, which the Second Circuit has held "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." United States v. Boustani, 932 F.3d 79, 82 (2d Cir. 2019). As in Boustani, the Defendant in the present case would be detained regardless of her wealth, and "if a similarly situated defendant of lesser means would be detained, a wealthy defendant cannot avoid detention by relying on his personal funds to pay for private detention." Id. + +In light of the above, the Court again concludes that the Government has shown by a preponderance of the evidence that the defendant presents a risk of flight and that the Defendant's proposed conditions are insufficient to reasonably assure her appearance. The presumption in favor of detention, the weight of the evidence, and the history and characteristics of the Defendant all support that conclusion, and none of Defendant's new arguments change the Court's original determination. + +#### D. The Defendant's conditions of confinement do not justify release + +Lastly, the Court is unpersuaded by the Defendant's argument that the conditions of her confinement are uniquely onerous, interfere with her ability to participate in her defense, and thus justify release. See Def. Mot. at 35-38. Indeed, the Defendant does not meaningfully dispute that she has received "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." Gov't Opp'n at 29. To the extent that the Defendant has concerns regarding some of the measures taken by BOP, including a recent lockdown due to COVID-19 that curtailed in-person legal visitations, the Defendant provides no authority to conclude that this, standing alone, violates her constitutional right to participate in her defense. And while the Court acknowledges the Defendant's concerns regarding the conditions of her confinement, the Defendant has failed to provide any basis to conclude that release is warranted on those grounds—even after the Court has determined that she continues to pose a flight risk.3 + +3 The Court will continue to ensure that the Defendant has the ability to speak and meet regularly with her attorneys and to review all necessary discovery materials to prepare for her defense. Defense counsel shall confer with the Government on any specific requests. To the extent they are not reasonably accommodated, an application may be made to the Court. + +Finally, as the Court expressed at the initial bail hearing, it has deep concerns about the spread of COVID-19 at BOP facilities, including at the MDC. Indeed, in recent weeks, the incidence of COVID-19 among the inmate population where the Defendant is housed is truly alarming. See COVID-19: Coronavirus, Fed. Bureau of Prisons, https://www.bop.gov/ coronavirus/ (last visited Dec. 28, 2020) (noting that the MDC currently has 99 inmates and 11 staff members who have tested positive for COVID-19). It could be argued that in the face of this, only those defendants who pose a danger to the community ought to be detained pending trial. If that were the law and in light of the increasing positivity rate, the Court would not hesitate to reopen the detention hearing and release the Defendant on bail since the Government rests none of its arguments on dangerousness. But that is not the law. Moreover, as the Court found at the initial bail hearing, the Defendant has no underlying health conditions that put her at heightened risk of health impacts were she to contract COVID. The pandemic, including increasing positivity numbers in the MDC, is not a basis for release in this case where the Court finds that the Defendant poses a substantial and actual risk of flight and that no combination of conditions could reasonably assure her appearance. + +### E A hearing is unnecessary + +Having carefully reviewed the parties' arguments, the Court determines that a hearing is unnecessary and that it can resolve the motion on the papers. The briefing from both sides comprehensively lays out the parties' respective arguments For the reasons stated above, none of the new information has a material bearing on the Court's determination that the Defendant poses a flight risk. Indeed, many of the reasons that the Court provided at the July 14, 2020 hearing continue to apply with equal, if not greater, force. The Court need not hold another + +hearing to evaluate Maxwell's motion, and it declines to do so. *See United States v. Raniere*, No. + +18-CR-2041 (NGG) (VMS), 2018 WL 6344202, at \*2 n.7 (E.D.N.Y. Dec. 5, 2018). + +**IV. Conclusion** + +Defendant Ghislaine Maxwell's renewed motion for release on bail, Dkt. No. 97, is + +DENIED. + +SO ORDERED. + +Dated: December 28, 2020 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00086915/EFTA00086915.metadata.json b/marker2/ds9/EFTA00086915/EFTA00086915.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..be4028f74de8bce6e59a0acb04e3b973d265ebd9 --- /dev/null +++ b/marker2/ds9/EFTA00086915/EFTA00086915.metadata.json @@ -0,0 +1,1025 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086915.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 22, + "chars": 42787, + "elapsed_seconds": 4.71, + "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": "I. 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b/marker2/ds9/EFTA00086937/EFTA00086937.md @@ -0,0 +1,464 @@ +From: ' yt To: ' .111r)a.r>alSANYS)" )" Cc: ' (CRM)" czi + +Subject: RE: SDNY case + +Date: Wed, 30 Dec 2020 10:46:21 +0000 + +Dea + +I heard you defeated the bail proposal. Congrats! + +My meeting with the Paris Prosecutor's Office was pushed by a day, and is now set for January 7th. Can we pick a time for a call between now and then? Would Tuesday the 5th in the am (NY time) work for everyone? + +In the meantime, I am referring the French MLAT request to your IC ). I don't know if you have any privilege issues in your case...and I don't see anything in the request that would revealed any privileged info. But I wanted to mention, in case anyone needs to screen it before it comes to you. If not, I can send it to you directly as well. + +DOJ Attache/Magistrat de liaison anthicain + +U.S. Embassy, Paris + +From: + +Sent: Sunday, December 20, 2020 6:03 PM + +To: (USANYS) (CRM) + +Cc: + +(CRM) < + +Subject: RE: SDNY case + +Hi all, + +Maxwell's attorneys filed the attached supplemental report from their French expert in connection with their reply brief. If the judge orders a hearing, which we think is likely, we'd like to be prepared to address this report during oral argument. If you are able to provide any guidance regarding how best to respond to the report, we would be very grateful. + +Thanks very much, + +--- + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Wednesday, December 16, 2020 2:46 PM +**To:** [REDACTED] (CRM) <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] (CRM) <[REDACTED]> +**Subject:** RE: SDNY case + +Thanks very much, [REDACTED]. We really appreciate your help. + +On Dec 16, 2020, at 11:28 AM, [REDACTED] (CRM) <[REDACTED]> wrote: + +Spoke with our litigation supervisor. It's probably fine to say OIA is unaware of any such country, so long as you're OK with the fact that we haven't surveyed every country on this, so theoretically it's a disprovable statement. Thanks again. + +--- + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Wednesday, December 16, 2020 10:36 AM +**To:** [REDACTED] (CRM) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] (CRM) <[REDACTED]> +**Subject:** RE: SDNY case + +Thanks, [REDACTED]. + +--- + +**From:** [REDACTED] (CRM) <[REDACTED]> +**Sent:** Tuesday, December 15, 2020 10:27 PM +**To:** [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] (CRM) <[REDACTED]> +**Subject:** RE: SDNY case + +Hi, [REDACTED]. + +I imagine the document [REDACTED] sent is our Jan. 2018 memo about anticipatory waivers (attached). I see the line to which you're referring – "OIA is unaware of any country that would consider a prospective extradition waiver binding in its extradition proceedings." I'll ask my supervisor, who heads our litigation group, if he's still comfortable with this sentence, but my sense is that in this case, the specific rebuttal information we have concerning the UK/France is more significant. + +Thanks, +[REDACTED] + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Tuesday, December 15, 2020 8:54 PM +**To:** [REDACTED] (CRM) <[REDACTED]>; [REDACTED] +<[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] +<[REDACTED]> +**Cc:** [REDACTED] (CRM) <[REDACTED]> +**Subject:** RE: SDNY case + +Thanks very much, [REDACTED]. To answer the question raised by [REDACTED] the line that you suggested striking is from a document on advance waivers that [REDACTED] sent us (the document is titled "Anticipatory Waivers Of Extradition In U.S. Prosecutions As A Factor Under The Bail Reform Act"). Our colleagues have also included this line in bail-related filings addressing this issue. We were planning to include but, of course, happy to discuss. Thank you both again. + +**From:** [REDACTED] (CRM) <[REDACTED]> +**Sent:** Tuesday, December 15, 2020 7:17 PM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] (USANYS) +<[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] +<[REDACTED]> +**Cc:** [REDACTED] (CRM) <[REDACTED]> +**Subject:** RE: SDNY case + +Thanks very much, all. + +Building on [REDACTED] thoughts, I've added a bit (not much). + +Thanks again, + +[REDACTED] +**From:** [REDACTED] <[REDACTED]> +**Sent:** Tuesday, December 15, 2020 4:30 PM +**To:** [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]> +**Cc:** [REDACTED] (CRM) <[REDACTED]>; [REDACTED] (CRM) <[REDACTED]> +[REDACTED] +**Subject:** RE: SDNY case + +[REDACTED]: + +Thanks for sharing. I made a few comments in the margins, capturing my thoughts. + +[REDACTED] + +[REDACTED] +DOJ Attaché/Magistrat de liaison américain +U.S. Embassy, Paris + +[REDACTED] +[REDACTED] +[REDACTED] + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Tuesday, December 15, 2020 5:10 PM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] +<[REDACTED]>; [REDACTED] <[REDACTED]> + +Subject: RE: SDNY case + +Attached is the portion of the current draft related to extradition. If there is anything we should discuss or that seems inaccurate in any way, please let us know. Thanks again for your help. + +Best, + +From: + +Sent: Monday, December 14, 2020 4:40 PM + +To: (USANYS) c + +Cc: (CRM) < (CRM) + +> + +Subject: RE: SDNY case + +State is okay with references to open sources concerning the Peterson Case. + +State responded that they are not aware of previous extraditions of French nationals, though they could not perform a full database check since they are teleworking and a check requires them to be in the office. + +and I just reviewed our OIA database (which goes back into the 1980s) and have found no evidence that we have ever extradited a French person from France. I can't speak to what may have occurred in the 1970s and earlier (though, obviously think it's unlikely to hove happened then either). + +Would it be possible to send us the text of the portion of your response pertaining to France, so we can share with State before its gets filed? + +DOJ Attache/Magistrat de liaison anthicain + +U.S. Embassy, Paris + +From: (USANYS) + +Sent: Monday, December 14, 2020 2:23 AM + +To: + +Thanks again for your help. An additional question - Is the following accurate: Indeed, the Government is unaware of any instance in which France has extradited a French citizen to the United States. + +Thanks, + +From: (USANYS) + +Sent: Saturday, December 12, 2020 12:53 PM + +To: + +Cc: (CRM) < (CRM) + +Subject: RE: SDNY case + +Thanks so much, We really appreciate you getting us this letter today. We will get the letter translated. We wanted to confirm that there is no issue with us referencing the open source articles regarding Peterson. If so, I don't think we need to ask the State Department for the declaration. I'm at if there is anything you would like to discuss. Thank you again for your help. + +From: + +Sent: Saturday, December 12, 2020 9:57 AM + +To: (USANYS) + + + +Cc: (CRM) < >; (CRM) <=I + +Subject: RE: SDNY case + +Dear, and + +Please find attached the letter from French MOJ I received last night. + +I think it's worth getting into translation and including in your response. + +The letter states in strong terms that France does not extradite its nationals outside the EU (regardless of the existence of double-citizenship), including to the United States, and has never derogated from that principal outside the EU. + +They did not touch on the issue of the validity of an advanced waiver as I had asked; but that is arguably unnecessary in light of the above statement. + +The State Department remains willing to draft a declaration for your use; it would essentially say the same thing, that France does not extradite its nationals, and it may reference the Peterson case...but may add that we do not request extradition of French nationals because we know they will say no (or, words to that effect). I don't know if that is still necessary in light of the attached. If you think it's still useful, we ask them to do it; but if you don't think it adds value, I'd just as soon spare them the effort. + +[REDACTED] +[REDACTED] +[REDACTED] + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Friday, December 11, 2020 4:55 PM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] (CRM) +<[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] +<[REDACTED]> +**Subject:** RE: SDNY case + +Thanks very much, [REDACTED] + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Friday, December 11, 2020 3:24 AM +**To:** [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] (CRM) <[REDACTED]>; +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: SDNY case + +Hi [REDACTED]: + +For MOJ, I will write to check in on where they are. The initial response was positive, but I have not seen a letter yet. I will advise that we'd really like it by COB Monday (Paris time). + +For State, we had an email exchange yesterday. They do not seem inclined to support including the French MFA letter from the Peterson case; however, they are proposing instead to provide a declaration for your use as a supporting attachment. I think this could be very effective, but I've asked what specifically they would be willing to say...and we're waiting to hear back. -[REDACTED] + +[REDACTED] +DOJ Attaché/Magistrat de liaison américain +U.S. Embassy, Paris +[REDACTED] +[REDACTED] +[REDACTED] + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Friday, December 11, 2020 12:37 AM +**To:** [REDACTED] (CRM) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]> +**Subject:** RE: SDNY case + +Thank you both for speaking yesterday. Our apologies for the bother, but we wanted to follow up on our conversation in light of our quickly approaching deadline. In particular, we were wondering if MOJ will be providing a letter and if so, your understanding of what will be in that letter. We were also wondering if you have any update from State about its position on us discussing particular cases (or open source material at a minimum). Thanks very much for your assistance – we really appreciate it. + +Best, +[REDACTED] + +Sent: Wednesday, December 09, 202012:30 PM + +To: < + +Cc: (USANYS) '4= > + +Subject: RE: SDNY case + +Hi, all. + +Just FYI, here's the anticipatory waiver of extradition I mentioned from United States v. Uuberes, No. 20-cr-493 (VSB), which the defendant appears to have executed after his bail hearing this past October , at the court's direction. Not ideal, but it happened. + +Thanks, + +From: + +Sent: Wednesday, December 9, 2020 9:04 AM + +To: > + +Cc: (CRM) < (USANYS) + +Subject: RE: SDNY case + +Thanks very much. We are all available at 12pm ET if that would work for you. Or if that's too late, I'd propose 11am Ell + +We can use the below dial-in: + +Dial-in: 844-215-6902 + +Code: 707522 + +Thanks, + +Assistant United States Attorney Southern District of New York I St. Plaza New York, NY 10007 + +From: + +Sent: Wednesday, December 9, 2020 8:39 AM + +To: + +Cc: (CRM) (USANYS) + +Subject: RE: SDNY case + +Sounds good, thanks. + +DOJ Attache/Magistrat de liaison anthicain U.S. Embassy, Paris + +From: + +Sent: Wednesday, December 9, 2020 2:38 PM + +To: + +Cc: (CRM) (USANYS) + +Subject: RE: SONY case + +Thanks No opposition to sending these two documents to MOJ. They are not being filed under seal and will end up on the public docket. + +Yes, we're in touch with regarding the UK side of this. + +I'm checking with and regarding their availability for a call today and will get back to you with a proposed time as soon as I can. + +Assistant United States Attorney + +Southern District of New York + +l St. Plaza + +New York, NY 10007 + +From: + +Sent: Wednesday, December 9, 2020 3:18 AM + +To: + +Cc: (CRM) (USANYS) + +Subject: RE: SDNY case + +Importance: High + +Thanks for sharing. I can be free today after 10:15am. + +I need to send this report to MOJ urgently in order to get a letter back in time. I assume there is no opposition to that we are unlikely to get an MOJ letter otherwise. + +Are you guys in touch with my colleagues who cover the UK? + +DOJ Attache/Magistrat de liaison anthicain + +U.S. Embassy, Paris + +From: + +Sent: Wednesday, December 9, 2020 1:46 AM + +We just received Maxwell's renewed bail application. Attached are the legal opinion on French law and proposed extradition waiver that she included as exhibits to that application. Is there a good time for a call to discuss tomorrow or Thursday? + +Thanks very much, + +Assistant United States Attorney Southern District of New York I St. Plaza New York, NY 10007 + +From: + +Sent: Tuesday, December 8, 2020 10:06 AM + +To: + +Cc: (CRM) c (USANYS) + +Subject: RE: SDNY case + +and + +Thank you both so much for your help. Everything you have outlined is very useful in our case. As to the specific points you raised: + +- Any materials from the State Department would be much appreciated. As you suggest, it would also be helpful to confirm with State that the Senate Report you attached is the best source to reference for the point that France will not extradite its nationals. +- It would be very helpful if it is possible to get the documents regarding Peterson and Tchikaya into translation so that we could review them, please. We would almost certainly want to reference these cases in our submission, but we'll need to discuss further with you before including these documents with our submission. Our Judge has been relatively limited in what she will allow us to file under seal, and I suspect she would not let us redact the defendant's names, though she may permit us to redact the names and Pll of officials involved in the case if we provide a justification for those redactions. The articles you sent indicate that Peterson is a dual U.S. citizen. Is Tchikaya a dual U.S. citizen as well? +- A letter from the Mal Central Authority would be very helpful. Ideally, we would like the letter to note that advance waivers of extradition are unenforceable as to French nationals. As you suggest, we can wait on this specific request until we see the particular argument Maxwell's attorneys make on this point. + +Thanks again, + +Assistant United States Attorney Southern District of New York I St. Plaza + +From: + +Sent: Tuesday, December 8, 2020 6:46 AM + +To: I + +Cc: (CRM) (USANYS) C + +Subject: RE: SDNY case + +I am adding Weiner from my office's litigation section, who is to assisting with organizing OIA's response. Here is an update from my end: + +- I've reached out to the State Department to get their assistance. I believe they have materials, including travaux preparatoires from the treaty that will shed light on France's consistent position that they do not extradition their nationals; +- I've located two cases in which OIA requested the extradition of French nationals, and this was refused. There would be more, but since we know they don't extradite French persons, we normally don't even ask. I detail below the documents I have related to these cases. I was thinking that it might make sense to get these documents into translation, so we have them available as exhibits to your response, in case you want to go that direction? o One is the Hans Peterson case, which saw some press in 2008 (ktps://www.durbin.senate.govinewsroom/press-releasesidurbin-schakowsky-emanuel-urge-frenchjustice-minister-to-ensure-justice-is-done-during-hans-peterson-retrial• https://www.nbcnews.com/id/wbna23601S83• https://www.chicagomag.com/Chicago-Magazine/December-2007/Bloodlines/index.php?cparticle=9&siarticle=8&requiressl=true).I have permission from Mal to provide the attached letter denying the extradition on grounds of nationality, so long as we redact Pll (including the name of the French officials involved, and the name of the defendant if possible). There is a more detailed letter from the French Minister of Foreign Affairs in the same case, which came after lobbying from the Embassy and the Durbin letter rejecting all of our arguments and reiterating France's inability to extradite its nationals. I do not yet have approval to include that. o The other is a PA request TCHIKAYA) we submitted in 2018 that was rejected because the fugitive was French (we can include with same restrictions regarding redaction). +- I am also attaching the June 2006 agreement between the EU and Iceland and Norway on the surrender procedure procedures between the EU and those countries, which entered into effect in November 2019. In case there was any doubt about whether France extradites its nationals, its statement at p. 29 makes clear that they do not. +- The Senate Report on the US-France extradition treaty (see page 82 of the PDF) includes a statement that the French delegation made clear that they will not extradite their nationals absent a change of law. France's code of criminal procedure (which is cited in the Tchikaya letter, CPP 696-2), but also CPP 696-4, underlies the refusal to extradite a French person from France. FYI, before we rely on this in your opposition I'd want to check with State to make sure that this is the best report to reference. +- Finally, I spoke to the head of MOJ's Central Authority this morning and he said he sees no problem providing us a letter stating that France does not extradite its nationals. He did not think it would be feasible to make a pronouncement on this defendant in particular, but was comfortable making a general statement. He agreed that there is no extradition waiver procedure in France (although someone can, of course, voluntarily return out of custody) and certainly no advance waiver. I have asked that any such letter refute any suggestion to the country... but we'll need to see specifically what the argument is. It's not impossible that one of his bosses would take a different position, but this is a good sign that we can get something from them on this. + +DOJ Attache/Magistrat de liaison anthicain + +U.S. Embassy, Paris + +From: + +Sent: Saturday, December 5, 2020 8:32 AM + +To: I < > + +Cc: c ) (USANYS).aa + +Subject: RE: SDNY case + +Sure. How about noon on Monday? + +Dal Attache/Magistrat de liaison americain + +U.S. Embassy, Paris + +From: `•• > + +Sent: Friday, December 4, 2020 8:29 PM + +To: + +Cc: (USANYS) + +Subject: RE: SDNY case + +Hi + +I hope you're doing well. Ghislaine Maxwell is filing a renewed bail application on Monday, and we expect that the motion will raise issues relating to the possibility of extradition from France. Are you available for a call on Monday for a few questions? I know we discussed this issue over the summer, and it would be very helpful to ask a few follow up questions. + +Thanks very much, + +From: + +Sent: Wednesday, July 8, 2020 11:48 AM + +To: + +Subject: RE: SDNY case + +From: c > Sent: Wednesday, July 8, 2020 5:46 PM To: Subject: Re: SDNY case + +Thanks very much, 9 a.m. on Friday would be great. What number should I call? + +Sent from my iPhone + +On Jul 8, 2020, at 11:44 AM, wrote: + +Sure thing. Friday looks pretty open for me. Would 9am or 9:30am work for you? + +From: Sent: Wednesday, July 8, 2020 5:38 PM To: Subject: Re: SDNY case + +Hi + +Do you have a moment this week for a quick call? I have a few questions about the extradition process in France generally, and it would be helpful to discuss. + +Thanks very much, + +Assistant United States Attorney Southern District of New York One Saint Plaza New York NY 10007 (212) 637-2225 + +Sent from my iPhone + +On Jul 8, 2020, at 11:21 AM, McNeil, John (CRM) < > wrote: + +I am putting you in touch with who is working the Maxwell/Epstein matter in SDNY. 