From: [REDACTED]
To: [REDACTED]
Cc: [REDACTED]
Subject: Re: following up
Date: Tue, 22 Dec 2020 16:26:58 +0000
2pm works for us. Speak with you then.
[REDACTED]
Sent from my iPhone
On Dec 22, 2020, at 9:24 AM, [REDACTED] wrote:
We are flexible this afternoon. How about 2pm?
We can use the below dial-in:
Dial-in: [REDACTED]
Code: [REDACTED]
Thanks,
[REDACTED]
On Dec 21, 2020, at 10:40 PM, [REDACTED] wrote:
[REDACTED] I was busy and just saw this. What time would be good?
[REDACTED]
Sent from my iPhone
On Dec 21, 2020, at 2:52 PM, [REDACTED] wrote:
Hi all,
Would you be available for a call tomorrow?
Thanks,
[REDACTED]
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
[REDACTED]
From: [REDACTED]
Sent: Wednesday, December 16, 2020 3:57 PM
To: [REDACTED]
Cc: [REDACTED]
Subject: RE: following up
Trying again
From: [REDACTED]
Sent: Wednesday, December 16, 2020 3:55 PM
To: [REDACTED]
Cc: [REDACTED]
Subject: Re: following up
Thanks! We are on the line when you're ready.
Sent from my iPhone
On Dec 16, 2020, at 3:52 PM, [REDACTED] > wrote:
No problem! Will call in right now
Sent from my iPhone
On Dec 16, 2020, at 3:51 PM, [REDACTED] > wrote:
Would it be possible to jump on the same line we used earlier today? I'm having tech issues merging the lines.
Thanks!
Sent from my iPhone
On Dec 16, 2020, at 3:43 PM, [REDACTED] > wrote:
Why don't you call me at your convenience? [REDACTED]
From: [REDACTED]
Sent: Wednesday, December 16, 2020 2:05 PM
To: [REDACTED]
Cc: [REDACTED]
Subject: Re: following up
Hi [REDACTED]
We'd be happy to talk that through— we are available from 3 p.m. onwards today for a call.
Sent from my iPhone
On Dec 16, 2020, at 1:23 PM, [REDACTED] > wrote:
Can you let us know how you calculated the guidelines?
Thanks,
[REDACTED]
Sent from my iPhone
On Dec 16, 2020, at 11:34 AM, [REDACTED] > wrote:
That's fine, thanks: [REDACTED]
From: [REDACTED]
Sent: Wednesday, December 16, 2020 11:20 AM
To: [REDACTED]
Cc: [REDACTED]
Subject: RE: following up
Should we use the same call-in number as last time?
From: [REDACTED]
Sent: Tuesday, December 15, 2020 12:10 PM
To: [REDACTED]
Cc: [REDACTED]
Subject: Re: following up
Noon tomorrow works for us, thanks.
Sent from my iPhone
On Dec 15, 2020, at 11:55 AM, [REDACTED] > wrote:
[REDACTED]
Can we move our call to tomorrow? How about noon tomorrow? If that doesn't work let us know a
different time that works tomorrow.
Thanks,
[REDACTED]
From: [REDACTED]
Sent: Monday, December 14, 2020 10:32 PM
To: [REDACTED]
Cc: [REDACTED]
Subject: Re: following up
3 tomorrow works, thanks.
Sent from my iPhone
On Dec 14, 2020, at 4:57 PM, [REDACTED] > wrote:
We can't do earlier unfortunately but could speak at 3 or 4.
From: [REDACTED]
Sent: Monday, December 14, 2020 3:35 PM
To: [REDACTED]
Cc: [REDACTED]
Subject: RE: following up
Hi [REDACTED]
[REDACTED] would be happy to speak tomorrow morning. Would it be possible to speak
sometime before 11 a.m.? We unfortunately have a conflict at 11, but could speak any time before then.
If not, we can find a time in the afternoon that works.
Thanks,
[REDACTED]
From: [REDACTED]
Sent: Monday, December 14, 2020 3:23 PM
To: [REDACTED]; [REDACTED]
Cc: [REDACTED]
Subject: RE: following up
Hi [REDACTED]
Would you all be able to speak tomorrow at 11am?
Thanks,
[REDACTED]
From: [REDACTED]
Sent: Sunday, December 13, 2020 6:37 PM
To: [REDACTED]
Cc: [REDACTED]
Subject: following up
All,
Thanks for speaking with us yesterday. Below is the most current version of the statement of facts we
have discussed. We want to emphasize that this is not a plea offer or a proposal, but we are passing this
along since you've asked us to send you a draft that reflects our must recent discussions. This is not final
from our perspective, and this may change following our conversations with victims during the conferral
process.
