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058.pdf
This document is a letter dated April 14, 2020, from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Debra C. Freeman. It requests a 30-day extension for various legal deadlines in several cases filed by 'Doe' plaintiffs (VE, Katlyn, Priscilla, Lisa, Anastasia) against the Defendants, citing the ongoing pandemic as the reason. The request notes that it is made with the Plaintiffs' consent.
045.pdf
A letter from U.S. District Judge Richard M. Berman to Warden Lamine N'Diaye dated August 12, 2019, acknowledging the death of Jeffrey Epstein. The Judge specifically inquires whether ongoing investigations will address the prior incident at the MCC involving Epstein on July 23, 2019, noting that the Bureau of Prisons' conclusions regarding that event have never been definitively explained.
050.pdf
This document contains a letter from Troutman Sanders LLP to Judge Debra Freeman in the SDNY, dated June 3, 2020, informing the court that the Superior Court of the Virgin Islands has officially authorized the establishment of the Epstein Victims' Compensation Program. Attached is the official Order from the USVI court (signed by Judge Hermon-Percell) granting the motion to establish the program and authorizing its commencement on June 15, 2020. The document notes that the USVI Attorney General has agreed to lift liens to allow funding for the program.
034.pdf
A letter from attorney Bennet J. Moskowitz to Judge Debra C. Freeman dated April 15, 2020, requesting a 30-day extension for various deadlines in civil cases filed by Jane Doe 1000, Teresa Helm, and Juliette Bryant against the Epstein Estate executors. The request cites the ongoing pandemic as the reason for the delay and lists specific new dates for discovery and reports, which Judge Freeman approved via a 'SO ORDERED' endorsement on the same day.
011.pdf
This document is a court order filed on January 14, 2020, by Magistrate Judge Debra Freeman in the Southern District of New York. It coordinates the discovery schedules for multiple civil cases filed against the Jeffrey Epstein estate (represented by Indyke et al.) by various plaintiffs claiming sexual abuse. The order mandates the submission of discovery plans by February 6, 2020, and sets a joint pretrial conference for February 11, 2020.
051.pdf
This document is a legal letter filed on May 11, 2020, by attorney Sigrid S. McCawley on behalf of Plaintiff Jane Doe 1000 in her case against Epstein estate executors Darren K. Indyke and Richard D. Kahn. The letter requests a court conference to address the Defendants' alleged failure to participate in discovery, specifically noting their refusal to produce documents regarding Epstein's broader sex-trafficking conspiracy and failure to answer interrogatories regarding Epstein's email accounts. The Plaintiff argues that the Defendants are engaging in intentional delay tactics.
046.pdf
This document is a legal filing from Plaintiff Jane Doe 1000's counsel requesting a pre-motion conference to compel Defendants (Epstein's executors Indyke and Kahn) to produce discovery documents and answer interrogatories. The filing includes exhibits of the discovery requests, which seek detailed information on Epstein's flight logs, financial transactions, communications with high-profile individuals (Prince Andrew, Bill Clinton, Alan Dershowitz), and the structure of his alleged sex-trafficking operation. The Defendants have objected to almost all requests, claiming they are overbroad or that they lack knowledge because Epstein is deceased, prompting the Plaintiff to seek court intervention. Note: While flight logs are requested, no actual flight data is contained in this document.
052.pdf
A joint status report filed on August 14, 2020, to Judge Debra Freeman in the case of Juliette Bryant v. the Estate of Jeffrey Epstein. The letter informs the court that Bryant submitted a claim to the Epstein Victims' Compensation Program on June 26, 2020, and requests a 45-day extension to the stay of discovery pending the program's determination. The document includes a stamp from Judge Freeman dated September 11, 2020, granting the requested extension.
011.pdf
A court order from the Southern District of New York dated January 14, 2020 (misdated 2019 in signature), by Magistrate Judge Debra Freeman. The order addresses thirteen separate civil cases brought by alleged victims of Jeffrey Epstein against his estate and associates (Indyke et al.). The judge sets deadlines for proposed discovery schedules (Feb 6, 2020) and schedules a joint pretrial conference for February 11, 2020, to coordinate supervision despite the cases not being formally consolidated.
EFTA00032547.pdf
This document is a letter from the U.S. Attorney (SDNY) to Judge Karas regarding the case of U.S. v. Nicholas Tartaglione. It admits that video footage requested by the defense—showing the outside of the cell Tartaglione shared with Jeffrey Epstein during the July 22-23, 2019 incident—has been permanently lost. The government attributes this loss to a clerical error in the MCC computer system which led to the wrong cell's video being preserved, and confirms the correct footage is also missing from the backup system.
EFTA00028265.pdf
A joint letter from the U.S. Department of Justice to Judge Alison J. Nathan regarding the trial of Ghislaine Maxwell. The letter outlines the Government and Defense positions on protecting witness identities, including the use of pseudonyms (nomenclature), voir dire procedures, jury instructions, and the handling of sealed exhibits to prevent public disclosure of victim identities. The document contains significant redactions regarding the actual names and pseudonyms of the witnesses.
EFTA00027704.pdf
A letter from U.S. Attorney Damian Williams to Judge Alison J. Nathan dated October 18, 2021, regarding the case United States v. Ghislaine Maxwell. The Government requests permission to file motions *in limine* with redactions designed to protect the privacy of victims and third parties, specifically requesting the sealing of 'Section X' until the conclusion of the trial. The specific Assistant US Attorney signing the document has their name redacted.
EFTA00025219.pdf
A letter from the U.S. Department of Justice to Judge Alison J. Nathan updating the court on Ghislaine Maxwell's conditions of confinement at the Metropolitan Detention Center (MDC). The letter details her extensive access to discovery review (13 hours/day), attorney communications (25 hours VTC/week), and specific search protocols including strip searches and body scans. It also notes she was weighed on June 3, 2021, at 138 pounds, and receives wellness checks every 15 minutes at night.