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this! + +From: (USANYS) Sent: Wednesday, December 30, 2020 1:33 PM To: (USANYS) [Contractor] Cc: (USANYS) (USANYS) [Contractor] >; (USANYS) [Contractor] Subject: RE: Mouradian + +Yes — Thank you! + +From: (USANYS) [Contractor] Sent: Wednesday, December 30, 2020 1:30 PM To: (USANYS) < >; (USANYS) Cc: (USANYS) [Contractor] (USANYS) [Contractor] Subject: FW: Mouradian + +I just wanted to follow up on this. + +From: (USANYS) [Contractor] Sent: Monday, December 28, 2020 12:00 PM To: (USANYS) < >; (USANYS) [Contractor] Cc: (USANYS) Subject: RE: Mouradian (USANYS) [Contractor] < + +sure + +From: (USANYS) Sent: Monday, December 28, 2020 11:35 AM To: (USANYS) [Contractor] Cc: (USANYS) Subject: FW: Mouradian > (USANYS) [Contractor] < (USANYS) [Contractor] + +From: Bennett Epstein + +Sent: Monday, December 28, 2020 11:24 AM + +To: (USANYS) < + +Subject: Mouradian + +Mouradian's number is \ No newline at end of file diff --git a/marker2/ds9/EFTA00086949/EFTA00086949.metadata.json 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He then tried to have intercourse with her and she said no. EPSTEIN the . He asked to . He then got up. EPSTEIN put \$300 on the massage table. + +After changing, left and met who was waiting for her. They passed by the kitchen and pointed out a tall slim girl in the kitchen who was about 19 years old and had short dark hair. stated that she was EPSTEIN's main girlfriend. later found a photo in an album from that time period with and in it. + +After this incident went home and did not tell anyone as she was ashamed. It turned her off to modelling and she stopped doing it. She left New York City in October and she never spoke with EPSTEIN again. She knows she left in October because her resume said + +recalled meetinglIIIIIIIIIIIIIII, the owner of at a club. recalled him being funny and she went back to his home with other models. At his home there was alcohol and cocaine. was not sure what, if anything, happened to the other girls but did nothing to . She does recall him being "handsy" with the others but was not sure if he was that way with her. + +never talked to about the sexual things that EPSTEIN would do. After leaving EPSTEIN's house, had seen out a few times. invited roommate to EPSTEIN's. went once, but at the time wasn't sure if she got paid. 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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//F000 + +Investigation on 01/08/2020 at New York, New York, United States (Phone) + +This document contains neither recommendations nor conclusions of the FBI. 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And the [REDACTED] and [REDACTED] notes are attached. + +--- + +**From:** [REDACTED] > + +**Sent:** Thursday, May 14, 2020 13:47 + +**To:** [REDACTED] >; [REDACTED] > + +**Cc:** [REDACTED] >; [REDACTED] >; [REDACTED] > + +[REDACTED] > + +**Subject:** RE: 302s / interview notes + +Hi all, + +I've attached the notes you've requested. I've also attached [REDACTED] 302 and notes; that interview was not in the batch we gave you. You'll see below where I've typed "attached" to reflect what notes we have. Interviews where this is not written simply meant there were no notes to attach likely because the interview/contact was brief (I double checked all to be sure). Let me know if there is anything else you come across that we've missed sending. + +Also, could you send over the notes from the last two phone interviews with [REDACTED] and [REDACTED]? Just want to make sure we have them on our end. + +Thanks, + +[REDACTED] + +--- + +**From:** [REDACTED] + +**Sent:** Friday, May 08, 2020 6:52 PM + +**To:** [REDACTED] >; [REDACTED] > + +**Cc:** [REDACTED] + +[REDACTED] + +**Subject:** RE: 302s / interview notes + +[REDACTED] + +Thanks very much again for getting us so many 302s recently, we really appreciate it. Collectively, there have been more than 120 interviews in this case, which is incredible. We've now completed a full review and cross-reference of all our materials, so wanted to address a handful of loose ends. In terms of reports, I think currently we're down to only missing three, all of which we have interview notes for but no 302s: + +- [REDACTED] +[REDACTED] + +And then there are a larger number of interviews where we have a 302 but not hand-written notes. My guess is that for some of these, and possibly most, there aren't notes because the "interviews" were so short that they just got typed up, but we wanted to check. Also most of them were interviews conducted by other agents (where it was agents other than one or both of you, I've indicated below). But if you could please double check to see if there are interview notes for the following, and in particular the few that are in bold? And let us know if any questions or issues. They are: + +Thanks again! + +[REDACTED] + +[REDACTED] + +Assistant U.S. Attorney +Southern District of New York + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00086959/EFTA00086959.metadata.json b/marker2/ds9/EFTA00086959/EFTA00086959.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..edc7c82220e8ad25bce0f3b85dd1d519d3e16848 --- /dev/null +++ b/marker2/ds9/EFTA00086959/EFTA00086959.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086959.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2429, + "elapsed_seconds": 116.58, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "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", + 17 + ], + [ + "Text", + 12 + ], + [ + "Line", + 9 + ], + [ + "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/EFTA00086959" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086961/EFTA00086961.md b/marker2/ds9/EFTA00086961/EFTA00086961.md new file mode 100644 index 0000000000000000000000000000000000000000..0e388eb1c1dbf20d2de6caab20529b735d14cfce --- /dev/null +++ b/marker2/ds9/EFTA00086961/EFTA00086961.md @@ -0,0 +1,75 @@ +To: (USANYS)" + +Subject: RE: Epstein Touhy + +Date: Thu, 30 Apr 2020 19:29:11 +0000 + +Thank you! + +From: (USANYS) + +Sent: Thursday, April 30, 2020 3:25 PM + +To: (USMS) + +Subject: RE: Epstein Touhy + +I'm sorry for the delay. I agree that you should continue to process the Tuohy request with the USAO VI. We have not received a similar request. Things are functioning as well as possible here, although as you say, it is amazing to see the degree to which the NYC area can grind to a halt. + +From: (USMS) + +Sent: Thursday, April 30, 2020 3:17 PM + +To: (USANYS) < + +Subject: RE: Epstein Touhy + +Does your office have any response? If not, I'll proceed to process the Touhy with the USAO in the GVI. + +I hope all is well with you and yours. I'm from NJ, and it's tough watching this virus cut such a wide swath through the NYC/NJ area I still consider home. + +V/r, + +KAF + +Associate General Counsel + +USMS/HQ/OGC + +(cell) + +From: (USMS) + +Sent: Thursday, April 23, 2020 2:11 PM + +To: (USANYS) sci > + +Cc: (USMS) (USMS) (USMS) < + +When we spoke in September, 2019, I advised you that the USMS had released the attached material in response to a FOIA request. We felt it prudent to inform you of this, given the potential pendency of other matters in your office related to the then-recently deceased Jeffrey Epstein. + +The USMS has recently received a copy of a Touhy request from the Government of the United States Virgin Islands (GVI) to the Office of Justice Programs and the USDO1 SMART Office that seeks information about Mr. Epstein for potential use in a civil matter in the GVI. I have attached a copy of that letter. + +I have also attached a response to that letter from the Office of Justice Programs that points out that the USMS is the more logical recipient of this Touhy request. + +I forwarded the Touhy request to the Civil Chief of the USAO/GVI, .arid I will be their USMS POC in crafting a response. The attached material will be a significant factor in our response. + +I thought the USMS should make you aware of these recent developments and the impending response to the Touhy request in the event your office is involved in any matters involving Mr. Epstein or his estate that could be impacted by the release of information as requested in the recent Touhy letter. Additionally, if your office has also received a Touhy request from the GVI regarding Mr. Epstein, I thought it best that we respond in a coordinated fashion. + +If you or one of your Assistants would like to discuss this, I will be available at your convenience. E-mail is the most reliable way to reach me quickly. + +V/r, + +Associate General Counsel USMS/HQ/OGC (cell) + +From: (USMS) Sent: Friday, September 13, 2019 2:08 PM To: (USANYS) < Subject: Epstein FOIA Disclosure + +Thank you for your prompt return call and your time this afternoon. + +Attached above is the material we discussed. + +You or anyone on your staff is welcome to call me if you have any questions or concerns about this material. + +V/r, + +![](_page_2_Picture_1.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00086961/EFTA00086961.metadata.json b/marker2/ds9/EFTA00086961/EFTA00086961.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..039da09913ddb9a2fb422268d85c06eb74e8456e --- /dev/null +++ b/marker2/ds9/EFTA00086961/EFTA00086961.metadata.json @@ -0,0 +1,120 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086961.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2984, + "elapsed_seconds": 1.41, + "image_assets": [ + "_page_2_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Line", + 32 + ], + [ + "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", + 61 + ], + [ + "Line", + 31 + ], + [ + "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": "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/EFTA00086961" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086961/_page_2_Picture_1.jpeg b/marker2/ds9/EFTA00086961/_page_2_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..1f4f1b7af3d980cbc82674f01d45d2e526f79bbd --- /dev/null +++ b/marker2/ds9/EFTA00086961/_page_2_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:a34d628b5100e5086725f7fe55e6d785ba157d3a889ba9f28ec7c54752f7846f +size 835 diff --git a/marker2/ds9/EFTA00086964/EFTA00086964.md b/marker2/ds9/EFTA00086964/EFTA00086964.md new file mode 100644 index 0000000000000000000000000000000000000000..8728aece156bb907a9f21eb406eb006ec99ca465 --- /dev/null +++ b/marker2/ds9/EFTA00086964/EFTA00086964.md @@ -0,0 +1,21 @@ +From: "I To: al C C] to + +Subject: RE: updated draft + +Date: Thu, 14 May 2020 04:26:12 +0000 + +Attachments: Maxwell,\_Ghislaine Transcri t 04-22-16).pdf; Maxwell,\_Ghislaine\_Transcript\_(07-22- 16).pdf; 2020-05-09 interview notes (no 302).pdf + +Added, at least for me our share drive takes forever to get anything, so in case it's helpful, attached are the two GM depos as well as my notes on the recent interview. Also forgot to mention but you'll see I added a big rundown, and am extremely happy for any suggestions, including on tone, on that (and similar on the substantive count stuff). Thx. + +From: Sent: Thursday, may 14, 2020 00:22 To: Subject: updated draft + +I ended up just really really wanting to cross this off my to-do list, even if just in terms of the latest turn. + +I tried to do a track-changes version for easier review, but because the structure got completely overhauled it ends up being a huge mess and I think basically useless. So I'm sorry about that! The main changes are that I added the "substantive count is super aggressive and also a great idea" section up top; rearranged the false statements (both internally and where they are in the memo); and accepted a million changes. + +Very happy for comments on all, though especially on what you think of the categories for the statements — I don't really think they ultimately fall neatly into categories, but I think multiple people thought that would be preferable so curious what y'all think. + +Also the comments or changes that I didn't delete or accept are the ones that I want to talk through. + +Let me know if any questions, etc, and happy to chat any time, and thanks as always. \ No newline at end of file diff --git a/marker2/ds9/EFTA00086964/EFTA00086964.metadata.json b/marker2/ds9/EFTA00086964/EFTA00086964.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..84d6edcb005e56eade249e29c509c0540d8f4407 --- /dev/null +++ b/marker2/ds9/EFTA00086964/EFTA00086964.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086964.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1655, + "elapsed_seconds": 0.66, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 26 + ], + [ + "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/EFTA00086964" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086965/EFTA00086965.md b/marker2/ds9/EFTA00086965/EFTA00086965.md new file mode 100644 index 0000000000000000000000000000000000000000..3f8a3a4e54c13cac096de3300d4783ec857a5390 --- /dev/null +++ b/marker2/ds9/EFTA00086965/EFTA00086965.md @@ -0,0 +1,35 @@ +From: ' + +To: "1 111 Y (FBI)" .0 (USANYS)" + +Cc: aSYS) " • I/ + +Subject: RE: Mark Epstein + +Date: The, 26 May 2020 21:52:50 +0000 + +I know his lawyer is asking to speak with you, here is some info on what was done. + +The phone numbers come back to VoIP lines and I am trying to determine where to send the subpoena request to. I have a emergency disclosure request with legal@signalwire.com for subscriber and IP Logs for the phone numbers. I can follow up tomorrow with a subpoena rider once they respond. + +The email's are originating from fastmail.com which is an Australian based company. I sent an emergency disclosure request for subscriber and IP logs regarding the user. Awaiting to see if they will respond if not the only other recourse would be an MLAT request. + +On another note, I did a simple google search and his email address and phone popped right up. + +On May 26, 2020 4:18 PM, (USANYS)" > wrote: + +Thanks + +Jose, nice to meet you. We're still waiting to hear from our supervisors about whether we (or other AUSAs) will be handling the investigation, but we are happy to get started on any subpoenas or process you need in the meantime. + +From: (NY) (FBI) < > + +Sent: Tuesday, May 26, 2020 2:43 PM + +To: (USANYS) + +Cc: + +Subject: Mark Epstein + +(cc'd) will be looking into the matter... \ No newline at end of file diff --git a/marker2/ds9/EFTA00086965/EFTA00086965.metadata.json b/marker2/ds9/EFTA00086965/EFTA00086965.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e9adde1edcc2e39f4e38f8daa3fac2a87f01f80c --- /dev/null +++ b/marker2/ds9/EFTA00086965/EFTA00086965.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086965.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1288, + "elapsed_seconds": 1.08, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Line", + 27 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00086965" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086966/EFTA00086966.md b/marker2/ds9/EFTA00086966/EFTA00086966.md new file mode 100644 index 0000000000000000000000000000000000000000..6be83b69c37d0cc2df5b2f67627a0e832acf0545 --- /dev/null +++ b/marker2/ds9/EFTA00086966/EFTA00086966.md @@ -0,0 +1,17 @@ +To: (USANYS)" + +Subject: Re: + +Date: Wed, 27 May 2020 00:15:54 +0000 + +We should give at least Laura if not Geoff a heads up we're opening this. If Mark goes out and announces he's a victim and we're investigating on his behalf, I don't think that will be well received. + +Sent from my iPhone + +> On May 26, 2020, at 8:11 PM, (USANYS) •<=1==> wrote: + +> Hagan is on board for the threats investigation. 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/EFTA00086966/EFTA00086966.metadata.json b/marker2/ds9/EFTA00086966/EFTA00086966.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e0350e2bb89d3a2eafc36c98a291c6ee86b88d9c --- /dev/null +++ b/marker2/ds9/EFTA00086966/EFTA00086966.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086966.pdf", + "engine": { + "marker_major": "2", + "marker_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": 588, + "elapsed_seconds": 0.71, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Text", + 14 + ], + [ + "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/EFTA00086966" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086967/EFTA00086967.md b/marker2/ds9/EFTA00086967/EFTA00086967.md new file mode 100644 index 0000000000000000000000000000000000000000..1bf057159f778d154b995acc3e8cf43140e5ad37 --- /dev/null +++ b/marker2/ds9/EFTA00086967/EFTA00086967.md @@ -0,0 +1,29 @@ +From + +To + +Cc + +Subject: Fwd: + +Date: Wed, 27 May 2020 00:11:53 +0000 + +Hey, thanks for doing this. Let me know when would be good for a call. + +Begin forwarded message: + +From: ' (USANYS)" -MIMIMME> + +Date: May 26, 2020 at 8:11:12 PM EDT + +To: "Donaleski Rebekah (USANYS)" "Roos, Nicolas (USANYS)" + +, "Lonergan, Jessica (USANYS)" + +Cc: "Scotten, Ha an USANYS)" , " (USANYS)" + +Hagan is on board for the threats investigation. 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/EFTA00086967/EFTA00086967.metadata.json b/marker2/ds9/EFTA00086967/EFTA00086967.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c889275169c54c8c69fc5f200972fce11a32e165 --- /dev/null +++ b/marker2/ds9/EFTA00086967/EFTA00086967.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086967.pdf", + "engine": { + "marker_major": "2", + "marker_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": 617, + "elapsed_seconds": 0.82, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 19 + ], + [ + "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/EFTA00086967" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086968/EFTA00086968.md b/marker2/ds9/EFTA00086968/EFTA00086968.md new file mode 100644 index 0000000000000000000000000000000000000000..6907912eca33ec6fc673d853ca3470d093ca8604 --- /dev/null +++ b/marker2/ds9/EFTA00086968/EFTA00086968.md @@ -0,0 +1,60 @@ +From: ' (USANYS)" ci + +To: ' (USANYS)" + +Cc: ' (USANYS)" + +Subject: RE: Virgin Island case + +Date: Fri, 29 May 2020 12:46:05 +0000 + +Okay, I would like to discuss at some point. + +From: (USANYS) < > + +Sent: Thursday, May 28, 2020 5:02 PM + +To: (USANYS) + +Cc: (USANYS) < + +Subject: RE: Virgin Island case + +Not really. I knew there was a meeting scheduled with civil today to discuss options, and Geoff initially wanted me to be involved but said that had cautioned against it for 6(e) reasons, so Geoff said ok —M. out. + +From: (USANYS) + +Sent: Thursday, May 28, 2020 4:53 PM + +To: (USANYS) . > + +Cc: (USANYS) + +Subject: FW: Virgin Island case + +Are you in the loop on this? + +From: + +Sent: Thursday, May 28, 2020 4:09 PM + +To: (USANYS) + +Cc: + +Subjec : irgin s an. case + +Hi M, + +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 witl 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/EFTA00086968/EFTA00086968.metadata.json b/marker2/ds9/EFTA00086968/EFTA00086968.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..150bc2f92bfa6e507c2146eb99f3c710c4258ee9 --- /dev/null +++ b/marker2/ds9/EFTA00086968/EFTA00086968.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086968.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2818, + "elapsed_seconds": 1.22, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Line", + 37 + ], + [ + "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 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 12 + ], + [ + "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/EFTA00086968" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086970/EFTA00086970.md b/marker2/ds9/EFTA00086970/EFTA00086970.md new file mode 100644 index 0000000000000000000000000000000000000000..161ab03904acabb209c7dc44a57003eeb902242f --- /dev/null +++ b/marker2/ds9/EFTA00086970/EFTA00086970.md @@ -0,0 +1,47 @@ +To: + +Subject: FW: Reply brief- Part I + +Date: Wed, 27 Oct 2021 21:05:58 +0000 + +Attachments: Govt\_Reply\_v3.docx + +Hi team, + +Attached is a new version of Part I. There are a couple of comment bubbles I'm hoping you'll check for accuracy, and then you should take a look at the section on MV-4 (p. 11), which I've adjusted in light of my conversation with + +I talked to about Part II. He said to expect minimal edits, except he thinks we should make the Prior Consistents section a short standalone section. I'm going to draft that now and then circulate. + +From: + +Sent: Wednesday, October 27, 2021 3:36 PM + +To: + +Subject: RE: Reply brief - Part I + +Team — This is really fantastic. A few minor comments from me and Janis in the attached. + +From: + +Sent: Wednesday, October 27, 2021 12:06 PM + +To: + +Cc: + +Subject: Reply brief - Part I + +Hi + +Attached is a draft of Part I of the reply brief, regarding the issue of pseudonyms. We are editing Part II (of II), which responds to the remaining issues. + +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/EFTA00086970/EFTA00086970.metadata.json b/marker2/ds9/EFTA00086970/EFTA00086970.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6b94051935e1c4890d63c0f7e4a5b05171ef3e10 --- /dev/null +++ b/marker2/ds9/EFTA00086970/EFTA00086970.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086970.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1108, + "elapsed_seconds": 1.21, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Text", + 29 + ], + [ + "Line", + 29 + ], + [ + "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/EFTA00086970" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086971/EFTA00086971.md b/marker2/ds9/EFTA00086971/EFTA00086971.md new file mode 100644 index 0000000000000000000000000000000000000000..fcc99da2574b3e2f67b0b9ce0b7cb636487b4b94 --- /dev/null +++ b/marker2/ds9/EFTA00086971/EFTA00086971.md @@ -0,0 +1,89 @@ +From: ' To: Joe Nascimento < Cc: ' < Subject: RE: call tomorrow? Date: Wed, 27 Oct 2021 22:09:52 +0000 + +Joe, + +Thanks for discussing scheduling earlier. We're available to meet by video on November 5, 2021, at 1 p.m., if that works for you. I'll send a WebEx invitation shortly. + +Thanks, + +From: Joe Nascimento Sent: Wednesday, October 27, 2021 4:41 PM To: Cc: Subject: (EXTERNAL] Re: call tomorrow? + +Please call me when you have a minute. + +Thanks, + +Joe + +Sent from my iPhone + +Joseph E. Nascimento, Esq. ROSS AMSEL RABEN NASCIMENTO, PLLC Lawyer's Plaza I 4th Floor 2250 S.W. 3LCI Avenue Miami Florida 33129 + +www.crimlawfirm.com + +On Oct 27, 2021, at 10:51 AM, wrote: + +Joe, + +From: Joe Nascimento Sent: Tuesday, October 26, 2021 2:30 PM To: Cc: Subject: [EXTERNAL] Re: call tomorrow? + +I am free for the next 15 min, then again after 4:30. Wide open tomorrow. + +-Joe + +Joseph E. Nascimento, Esq. ROSS AMSEL RABEN NASCIMENTO, PLLC Lawyer's Plaza 14th Floor 2250 S.W. 3al Avenue Miami Florida 33129 + +www.crimlawfirm.com + +From: Date: Tuesday, October 26, 2021 at 2:25 PM To: Joe Nascimento Cc: < Subject: RE: call tomorrow? + +Hi Joe, + +Are you available for a call this afternoon or tomorrow? + +Thanks very much, + +From: Joe Nascimento Sent: Thursday, October 14, 2021 5:49 PM To: Cc: Subject: (EXTERNAL] Re: call tomorrow? + +Thanks for the call and update today. is comfortable with you sharing information about how she was also victimized by Epstein with the victims and their counsel. She is very appreciative of how sensitive you have been with these issues. + +Joe + +Sent from my iPhone + +Joseph E. Nascimento, Esq. ROSS AMSEL RABEN NASCIMENTO, PLLC Lawyer's Plaza I 4th Floor 2250 S.W. 3rd Avenue Miami Florida 33129 + +www.crimlawfirm.com + +On Oct 13, 2021, at 10:20 PM, I 4 > wrote: + +Thanks very much — talk to you then. + +From: Joe Nascimento c= > Sent: Wednesday, October 13, 2021 10:15 PM To: ) + +**To:** "[REDACTED] (USANYS) [Contractor]" <[REDACTED]>, "[REDACTED] (USANYS) [Contractor]" <[REDACTED]> + +**Cc:** "[REDACTED] (USANYS)" <[REDACTED]> + +**Subject:** discovery + +**Date:** Thu, 28 Oct 2021 03:15:24 +0000 + +--- + +Hi team, + +Could you please add the materials saved here to the next production? Thanks! + +[REDACTED] +[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/EFTA00086975/EFTA00086975.metadata.json b/marker2/ds9/EFTA00086975/EFTA00086975.