We recognize and respect that you will need to speak with your client this week. However, we do not
want to delay notifying the victims, and, as we've discussed, we plan to issue a letter to the victims
notifying them that we are in plea negotiations. That letter will need to go out this week. From our
conversation, it sounds like you plan to meet with your client in the next few days, so let's plan to talk
mid-week.
Thanks,
[REDACTED]
-----------------------------
Between approximately 2001 and 2013, [REDACTED] worked for Jeffrey Epstein as a personal assistant.
[REDACTED] has been evaluated by an expert psychologist who specializes in victims of sexual trauma, who
completed a report dated April 21, 2020 regarding [REDACTED] experiences before, during, and after her
employment with Epstein. The parties agree that the contents of the expert's report may be considered
at sentencing, and the Government does not dispute that [REDACTED] was herself a victim of sexual abuse by
Epstein, as discussed in the expert report.
During the period of her employment between approximately 2002 and 2005, as part of her duties to
schedule appointments at the direction of Epstein and Maxwell, [REDACTED] scheduled hundreds of
appointments for women and girls, including dozens of minors, to massage Epstein. Over the course of
that several year period, Epstein received approximately two to three massages per day, and during
those massage appointments, Epstein sexually abused dozens of minor victims. The vast majority of the
massage appointments that [REDACTED] scheduled took place at Epstein's residence in Palm Beach, Florida,
though some victims recall that [REDACTED] arranged massages which took place at Epstein's residence in New
York, New York. [REDACTED] has reported that she has no recollection of scheduling massages for anyone in
New York. [REDACTED] did occasionally schedule massages to take place in Florida by phone while she was in
New York City. When [REDACTED] was first hired, she used a directory provided to her by Epstein's previous
personal assistant and Ghislaine Maxwell to contact women and girls to massage Epstein. Over the
ensuing years, [REDACTED] would add new names to the directory when directed to do so by Epstein or
Maxwell.
Through the process of arranging and facilitating massage appointments for Epstein, [REDACTED] met dozens
of underage victims, who ranged in age from 14 to 17 years old. For example, when minor victims arrived
for the appointments at Palm Beach, [REDACTED] sometimes met them, walked them up to the massage room,
and set up the massage table for the appointment. After some of the appointments, [REDACTED] paid minor
victims in cash. Epstein encouraged minor victims to bring other girls to massage him, which led to an
increasing number of victims coming to massage Epstein at his residences.
None of those victims told [REDACTED] that they were underage. [REDACTED] did know that some of those victims
did not have their own cars, and [REDACTED] arranged for a driver to pick them up and take them to their
appointments with Epstein. Additionally, some of those victims told [REDACTED] they could not attend certain
appointment times because they were attending school. Epstein also told [REDACTED] that at least one of
those victims was studying for the SATs.
During some of the massage appointments with minor girls that [REDACTED] scheduled, Epstein sexually
abused the minor girls by, among other things, [REDACTED]
[REDACTED]. In addition, the Government would be prepared to prove that [REDACTED] witnessed some of the
sexual abuse that occurred. In particular, one victim ("Victim-1") has informed law enforcement that
[REDACTED] was present for and participated in one massage when Victim-1 was a minor, during which Epstein
touched Victim-1's [REDACTED]. Another victim ("Victim-2") has informed law enforcement that [REDACTED]
walked in on one instance in which Victim-2, a minor, was [REDACTED] Epstein. Another victim
("Victim-3") has informed law enforcement that [REDACTED] walked in when Victim-3 was a minor and was
[REDACTED] in Epstein's massage room. [REDACTED] has informed the U.S. Attorney's Office that she denies
participating in any of the incidents described by Victim-1, Victim-2, and Victim-3.
In or about 2005, [REDACTED] learned that law enforcement was investigating Epstein for sex crimes involving
minors, arising from the massage appointments, some of which [REDACTED] had scheduled. After learning
about the investigation into Epstein, at Epstein's direction, [REDACTED] called multiple minor victims and
encouraged them to "help" Epstein and conveyed that Epstein would help them if they helped him.
[REDACTED] encouraged them to talk to Epstein's investigator, offered that Epstein would pay for an attorney
for them, and, in one or two cases, [REDACTED] offered financial incentives to victims. [REDACTED] understood that
by asking her to make these calls, Epstein intended to dissuade the victims from speaking to law
enforcement, and by agreeing to make the calls and take these steps, she was aiding him in this
objective. Beginning in approximately 2006, multiple minor victims were interviewed by federal law
enforcement officers who were conducting a criminal investigation of Epstein and his associates for sex
trafficking of minors, among other federal offenses. During those interviews, minor victims reported to
federal agents that Epstein paid them for sexualized massages while they were underage girls, including
during massages that [REDACTED] scheduled.
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