EFTA00022527.pdf
This document is a Grand Jury Subpoena issued on July 11, 2019, by the U.S. Attorney for the Southern District of New York to Deutsche Bank. It demands the production of comprehensive financial records regarding Jeffrey Epstein (including KYC files, statements, loans, and correspondence) from January 1, 2010, to the present. The subpoena cites an investigation into alleged violations of federal sex trafficking and conspiracy laws (18 U.S.C. §§ 1591, 1594(c), 2422(b)).
EFTA00022514.pdf
This document is a letter motion filed by Ghislaine Maxwell's defense attorney, Christian Everdell, on April 30, 2021, requesting Judge Alison Nathan to order the Metropolitan Detention Center (MDC) to accept two hard drives containing discovery materials for Maxwell's review. The defense argues the current format of 2.2 million pages is difficult to navigate, and they have reorganized the files to be more user-friendly. Judge Nathan granted the order on May 3, 2021, with a stipulation allowing MDC counsel to submit objections by May 4, 2021.
EFTA00021425.pdf
This document is a letter filed on July 15, 2019, by U.S. Attorney Geoffrey S. Berman to Judge Richard M. Berman regarding the case United States v. Jeffrey Epstein. The Government requests the exclusion of speedy trial time until the next conference on July 18, 2019, noting that defense counsel (Martin Weinberg and Reid Weingarten) consent to the request.
EFTA00018955.pdf
This document is a Grand Jury Subpoena issued on August 15, 2019, by U.S. Attorney Geoffrey S. Berman of the Southern District of New York. It commands a redacted individual to testify and produce evidence regarding alleged violations of 18 U.S.C. §§ 371 (Conspiracy), 1001 (False Statements), and 1519 (Obstruction). The subpoena specifically demands the production of all materials relating to Jeffrey Epstein, including text messages, emails, social media posts, and notes.
EFTA00018874.pdf
A Grand Jury Subpoena from the Southern District of New York issued on August 28, 2019, commanding a redacted individual to testify and produce evidence regarding alleged violations of 18 U.S.C. §§ 371 (Conspiracy), 1001 (False Statements), and 1519 (Obstruction). The subpoena specifically demands the production of all materials relating to Jeffrey Epstein, including text messages, emails, and social media posts.
EFTA00017953.pdf
This document is a letter from the U.S. Attorney's Office to Judge Kenneth Karas regarding the case of Nicholas Tartaglione. It reveals that video footage from outside the cell Tartaglione shared with Jeffrey Epstein during the night of July 22-23, 2019 (the date of Epstein's first reported suicide attempt/incident), no longer exists. The MCC inadvertently preserved video of the wrong cell due to a clerical error in their system, and the backup system for the Special Housing Unit failed to retain the footage due to technical errors.
EFTA00017832.pdf
This document is a letter from the U.S. Department of Justice to Judge Alison Nathan opposing Ghislaine Maxwell's requests for early disclosure of witness names and court intervention in her confinement conditions. The Government argues the requests are premature given the trial is 11 months away and discovery has just begun, noting they have already produced over 165,000 pages of evidence. The letter also defends the Bureau of Prisons' protocols for Maxwell, stating her monitoring is appropriate for a high-profile inmate facing significant prison time and confirming she has been granted extensive daily access to review discovery materials.
EFTA00014636.pdf
This document is a letter dated May 14, 2021, from the U.S. Attorney's Office (SDNY) to Judge Alison J. Nathan requesting a one-week extension (to May 21, 2021) to file a joint letter regarding the pretrial schedule in the case against Ghislaine Maxwell. The letter notes that the prosecution and defense conferred by phone for 45 minutes on the previous day but require more time to resolve disagreements on scheduling proposals. The signatory names of the Assistant U.S. Attorneys are redacted.
EFTA00014334.pdf
This document is a Grand Jury Subpoena issued by the US District Court for the Southern District of New York on July 15, 2019. It commands a redacted individual to appear on July 31, 2019, to testify regarding alleged violations of federal laws related to sex trafficking and conspiracy (18 U.S.C. §§ 1591, 2421, 2422, 2423, 371). The document includes an 'Advice of Rights' regarding self-incrimination and legal counsel, as well as a cover letter requesting the recipient keep the subpoena confidential to avoid impeding the investigation.
EFTA00011177.pdf
This document is a character reference letter dated November 2, 2020, addressed to Judge Alison J. Nathan regarding Ghislaine Maxwell's bail application. The redacted sender describes a decades-long friendship with Maxwell, attesting to her integrity and stating they would trust her to look after their children (implied by context) at any time. The sender argues Maxwell is not a flight risk and offers to provide financial surety for her bail.
EFTA00010422.pdf
This document is a formal letter and proposed legal order from U.S. Attorney Geoffrey S. Berman to Judge Richard M. Berman dated August 19, 2019. It requests the dismissal (nolle prosequi) of the indictment against Jeffrey Epstein following his death by suicide in custody on August 10, 2019, citing the legal rule of abatement. The document also affirms the Government's commitment to continuing support for the victims despite the dismissal of the specific case against Epstein.
EFTA00010037.pdf
This document is a letter from the U.S. Department of Justice to Judge Alison J. Nathan dated November 12, 2021, regarding the case United States v. Ghislaine Maxwell. The Government seeks clarification on two pretrial matters: limiting cross-examination regarding the specific genres of witnesses' acting careers (e.g., action vs. soap opera) to protect their identities, and ensuring the ban on courtroom sketch artists drawing the likenesses of pseudonymized witnesses.
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