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..38458eb680c1849af034c84cdda7da193b47b25e --- /dev/null +++ b/marker2/ds9/EFTA00086975/EFTA00086975.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086975.pdf", + "engine": { + "marker_major": "2", + "marker_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": 511, + "elapsed_seconds": 2.77, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Text", + 18 + ], + [ + "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/EFTA00086975" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086976/EFTA00086976.md b/marker2/ds9/EFTA00086976/EFTA00086976.md new file mode 100644 index 0000000000000000000000000000000000000000..d71463b7c2312fd991d4fd2baeb95b7ed1c3f94c --- /dev/null +++ b/marker2/ds9/EFTA00086976/EFTA00086976.md @@ -0,0 +1,173 @@ +To: Louise Scott + +Sent: Friday, September 18, 2020 11:58 AM + +To: Cc: Subject: Re: SDNY investigation + +You can just say I have approved for OIA. + +John T. McNeil U.S. Department of Justice Attaché - London US Mobile: + +On Sep 30, 2020, at 6:42 PM, wrote: + +John, + +Is there a counterpoint at OIA in Washington we should be emailing for OIA approval, or should we send you an email requesting approval? + +Thanks, + +From: McNeil, John (CRM) Sent: Wednesday, September 30, 2020 11:18 AM To: Cc: Subject: RE: SDNY investigation + +Is she OK with the Met Police knowing about her speaking with us? + +From: Sent: Wednesday, September 30, 2020 4:17 PM To: McNeil, John (CRM) Cc: Subject: RE: SDNY investigation + +Thanks, + +From: McNeil, John (CRM) + +Sent: Wednesday, September 30, 2020 11:16 AM + +To: + +Cc: + +Subject: RE: SDNY investigation + +Thanks. Very helpful. Am I correct in assuming that you have not seen the statement she gave to the police? Also, do you have the names of the Met officers involved? + +From: + +Sent: Wednesday, September 30, 2020 3:53 PM + +To: McNeil, John (CRM) + +Cc: + +Subject: RE: SDNY investigation + +Hi John, + +Thank you. We have not interviewed this witness, so we have not confirmed the details about where the abuse happened, who the perpetrator was, or how old she was when it happened. What we do know is (1) she is currently in England, (2) she is a UK national, and (3) according to her lawyer, she recently made a statement to the Met Police reporting some sort of past abuse by Jeffrey Epstein (and not necessarily the full scope of the information she may have in connection with our investigation), so we would be open to the possibility of sharing her name with the Met Police if, in your view, that was necessary. + +We are preparing travel paperwork on our end, and will try to get this moving quickly. Thanks so much for your guidance on this. + +Best, + +From: McNeil, John (CRM) + +Sent: Wednesday, September 30, 2020 7:07 AM + +To: + +Subject: RE: SDNY investigation + +One other question. If there is anything that would implicate UK government interests in this witness (other than any connection with witness PA) - if she was assaulted in connection with a UK gov't function, or was a UK gov't employee, etc. - that would also be helpful to know. + +From: McNeil, John (CRM) + +Sent: Wednesday, September 30, 2020 11:05 AM + +To: ) <->; + +In speaking with LEGAT colleagues about how to do this without disclosing the witness identity, they said the UK will want to know if the conduct is also a UK crime. So a few questions: + +is the victim a UK national; + +did the alleged conduct occur on UK soil; + +if the conduct occurred elsewhere, was the perp a UK national and the victim under age (I think it has to be under age 16)? + +Also, what country is the victim currently in - England/Wales; Scotland, or N. Ireland (they each have their own procedures)? + +Did the victim ever report the conduct to UK law enforcement? + +Thx, + +John + +From: McNeil, John T (London) [ + +Sent: Tuesday, September 29, 2020 6:40 PM + +To: I < :.; McNeil, John (CRM) + +Cc: + +Subject: Re: SDNY investigation + +My apologies. I haven't been able to get back on the line. + +John T. McNeil + +U.S. Dept. of Justice Attaché - London + +UK Mobile: + +Sent from a mobile device + +From: + +Sent: Tuesday, September 29, 2020 6:09:57 PM + +To: McNeil, John T (London) scI MI>: McNeil, John (CRM) < + +Cc: + +Subject: RE: SDNY investigation + +Hi John, + +Thanks again for taking the time to talk to us today. We can use this conference line: passcode + +From: McNeil, John T (London) < + +Sent: Monday, September 28, 2020 11:58 AM + +To: McNeil, John (CRM) cc > + +Subject: Re: SDNY investigation + +I'll be in court much of the day tomorrow, so how about 1:30 pm EDT or later? Thx + +John T. McNeil + +From: McNeil, John (CRM) + +Sent: Friday, September 25, 2020 8:14:17 PM + +To: McNeil, John T (London) fl + +Subject: FW: SDNY investigation + +From: + +Sent: Friday, September 25, 2020 8:14:13 PM (UTC+00:00) Dublin, Edinburgh, Lisbon, London + +To: McNeil, John (CRM) + +Cc: ); (USANYS) + +Subject: Re: SDNY investigation + +Thanks very much. Is there a time on Tuesday that works best for you? + +Sent from my iPhone + +On Sep 25, 2020, at 1:49 PM, McNeil, John (CRM) > 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, + +John + +John T. McNeil + +U.S. Department of Justice Attaché United States Embassy - London + +U.K. Mobile: + +From: c > + +Sent: Friday, September 25, 2020 3:16 PM + +To: McNeil, John (CRM) I + +Cc: >.; (USANYS) < + +Subject: SDNY investigation + +Hi John, + +I hope you're doing well. Are you possibly available for a brief call on Monday? + +Assistant United States Attorney + +Southern District of New York + +New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00086981/EFTA00086981.metadata.json b/marker2/ds9/EFTA00086981/EFTA00086981.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..241520b66586d0afa630d114243dacafdd7ba92b --- /dev/null +++ b/marker2/ds9/EFTA00086981/EFTA00086981.metadata.json @@ -0,0 +1,174 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086981.pdf", + "engine": { + "marker_major": "2", + "marker_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": 5020, + "elapsed_seconds": 1.74, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 33 + ], + [ + "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", + 73 + ], + [ + "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", + 84 + ], + [ + "Line", + 39 + ], + [ + "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": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Line", + 33 + ], + [ + "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": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 7 + ], + [ + "Text", + 6 + ], + [ + "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/EFTA00086981" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086986/EFTA00086986.md b/marker2/ds9/EFTA00086986/EFTA00086986.md new file mode 100644 index 0000000000000000000000000000000000000000..afae8686e4dee89d9bd2d3251c4e655dbe0bbdc8 --- /dev/null +++ b/marker2/ds9/EFTA00086986/EFTA00086986.md @@ -0,0 +1,178 @@ +**From:** "[REDACTED]" <[REDACTED]> +**To:** "[REDACTED]" <[REDACTED]> +**Subject:** Re: [REDACTED] follow-up request +**Date:** Fri, 08 May 2020 15:00:27 +0000 + +--- + +That sounds right. Probably not even that long. + +Sent from my iPhone + +On May 8, 2020, at 10:45 AM, [REDACTED] <[REDACTED]> wrote: + +What do you think? Hour and a half or so?? + +--- + +**From:** Sigrid McCawley <[REDACTED]> +**Sent:** Thursday, May 07, 2020 18:57 +**To:** [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]> +**Subject:** RE: [REDACTED] follow-up request + +Hello [REDACTED], + +I am sure [REDACTED] will be happy to help in any way she can. Let me find out what her patient schedule is like for next week and find a time that works. How much time do you think she should allot for the interview – just so she can plan? + +Best, + +[REDACTED] + +[REDACTED] + +Partner + +BOIES SCHILLER FLEXNER LLP + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +[www.bsfllp.com](http://www.bsfllp.com) + +--- + +**From:** [REDACTED] [mailto:[REDACTED]] +**Sent:** Thursday, May 7, 2020 6:41 PM +**To:** [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]> +**Subject:** RE: [REDACTED] follow-up request + +**CAUTION:** External email. Please do not respond to or click on links/attachments unless you recognize the sender. + +We wanted to follow up in connection with — our supervisors have asked us to do an additional interview with her, both to follow up on some specific aspects of her recollection but also do basically go through her experiences again. As I'm sure you know, we have no doubts whatsoever, at all, about her candor and truthfulness in our previous interview, which also was broadly consistent with what she has said in other interviews, but we are nevertheless hoping she might be willing to speak with us sometime in the next week or two? Obviously due to the current situation we would plan to do it via phone, and we would be happy to chat about logistics with you if that would be helpful, or to answer any questions at all. And if is willing to speak with us again, we're happy to work around her schedule, including talking during an evening or weekend if that's easier for her than during the day—whatever you and she would prefer. + +Please let us know if any questions, or if it would be useful to chat, and thanks very much. + +From: Sent: Thursday, January 16, 2020 14:35 To: Cc: Subject: RE: follow-up request + +Got it, thanks. + +Assistant United States Attorney Southern District of New York New York, NY 10007 + +From Sent: Thursday, January 16, 2020 2:29 PM To: Cc: Subject: RE: follow-up request + +I checked back with and she said that the last entry in her journal is in late February and she went to New Mexico in April. + +Thanks + +Partner BOLES SCHILLER FLEXNER LLP + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +[www.bsfllp.com](http://www.bsfllp.com) + +Sent by Boxer + +On January 16, 2020 at 1:05:54 PM EST, [REDACTED] <[REDACTED]> wrote: + +Thank you very much, [REDACTED] + +Just to confirm, does [REDACTED] have any journal entries regarding the time when she traveled to New Mexico? I believe she told us during our interview that she does not have any entries from that time, but I just wanted to make sure. + +Thanks again, +[REDACTED] + +[REDACTED] + +Assistant United States Attorney +Southern District of New York +[REDACTED] + +New York, NY 10007 +[REDACTED] +[REDACTED] + +--- + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Thursday, January 16, 2020 12:31 PM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] + +<[REDACTED]> + +**Subject:** RE: [REDACTED] follow-up request + +Hello – attached are the pages [REDACTED] sent me to provide to you. Here is a bit of an explanation and I also asked her to take a copy of the front and back of the journal book which she did. Hope this helps. Please let me know if you need anything else: + +“The shortest page and the one that is the hardest to read is the first entry from 12/95. It is written in colored pencil and is fading. There are then two pages from 01/07/1996 where I talk about the highlights of my NY trip and going to Epstein’s house and then the next entry from 01/25/1996 is where I talk about going to the movies with him.” + +Best, +[REDACTED] + +www.bsfIlp.corn + +From: [mailto: + +Sent: Friday, January 10, 2020 4:01 PM + +"to: + +Cc: + +Subject: RE: follow-up request + +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 + +New York. NY 10007 + +From: + +Sent: Frida , January 10. 2020 3:59 I'M + +To: + +Cc: + +Hello + +Subject: RI' follow-up request + +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. + +Partner + +Front: [mailto: Sent: Frida Janua 10, 2020 3:30 PM To: Cc: • Subject: follow-up request + +Hi + +Hope you had a wonderful holida 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 hiato 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. + +Thaiailcou, + +Assistant United States Attorney Southern District of New York + +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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Washington Road, Bradford, NH + +Date: Tue, 07 Jul 2020 20:28:11 +0000 + +Inline-Images: image001.jpg; image002.jpg + +Sure, will do, thanks. + +From: (USANYS) ; + +That does sound familiar, thanks for reminding me. Would you mind drafting a short email to on this? Happy to look at a draft if it would be helpful. + +From: Sent: Tuesday, July 7, 2020 4:07 PM To: (USANYS) Cc: Subject: RE: 338 E. Washington Road, Bradford, NH + +We had to get Geoff's approval for the friendly subpoena to the plaintiffs' attorney in Hadden, which is why I thought we would need approval for this. + +The relevant USAM provision is 9-13.410(D)(1): + +Friendly Subpoenas for Client-Related Information. The United States Attorney or Assistant Attorney General responsible for a matter may authorize the issuance of a "friendly subpoena" for client-related information, that is, in a situation in which an attorney witness expressly agrees in writing (including by email) to provide the information, but requests the formality of a subpoena. Before issuing any such subpoena, the responsible United States Attorney or Assistant Attorney General must evaluate the request consistent with subsection C of this policy. If the friendly subpoena seeks testimony, information, or materials identified in Items (D)(z)(a)-(h) below, the federal prosecutor handling the case may authorize the issuance of the subpoena. + +From: (USANYS) < Sent: Tuesday, July 7, 2020 3:49 PM To: Cc: Subject: RE: 338 E. Washington Road, Bradford, NH >; + +Check the USAM, I don't recall, but I don't think so. + +From: Sent: Tuesday, July 7, 2020 3:46 PM To: (USANYS) Cc: Subject: RE: 338 E. Washington Road, Bradford, NH >; + +From: (USANYS) + +Sent: Tuesday, July 7, 2020 3:03 PM + +To: + +Cc: + +Subject: RE: 338 E. Washington Road, Bradford, NH + +Aren't we continuing to look at her finances as relevant to, among other things, her ongoing ties to Epstein and/or any efforts he may have made to buy her silence? Particularly given that we already have some reason to believe (based on what I recall of our detention memo) that money from Epstein may have been used to finance the purchase of the property, I would think we have a good faith basis to believe these records might be relevant to the grand jury's ongoing examination of the conduct already in and surrounding the charged case, especially since we are continuing to investigate/conduct new interviews/review new materials, and we don't have a trial date. But happy to discuss further. + +From: + +Sent: Tuesday, July 7, 2020 2:58 PM + +To: (USANYS) + +Cc: + +Subject: FW: 338 E. Washington Road, Bradford, NH + +Hi M, + +Our case agent has heard from the attorney who represented Maxwell (or rather, Granite Realty) in the NH real estate closing. She has volunteered to disclose her file, but asked for a subpoena. We would like to get more information about this, but issuing a grand jury subpoena seems potentially problematic, as it is not immediately clear to us that these records relate to any prospective superseder, and we don't have a trial date for a trial subpoena. (Although these would be attorney subpoenas, since they are "friendly" subpoenas, my understanding is that PSEU approval is not required). + +We wanted to check with you to see if you think we should proceed another way, or if we should just ask our case agent to interview her and see what she is willing to share, or if we should just leave this alone. + +Thanks, + +From: (NY) (FBI) + +Subject: RE: 338 E. Washington Road, Bradford, NH + +I hope that you had a nice weekend and good July 4th. CC'ed on this email is Special Agent . She will follow up with you directly about Ghislaine Maxwell. + +Thank you again for reaching out and don't ever hesitate to be in touch, + +Special Agent Federal Bureau of Investigation — Boston + +From: Sent: Friday, July 3, 2020 6:58 PM To: (BS) (FBI) < Subject: Re: 338 E. Washington Road, Bradford, NH + +Thank you I appreciate your assistance. + +Happy Fourth! + +Attorney at Law-NH & MA + +From: (BS) (FBI) Sent: Friday, July 3, 2020 6:44 PM To Subject: Re: 338 E. Washington Road, Bradford, NH + +Hi + +I remember meeting! Thank you for reaching out! That was a great conference, I really enjoyed being part of it. I will reach out to the agents involved in that case and be in touch shortly (it will likely be Monday). + +Thanks again for reaching out, I hope that you are doing well! Have a great July 4th. + +Special Agent Federal Bureau of Investigation - Boston Division + +Dear Mr. + +We met at the Mortgage Banker's conference in Portsmouth, NH in February. + +I handled the real estate closing for 338 E. Washington Road, Bradford, NH where Ghislaine Maxwell was arrested yesterday. I have information regarding my legal representation that could be of interest. I am hoping you may be willing to connect me with an agent so that I may be helpful in providing my file. + +Thank you + +Regards, + +Attorney at Law + +Admitted to Practice in NH and MA + +Phone + +Fax + +Click to view our YouTube channel + +![](_page_4_Picture_12.jpeg) + +## Celebrating 13 'Years of Service + +Locations: Bedford, NH — Concord, NH — Hampton, NH — Keene, NH — New London, NH — Windham, NH — Wilder, VT — Andover, MA + +Mailing Address For All Correspondence: + +FRAUD ALERT: DO NOT WIRE FUNDS unless you have called our firm to verify wire instructions. Even if an email appears as if lt was generated by this firm or a party to your transaction, CALL US a 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. 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https://git-lfs.github.com/spec/v1 +oid sha256:478f758f3caf315702ac2b04fad4cb7fea3ef92787a3f44e28a8d44afa1ffc54 +size 4338 diff --git a/marker2/ds9/EFTA00086991/_page_4_Picture_12.jpeg b/marker2/ds9/EFTA00086991/_page_4_Picture_12.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..bb57459ae0dc252d5ce45efef6c77fec7796d3f8 --- /dev/null +++ b/marker2/ds9/EFTA00086991/_page_4_Picture_12.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:aba502d45edaf0fcb25b8fbf21054b1189f32cc3eed5d3d7af0cd50d073a97d0 +size 5039 diff --git a/marker2/ds9/EFTA00086996/EFTA00086996.md b/marker2/ds9/EFTA00086996/EFTA00086996.md new file mode 100644 index 0000000000000000000000000000000000000000..b9733fb4159c32e93e6ba67389dd4235db0d671d --- /dev/null +++ b/marker2/ds9/EFTA00086996/EFTA00086996.md @@ -0,0 +1,31 @@ +To: + +Cc: ' + +Subject: RE: Epstein + +Date: Thu, 29 Nov 2018 19:23:53 +0000 + +Importance: Normal + +This is a particularly intriguing tid-bit: + +Facing a 53-page federal indictment, Epstein could have ended up in federal prison for the rest of his life. + +You may want to see if anything was ever publicly filed. + +From: + +Sent: Thursday, November 29, 2018 2:13 PM + +To: + +Cc: + +Subject: Epstein + +Here's the article: + +https://www.miamiherald.corninews/local/article220097825.html + +Sent from my iPhone \ No newline at end of file diff --git a/marker2/ds9/EFTA00086996/EFTA00086996.metadata.json b/marker2/ds9/EFTA00086996/EFTA00086996.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1148a971f66ad3610099d85d936f15f9ade43e6c --- /dev/null +++ b/marker2/ds9/EFTA00086996/EFTA00086996.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086996.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: Tue, 04 Dec 2018 00:29:10 +0000 EMAIL,!sail + +We've assigned two people who a re w reading the file. We'll let you know when that process is completed and then we'll sit down. We'll get the 302s to you. Thanks + +Assistant Special Agent in Charge Ncw York Field Office Desk Cell + +Original messa e ------- + +From: " (USANYS)" Date: 12' 18 7:17 1'\1 (GMT-05:00) To\_" < >, (NY) (FBI)" Cc: (USANYS)" Subject: Epstein + +Let us know when you think it makes sense to meet jointly with our teams this week to discuss operational steps; in addition, if you could send those 302s we discussed, that would be great. Thanksl + +Chief Public Corruption Unit United States Attorney's Office for the Southern District of New York 1 St. Andrew's Plaza t. \ No newline at end of file diff --git a/marker2/ds9/EFTA00086997/EFTA00086997.metadata.json b/marker2/ds9/EFTA00086997/EFTA00086997.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..aab96f1518a2c940d0765b74b55046f2ddc73643 --- /dev/null +++ b/marker2/ds9/EFTA00086997/EFTA00086997.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086997.pdf", + "engine": { + "marker_major": "2", + "marker_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": 795, + "elapsed_seconds": 0.41, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 29 + ], + [ + "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/EFTA00086997" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086998/EFTA00086998.md b/marker2/ds9/EFTA00086998/EFTA00086998.md new file mode 100644 index 0000000000000000000000000000000000000000..5db46bcae3cbdcf6a53b8b1cc17ef8fde1cda1e9 --- /dev/null +++ b/marker2/ds9/EFTA00086998/EFTA00086998.md @@ -0,0 +1,70 @@ +**From:** "[REDACTED]" +**To:** "[REDACTED]" + +**Subject:** RE: SDNY DAILY NEWS CLIPPINGS; THURSDAY, OCTOBER 21, 2021 + +**Date:** Thu, 21 Oct 2021 21:09:23 +0000 + +**Inline-Images:** image001.png + +--- + +Ha! As of the last time I checked [REDACTED] still had [REDACTED] on the circulation list for Circuit opinions. + +--- + +**From:** [REDACTED] +**Sent:** Thursday, October 21, 2021 4:55 PM +**To:** [REDACTED] +**Subject:** FW: SDNY DAILY NEWS CLIPPINGS; THURSDAY, OCTOBER 21, 2021 + +Note the first person in the To line. Caused me to skim the rest . . . he must get a lot of bounce backs. + +--- + +**From:** [REDACTED] +**Sent:** Thursday, October 21, 2021 1:54 PM +**To:** [REDACTED] + +[REDACTED] + +**Subject:** SDNY DAILY NEWS CLIPPINGS; THURSDAY, OCTOBER 21, 2021 + +![](_page_0_Picture_145.jpeg) + +## SDNY PRESS CLIPPINGS + +[Pain Doctor Accused of Sexually Assaulting Patients Faces New Federal Charges - The New York Times \(nytimes.com\)](https://www.nytimes.com/news/sexuality/assaulting-patients-faces-new-federal-charges-the-new-york-times) + +[Neurologist arrested on federal charges in sex assault probe \(apnews.com\)](https://www.newspaper.com/news/arrested-on-federal-charges-in-sex-assault-probe) + +[Hindenburg Takes Aim At Its Latest Target with \\$1 Million "Bounty" | The Motley Fool](https://www.newspaper.com/news/hindenburg-takes-aim-at-its-latest-target-with-$1-million-bounty-) + +[Hunter Biden pitched himself as expert in Russian oligarch targeted by FBI: Devine \(nypost.com\)](https://www.newspaper.com/news/hunter-biden-pitched-himself-as-expert-in-russian-oligarch-targeted-by-fbi-) + +[What It's Like to Face Larry Ray, Monster of Sarah Lawrence \(nymag.com\)](https://www.newspaper.com/news/what-it's-like-to-face-larry-ray-monster-of-sarah-lawrence-) + +[Big Money in the Running in the Race for New York Governor - THE CITY](https://www.newspaper.com/news/big-money-in-the-running-in-the-race-for-new-york-governor-) + +[Oversight Board slams Facebook for giving special treatment to high-profile users : NPR](https://www.newspaper.com/news/oversight-board-slams-facebook-for-giving-special-treatment-to-high-profile-users-) + +[FBI Releases 2020 Statistics for Law Enforcement Officers Assaulted in the Line of Duty - Histoday](https://www.newspaper.com/news/fbi-releases-2020-statistics-for-law-enforcement-officers-assaulted-in-the-line-of-duty-) + +[Ex-CIA Head Gina Haspel to Advise Super Rich on Risks for Law Firm - Bloomberg](https://www.newspaper.com/news/ex-cia-head-gina-haspel-to-advise-super-rich-on-risks-for-law-firm-) + +[College basketball: Four NCAA cases making key progress - Sports Illustrated](https://www.newspaper.com/news/college-basketball-four-ncaa-cases-making-key-progress-) + +[Epstein's Ranch Had Huge Surveillance Rooms Where He Creeped on Guests, Victim Claims \(thedailybeast.com\)](https://www.newspaper.com/news/Epstein's-Ranch-Had-Huge-Surveillance-Rooms-Where-He-Creeped-on-Guests-Victim-Claims-) + +Nicholas Blase +Spokesman +United States Department of Justice +U.S. Attorney's Office | Southern District of New York + +Nicholas Blase + +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/EFTA00086998/EFTA00086998.metadata.json b/marker2/ds9/EFTA00086998/EFTA00086998.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b321a87e2d7dc06d6ea849f7333512d9f53a3825 --- /dev/null +++ b/marker2/ds9/EFTA00086998/EFTA00086998.metadata.json @@ -0,0 +1,118 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00086998.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3182, + "elapsed_seconds": 55.41, + "image_assets": [ + "_page_0_Picture_145.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "SDNY PRESS CLIPPINGS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 237.32700000000003, + 446.31000000000006 + ], + [ + 479.67300000000006, + 446.31000000000006 + ], + [ + 479.67300000000006, + 468.18 + ], + [ + 237.32700000000003, + 468.18 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Text", + 50 + ], + [ + "Line", + 31 + ], + [ + "Picture", + 2 + ], + [ + "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", + 9 + ], + [ + "Line", + 5 + ], + [ + "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/EFTA00086998" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00086998/_page_0_Picture_145.jpeg b/marker2/ds9/EFTA00086998/_page_0_Picture_145.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..579188da44a087867612351a5feb8e8f629fa8ce --- /dev/null +++ b/marker2/ds9/EFTA00086998/_page_0_Picture_145.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9d949feb6ec27588291cba6909c93c17fa49abc4b354faa0e432465fa239a0b5 +size 12628 diff --git a/marker2/ds9/EFTA00087000/EFTA00087000.md b/marker2/ds9/EFTA00087000/EFTA00087000.md new file mode 100644 index 0000000000000000000000000000000000000000..32f8eff2934a87d8fbdd7211da3e9f6731b6f63f --- /dev/null +++ b/marker2/ds9/EFTA00087000/EFTA00087000.md @@ -0,0 +1,25 @@ +## Aniteb Stain Pistrith (Erfurt SOUTHERN DISTRICT OF NEW YORK + +TO: Estate of Jeffrey Epstein Attn: Darren Indyke and Richard Kahn, Executors + +## 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 flights on private airplanes owned and operated by Jeffrey Epstein, between 1990 and 2005. Records should include, hut not be limited to, flight logs and flight manifests. + +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 24, 2021 + +DAMIAN WILLIAMS United States Attorney for the Southern District of New York + +Assistant United States Attorney New York, New York 10007 Email: Telephone: + +![](_page_0_Picture_13.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00087000/EFTA00087000.metadata.json b/marker2/ds9/EFTA00087000/EFTA00087000.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d759ad64db9afd971507b8d135bad2fe57f5f052 --- /dev/null +++ b/marker2/ds9/EFTA00087000/EFTA00087000.metadata.json @@ -0,0 +1,146 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087000.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1511, + "elapsed_seconds": 0.76, + "image_assets": [ + "_page_0_Picture_13.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Aniteb Stain Pistrith (Erfurt \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 186.66, + 91.53 + ], + [ + 432.89410400390625, + 91.53 + ], + [ + 432.89410400390625, + 129.603515625 + ], + [ + 186.66, + 129.603515625 + ] + ] + }, + { + "title": "GREETINGS:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 56.304, + 223.56000000000003 + ], + [ + 132.25616455078125, + 223.56000000000003 + ], + [ + 132.25616455078125, + 239.4735107421875 + ], + [ + 56.304, + 239.4735107421875 + ] + ] + }, + { + "title": "United States v. 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Fvcaltil +I (21Z;9>"-;600 coved& ril cishmgrestrr.ann + +# BY CERTIFIED MAIL + +Office of the Legal Adviser U.S...rtment of State Suit 600 19th Street, NW Washington, D.C. 20522 + +Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) + +Deal-: + +7 • • L A 201i ("\*" 1 2 A co DD. + +October 14, 2021 + +D IN ITV ONLY CTOR F LEGAL ADVISER + +We represent the defendant, Ghislaine Maxwell, in the above-referenced matter. This letter constitutes a request made pursuant to United States ex. rel. Touhy v. Regan, 340 U.S. 462 (1951) and 22 C.F.R. § 172.3(a)(1) for the production of documents in the possession of the U.S. Department of State at the trial in this case on November 29, 2019 at 9:00 A.M., before the Honorable Alison J. Nathan, United States District Judge. The requested documents are set forth in the attached subpoena. + +In accordance with 22 C.F.R. § 172.5(a), we make the following statement setting forth "the nature and relevance" of the information we seek: + +On March 29, 2021, Ghislaine Maxwell was charged in a superseding indictment with the following offenses: (1) Count One: conspiracy to entice minors to travel to engage in illegal sex acts, (2) Count Two: enticement of a minor to travel to engage in illegal sex acts, (3) Count Three: conspiracy to transport minors with intent to engage in criminal sexual activity, (4) Count Four: transportation of a minor with intent to engage in criminal sexual activity, (5) Count Five: sex trafficking conspiracy, and (6) Count Six: sex trafficking of a minor. The charges relate to an alleged scheme between Ms. Maxwell and Jeffrey Epstein to sexually abuse underaged girls from in or about 1994 to in or about 2004. + +The three individuals listed in the attached subpoena are identified in the superseding indictment as "Minor Victim 1," "Minor Victim 2," and "Minor Victim 3." All three individuals are expected to testify for the government at trial. + +All three of the witnesses traveled internationally during the time period covered by the attached subpoena, and some have alleged that they traveled at the request of, or with the assistance of, Jeffrey Epstein. Because the crimes alleged require interstate or foreign travel, the passport applications for these individuals will be directly relevant at trial. + +If you have any questions or would like to discuss further, please do not hesitate to contact me. + +Sincerely, + +/s/ Christian R. Everdell + +Christian R. Everdell + +COHEN & GRESSER LLP + +800 Third Avenue, 21st Floor + +New York. New York 10022 + +# UNITED STATES DISTRICT COURT + +for the + +Southernasiacjof New York + +United States of America ) + +v. + +Ghislaine Maxwell + +Defendant + +Case No. S2 Cr 330 (AJN) + +#### SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS IN A CRIMINAL CASE + +To. Office of the Legal Adviser, U S. Department of State, Suit 600 19th Street, NW, Washington, D.C. 20522 + +(Name of person to whom this subpoena is directed) + +YOU ARE COMMANDED to produce at the time, date, and place set forth below the following books, papers, documents, data, or other objects: + +See attached rider -- personal appearance is not required if the documents can be produced in advance of the trial date. Please call Christian Everdell at + +Certain provisions of Fed. R. Crim. P. 17 are attached, including Rule 17(O(2), relating to your ability to file a motion to quash or modify the subpoena; Rule 17(d) and (e), which govern service of subpoenas; and Rule 17(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so. + +(SEAL) + +Date: OCT 14 2021 RUBY J. KRAJICK. + +CLERK OF COURT + +Signature of Clerk or Deputy Clerk + +The name, address, e-mail, and telephone number of the attorney representing (name of party) Ms. Ghislaine Maxwell , who requests this subpoena, are: + +Christian R. Everdell, Cohen & Grosser LLP, 800 Third Avenue, New York, NY 10022, + +#### Notice to those who use this form to request a subpoena + +Before requesting and serving a subpoena pursuant to Fed. R. CrinL P. 17(c), the party seeking the subpoena is advised to consult the rules of practice of the court in which the criminal proceeding is pending to determine whether any local rules or orders establish requirements in connection with the issuance of such a subpoena. If no local rules or orders govern practice under Rule 17(c), counsel should ask the assigned judge whether the court regulates practice under Rule 17(c) to I) require prior judicial approval for the issuance of the subpoena, either on notice or ex pane; 2) specify where the documents must be returned (e.g., to the court clerk, the chambers of the assigned judge, or counsel's office); and 3) require that counsel who receives produced documents provide them to opposing counsel absent a disclosure obligation under Fed. R. Crim. P. 16. + +Please note that Rule 17(c) (attached) provides that a subpoena for the production of certain information about a victim may not be issued unless first approved by separate court order. + +Case No. S2 Cr. 330 (AJN) + +## PROOF OF SERVICE + +This subpoena for (name of individual and tide. (Amy) U.S. Department of State was received by me on (date) + +O I served the subpoena by delivering a copy to the named person as follows: + +on (date) ; or + +0 I returned the subpoena unexecuted because: + +Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of + +My fees are \$ for travel and \$ for services, for a total of Y 0.00 + +Date: + +I declare under penalty of perjury that this information is true. + +Server's signature + +Printed name and tide + +Additional information regarding attempted service, etc.: + +Server's address + +### Federal Rule of Criminal Procedure 17 (c), (d), (e), and (g) (Effective 12/1/08) + +#### (c) Producing Documents and Objects. + +- (1) In General. A subpoena may order the witness to produce any books, papers, documents, data, or other objects the subpoena designates. The court may direct the witness to produce the designated items in court before trial or before they am to be ofibred in evidence. When the items arrive, the court may permit the parties and their attorneys to inspect all or part of them. +- (2) Quashing or Modifying the Subpoena. On motion made promptly, the court may quash or modify the subpoena if compliance would be unreasonable or oppressive. +- (3) Subpoena for Personal or Confidential Information About a Victim. After a complaint, indictment, or information is filed, a subpoena requiring the production of personal or confidential information about a victim may be served on a third party only by court order. Before entering the order and unless there are exceptional circumstances, the court must require giving notice to the victim so that the victim can move to quash or modify the subpoena or otherwise object. +- (d) Service. A marshal, a deputy marshal, or any nonparty who is at least I8 years old may serve a subpoena. The server must deliver a copy of the subpoena to the witness and must tender to the witness one day's witness-attendance fee and the legal mileage allowance. The server need not tender the attendance fee or mileage allowance when the United States. a federal officer, or a federal agency has requested the subpoena. +- (e) Place of Service. + - (I) In the United States. A subpoena requiring a witness to attend a hearing or trial may be served at any place within the United States. + - (2) Ina Foreign Country. If the witness is in a foreign country, 28 U.S.C. § 1783 governs the subpoena's service. +- (g) Contempt. The court (other than a magistrate judge) may hold in contempt a witness who. without adequate excuse, disobeys a subpoena issued by a federal court in that district. A magistrate judge may hold in contempt a witness who, without adequate excuse, disobeys a subpoena issued by that magistrate judge as provided in 28 U.S.C. § 636(e). + +**Subpoena Rider** +**Subpoena to the U.S. Department of State** + +**YOU ARE COMMANDED** to produce at the time, date, and place set forth in the subpoena the following books, papers, documents, data, or other objects:\* + +1. 1. All passport applications for the time period **1994 to the present** for the following individuals: + +a. + +[REDACTED] + +[REDACTED] + +[REDACTED] + +1. 2. Please provide a certificate of authenticity from a custodian of records or another qualified employee certifying, pursuant to Rules 902(1) and 803(6) of the Federal Rules of Evidence, that the records responsive to Request #1 are authentic business records maintained by the U.S. Department of State. + +\* Personal appearance is not required if the documents can be produced in advance of the trial date. 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"debug_data/EFTA00087001" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087001/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00087001/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a006d0a7947486095f6864dbaa22b9d186466989 --- /dev/null +++ b/marker2/ds9/EFTA00087001/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:2468c27baad16535e1aed80a7a3b79c79190e03dec7541d73f99f5eb6de0067d +size 2589 diff --git a/marker2/ds9/EFTA00087007/EFTA00087007.md b/marker2/ds9/EFTA00087007/EFTA00087007.md new file mode 100644 index 0000000000000000000000000000000000000000..0e70e347d6e60f13fe3ff92b21f7f382774ed64e --- /dev/null +++ b/marker2/ds9/EFTA00087007/EFTA00087007.md @@ -0,0 +1,34 @@ +## Exhibit K + +![](_page_1_Picture_10.jpeg) + +October 28, 2020 + +The Honorable Alison J. Nathan +United States District Court +Southern District of New York +United States Courthouse +40 Foley Square +New York, NY 10007 + +Your Honor: + +This statement is in support of Guislaine Maxwell's request for bail and her character. + +My name is [REDACTED] + +[REDACTED] I have maintained a fairly close relationship with the entire family for most of my life. I not only got to know the senior Maxwells but also got to know very well their children including Ghislaine, since my age of 15. + +Though I was spending more of my time with the older siblings [REDACTED] I also chose deliberately to spend time with Ian, Kevin and Ghislaine, who were soon going to prep school together during term-time. You need to know that their father was narcissistic, highly controlling and demanding as a father, and let them know early that he was going to leave his large fortune to charity. So all the kids knew they had to "make it on their own" despite the wealth and privilege in which they were growing up. + +As I got to know each of these kids, including Ghislaine, I noticed that early on, every single one worked very hard at their jobs, as neither parent, Bob nor Betty, would easily bear any idleness, and each strove for their father's and mother's respect through that their intelligence and that hard work. So it didn't surprise me that in her prep school classes, as well as her bachelor's and master's work at Oxford, where she'd followed her elder siblings, Ghislaine produced exemplary grades and a reputation as a serious student. I also noticed that personally, Ghislaine was quick-witted, full of initiative and good humor, sincerely caring towards everyone she knew. + +I've maintained a fairly close relationship with the entire Maxwell clan for most of my life. I didn't continue to visit them regularly in England, but I stayed in touch by phone, especially with Philip, Isabel, Betty and Christine from 1962 through the present. I spent time with Betty, Mrs Maxwell, as she needed support, having suddenly been left after the death of Robert Maxwell. Later on, I wrote a book explaining my gratitude to Betty for all she'd taught me about goodness and maturity. When she was finally on her deathbed with Parkinson's in 2013, I was glad Isabel, who was caring for her, read her my book. + +So I am in a position to speak to Guislaine's character. I had gotten to know her vital personality quite well when she was young. And even though I wasn't in direct touch with her later on, all these Maxwell children are quite "tight" - they've always stayed closely in touch with each other. Thus whenever I'd speak to any of her elders – Philip, Anne, Isabel and Christine, I'd also hear reports not just about their own lives and activities, but also Kevin's and Ian's, as well about Ghislaine's life. Her siblings consistently reported for about a decade that she was enjoying life while starting her own charity. + +So what kind of a character is Ghislaine? I can testify without the least doubt that she is mature, sensitive, thoughtful, honest and, like all her siblings, strong-willed, determined and quite obviously grounded in good human values. She does not lie. She is no "chicken" - it would be totally unlike her to run away from the charges leveled against her by the Government. In fact, the idea of not "facing the music" is totally against the values of every single Maxwell, because both their parents always emphasized personal responsibility – specifically to face Bob's temper. These people consider running away their greatest shame. Furthermore, in facing their father's criticisms, they were trained, over and over, to defend themselves with real courage. So I have no doubt that not only did Ghislaine – despite the blaring headlines in the press and the governments' own opposition to bail alleging incorrectly that she is a "flight risk" – made absolutely no attempt to leave the US at any time in 2019, but has stayed to fight the civil accusations against her starting earlier. Nor do I have any doubt whatsoever that she fully intends to defend herself to the limit of her energy based upon her actual innocence and that above all she wants to go to trial and she is categorically not a flight risk. + +Yours sincerely, + +![](_page_2_Picture_8.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00087007/EFTA00087007.metadata.json b/marker2/ds9/EFTA00087007/EFTA00087007.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e20b62ee3e27143d6a8cce9d09f7efcc61128e03 --- /dev/null +++ b/marker2/ds9/EFTA00087007/EFTA00087007.metadata.json @@ -0,0 +1,133 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087007.pdf", + "engine": { + "marker_major": "2", + "marker_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": 4359, + "elapsed_seconds": 8.19, + "image_assets": [ + "_page_1_Picture_10.jpeg", + "_page_2_Picture_8.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Exhibit K", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 206.24400000000003, + 203.31 + ], + [ + 413.1471862792969, + 203.31 + ], + [ + 413.1471862792969, + 255.03216552734375 + ], + [ + 206.24400000000003, + 255.03216552734375 + ] + ] + } + ], + "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", + 18 + ], + [ + "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": [ + [ + "Text", + 7 + ], + [ + "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/EFTA00087007" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087007/_page_1_Picture_10.jpeg b/marker2/ds9/EFTA00087007/_page_1_Picture_10.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a2059c0b8c9ca152489a74f935594b9f3ae07641 --- /dev/null +++ b/marker2/ds9/EFTA00087007/_page_1_Picture_10.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:28ec8913e2cff3ff215cbf1a3a41c96e01f37da9c7443e3402ac4032a2ff6e45 +size 3904 diff --git a/marker2/ds9/EFTA00087007/_page_2_Picture_8.jpeg b/marker2/ds9/EFTA00087007/_page_2_Picture_8.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..0e5f3801162ec59e2fd8276ee3518b7fbf3566dd --- /dev/null +++ b/marker2/ds9/EFTA00087007/_page_2_Picture_8.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:3b731ef6a658c89fb46e867ef4202691294011dc416365ebde572ff4e737df0c +size 3002 diff --git a/marker2/ds9/EFTA00087010/EFTA00087010.md b/marker2/ds9/EFTA00087010/EFTA00087010.md new file mode 100644 index 0000000000000000000000000000000000000000..f06ed0d7403e7ee844e3b303fdd0931dac406bcd --- /dev/null +++ b/marker2/ds9/EFTA00087010/EFTA00087010.md @@ -0,0 +1,25 @@ +## Exhibit L + +![]()4th November 2020 + +Your Honor, + +I am [REDACTED] I have no idea what value, if any, you will place on my words -- but I write anyway in the hope that she can be granted bail. + +We are all living through extraordinary times - across the world people have had their liberties curtailed due to the spread of Covid-19. Here [REDACTED] we are about to enter into another month long lockdown and must stay at home. + +This loss of all our liberties, I think, has had the impact of making us all reflect on what liberties it is we most value - the ability to see our families and friends; the ability to hug them; the ability to feed ourselves and do exercise. + +I appreciate that Ghislaine is one of many in the MDC right now - however it does strike me as deeply troubling that a person - though innocent until proven guilty - can be treated in a way that on any measure is inhumane and degrading. I can think of no justification whatever for her not having been fed properly, or not having access to glasses so she can read, or indeed the majority of the letters I have written to her being sent back. For any trial to be fair, she must have the opportunity to defend herself and to do that she needs a functioning mind - solitary confinement since July and potentially until next July surely puts that at risk. + +I understand you are balancing any perceived risk against the odds of her fleeing - she is of no danger to the public. + +It cannot be beyond the realms of possibility and practicality to define terms that guarantee her presence - not least because I firmly believe she intends to defend herself. She should be allowed to sleep. She should be allowed to eat. She should be allowed to have the support of friends and family as she prepares her defence. + +Her treatment to date feels punitive and unjust. She had ample opportunity to leave the US legally prior to her arrest and did not do so. It is less likely not more likely that she would do so now. + +![]()Since she is no danger and the only fear is flight, I urge you to look at her history of not fleeing and use the practical and technological tools at your disposal to assuage any fears of flight. + +Yours sincerely + +![]() \ No newline at end of file diff --git a/marker2/ds9/EFTA00087010/EFTA00087010.metadata.json b/marker2/ds9/EFTA00087010/EFTA00087010.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3bbddc4ccedd06d4f92f432d676e66304050bed1 --- /dev/null +++ b/marker2/ds9/EFTA00087010/EFTA00087010.metadata.json @@ -0,0 +1,108 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087010.pdf", + "engine": { + "marker_major": "2", + "marker_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": 2197, + "elapsed_seconds": 7.98, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Exhibit L", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 208.692, + 203.31 + ], + [ + 408.6573791503906, + 203.31 + ], + [ + 408.6573791503906, + 255.03216552734375 + ], + [ + 208.692, + 255.03216552734375 + ] + ] + } + ], + "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": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 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/EFTA00087010" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087012/EFTA00087012.md b/marker2/ds9/EFTA00087012/EFTA00087012.md new file mode 100644 index 0000000000000000000000000000000000000000..bcc2f7c8cca40691a8c55990159b09c366c66ade --- /dev/null +++ b/marker2/ds9/EFTA00087012/EFTA00087012.md @@ -0,0 +1,32 @@ +## Exhibit M + +17 November, 2020 + +The Honorable Alison J. Nathan +United States District Court +Southern District of New York +United States Courthouse +40 Foley Square +New York, NY 10007 + +Re: *United States v. Ghislaine Maxwell*, 20 Cr. 330 (AJN) + +Confidential Letter in Support of Ghislaine Maxwell + +Your Honor, + +I, [REDACTED] am petitioning the court to release on bail [REDACTED] Ms. Ghislaine Maxwell. It is my belief that she is of good character to warrant this release. I am also setting aside cash money in case it is needed as security for her bond. [REDACTED] + +[REDACTED] We have always been close to Ghislaine's family. [REDACTED] + +[REDACTED] We have all remained close, I would dine with Ghislaine a few times a year and she came over to my place of business for a lovely lunch the Summer before last. + +I live in [REDACTED] and have six-decade roots in that community. I am on staff at [REDACTED] I've worked there for nearly three decades as [REDACTED] and am a respected member [REDACTED] + +I have a reputation to hold fast. I treat this petition seriously. I don't have lots of cash, but I am putting up \$ 2,000 as bond towards her bail because I believe in Ghislaine's innocence and I believe that the only way Ms. Maxwell will be able to defend herself against the charges is out on bail. Her conditions of confinement are extreme even for the BOP. + +As to her "fleeing" she didn't before, she won't. I believe that. The Court should release her on bail. + +Respectfully, + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00087012/EFTA00087012.metadata.json b/marker2/ds9/EFTA00087012/EFTA00087012.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2e37447091f9828f4455cd20b39a9fbaae058c25 --- /dev/null +++ b/marker2/ds9/EFTA00087012/EFTA00087012.metadata.json @@ -0,0 +1,100 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087012.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1503, + "elapsed_seconds": 5.67, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Exhibit M", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 201.96000000000004, + 203.31 + ], + [ + 415.97747802734375, + 203.31 + ], + [ + 415.97747802734375, + 255.03216552734375 + ], + [ + 201.96000000000004, + 255.03216552734375 + ] + ] + } + ], + "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", + 26 + ], + [ + "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/EFTA00087012" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087014/EFTA00087014.md b/marker2/ds9/EFTA00087014/EFTA00087014.md new file mode 100644 index 0000000000000000000000000000000000000000..79f3f8f2cd43e4e4ed5566d105605bfb3ae472ea --- /dev/null +++ b/marker2/ds9/EFTA00087014/EFTA00087014.md @@ -0,0 +1,28 @@ +## Exhibit N + +![](_page_1_Picture_253.jpeg) + +December 1st 2020 + +The Honorable Alison J. Nathan +United States District Court +Southern District of New York +United States Courthouse +40 Foley Square +New York, NY 10007 + +**Ghislaine Maxwell** + +Your Honor, + +Ghislaine has been a friend of mine for over 25 years. + +![](_page_1_Picture_259.jpeg) + +Ghislaine, without judgment or prejudice, offered me a roof over my head [REDACTED] free of charge or bill payments until I could get back on my feet so to speak. I had nothing to give her and she had nothing to gain from me living there. Given those circumstances I think it says a great deal about Ghislaine's moral character: in particular her loyalty and kindness towards someone who could offer her nothing in return. When another friend subsequently offered to pay rent for me this was still at a substantially lower than market rate. + +I want to conclude by saying that never in my wildest dreams do I think Ghislaine could be guilty of the terrible charges against. Like anyone charged with any crime, she is innocent unless proven guilty and has a right to due process and humane treatment and should be treated accordingly. + +Yours respectfully, + +![](_page_1_Picture_263.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00087014/EFTA00087014.metadata.json b/marker2/ds9/EFTA00087014/EFTA00087014.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ec033474afdd415b1cbcb5837da0d91a469b7d22 --- /dev/null +++ b/marker2/ds9/EFTA00087014/EFTA00087014.metadata.json @@ -0,0 +1,116 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087014.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1243, + "elapsed_seconds": 4.54, + "image_assets": [ + "_page_1_Picture_253.jpeg", + "_page_1_Picture_259.jpeg", + "_page_1_Picture_263.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Exhibit N", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 206.24400000000003, + 203.31 + ], + [ + 412.016357421875, + 203.31 + ], + [ + 412.016357421875, + 255.40216064453125 + ], + [ + 206.24400000000003, + 255.40216064453125 + ] + ] + } + ], + "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": [ + [ + "Span", + 220 + ], + [ + "Line", + 23 + ], + [ + "Text", + 17 + ], + [ + "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/EFTA00087014" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087014/_page_1_Picture_253.jpeg b/marker2/ds9/EFTA00087014/_page_1_Picture_253.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..88ff44d280524d70938676d04d44722a4800ee39 --- /dev/null +++ b/marker2/ds9/EFTA00087014/_page_1_Picture_253.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9acd6446ec6b17477b49f9deab613f108298443f253e4b45e621754d74a87509 +size 1874 diff --git a/marker2/ds9/EFTA00087014/_page_1_Picture_259.jpeg b/marker2/ds9/EFTA00087014/_page_1_Picture_259.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..c473fb6775b799b08b1d823a6ea0465f082fefdd --- /dev/null +++ b/marker2/ds9/EFTA00087014/_page_1_Picture_259.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:f9b747fb76a464f2e194883fc510884f8b220dc5140c6cf2eed3e4e06484166b +size 13253 diff --git a/marker2/ds9/EFTA00087014/_page_1_Picture_263.jpeg b/marker2/ds9/EFTA00087014/_page_1_Picture_263.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..74848184009d869882296cc00da811928239e569 --- /dev/null +++ b/marker2/ds9/EFTA00087014/_page_1_Picture_263.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:2f0488381b511e1d51e8a441eb38fa13e5c04efd61e76634cb0b15777fbc97e4 +size 2597 diff --git a/marker2/ds9/EFTA00087016/EFTA00087016.md b/marker2/ds9/EFTA00087016/EFTA00087016.md new file mode 100644 index 0000000000000000000000000000000000000000..aab8b70de132d7b003a481d7ff83db719e9aa2b8 --- /dev/null +++ b/marker2/ds9/EFTA00087016/EFTA00087016.md @@ -0,0 +1,49 @@ +![](_page_0_Picture_1.jpeg) + +United States Attorney Southern District of New York + +86 Chambers Street New York, New York 10007 + +December 7, 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") seeking the release of certain records related to Jeffrey Epstein. BOP respectfully requests that that the deadline for BOP to produce any additional non-exempt material in response to plaintiff's FOIA request be extended from December 11, 2020, to January 8, 2021, and that the deadlines for the remaining submissions in this action be extended accordingly: from December 18, 2020, to January 15, 2021, for the government's opposition and reply papers and from January 13, 2021, to February 10, 2021, for plaintiff's reply papers. This is BOP's first request for an extension of the December 11 production deadline and its sixth request to extend or stay the summary judgment schedule overall. See ECF Nos. 16, 18, 28, 30, 32. The Court granted BOP's prior requests. See ECF Nos. 17, 19, 29, 31, 33. Plaintiff's counsel consents to the present request. + +Since its November 6, 2020, letter to the Court, BOP has made progress in reviewing the materials produced to it by OIG and, as anticipated, has been able to review the records on an expedited basis because of the presence of duplicative or non-responsive records in the production. See ECF No. 34. However, as noted as a possibility in BOP's November 6, 2020, letter, BOP needs additional time to complete its review of the production from O1G. BOP estimates that over two thousand five hundred pages of records remain to be reviewed, but, based on its progress so far, BOP anticipates it can complete its review of these remaining pages by later this month.' After BOP completes its review, other components of the Department of Justice, including the United States Attorney's Office for the Southern District of New York, will need to complete their review of any additional material determined to be responsive by BOP. Taking into account the upcoming holidays, an extension until January 8, 2021, should allow for sufficient time to complete these review processes and to finalize any production of any additional non-exempt material. After that production, BOP anticipates needing one week, until January 15, 2021, to finalize its remaining briefing and any supplemental declarations. Plaintiff, + +&#x27; The parties have agreed that BOP will not review email records provided from OIG to BOP, except for any emails sent to or from Epstein himself while he was held at the Metropolitan Correctional Center. + +which has consented to the proposed schedule, would have until February 10, 2021, to file its reply papers. + +I thank the Court for its consideration of this submission. + +Respectfully submitted, + +AUDREY STRAUSS Actin United States Attorney + +By: Is/ + +Assistant United States Attorney 86 Chambers Street, 3`d Floor New York, NY 10007 + +Tele hone: + +Fax: + +Email: + +Cc (by ECF): Counsel of Record + +Granted. Defendant shall produce any additional non-exempt material to plaintiff by January 8, 2021. Defendant's opposition brief and reply in support of its own motion, and any additional supporting declarations, are due by January 15, 2021. Plaintiff's reply is due by February 10, 2021. The Court does not expect to grant further extensions absent extraordinary circumstances. + +SO ORDERED. + +PoAti A. PAUL A. ENGp AYE United States District Judge + +December 8, 2020 \ No newline at end of file diff --git a/marker2/ds9/EFTA00087016/EFTA00087016.metadata.json b/marker2/ds9/EFTA00087016/EFTA00087016.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9f905516197cb3aa8f81bf3640b13890b3b2a337 --- /dev/null +++ b/marker2/ds9/EFTA00087016/EFTA00087016.metadata.json @@ -0,0 +1,153 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087016.pdf", + "engine": { + "marker_major": "2", + "marker_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": 3821, + "elapsed_seconds": 0.95, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 319.464, + 32.400000000000006 + ], + [ + 464.119140625, + 32.400000000000006 + ], + [ + 464.119140625, + 46.7335205078125 + ], + [ + 319.464, + 46.7335205078125 + ] + ] + }, + { + "title": "By ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 147.42000000000002 + ], + [ + 115.8724365234375, + 147.42000000000002 + ], + [ + 115.8724365234375, + 160.38 + ], + [ + 68.544, + 160.38 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 89 + ], + [ + "Line", + 45 + ], + [ + "Text", + 8 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "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", + 59 + ], + [ + "Line", + 28 + ], + [ + "Text", + 15 + ], + [ + "PageHeader", + 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/EFTA00087016" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087016/_page_0_Picture_1.jpeg b/marker2/ds9/EFTA00087016/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..cb663734626b93c7e3a160be98c16c147d1fc8a4 --- /dev/null +++ b/marker2/ds9/EFTA00087016/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:40ca63e6994acb34871415ca8e67712c10990e3fec77daf6cbbe8f1ee28b5e3f +size 3732 diff --git a/marker2/ds9/EFTA00087018/EFTA00087018.md b/marker2/ds9/EFTA00087018/EFTA00087018.md new file mode 100644 index 0000000000000000000000000000000000000000..d0190b18ca35f912f43a325f6d65d8b8da6af0d0 --- /dev/null +++ b/marker2/ds9/EFTA00087018/EFTA00087018.md @@ -0,0 +1,9 @@ +From: To: + +Subject: Accepted: Jason Mojica Proffer (Ordered) (re Epstein) + +Date: Wed, 04 Sep 2019 16:44:14 +0000 + +Importance: Normal + +Attachments: unnamed \ No newline at end of file diff --git a/marker2/ds9/EFTA00087018/EFTA00087018.metadata.json b/marker2/ds9/EFTA00087018/EFTA00087018.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..84ed52038be15bb233964c688f98a06aa6eae8ec --- /dev/null +++ b/marker2/ds9/EFTA00087018/EFTA00087018.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087018.pdf", + "engine": { + "marker_major": "2", + "marker_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": 154, + "elapsed_seconds": 0.34, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Line", + 7 + ], + [ + "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/EFTA00087018" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087019/EFTA00087019.md b/marker2/ds9/EFTA00087019/EFTA00087019.md new file mode 100644 index 0000000000000000000000000000000000000000..7d9c0f6c79fd7d2898df71c0d0ad468717a20fac --- /dev/null +++ b/marker2/ds9/EFTA00087019/EFTA00087019.md @@ -0,0 +1,19 @@ +To: + +Cc: + +Subject: Re: Epstein + +Date: Wed, 04 Sep 2019 19:03:22 +0000 + +Importance: Normal + +We're both around. When works for you? + +Sent from my iPhone + +> On Sep 4, 2019, at 2:59 PM, wrote: + +> Can we briefly discuss at some point? + +> Sent from my iPhone \ No newline at end of file diff --git a/marker2/ds9/EFTA00087019/EFTA00087019.metadata.json b/marker2/ds9/EFTA00087019/EFTA00087019.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0aa7b4016dfa0ed43ebe30cc31a2876464900f57 --- /dev/null +++ b/marker2/ds9/EFTA00087019/EFTA00087019.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087019.pdf", + "engine": { + "marker_major": "2", + "marker_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": 252, + "elapsed_seconds": 0.66, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "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/EFTA00087019" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087020/EFTA00087020.md b/marker2/ds9/EFTA00087020/EFTA00087020.md new file mode 100644 index 0000000000000000000000000000000000000000..d584c8cbfcf2c08370a0000771ec4e5d6c27edf1 --- /dev/null +++ b/marker2/ds9/EFTA00087020/EFTA00087020.md @@ -0,0 +1,66 @@ +**To:** [REDACTED] + +**Subject:** Re: annoying but important project + +**Date:** Wed, 24 Apr 2019 01:38:53 +0000 + +**Importance:** Normal + +--- + +Will do. + +Sent from my iPhone + +On Apr 23, 2019, at 20:09 [REDACTED] vrote: + +Hey we got an additional small production in today – could you please do the same thing for the files here: + +[REDACTED] +thank you!! + +--- + +**From:** [REDACTED] + +**Sent:** Monday, April 22, 2019 14:13 + +**To:** [REDACTED] + +**Subject:** RE: annoying but important project + +This is all set. Let me know if you want anything changed. + +--- + +**From:** [REDACTED] + +**Sent:** Monday, April 22, 2019 12:35 PM + +**To:** [REDACTED] + +**Subject:** RE: annoying but important project + +I've unzipped all of these locally. Do you want them re-saved in that same folder? + +--- + +**From:** [REDACTED] + +**Sent:** Saturday, April 20, 2019 12:55 PM + +**To:** [REDACTED] + +**Subject:** annoying but important project + +Hey – I have a project that's kind of painstaking, which I apologize for, but it's really important (to have it done correctly) – we've received a significant production in the Epstein case that's mostly in .zip folders, saved here: + +W + +I started trying to unzip them into that folder, but I keep getting error messages – I think each one needs to be unzipped to a desktop or local drive, and then Beyond Compare copied back into the share drive. Could you please do that for us? Anything in each particular zip file (there are 16 total) can be unzipped into a folder with the same name as the original .zip file, and then let's just put all the zip files in a separate folder so we have them just in case. + +Do you have the bandwidth to do this sometime Monday? Thank you, and sorry to come to you for this rather than IT or an intern or something, we just want to make sure nothing gets lost in the various transfers. Or let me know if you're swamped Monday, too. + +thank you! + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00087020/EFTA00087020.metadata.json b/marker2/ds9/EFTA00087020/EFTA00087020.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..94c88a17f108156b71fdfe7c793dbd837c488539 --- /dev/null +++ b/marker2/ds9/EFTA00087020/EFTA00087020.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087020.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1939, + "elapsed_seconds": 6.8, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "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": 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/EFTA00087020" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087022/EFTA00087022.md b/marker2/ds9/EFTA00087022/EFTA00087022.md new file mode 100644 index 0000000000000000000000000000000000000000..027caa8b0bd1b77889190d35caa8ca0ff390425e --- /dev/null +++ b/marker2/ds9/EFTA00087022/EFTA00087022.md @@ -0,0 +1,40 @@ +From: To: Cc: + +Subject: RE: US v. Epstein + +Date: Thu, 15 Oct 2020 18:12:23 +0000 + +Inline-Images: image001.jpg: image002.jpg + +Thanks very much, =I. + +The searches in the US v. Epstein database look good to me. Those materials are ready stamp as set out in my prior email. + +I'll review the searches in US v. Epstein (SW) now. + +From: + +Sent: Thursday, October 15, 2020 12:19 PM + +To: + +Cc: + +Subject: US v. Epstein + +Hello, + +Can you please review the following searches + +US v. Epstein database: + +- Q 01.Produce As Confidential Q 01.Produce As Highly Confidential +- Q 01.Produce As Is + +US v. Epstein (SW) + +Q Epstein • Junk Search Terms (From) Q Epstein - Junk Search Terms (Keywords) + +Please let me know if there are any questions. + +Thank you. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087022/EFTA00087022.metadata.json b/marker2/ds9/EFTA00087022/EFTA00087022.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9bb24cf08a45675d13cff3a6fe3206e9a432b22b --- /dev/null +++ b/marker2/ds9/EFTA00087022/EFTA00087022.metadata.json @@ -0,0 +1,62 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087022.pdf", + "engine": { + "marker_major": "2", + "marker_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": 733, + "elapsed_seconds": 1.0, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 26 + ], + [ + "Text", + 21 + ], + [ + "ListGroup", + 2 + ], + [ + "ListItem", + 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/EFTA00087022" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087023/EFTA00087023.md b/marker2/ds9/EFTA00087023/EFTA00087023.md new file mode 100644 index 0000000000000000000000000000000000000000..e094d50296c475c1edd41cd4d4acd8a0e9ba04b1 --- /dev/null +++ b/marker2/ds9/EFTA00087023/EFTA00087023.md @@ -0,0 +1,31 @@ +## FEDERAL BUREAU OF INVESTIGATION + +Electronic Communication + +Title: (U//FOUO) INTERVIEW OF Date: 12/04/2018 + +Drafted By: Missing + +Case ID #: 31E-MM-NEW (U) EPSTEIN, JEFFREY + +Details: 01/10/2007 West Palm Beach, Florida, the sexual exploitation of of the interviewing agents provided the following information: throw h his irlfriend and ol, le datin again when, through had not yet turne !!!!!" the month of May. apartment complex located !!!!!!!! ii on the left side of the street. approximately one month later e rent for the apartm nt. between \$980.00 - \$1200.00. EPSTEIN's Personal Assistant. massages to EPSTEIN. perform massages for was interviewed in regarding a federal investigation involving minors. After being advised of the identity and the nature of the interview, first met JEFFREY EPSTEIN date of birth both of them dropping out 1 first and stopped attending around his 10th grade year. They began a mutual friend, they ran into each other. n and was residing at believed it may have , an moved in with stated that EPSTEIN believed the rent was who had no h r job, was stated was also to lo According to with EPSTEIN, accompanying him on trips had lust returned from a reunited, believed at EPSTEIN's island. When asked was sexual involved with EPSTE asked ner, but that he was not stupid. provided n 1 females to traveled frequently. stated rip with EPSTEIN when he and was with EPSTEIN in New the interviewing agent if stated he never continued statin•, said that was paid w they both transported females to the i benefitte• rom the money rair.i was paying . stated EPSTEIN r so t illilluld would be paid \$200.00 by that he provide EPSTEIN drove a to drive EPSTEIN with a massage. for driving or bringing females to the EPSTEIN residence. He red Dodge Dakota or sometimes white Pontiac Grand AM transport th ef~f males. On occasion, had friends that would with him. also found other females to perform massages + +1 Document Classification Required) + +Title: (U//FOUO) INTERVIEW OF + +Re: 31E-MM-NEW, 12/04/2018 + +for EPSTEIN. said they would find females at different iiiies: the mall, the clubs or the schools. said that area code 212) or GHISALINE MAXWELL would also call and ask him to i k a specific girl and bring them to EPSTEIN's residence. + +believed MAXWELL was EPSTEIN's wife at first, but he knows now that was not the case. EPSTEIN's residence, while waitin for a female, he would, on occasion, see EPSTEIN's chef. described him as a Spanish guy with dark hair. said that sometimes after he had taken the females to EPSTEIN' residence, he would from EPSTEIN. explained stating go on their own or they would brin remember the names of two girls, taken to EPSTEIN's residence. Whe he recalled someone by the name of attende females workin for EPSTEIN. He said that he recruit d I to work for EPSTEIN. wa llllll s-twenty paid for her to attend a school specializing in massages. was there for a month, he received a letter from would not be returning and has not seen nor heard from that he still has her dog. telephone bill that take had no association with EPSTEIN. reimburse his parents. e to the fact that said that EPSTEIN whereabouts and if h EPSTEIN knew where sending her to that said him were stated that heard a n not receive that the w femal and by the the \$200.00 fee ould either could only that he had sewing agent if he stated that she had d she wa and his parents had to care of phone bill when he was at the were over as since that time. stated also went on to sa that he has a pay. told upon return from about the bill because of said that he would like tually stopped working did not return from another ne of the rhad basu toet when a to i• after OM that from aus std the one resp he had loved he and EPSTEIN had argued about not returning. that EPSTEIN of him o make su females the he brought to eighteen. said he was the driver and working for as an easy way to make \$200.00 for 30-45 minutes work. said that he had never been upstairs in EPSTEIN's residence. has also never traveled with EPSTEIN. said that EPSTEIN had given him \$500.00 in cash to help pay off car tickets. 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After being advised of the identity of the interviewing Agents and the nature of the interview, provided the following information: + +advised interviewing agents that approximately 5 years ago he was deposed by BRAD EDWARDS for a lawsuit pertaining to GHISLAINE MAXWELL. Additionally he recalled speaking with the FBI around the time that JEFFREY EPSTEIN first went to jail. + +currently lives with his parents in Georgia where he has been for the last ear and a half. He has a girlfriend who has 2 children. has a biological son who lives with his mother in Kansas City. works at Longhorn Steakhouse as a server. + +was born in Plantation Florida, and lived there and around South Florida until he was about 25 years old. After 25 he moved back and forth between Georgia and Florida. + +attended several high schools including Piper High School, Royal Palm, Wellington, Gold Coast, South Area and Survivor Charter School. He eventually received his GED and then continued on to work in various restaurants at various positions up until current day. + +described that he briefly dated when he was approximately in 10th grade. She stayed at is house. At some point M I brother picked her up and she went to rehab. does not see again until he is about 18 years old. + +described being at his friend JJ's apartment and seeing a picture aof on his refrigerator. They talked about and JJ advised that she was currently going by i t, living at this apartment + +New York, New York, United States (, Other (Video invcstigationon 08/19/2020 at Conference)) + +This document contains neither recommendations nor conclusions of the FBI. It is the piupu ty 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 08/19/2020 m g, 2 of 4 + +and engaged to a man named Additionally he learned fromEthat was working for a rich guy in Palm Beach as a traveling massage therapist. He learned that she was only at the apartment about two weeks out of the month because the other 2 weeks she traveled with this man (EPSTEIN). + +The next day while at this apartment reconnected. Within two weeks, kicked everyone else out of the apartment, dating again. returned home and she and broke off her engagement, moved in and they began + +continued to work for EPSTEIN after this time and would travel with him on and off for two weeks at a time, leaving home at the apartment. She would go to Santa Fe, New York and the Island. learned that EPSTEIN was paying for the apartment, but did not meet him right away. would either get picked up or dropped off. At the time, had told the was a masseuse but had assumed that there was more going on. knew that had previously worked at Mar-A-Lago and thought she met MAXWELL there. + +A few months into being back with dropped her off at EPSTEIN's house as she was going on i went inside the house and met EPSTEIN in the kitchen. EPSTEIN said they were traveling somewhere but does not recall where. + +Sometime later, askde wanted to make money giving EPSTEIN mas knows more irls to give massages then much. recruited wanted to a few girls and more girls. if he knew any other girls that She tells that if he will not have to go over as see his girlfriend more so he helped. then EPSTEIN would try to get those girls to bring + +a recalled two girls' names that he recruited, and told these girls that there was a guy that likes to get massages. He stated that he went to with and she was one of his friend's girlfriends. \$200 in cash for each girl. EPSTEIN would be the only person to pay EPSTEIN would pay would drive the girls he knew to EPSTEIN's and he would get paid when he brought them. If EPSTEIN liked them enough he would + +Continuation of FD-302 of (U) Interview of a 08/19/2020 ,page 3 of 4 + +stay in touch with them and get them their own rides. + +met MAXF uple of times in which they would talk for a couple of minutes. doesn't recall MAXWELL calling him but stated he thought called him. + +would talk about MAXWELL and EPSTEIN. told she and MAXWELL would go out and get girls together for EPSTEIN. that + +was asked if he recalled a girl named stated that he thought that his friend. He said, "it's was the girl who he brought over who was dating (not ". When asked to describe he stated she had brought to EPSTEIN. thought that would tell that there was a guy that wanted to get massages. They would say at sometimes the guy (EPSTEIN) would ask the girls to do more than massage and sometimes girls would get paid more to do so, but you did not have to do more. + +was asked if he recalled the name thought that was last name. described him as a skinny white dude. to which he stated he boyfriend. He did not recall the boyfriend's + +was asked if the name stated he was not sure. sounded familiar to which he + +stated at some went to . After that, EPSTEIN called a few times asking him about married. whereabouts. told at some point while away that she was getting + +EPSTEIN would tell to make sure the girls are 18 years old. As far as knew they were all his age at the time. EPSTEIN said to make sure they are not fat. + +was directed to a statement he previously made to the FBI in which he stated MAXWELL would call him and "ask him to pick up a specific girl and bring them to EPSTEIN's residence" (31E-MM-108062 serial # 104). stated he did not recall making that particular statement. He said that MAXWELL may have called him once or twice but he did not really + +ContthmtionofFD402of (13) Interview of on 08/19/2020 ins, 4 of 4 + +deal with her. only met her a handful of times. + +for EPSTEIN would give cash. EPSTEIN said that he would pay phone bill when he was talking with while she was in EPSTEIN paid for anything. was living with his parents back then and said, "you know EPSTEIN will pay for it when I come back...he will take care of it". The bill racked up and EPSTEIN never paid for it and parents eventually paid for it. + +EPSTEIN would call cell phone after call every other day looking for her. left. He would + +EPSTEIN would not contact if wasn't around other than the time she was in would ask to get girls with her. Sometimes would call when she was with EPSTEIN and ask for girls for when they returned to Florida. + +was approached by MAXWELL at Mar-A-Lago. MAXWELL were together. said she and sexually active with each other and would go out and get girls + +had gotten a call from someone working on ibook to fact check. 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Epstein + +Date: Thu, 15 Oct 2020 19:54:54 +0000 + +Inline-Images: image00 ljpg; image002.jpg + +I am assuming that when we run the responsiveness terms and e-mail addresses we are excluding the junk documents correct? Also, once the search for the responsiveness terms are run what do you want to do with the documents? Will you be conducting a review and will I need to batch these documents out for you? + +From: Sent: Thursday, October 15, 2020 3:41 PM To: Cc: Subject: RE: US v. Epstein + +Thanks =. I think we'd like to scrap this second search entirely. So please only keep the first search entitled "Epstein — Junk Search Terms (From)" and tag those hits as junk. Please run the responsiveness search terms on all of the remaining documents. + +From: Sent: Thursday, October 15, 2020 3:11 PM To: > Cc: Subject: RE: US v. Epstein >; + +The searches were run on the e-mails and the attachments. Do you not want the searches run on the full families? + +From: Sent: Thursday, October 15, 2020 3:06 PM To: Cc: Subject: RE: US v. Epstein + +I've reviewed the searched in US v. Epstein (SW). The search entitled "Epstein —Junk Search Terms (From)" looks good to me. Please tag all of those as junk. + +The search entitled "Epstein — Junk Search Terms (Keywords)" seems to have caught up a number of documents that are not junk and appear responsive to the warrant. It's not clear to me why that happened—the ones I'm seeing don't appear to have any of the keywords on the attached list. Is there a reason that would be? Also, I realized that this search caught up a number of non-email documents. Would it be possible to run this search only on emails files, please? + +From: Sent: Thursday, October 15, 2020 2:12 PM + +To: Cc: Subject: RE: US v. Epstein + +Thanks very much, =I. + +The searches in the US v. Epstein database look good to me. Those materials are ready stamp as set out in my prior email. + +I'll review the searches in US v. Epstein (SW) now. + +From: Sent: Thursday, October 15, 2020 12:19 PM To: Cc: >; Subject: US v. Epstein + +Hello, + +Can you please review the following searches + +US v. Epstein database: + +Q 01.Produce As Confidential -- Q 01.Produce As Highly Confidential Q 01.Produce As Is + +US v. 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The application has not yet been filed, and we don't have a specific briefing schedule or hearing date. We will make sure to keep you updated, but we wanted to touch base in advance to make sure you were aware. As always, please feel free to give us a call if you have any questions or if you'd like to discuss this. + +Thank you, + +Assistant United States Attorney Southern District of New York + +007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00087033/EFTA00087033.metadata.json b/marker2/ds9/EFTA00087033/EFTA00087033.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..63a36e98e55ad37f8fe0eb4130d9792a6a34721b --- /dev/null +++ b/marker2/ds9/EFTA00087033/EFTA00087033.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087033.pdf", + "engine": { + "marker_major": "2", + "marker_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": 600, + "elapsed_seconds": 0.59, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 16 + ], + [ + "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/EFTA00087033" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087034/EFTA00087034.md b/marker2/ds9/EFTA00087034/EFTA00087034.md new file mode 100644 index 0000000000000000000000000000000000000000..dfefa0dbb7e90ff94ad2b146673aa7af61e633e1 --- /dev/null +++ b/marker2/ds9/EFTA00087034/EFTA00087034.md @@ -0,0 +1,308 @@ +From: "Alleyne, Darlene (USANYS)" + +To:' < + +Subject: RE: travel approval request + +Date: Wed, 12 Feb 2020 18:18:08 +0000 + +Importance: High + +Inline-Images: image001.png + +Good afternoon Alison, + +I was able to make reservations for your upcoming trip to Pensacola, FL from 2/18 - 2/19/20. Have you chosen your preferred flight options, or would you like me to send you a few? Let me know so I can complete your flight reservations as well. Thanks as always. + +Darlene Alleyne + +U.S. Attorney's Office (SDNY) + +Legal Assistant, Public Corruption + +(212) 637-2437 + +From: Duncan, Michele (USANYS) + +Sent: Wednesday, February 12, 2020 12:11 PM + +To: Alleyne, Darlene (USANYS) cDAlleyne@usa.doj.goy>; + +Cc: ) + +Subject: RE: travel approval request + +Inquiries/ assistance from a live agent at CWT are free. + +The charge is only incurred if they actually book it for you. + +CWT 877-905-9644 option 1,1,5 + +From: Alleyne, Darlene (USANYS) + +Sent: Wednesday, February 12, 2020 10:49 AM + +To: + +Cc: a; Duncan, Michele (USANYS) + +Subject: RE: travel approval request + +Importance: High + +Maurene, I was in the midst of making your travel reservations, but I'm unable to see the return flight from PNS — LGA departing at 6:44pm on 2/19, arriving at 12:03am on 2/20 that you requested in the attached email below. I assume that it's no longer available. + +The latest flight returning to LGA is leaving at 4:06pm, which I assume is too early. The latest return flight time I found that's fully refundable is departing PNS at 5:53pm, arriving in JFK at 1:24am on 2/20/20. Let me know if this flight is okay to book and I'll reserve it ASAP. Thanks. + +2/19/2020: PNS — JFK (leaving late afternoon / evening) + +ericanAirlines ed, Feb 19 msacola, FL (PNS), 5:53 PM ami, FL (MIA), 8:35 PM ;0 miles + +n raer ERJ-145 + +e iew seat map + +ayover (1h 53m) + +iami, FL (MIA) + +ericanitirlineAs + +e , Feb 19 + +mi, FL (MIA), 10:28 PM + +York, NY (JFK), 1:24 AM Different date Thu, Feb 20 + +2 miles + +1357 + +) ch Unrestricted + +): ing 737-800 + +e iew seat map + +Top of Form + +II available fares for Option 25 + +188.20 + +Govt non-contract fare limited availability + +Bottom of Form + +Darlene Alleyne + +U.S. Attorney's Office (SDNY) + +Legal Assistant, Public Corruption + +(212) 637-2437 + +From: + +Sent: Wednesday, February 12, 2020 10:03 AM + +To: Alleyne, Darlene (USANYS) + +Cc: ) < M>; Duncan, Michele (USANYS) < + +Subject: FW: travel approval request + +Hi Darlene, + +Would you please help us book travel to Pensacola, FL and back for next week? I'd like refundable tickets for the following flights, please: + +- Tuesday 2/18 American Airlines flight from LGA to PNS, departing 5:00 PM, arriving 9:03 PM (layover in DCA) +- Wednesday 2/19 American Airlines flight from PNS to LGA, departing 6:44 PM, arriving 12:03 AM (layover in CLT) + +Please make sure the tickets are refundable just in case we need to move things around. We are still waiting to hear back from the agents about where exactly we should be staying for the hotel, so we'd like to just book the flights for now, and I'll let you know when we have a more precise location for the hotel. + +Thanks very much, + +Maurene + +From: Tyrrell, Edward (USANYS) + +Sent: Wednesday, February 12, 2020 6:43 AM + +To: + +Approved + +Sent from my iPad + +On Feb 11, 2020, at 7:53 PM, wrote: + +Ed, + +Similar to prior requests in connection with the Epstein investigation (2018R01618), Alison and I would like to please request permission for the two of us to travel next week for an interview of a witness in Pensacola, Florida on 2/19. We'd plan to fly down on 2/18 and fly back on 2/19. Also, similar to prior requests, we'd like to request approval to get a conference room on 2/19. + +Thank you, Maurene + +From: Tyrrell, Edward (USANYS) < > + +Sent: Tuesday, January 21, 2020 2:56 PM + +To: + +Cc: c ); / <->; Alleyne, Darlene (USANYS) ; Perez, Cynthia (USANYS) ; Duncan, Michele (USANYS) + +Subject: RE: travel approval request + +Approved + +From: < + +Sent: Tuesday, January 21, 2020 2:49 PM + +To: Tyrrell, Edward (USANYS) , + +Cc: (USANYS) <->; Alleyne, Darlene + +Subject: RE: travel approval request + +Ed, + +Similar to prior requests in connection with the Epstein investigation (2018R01618), but with an added international element, we'd like to please request permission for the team to travel next week for an interview near Stockholm, Sweden, next week on January 29th and/or 30th. We expect to be traveling, respectively, some combination of the 27th (overnight) to the 31st, depending on when the interview ends up being scheduled, and we'll put final dates on our formal applications. Also similar to prior trips, we'd like to request approval to get a conference room for one of those days at a hotel for the interview itself. + +Also based on our discussion earlier we'll be mindful of looking for domestic (or domestic-flagged) carrier flights, as well as the costs of any alternatives, in looking at possible specific bookings. Thanks as always for your help and input on that. + +thank you, Alex. + +To: Tyrrell, Edward (USANYS) : + +Cc: cz ; <->; Darlene A. + +.Alleyne + +Subject: RE: travel approval request + +Ed, + +Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request permission for the team to travel next week for an interview (or possibly interviews) in Los Angeles on December 16 and/or 17. We expect to be traveling, respectively, some combination of the 15th to the 18th. Also similar to prior trips, we'd like to request approval to get a conference room for one of those days. + +thank you, + +Alex. + +From: + +Sent: Tuesday, November 05, 2019 16:53 + +To: Tyrrell, Edward (USANYS) + +Cc: <->; Darlene A. + +.Alleyne C + +Subject: RE: travel approval request + +Ed, + +Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request permission for the team to travel next week for an interview in Los Angeles on November 14. We expect to be traveling, respectively, some combination of the 13th to the 15th (and no conference room necessary for this trip). + +thanks, + +Alex. + +From: + +Sent: Tuesday, October 22, 2019 13:55 + +To: Tyrrell, Edward (USANYS) + +Cc: Duncan, Michele (USANYS) >; + +>; Darlene A. .Alleyne + +Subject: RE: travel approval request + +Ed, + +Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and Maurene, and we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to reserve a conference room at the hotel on that Monday for the interview, please. + +thanks very much, + +Sent: Wednesday, June 12, 2019 14:51 + +To: Tyrrell, Edward (USANYS) •z: > + +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) + +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/EFTA00087034/EFTA00087034.metadata.json b/marker2/ds9/EFTA00087034/EFTA00087034.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..caaa5373b6e54fc451dff23285dd93cf01002b7c --- /dev/null +++ b/marker2/ds9/EFTA00087034/EFTA00087034.metadata.json @@ -0,0 +1,212 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087034.pdf", + "engine": { + "marker_major": "2", + "marker_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": 9837, + "elapsed_seconds": 2.44, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 93 + ], + [ + "Line", + 41 + ], + [ + "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", + 98 + ], + [ + "Text", + 45 + ], + [ + "Line", + 45 + ], + [ + "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", + 85 + ], + [ + "Line", + 39 + ], + [ + "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": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 87 + ], + [ + "Line", + 41 + ], + [ + "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": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 89 + ], + [ + "Line", + 41 + ], + [ + "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": 5, + "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/EFTA00087034" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087040/EFTA00087040.md b/marker2/ds9/EFTA00087040/EFTA00087040.md new file mode 100644 index 0000000000000000000000000000000000000000..c9532ac4cc904eecbc28b4056dc98fde01a42563 --- /dev/null +++ b/marker2/ds9/EFTA00087040/EFTA00087040.md @@ -0,0 +1,55 @@ +To: + +Subject: FW: Final Voucher 10982122(1) prepared by a travel arranger is pending your review Date: Wed, 12 Feb 2020 19:43:30 +0000 + +HMI.- I logged in and tried to approve, but the only option listed for the trip is for me to click "recall." + +From: etravelservices@cwtsatotravel.com + +Sent: Wednesday, February12, 2020 2:32 PM + +To: + +Subject: Final Voucher 10 prepare y a rave arranger is pen ing your review + +Dear + +Final voucher 10982122(1) has been prepared by your travel arranger and is ready for your review. Please log into E2 Solutions to review the document. + +Trip ID: 10982122 + +Voucher ID: 1 + +Voucher type: Final + +Traveler name: + +Purpose: R20NYS 13340 - Epstein investigation (2018R01618) - Witness Interviews + +Destination: Stockholm, Sweden + +Dates: 2020-02-03 - 2020-02-06 + +Current status: Pending Voucher Approval + +Voucher total expenses: 2143.49 + +Estimated trip cost: 2954.54 + +E2 Single Sign On Login (within DOJ Network Only): + +https://dojnet.doj.gov/jmd/fs/e2-redirect.html + +E2 Manual Login (User ID and Password): + +https://e2.gov.cwtsatotravel.com + +Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link. + +Please note: Replies to this mailbox are not monitored. + +Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the emails that you receive from us. + +Reference ID# V0012 + +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/EFTA00087040/EFTA00087040.metadata.json b/marker2/ds9/EFTA00087040/EFTA00087040.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e71fef77f4c9ce17599691d533baaad63970b741 --- /dev/null +++ b/marker2/ds9/EFTA00087040/EFTA00087040.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087040.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1837, + "elapsed_seconds": 1.26, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 36 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00087040" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087041/EFTA00087041.md b/marker2/ds9/EFTA00087041/EFTA00087041.md new file mode 100644 index 0000000000000000000000000000000000000000..37a1df7fd47c087da766bf24521dfa78a700c0ee --- /dev/null +++ b/marker2/ds9/EFTA00087041/EFTA00087041.md @@ -0,0 +1,245 @@ +From: ' To: "Duncan, Michele (USANYS)" < Cc: 'I "< Subject: RE: travel approval request Date: Tue, 18 Feb 2020 16:58:15 +0000 )"< >, "Perez, Cynthia (USANYS)" >, "Alleyne, Darlene (USANYS)" + +Wanted to follow up on this — please let us know? I can call them directly if that's necessary. Thanks! + +From: Sent: Monday, February 17, 2020 13:03 To: Duncan, Michele (USANYS) •: =>; Perez, Cynthia (USANYS) Cc: ) Alleyne, Darlene (USANYS) Subject: FW: travel approval request + +Michele, Cynthia, + +Re: the below, I just got a bounce-back from Darlene that she's out tomorrow. Is this something one of you might be able to check and/or assist with? Or should I just do it myself tomorrow? + +thanks, Alex. + +From: Sent: Monday, February 17, 2020 13:02 To: Alleyne, Darlene (USANYS) Cc: Perez, Cynthia (USANYS) ; • (USANYS) Subject: RE: travel approval request >; Duncan, Michele + +Darlene, + +Wanted to see if you had reserved a conference room for us, per the below from Thursday? I got a confirmation for the hotel (attached) but it doesn't seem to say anything about a conference room. Could you please let us know either way? And if not yet, could you please reserve that for us tomorrow (Tuesday) and let us know when it's finalized? + +thank you! Alex. + +From: Sent: Thursday, February 13, 2020 13:26 To: Duncan, Michele (USANYS) Cc: Perez, Cynthia (USANYS) ; Subject: RE: travel approval request ; Alleyne, Darlene (USANYS) < + +Apologies for the slight delay yesterday on this travel, we had a witness scheduling issue so the travel will be a day later than originally anticipated. The city is Pensacola, Florida, and it will be me and Alison (rather than Maurene and Alison). + +Feb. 19: Delta, LGA to PNS, 9:00 a.m. (arriving 12:49 p.m.) + +Feb. 20: Delta, PNS to LGA, 4:06 p.m. (arriving 9:41 p.m.) + +And the following hotel, for the night of Feb. 19: + +- Hilton Garden Inn (listed in E2 as "HGI PENSACOLA AIRPORT MEDICAL") + +We will also need a conference room at the Hilton Garden Inn for February 19, starting at 5:00 p.m. for three hours (or for the entire day, if that's the only way they'll do it). + +Please let us know if any questions or issues, and thanks as always. + +Alex. + +From: Duncan, Michele (USANYS) + +Sent: Wednesday, February 12, 2020 09:02 + +To: >; + +Alleyne, Darlene (USANYS); •= > + +Cc: Perez, Cynthia (USANYS) + +Subject: Re: travel approval request + +Hi, + +Which specific city will the hotel be in? + +If Darlene could push the travel authorizations thru to Ed & I today, that would be great.... As well as sending the conference room payment request to Nick Siu. + +Remember to take the FL tax exempt form along with you. + +Thanks + +Sent from my iPhone + +On Feb 12, 2020, at 6:43 AM, Tyrrell, Edward (USANYS) <-> wrote: + +Approved + +Sent from my iPad + +On Feb 11, 2020, at 7:53 PM, ) < wrote: + +Ed, + +Similar to prior requests in connection with the Epstein investigation (2018R01618), Alison and I would like to please request permission for the two of us to travel next week for an interview of a witness in Pensacola, Florida on 2/19. We'd plan to fly down on 2/18 and fly back on 2/19. Also, similar to prior requests, we'd like to request approval to get a conference room on 2/19. + +From: Tyrrell, Edward (USANYS) < + +Sent: Tuesday, January 21, 2020 2:56 PM + +To: + +Cc: ; Alleyne, + +Darlene (USANYS) ; Perez, Cynthia (USANYS) ; Duncan, Michele (USANYS) + +Subject: RE: travel approval request + +Approved + +From: + +Sent: Tuesday, January 21, 2020 2:49 PM + +To: Tyrrell, Edward (USANYS) < > + +Cc: ; Alleyne, + +Darlene (USANYS) + +Subject: RE: travel approval request + +Ed, + +Similar to prior requests in connection with the Epstein investigation (2018R01618), but with an added international element, we'd like to please request permission for the team to travel next week for an interview near Stockholm, Sweden, next week on January 29th and/or 30th. We expect to be traveling, respectively, some combination of the 27th (overnight) to the 31st, depending on when the interview ends up being scheduled, and we'll put final dates on our formal applications. Also similar to prior trips, we'd like to request approval to get a conference room for one of those days at a hotel for the interview itself. + +Also based on our discussion earlier we'll be mindful of looking for domestic (or domestic-flagged) carrier flights, as well as the costs of any alternatives, in looking at possible specific bookings. Thanks as always for your help and input on that. + +thank you, + +Alex. + +From: + +Sent: Wednesday, December 11, 2019 09:58 + +To: Tyrrell, Edward (USANYS) < > + +Cc: c > ; Darlene A. + +.Alleyne + +Subject: RE: travel approval request + +Ed, + +Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request permission for the team to travel next week for an interview (or possibly interviews) in Los Angeles on December 16 and/or 17. We expect to be traveling, respectively, some combination of the 15th to the 18th. Also similar to prior trips, we'd like to request approval to get a conference room for one of those days. + +thank you, + +Sent: Tuesday, November 05, 2019 16:53 + +To: Tyrrell, Edward (USANYS) ca. + +Cc: / C> . , <->; Darlene A. + +.Alleyne ( O + +Subject: RE: travel approval request + +Ed, + +Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request permission for the team to travel next week for an interview in Los Angeles on November 14. We expect to be traveling, respectively, some combination of the 13th to the 15th (and no conference room necessary for this trip). + +thanks, Alex. + +From: + +Sent: Tuesday, October 22, 2019 13:55 + +To: Tyrrell, Edward (USANYS) + +Cc: Duncan, Michele (USANYS) + +) < >; Darlene A..Alleyne + +Subject: RE: travel approval request + +Ed, + +Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and Maurene, and we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to reserve a conference room at the hotel on that Monday for the interview, please. + +thanks very much, Alex. + +From: + +Sent: Wednesday, June 12, 2019 14:51 + +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. + +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. + +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/EFTA00087041/EFTA00087041.metadata.json b/marker2/ds9/EFTA00087041/EFTA00087041.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d9deec3045d1aecd25c043c36a2d36b99ca06a12 --- /dev/null +++ b/marker2/ds9/EFTA00087041/EFTA00087041.metadata.json @@ -0,0 +1,204 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087041.pdf", + "engine": { + "marker_major": "2", + "marker_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": 9595, + "elapsed_seconds": 2.15, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 98 + ], + [ + "Line", + 44 + ], + [ + "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", + 75 + ], + [ + "Line", + 36 + ], + [ + "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", + 87 + ], + [ + "Line", + 40 + ], + [ + "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", + 85 + ], + [ + "Line", + 41 + ], + [ + "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": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 39 + ], + [ + "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": 5, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 16 + ], + [ + "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/EFTA00087041" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087047/EFTA00087047.md b/marker2/ds9/EFTA00087047/EFTA00087047.md new file mode 100644 index 0000000000000000000000000000000000000000..ced6184566a206662a6a5aa6647180a6edcd83a1 --- /dev/null +++ b/marker2/ds9/EFTA00087047/EFTA00087047.md @@ -0,0 +1,130 @@ +![](_page_0_Picture_98.jpeg) + +Christian R. Everdell + +[Redacted] + +October 13, 2020 + +**BY EMAIL** + +[Redacted] + +United States Attorney's Office +Southern District of New York + +[Redacted] + +**Re: *United States v. Ghislaine Maxwell*, 20 Cr. 330 (AJN)** + +Dear [Redacted] + +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. 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. 2. We request that the government disclose and identify any statements of alleged co-conspirators that it intends to introduce at trial. +3. 3. We request any prior criminal records of Ms. Maxwell. Fed R. Crim. P. 16(a)(1)(D). +4. 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)(1)(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, + +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.nydailynews.com/new-vork/nvjeffrey-epstein-maxwell-case-20201013-jmzh17zdrzdgrbbs7yc6bfnszustory.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 Alfredo Rodriguez 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. + +1. 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. +2. 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. +3. 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. +4. 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. Maryland*, 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. Agurs*, 427 U.S. 97 (1976). We also make the following specific *Brady* requests: + +1. 1. 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: + 1. 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. + 2. 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. + +c o er Ii, + +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 + +800 Third Avenue, 21st Floor + +New York, New York 10022 + +cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C. 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The Crim team does not know who these victims are. I am going to write back to stating that we cannot process these under pseudonyms, and he should re-submit with names. I assume he will ask to call me and tell me the names over the phone. I am going to tell him that we cannot accept that and need complete Touhy requests with names, in writing. Please let me know if you have any concerns with this approach. + +Thanks, + +From: S (USANYS) + +Sent: Wednesday, September 9,2020 3:56 PM + +To: (USANYS) + +Cc: cMa ; (USANYS) (USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +This string is a mile long so I'm going to truncate it. + +I think at this point we need to ask 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 it. + +Criminals, anything in particular you would like 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/EFTA00087055/EFTA00087055.metadata.json b/marker2/ds9/EFTA00087055/EFTA00087055.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cd3986e47b7632d00da6e21fcae1417fa92bd5b5 --- /dev/null +++ b/marker2/ds9/EFTA00087055/EFTA00087055.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087055.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1798, + "elapsed_seconds": 0.89, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00087055" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087056/EFTA00087056.md b/marker2/ds9/EFTA00087056/EFTA00087056.md new file mode 100644 index 0000000000000000000000000000000000000000..84a1cb6562833d65fd415bc762e1156893f4b343 --- /dev/null +++ b/marker2/ds9/EFTA00087056/EFTA00087056.md @@ -0,0 +1,64 @@ +![](_page_0_Picture_0.jpeg) + +EDWARDS POTTING ER LLC + +Florida Office + +Bradley J. Edwards "01 Seth M. Lehrman "t 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 + +do Assistant United States Attorney 86 Chambers Street, Third Floor New York, New York 10007 + +Dear + +425 North Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 + +Telephone (954)524-2820 Fax (954)524-2822 + +October 15, 2020 + +New York Office J. Stanley Pottinger + +Admitted in California 0 Admitted in District of C.olumbia • Admitted in florid t Admitted in Net York I Dowd Certified Trial knqtr + +Re: Re uest for Tangible and Documentary Evidence (Touhy Request) v. Darren K. Indyke, 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, .1 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. + +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 assaulted 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 + +&#x27; To protect her anonymity, our client has elected to proceed as a 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 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 the sexual abuse of minor children. Given the highly relevant nature of this tangible evidence to currently pending litigation, we request production of documentary evidence relating to 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: + +- 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 + +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. + +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/EFTA00087056/EFTA00087056.metadata.json b/marker2/ds9/EFTA00087056/EFTA00087056.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7818364b8fedd37d8c0940d9de5a33a7ab3e8b36 --- /dev/null +++ b/marker2/ds9/EFTA00087056/EFTA00087056.metadata.json @@ -0,0 +1,172 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087056.pdf", + "engine": { + "marker_major": "2", + "marker_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": 5519, + "elapsed_seconds": 1.02, + "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, + 237.32999999999998 + ], + [ + 217.50064086914062, + 237.32999999999998 + ], + [ + 217.50064086914062, + 252.603515625 + ], + [ + 68.544, + 252.603515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 101 + ], + [ + "Line", + 50 + ], + [ + "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", + 75 + ], + [ + "Line", + 38 + ], + [ + "ListItem", + 12 + ], + [ + "Text", + 5 + ], + [ + "ListGroup", + 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": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 15 + ], + [ + "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/EFTA00087056" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087056/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00087056/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..c8f07118ee6bf82ed7111449dc19e2a37229fe30 --- /dev/null +++ b/marker2/ds9/EFTA00087056/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:7896014b60592e9b261cfd1f166e0839ef61be62d795bf2305e24beca8e0f765 +size 3866 diff --git a/marker2/ds9/EFTA00087059/EFTA00087059.md b/marker2/ds9/EFTA00087059/EFTA00087059.md new file mode 100644 index 0000000000000000000000000000000000000000..545deaee55eba845cf069fdcb55ce67a74473796 --- /dev/null +++ b/marker2/ds9/EFTA00087059/EFTA00087059.md @@ -0,0 +1,64 @@ +![](_page_0_Picture_0.jpeg) + +rrn EDWARDS POTTING ER LLC + +Florida Office + +Bradley J. Edwards \*Of Seth M. Lehrman 't 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 + +do Assistant United States Attorney 86 Chambers Street, Third Floor New York, New York 10007 + +Dear + +425 North Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 + +Telephone (954)524-2820 Fax (954)524-2822 + +October 15, 2020 + +New York Office J. Stanley Pottinger + +Admitted in California 0 Admitted in District of Columbia • Admitted in florid t Admitted in New York I Herald Certified f:iva Trial Latqtr + +Re: Re uest for Tangible and Documentary Evidence (Touhy Request) v. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07771 + +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. Roger:, 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. + +was sexually assaulted by prolific pedophile, Jeffrey Epstein, from 2007 through 2014. From the time the met when she was only seventeen years old, Epstein sexually abused and assaulted in the most horrific ways imaginable. Throughout the years of abuse, Epstein paid for medical treatments, provided legal counsel, purchased a number of commercial flights, + +&#x27; To protect her anonymity, our client has elected to proceed as a 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. + +provided housing, and purchased a number of items of value for , 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 the sexual abuse of minor children. Given the highly relevant nature of this tangible evidence to currently pending litigation, we request production of documentary evidence relating to 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: + +- I) Photographs of +- 2) Videos of +- 3) Any and all correspondence between Jeffrey Epstein, his agents, employees, medical providers, or attorneys and M=; +- 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 + +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. + +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/EFTA00087059/EFTA00087059.metadata.json b/marker2/ds9/EFTA00087059/EFTA00087059.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..65999d05da925ddf19f552bb1dfbf799600de5a4 --- /dev/null +++ b/marker2/ds9/EFTA00087059/EFTA00087059.metadata.json @@ -0,0 +1,172 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087059.pdf", + "engine": { + "marker_major": "2", + "marker_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": 5596, + "elapsed_seconds": 1.09, + "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, + 238.14 + ], + [ + 217.50064086914062, + 238.14 + ], + [ + 217.50064086914062, + 252.603515625 + ], + [ + 68.544, + 252.603515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 95 + ], + [ + "Line", + 47 + ], + [ + "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", + 77 + ], + [ + "Line", + 39 + ], + [ + "ListItem", + 12 + ], + [ + "Text", + 5 + ], + [ + "ListGroup", + 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": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Line", + 14 + ], + [ + "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/EFTA00087059" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087059/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00087059/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..499e7ef6f9207b8a37cf1fe6b6dad874e2145f79 --- /dev/null +++ b/marker2/ds9/EFTA00087059/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:a33fcea5047a8b072d421f3e4528cdee7a6bb62e5f34b332ea0045ea6985d24c +size 3777 diff --git a/marker2/ds9/EFTA00087062/EFTA00087062.md b/marker2/ds9/EFTA00087062/EFTA00087062.md new file mode 100644 index 0000000000000000000000000000000000000000..95577ee1770142fff3f58acbf394da444db59b75 --- /dev/null +++ b/marker2/ds9/EFTA00087062/EFTA00087062.md @@ -0,0 +1,65 @@ +![](_page_0_Picture_0.jpeg) + +EDWARDS POTTING ER LLC + +Florida Office + +Bradley J. Edwards "Ot Seth M. Lehrman "t 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 + +c/o Assistant United States Attorney 86 Chambers Street, Third Floor New York, New York 10007 + +Dear + +425 North Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 + +Telephone (954)524-2820 Fax (954)524-2822 + +October 15, 2020 + +New York Office J. Stanley Pottinger + +Admitted in California 0 Admitted in District of Columbia • Admitted in Florida t Admitted in Nat York I Hoard Certified Civil Trial Lawyer + +Re: Re uest for Tangible and Documentary Evidence (Touhy Request) V. Darren K. I ndyke, 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. + +was sexually assaulted by prolific pedophile, Jeffrey Epstein, from 2002 through 2010. From the time met when she was only seventeen years old, Epstein sexually abused and assaulted in the most horrific ways imaginable. Throughout the years of abuse, Epstein paid for medical treatments, provided legal counsel, purchased a number of commercial flights, + +&#x27; To protect her anonymity, our client has elected to proceed as a 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. + +provided housing, and purchased a number of items of value for , 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 the sexual abuse of minor children. Given the highly relevant nature of this tangible evidence to currently pending litigation, we request production of documentary evidence relating to 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: + +- 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 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 Doe's 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 justice 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/EFTA00087062/EFTA00087062.metadata.json b/marker2/ds9/EFTA00087062/EFTA00087062.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9d2157ffbcfbebc92c6562dc91ad2bf9c4af649d --- /dev/null +++ b/marker2/ds9/EFTA00087062/EFTA00087062.metadata.json @@ -0,0 +1,172 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087062.pdf", + "engine": { + "marker_major": "2", + "marker_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": 5522, + "elapsed_seconds": 1.06, + "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, + 238.14 + ], + [ + 217.50064086914062, + 238.14 + ], + [ + 217.50064086914062, + 252.603515625 + ], + [ + 68.544, + 252.603515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 100 + ], + [ + "Line", + 49 + ], + [ + "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", + 77 + ], + [ + "Line", + 39 + ], + [ + "ListItem", + 11 + ], + [ + "Text", + 5 + ], + [ + "ListGroup", + 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": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Line", + 14 + ], + [ + "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/EFTA00087062" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087062/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00087062/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..eecfb212d63a47e2faf02bac6cea250b0bc6cb7c --- /dev/null +++ b/marker2/ds9/EFTA00087062/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:aaea9ef06f1ae909a461c40e218d21a07587419fc4ebdda192d351139d2b14c3 +size 3839 diff --git a/marker2/ds9/EFTA00087065/EFTA00087065.md b/marker2/ds9/EFTA00087065/EFTA00087065.md new file mode 100644 index 0000000000000000000000000000000000000000..423fe17de212746286a0d33dcfd8b0edc2592365 --- /dev/null +++ b/marker2/ds9/EFTA00087065/EFTA00087065.md @@ -0,0 +1,61 @@ +![](_page_0_Picture_0.jpeg) + +Florida Office + +Bradley J. Edwards "Of Seth M. Lehrman "t 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 + +do Assistant United States Attorney 86 Chambers Street, Third Floor New York, New York 10007 + +Dear + +EDWARDS POTTING ER LLC + +425 North Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 + +Telephone (954)524-2820 Fax (954)524-2822 + +October 15, 2020 + +New York Office J. Stanley Pottinger + +Admitted in California 0 Admitted in District of C.olumbia • Admitted in llorida t Admitted in Net York I Hoard Certified Trial LatAr + +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, .1 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. + +was sexually assaulted by prolific pedophile, Jeffrey Epstein, from 2002 through 2009. met Epstein just after at a time when she had nothing and no one to turn to. From the time they met when she was only fifteen years old, Epstein sexually abused and assaulted in the most horrific ways imaginable. Throughout the years of abuse, Epstein sent a number of gifts to 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 the sexual abuse of minor children. Given the highly relevant nature of this + +&#x27; To protect her anon miry, our client has elected to proceed as a As such, we have referred to her herein as . Please contact us at your earliest convenience to discuss her true identity. + +tangible evidence to civil claim, we request production of documentary evidence relating to 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: + +- 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)( 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 Doe's 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 + +Bradley Edwards Brittany Henderson \ No newline at end of file diff --git a/marker2/ds9/EFTA00087065/EFTA00087065.metadata.json b/marker2/ds9/EFTA00087065/EFTA00087065.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8184fa795560eb2bcc9d67ec1d0453e0190b2108 --- /dev/null +++ b/marker2/ds9/EFTA00087065/EFTA00087065.metadata.json @@ -0,0 +1,172 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087065.pdf", + "engine": { + "marker_major": "2", + "marker_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": 5037, + "elapsed_seconds": 1.08, + "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, + 238.14 + ], + [ + 217.50064086914062, + 238.14 + ], + [ + 217.50064086914062, + 252.603515625 + ], + [ + 68.544, + 252.603515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 105 + ], + [ + "Line", + 49 + ], + [ + "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", + 77 + ], + [ + "Line", + 38 + ], + [ + "ListItem", + 9 + ], + [ + "Text", + 5 + ], + [ + "ListGroup", + 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": 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/EFTA00087065" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087065/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00087065/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..2733bf41159efb5dd947916e7ca4dda61aab2c60 --- /dev/null +++ b/marker2/ds9/EFTA00087065/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:66c05fb86118f3f153f89c51e34d5ebed91326a497212c899b3e8db86415e4fa +size 3974 diff --git a/marker2/ds9/EFTA00087068/EFTA00087068.md b/marker2/ds9/EFTA00087068/EFTA00087068.md new file mode 100644 index 0000000000000000000000000000000000000000..f307ed004130f69a40495c7485402ad7a4e78066 --- /dev/null +++ b/marker2/ds9/EFTA00087068/EFTA00087068.md @@ -0,0 +1,62 @@ +![](_page_0_Picture_0.jpeg) + +Florida Office + +Bradley J. Edwards \*Of Seth M. Lehrman 't 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 + +c/o Assistant United States Attorney 86 Chambers Street, Third Floor New York, New York 10007 + +Dear + +EDWARDS POTTINGER LLC + +425 North Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 + +Telephone (954)524-2820 Fax (954)524-2822 + +October 15, 2020 + +New York Office J. Stanley Pottinger + +j Admitted in California 0 Admitted in I>istrict of Columbia • Admitted m Florida t Admitted in New York Beard (:cnified Civil Trial lau)vr + +## 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. + +was sexually assaulted by prolific pedophile, Jeffrey Epstein, from 2000 through 2004. From the time the met when she was only thirteen years old, Epstein sexually abused and assaulted in the most horrific ways imaginable. Throughout the years of abuse, Epstein sent a number of gifts to 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 the sexual abuse of minor children. Given the highly relevant nature of this tangible + +&#x27; To protect her anon ity, our client has elected to proceed as a As such, we have referred to her herein as . Please contact us at your earliest convenience to discuss her true identity. + +evidence to 's civil claim, we request production of documentary evidence relating to 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: + +- 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 requested non-privileged documentary evidence directly concerns the allegations in Doe's 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/EFTA00087068/EFTA00087068.metadata.json b/marker2/ds9/EFTA00087068/EFTA00087068.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cf37fbb4acd49a88bf8757201312bfe05fb4b5ae --- /dev/null +++ b/marker2/ds9/EFTA00087068/EFTA00087068.metadata.json @@ -0,0 +1,195 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087068.pdf", + "engine": { + "marker_major": "2", + "marker_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": 4991, + "elapsed_seconds": 1.16, + "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, + 238.14 + ], + [ + 217.50064086914062, + 238.14 + ], + [ + 217.50064086914062, + 252.603515625 + ], + [ + 68.544, + 252.603515625 + ] + ] + }, + { + "title": "Re: Request for Tangible and Documentary Evidence (Touhy Request)", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 105.26399999999998, + 389.61 + ], + [ + 489.0724792480469, + 389.61 + ], + [ + 489.0724792480469, + 405.0 + ], + [ + 105.26399999999998, + 405.0 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 98 + ], + [ + "Line", + 47 + ], + [ + "Text", + 15 + ], + [ + "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", + 75 + ], + [ + "Line", + 38 + ], + [ + "ListItem", + 10 + ], + [ + "Text", + 5 + ], + [ + "ListGroup", + 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": 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/EFTA00087068" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087068/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00087068/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..451ff6bb756eeda90cfc5ef6a04d900b32599d7b --- /dev/null +++ b/marker2/ds9/EFTA00087068/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:5d0efc87ea7b977e75caaa9849d768cd107ae96cf45f6457825788f152f912cd +size 3974 diff --git a/marker2/ds9/EFTA00087071/EFTA00087071.md b/marker2/ds9/EFTA00087071/EFTA00087071.md new file mode 100644 index 0000000000000000000000000000000000000000..87a76733ef0c77388c50eabdccddfcc863d92f24 --- /dev/null +++ b/marker2/ds9/EFTA00087071/EFTA00087071.md @@ -0,0 +1,27 @@ +From: ' To:' E t Subject: RE: 2020-03-09, GM, prosecution memo, Ipdate.docx Date: Thu, 12 Mar 2020 16:29:55 +0000 + +Thanks-- talk soon. I have to jump to another call as soon as we finish this one, but if there are follow ups I should be free later this afternoon. + +From: Sent: Thursday, March 12, 2020 12:19 PM To: Subject: RE: 2020-03-09, GM, prosecution memoipdate.docx > + +I would just send this to the chiefs once you're all set with it — I don't think has been able to respond to an Epstein email all week. + +And of course I'll dial you in at 12:30! Call you in 10 mins. + +From: Sent: Thursday, March 12, 2020 09:44 To: Cc: Subject: RE: 2020-03-09, GM, prosecution memo, npdate.docx > + +Thanks. do you have any comments before this goes to the chiefs. + +Let's keep discussing these issues as we pass the draft up. On the perjury question, I think when we have time we should just print the transcript excerpts and talk through them as a team. + +I think the child endangerment issue is a tough call, and definitely worth continuing to discuss. + +From: Sent: Wednesday, March 11, 2020 9:05 PM To: ) Cc: I wrote: + +I got a hit on this as an end-of-year thing from my google alert on Epstein - I had not realized that he did a huge, crazy, absurdly self-aggrandizing interview on this!! + +https://atlantajewishtimes.timesofisrael.comijeffrey-epstein-consulted-atlanta-attomey-days-before-death/ + +I don't believe a word of his. Just unreal. + +From: + +Sent: Saturday, August 17, 2019 20:00 + +To: (USANYS) + +Subject: RE: Schoen and Epstein + +A well-matched team. + +From: (USANYS) Sent: Saturday, August 17, 2019 19:50 To: Subject: Schoen and Epstein + +Have you seen this? + +https://www.nytimes.corn/2019/08/17/nyregion/epstein-suicide-death.html? action=click&module=Top%20Stories&pgtype=Homepage \ No newline at end of file diff --git a/marker2/ds9/EFTA00087073/EFTA00087073.metadata.json b/marker2/ds9/EFTA00087073/EFTA00087073.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..febb939290e27d35047f0e9c34fcc49baaeddc40 --- /dev/null +++ b/marker2/ds9/EFTA00087073/EFTA00087073.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087073.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1235, + "elapsed_seconds": 1.22, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 31 + ], + [ + "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", + 15 + ], + [ + "Line", + 8 + ], + [ + "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/EFTA00087073" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087075/EFTA00087075.md b/marker2/ds9/EFTA00087075/EFTA00087075.md new file mode 100644 index 0000000000000000000000000000000000000000..a7e349201e9fd56c78cbd1d514c831819f74c002 --- /dev/null +++ b/marker2/ds9/EFTA00087075/EFTA00087075.md @@ -0,0 +1,15 @@ +To: + +Subject: tic with + +Date: Wed, 08 Jan 2020 23:19:23 +0000 + +- o igacgrounh l in 2001, visited a club, Tramp nightclub o don't know if there's any more specificity on the date o was soon after she had moved to +- visited a club with Matthew John Walker, who trafficked him +- Walker spoke to individuals she believed were Epstein and Prince Andrew +- saw the woman Prince Andrew was dancing with, believes it was +- stared at them for some time +- didn't hear the conversations +- [attorneys not sure when she realized it was Prince Andrew] + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00087075/EFTA00087075.metadata.json b/marker2/ds9/EFTA00087075/EFTA00087075.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7a562ca8c3f8c1e253f4f673105de3d27204b3be --- /dev/null +++ b/marker2/ds9/EFTA00087075/EFTA00087075.metadata.json @@ -0,0 +1,62 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087075.pdf", + "engine": { + "marker_major": "2", + "marker_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": 591, + "elapsed_seconds": 0.61, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 17 + ], + [ + "ListItem", + 7 + ], + [ + "Text", + 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 + } + } + ], + "debug_data_path": "debug_data/EFTA00087075" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087076/EFTA00087076.md b/marker2/ds9/EFTA00087076/EFTA00087076.md new file mode 100644 index 0000000000000000000000000000000000000000..186f1012825765d3a28c2b8b90475471858657a0 --- /dev/null +++ b/marker2/ds9/EFTA00087076/EFTA00087076.md @@ -0,0 +1,17 @@ +**From:** [REDACTED] + +**To:** [REDACTED] + +**Subject:** Thursday -- tasks + +**Date:** Thu, 09 Jan 2020 01:01:56 +0000 + +--- + +[REDACTED] + +4. Epstein meeting + +[REDACTED] + +--- \ No newline at end of file diff --git a/marker2/ds9/EFTA00087076/EFTA00087076.metadata.json b/marker2/ds9/EFTA00087076/EFTA00087076.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e9e8bcf16a94a005bc3784694353cb9a8b1a1ecb --- /dev/null +++ b/marker2/ds9/EFTA00087076/EFTA00087076.metadata.json @@ -0,0 +1,82 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087076.pdf", + "engine": { + "marker_major": "2", + "marker_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": 169, + "elapsed_seconds": 1.55, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "4. Epstein meeting", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 47.736000000000004, + 175.76999999999998 + ], + [ + 146.268, + 175.76999999999998 + ], + [ + 146.268, + 190.35 + ], + [ + 47.736000000000004, + 190.35 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 13 + ], + [ + "Span", + 11 + ], + [ + "Line", + 6 + ], + [ + "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/EFTA00087076" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087077/EFTA00087077.md b/marker2/ds9/EFTA00087077/EFTA00087077.md new file mode 100644 index 0000000000000000000000000000000000000000..631fbf206524c9f1465a442d2fe661e47c1f6a90 --- /dev/null +++ b/marker2/ds9/EFTA00087077/EFTA00087077.md @@ -0,0 +1,10 @@ +To: + +Subject: tic with counsel to JPMorgan Chase + +Date: Mon, 10 Aug 2020 20:17:28 +0000 + +- wanted to touch base on status of subpoena response ready to produce some additional wire data, Epstein and Maxwell and intend to reproduce, with Bates stamps, someMhocuments will produce via FTP o that will complete production of onboarding docs, KYC forms, account opening forms, signature cards, monthly account statements for 66 accounts, including credit card and trust accounts, and wire documentation o no loan files found, no safe deposit records o cashier's checks drawn from the general register, so difficult to get; ran searches and didn't find anything o as discussed last fall, held off on collecting and producing email correspondence (and calls) +- We advised that we will hold in abeyance any current requirement to produce email and telephonic communication, as otherwise requested in the subpoena. We noted that we may seek such records in the future, but currently do not require them. one other request they recently received, subpoena from AG USVI o We advised that we generally prefer that entities don't produce precisely what they've given to us to others, but in particular would have concerns about the production of our subpoena itself o Also noted that we understand that other entities received similar requests and expect to make similar objections + +Assistant U.S. Attorney \ No newline at end of file diff --git a/marker2/ds9/EFTA00087077/EFTA00087077.metadata.json b/marker2/ds9/EFTA00087077/EFTA00087077.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..99cfe3b7f22de220f0b4716f89e01b4cabbb10d8 --- /dev/null +++ b/marker2/ds9/EFTA00087077/EFTA00087077.metadata.json @@ -0,0 +1,62 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087077.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1394, + "elapsed_seconds": 0.42, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Line", + 24 + ], + [ + "Text", + 6 + ], + [ + "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/EFTA00087077" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087078/EFTA00087078.md b/marker2/ds9/EFTA00087078/EFTA00087078.md new file mode 100644 index 0000000000000000000000000000000000000000..cd5e0049617c33e625e4b7a0d3eca77a5704ad32 --- /dev/null +++ b/marker2/ds9/EFTA00087078/EFTA00087078.md @@ -0,0 +1,11 @@ +To: + +Subject: Epstein/Maxwell GJ + +Date: Wed, 05 Aug 2020 14:39:09 +0000 + +Hey— Since=is on vacation, I didn't want to bother her. Can you please send me the G.' materials (script, presentation) for Epstein and Maxwell? + +Thanksl + +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/EFTA00087078/EFTA00087078.metadata.json b/marker2/ds9/EFTA00087078/EFTA00087078.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7592fdf00cd97cc222f2262a234503aef9618684 --- /dev/null +++ b/marker2/ds9/EFTA00087078/EFTA00087078.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087078.pdf", + "engine": { + "marker_major": "2", + "marker_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": 375, + "elapsed_seconds": 0.41, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "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/EFTA00087078" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087079/EFTA00087079.md b/marker2/ds9/EFTA00087079/EFTA00087079.md new file mode 100644 index 0000000000000000000000000000000000000000..54c00e8a121e5023a4384db1754b7224e40329cd --- /dev/null +++ b/marker2/ds9/EFTA00087079/EFTA00087079.md @@ -0,0 +1,39 @@ +To:" + +Subject: RE: Epstein/Maxwell GJ + +Date: Thu, 06 Aug 2020 13:25:19 +0000 + +Thanks! + +From: a > + +Sent: Wednesday, August 05, 2020 6:27 PM + +To: (USANYS) + +Subject: RE: Epstein/Maxwell GJ + +Hi! Attached are the scripts. The presentations are huge ppt files that are tough to email, but they're essentially just our exhibits dropped into a powerpoint to make the presentation easier, without any text or anything. They both followed the same structure: + +- Slides introducing defendants (photos of locations and defendants) for background +- Photo of a victim, then any victim-specific exhibits (travel records, etc.) +- Repeat for next victim + +Feel free to call anytime with questions if that would be useful, and good luck!! + +From: (USANYS) + +Sent: Wednesday, August 5, 2020 10:39 AM + +To: + +Subject: Epstein/Maxwell al + +Hey - SinceMs on vacation, I didn't want to bother her. Can you please send me the GJ materials (script, presentation) for Epstein and Maxwell? + +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/EFTA00087079/EFTA00087079.metadata.json b/marker2/ds9/EFTA00087079/EFTA00087079.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..eedffc46da1bab99573c0f34acb7e0ac6eed2452 --- /dev/null +++ b/marker2/ds9/EFTA00087079/EFTA00087079.metadata.json @@ -0,0 +1,62 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087079.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1115, + "elapsed_seconds": 0.92, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 30 + ], + [ + "Text", + 19 + ], + [ + "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 + } + } + ], + "debug_data_path": "debug_data/EFTA00087079" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087080/EFTA00087080.md b/marker2/ds9/EFTA00087080/EFTA00087080.md new file mode 100644 index 0000000000000000000000000000000000000000..f7c7a964a55c0f5525432293943f5afd54f209b4 --- /dev/null +++ b/marker2/ds9/EFTA00087080/EFTA00087080.md @@ -0,0 +1,13 @@ +To + +Cc + +Subject: IIG + +Date: Wed, 12 Aug 2020 20:09:26 +0000 + +wanted to introduce you to who is joining the IIG team. He recently joined the unit from Public Corruption where he prosecuted boring cases like Jeffrey Epstein. =id I started in the office the same day, and we're lucky to have him. + +Assistant United States Attorney Southern District of New York + +New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00087080/EFTA00087080.metadata.json b/marker2/ds9/EFTA00087080/EFTA00087080.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d588c1e510dc20878b330eb48cc28d86576dbe75 --- /dev/null +++ b/marker2/ds9/EFTA00087080/EFTA00087080.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087080.pdf", + "engine": { + "marker_major": "2", + "marker_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": 377, + "elapsed_seconds": 0.43, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 12 + ], + [ + "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/EFTA00087080" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087081/EFTA00087081.md b/marker2/ds9/EFTA00087081/EFTA00087081.md new file mode 100644 index 0000000000000000000000000000000000000000..f3ac9dd2e9ceae194e9065e822daae3c90da19a6 --- /dev/null +++ b/marker2/ds9/EFTA00087081/EFTA00087081.md @@ -0,0 +1,81 @@ +To: + +Subject: RE: Taint Review - Epstein + +Date: Thu, 26 Sep 2019 15:32:43 +0000 + +Out of curiosity, do you know what the volume of NP documents is? Thanks. + +Orginal Message + +From: + +Sent: Thursda Se ember 26.2019 11:02 AM + +To: + +Cc: + +Subject: RE: Taint Review - Epstein + +I've run all the terms that Epstein's attorney gave me and segregated the hits, there were not many. Can I release the NP or did you come to some agreement with the defense that we would give them notice or let them review them first? + +Thanks, + +Original Message + +From: + +To: + +Cc: + +Sent: on a , September e + +Sub . . w + +Great, thanks very much. + +From: + +Sent: Monda Se p tember 23 2019 16:56 + +To: + +Cc: + +Subject: v : aint eview + +We are running the lawyer/paralegal names now, you should have access in a couple of days. + +Ori inal M- ssa:e + +From: + +Sent: Saturda , Se .tember 21, 2019 5:02 PM + +To: + +Cc: + +Subject: 19 : aim ' eview + +from his Manhattan residence, which were made available on September 10 (see attached). I know that you had dealt directly with Epstein's attorneys regarding search terms, etc., so we haven't had visibility on that, but could you please let us know the current status, and when you expect we'll be able to get access to the materials? + +very much, + +Ori final Messa e + +From: + +Sent: Tuesda Se tember 17, 2019 1 7: 1 - + +To: + +Subject: Taint Review + +Hey guys, + +Our supervisors are requesting a status update on the taint review process on your end. I simple percentage complete is fine, they just want to know before tomorrow they have a meeting with the ADIC about the case. + +Thanks \ No newline at end of file diff --git a/marker2/ds9/EFTA00087081/EFTA00087081.metadata.json b/marker2/ds9/EFTA00087081/EFTA00087081.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c0489ce8b6856b160eb5a93cdd14ca0364edb0fc --- /dev/null +++ b/marker2/ds9/EFTA00087081/EFTA00087081.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087081.pdf", + "engine": { + "marker_major": "2", + "marker_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": 1580, + "elapsed_seconds": 1.51, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 37 + ], + [ + "Text", + 34 + ], + [ + "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", + 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/EFTA00087081" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087083/EFTA00087083.md b/marker2/ds9/EFTA00087083/EFTA00087083.md new file mode 100644 index 0000000000000000000000000000000000000000..a41744f169b0e9dcad93fe7dfb523e950a0ed0d6 --- /dev/null +++ b/marker2/ds9/EFTA00087083/EFTA00087083.md @@ -0,0 +1,49 @@ +To + +Cc + +Subject: VANITY FAIR; "IT WOULD BE RIDICULOUSLY NAIVE NOT TO BE CONCERNED": TRUMP HAS POLITICIZED THE DOJ. HOW LONG CAN THE SDNY HOLD OUT? + +Date: Tue, 09 Jul 2019 15:45:56 +0000 + +Importance: Normal + +LINK TO ARTICLE: https://www.vanityfaircominews/2019/07/trump-has-politicized-the-doj-how-long-can-the-sdnyhold-out + +## "IT WOULD BE RIDICULOUSLY NAIVE NOT TO BE CONCERNED": TRUMP HAS POLITICIZED THE DOJ. HOW LONG CAN THE SDNY HOLD OUT? + +The battles over the border and the census show that the West Wing is fully in control of Justice. "The fear is that Trump doesn't even need to say it out loud anymore." + +BY + +CHRIS SMITH + +Sally Yates tried to warn us. Way back in January 2017, at the end of the very first week of the Trump administration, the new president signed an executive order banning refugees and immigrants from seven majority-Muslim countries from entering the United States. It was a blatantly political act, following months of Trump campaign promises, and it immediately provoked lawsuits challenging the order as religious discrimination. Yates, the acting attorney general, refused to defend the legally indefensible and was summarily fired. "The president is attempting to dismantle the rule of law, destroy the time-honored independence of the Justice Department, and undermine the career men and women who are devoted to seeking justice day in and day out," Yates wrote in a New York Times op-ed published in July 2017. + +Two Julys later, Trump's politicization of the DOJ is gaining new momentum and depth. The president's choice of William Barr as attorney general, and Barr's entirely predictable attempts to undercut the Mueller report, has been the highest-profile, highest-stakes move to weaponize the department for partisan purposes. But two fresh episodes demonstrate Trump's relentless push to subvert the DOJ, and how far-reaching the damage will be to the rule of law. First came Sarah Fabian, the senior attorney in the DOJ's Office of Immigration Litigation, telling a California appeals + +court that it is "safe and sanitary" for jailed immigrant children to go without soap or toothbrushes and to sleep on concrete floors under bright lights. "I actually felt somewhat sorry for her," a former federal prosecutor says. "You could hear how half-hearted she was in making the point. But there is no way she would have been making that argument at all without it being approved at the highest levels of DOJ. And then when it became controversial, Mike Pence threw her completely under the bus!" + +The second, ongoing case echoes the events that got Yates fired. Last week, the Supreme Court ruled against adding a citizenship question to the 2020 census, after documents from a now deceased Republican consultant's hard drives were exposed. The census citizenship question, Thomas Hotelier wrote in an analysis, "would clearly be a disadvantage to the Democrats" and "advantageous to Republicans and non-Hispanic whites." The DOJ announced it would not be fighting the Supreme Court ruling; the Commerce Department announced it would begin printing the census forms without the question in question. + +Trump didn't care. "We are absolutely moving forward," he declared on Twitter. Which was news to DOJ lawyers, who found themselves fumbling during an emergency conference call with a Maryland district court judge. "I've been with the United States Department of Justice for i6 years, through multiple administrations, and I've always endeavored to be as candid as possible with the Court," a clearly flummoxed Joshua Gardner said. "The tweet this morning was the first I had heard of the president's position on this issue." + +After a few more days of confusion, the DOJ said on Friday it would demur from pursuing the case, at least until the Commerce Department "adopts a new rationale for including the citizenship question." That new spin should arrive very soon. Over the weekend Trump and Barr replaced the DOJ legal team handling the case. Whether the prior group of career lawyers balked at returning to the Supreme Court with a new, possibly untenable argument or whether Barr simply wants fresh minds on the case, the shift was all but unprecedented, and is yet another indication that Trump sees the DOJ as a political tool. "Look, every administration makes different decisions about policies. That's the consequence of an election," says Emily Pierce, a senior adviser in the Justice Department under Barack Obama. "What's different here is Trump threatening to prosecute political opponents, and not deferring to the judgment of law enforcement or of the courts." + +Career DOJ attorneys were troubled early on when Trump pardoned former Arizona sheriff Joe Arpaio, who had been convicted of criminal contempt of court. "With that pardon Trump said there were no consequences for defying a court order," Pierce says. "That's a significant message. Now, with a tweet basically overruling the judgment of the DOJ on the citizenship question, it's not just a perversion of the department's authority. It's about using the civil division for political purposes." + +Yet as much as Trump seems to care about the citizenship question, he cares far more about protecting himself. "For two years Trump has been battering DOJ and completely politicizing its work. Sometimes he got what he wanted out of them and sometimes he didn't," says Matthew Miller, a Justice Department spokesman under President Obama. "Now he's got an A.G. who will talk publicly about the Democrats `spying' and spin the Mueller report to help the president. One big question that flows from that is, What does it mean for the Southern District of New York's investigation into the Trump Organization?" + +And the SDNY's investigation into Trump's role in paying off Stormy Daniels. And the office's probe of Deutsche Bank, which loaned Trump more than \$2 billion over the course of 20 years. And its attempts to track the \$1o7 million raised by Trump's inaugural committee. "The SDNY presents the greatest ongoing legal threat to Trump and his people," says Mimi Rocah, a former chief of the office's organized crime unit. In February the Times reported that Trump had asked Barr's predecessor, Matthew Whitaker, whether a perceived loyalist could be put in charge of the SDNY's + +work; Whitaker subsequently denied, under oath, having had any such conversation. But it's hard to imagine Trump won't try to intercede if the famously independent SDNY—currently back in the headlines for charging billionaire Jeffrey Epstein with sex trafficking—moves to indict one or more of the president's high-ranking associates. (Epstein has pleaded not guilty.) "The fear is that Trump doesn't even need to say it out loud anymore, because Barr is so protective of him," Rocah says. "It would be ridiculously naive not to be concerned." + +Nicholas Biase + +Public Affairs + +United States Department of Justice + +U.S. Attorney's Office 'Southern District of New York + +Nicholas.Biase@usdoj.gov I Mobile: (646) 261-2074 Press Office: (212) 637-1020 \ No newline at end of file diff --git a/marker2/ds9/EFTA00087083/EFTA00087083.metadata.json b/marker2/ds9/EFTA00087083/EFTA00087083.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ee0e25b3189e863c2b4feb40d44cf16c7bde00d2 --- /dev/null +++ b/marker2/ds9/EFTA00087083/EFTA00087083.metadata.json @@ -0,0 +1,142 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087083.pdf", + "engine": { + "marker_major": "2", + "marker_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": 7044, + "elapsed_seconds": 0.86, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "\"IT WOULD BE RIDICULOUSLY \nNAIVE NOT TO BE CONCERNED\": \nTRUMP HAS POLITICIZED THE \nDOJ. 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EPSTEIN was escorted to medical and was assessed. EPSTEIN was initially placed on suicide watch and subsequently downgraded to suicide observation, where he currently remains. Additionally, Advised that EPSTEIN's cell mate reported threated to kill him. No further information was provided. + +The above incident is currently under investigation with the BOP. + +Supervisory Deputy United States Marshal Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00087086/EFTA00087086.metadata.json b/marker2/ds9/EFTA00087086/EFTA00087086.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..15429fa7cc490c04bd84b0b443a53dd192abd878 --- /dev/null +++ b/marker2/ds9/EFTA00087086/EFTA00087086.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087086.pdf", + "engine": { + "marker_major": "2", + "marker_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": 0.61, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 16 + ], + [ + "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/EFTA00087086" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087087/EFTA00087087.md b/marker2/ds9/EFTA00087087/EFTA00087087.md new file mode 100644 index 0000000000000000000000000000000000000000..d1c2bbfb3f61044c014fcfff8ad1a6958d4fb655 --- /dev/null +++ b/marker2/ds9/EFTA00087087/EFTA00087087.md @@ -0,0 +1,15 @@ +To: (USANYS) [Contractor]" + +Subject: Epstein + +Date: Tue, 23 Jul 2019 21:19:40 +0000 + +Importance: High + +WaPo is hearing that he was found unresponsive is his cell last night, possibly a suicide attempt. I'm here if you want to stop in. + +Public Affairs + +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/EFTA00087087/EFTA00087087.metadata.json b/marker2/ds9/EFTA00087087/EFTA00087087.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1538d2feb1437c82e0b9664b07915b73646e6e7c --- /dev/null +++ b/marker2/ds9/EFTA00087087/EFTA00087087.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087087.pdf", + "engine": { + "marker_major": "2", + "marker_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": 343, + "elapsed_seconds": 0.47, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 13 + ], + [ + "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/EFTA00087087" + } +} \ No newline at end of file