This document is an email dated August 17, 2021, from Assistant US Attorney Andrew (likely Andrew Rohrbach) to redacted colleagues. It discusses a recent ruling by Judge Nathan denying Ghislaine Maxwell's supplemental motions. The email focuses on correcting the Judge's presumption that the prosecution intended to provide the defense with the identities of uncharged co-conspirators, stating clearly that they 'do not, in fact, intend to do so' and have drafted a letter to that effect.
An email dated September 30, 2021, from an Assistant US Attorney in the Southern District of New York regarding the 'Maxwell case.' The email discusses a draft 'RTC' (likely Requests to Charge/Jury Instructions) attached as 'Maxwell_RTC_v11.docx' and notes a filing deadline of October 27 for a joint proposal.
An email dated November 15, 2021, from an Assistant United States Attorney in the Southern District of New York to supervisors ('Chiefs'). The email submits a 'Second Daubert Motion' (specifically 'Motion_to_preclude_Hall_et_al_v3.docx') for review ahead of a filing deadline the next day. The sender's identity and recipients are redacted.
An email chain from November 2021 involving Assistant United States Attorneys from the Southern District of New York. The correspondence concerns the filing of a 'Second Daubert Motion' intended to preclude the testimony of a 'Dr. Hall' (likely an expert witness). The emails discuss the drafting of the motion and a deadline for the following day.
An email from the Southern District of New York (Government) to Judge Nathan's chambers regarding the case US v. Maxwell. The email submits proposed redactions related to 'Witness-3' (also referred to as Accuser-3 in attachments) pursuant to previous court orders and motions.
This document is an email dated October 24, 2021, from an Assistant United States Attorney in the Southern District of New York to a legal team. The email subjects concerns 'Drafts of the remaining motions' and includes two attachments titled 'Forbidden_Words_v1.docx' and 'Suppress_ID_v2.docx', suggesting ongoing legal preparation, likely for a trial (potentially the Ghislaine Maxwell trial given the timeframe and context of SDNY involvement).
An email chain from July 2020 between officials at the USAO SDNY regarding new Bureau of Prisons (BOP) documents. The Co-Chief of the Narcotics Unit identifies specific pages to be withheld because they impact 'Tartaglione' (Nicholas Tartaglione), specifically citing reports related to the 'July 23 incident' involving Epstein's mental health and Tartaglione's disciplinary history.
This document is an email thread from November 2021 between an Assistant United States Attorney (SDNY) and attorneys Brad Edwards and Brittany Henderson. The correspondence involves the transmission of legal documents related to the Ghislaine Maxwell case, specifically regarding Rule 17(c) subpoenas and a court order on motions to quash them. The sender's identity is redacted, but the signature block confirms their role within the SDNY.
This document is an email chain from September and October 2021 between the Southern District of New York (USANYS) and AIC Title Service. It concerns a subpoena issued regarding aircraft N722JE. Bruce Marshall, General Counsel for AIC, provides the subpoena response in multiple parts to the US Attorney's office following initial coordination by Document Specialist Callie Meier.
This is a subpoena issued by the United States District Court for the Southern District of New York on July 13, 2021. It commands an unnamed (redacted) individual to appear on November 29, 2021, to testify in the case of United States v. Ghislaine Maxwell (20 Cr. 330). The document is signed by US Attorney Audrey Strauss and Clerk of Court Ruby J. Krajick.
This document is an email chain from August 8, 2019, originating from the United States Attorney's Office for the Southern District of New York. The subject matter concerns a request for Jeffrey Epstein's Social Security Number (SSN). Nicolas Roos is identified as a recipient in the chain, while an unnamed Assistant United States Attorney initiates the request.
This email chain between the US Attorney's Office (SDNY) and investigators discusses the identification of Jeffrey Epstein's associates who might facilitate financial transactions on his behalf. The response highlights the massive scale of Epstein's network, noting over 30 attorneys, 60+ accounts at Deutsche Bank, and AmEx records showing payments for nearly 5,000 flights over ten years. Darren Indyke and Jeffrey Schantz are specifically named as individuals likely to send money for Epstein.
This document is an email dated November 4, 2021, from an Assistant United States Attorney to Judge Nathan's chambers regarding the trial of Ghislaine Maxwell. The email submits an unredacted request to charge (RTC) and verdict sheet, noting that redacted versions will be filed on the Electronic Court Filing (ECF) system and that the defense seeks to seal 'Exhibit A'. Defense attorneys Christian Everdell, Jeff Pagliuca, and Laura Menninger are copied on the correspondence.
An email dated September 17, 2021, sent by an Assistant United States Attorney from the Southern District of New York to a redacted recipient. The subject is 'To read on train' and it includes several attachments containing interview notes (302s) and records related to Ghislaine Maxwell's arraignment and bail hearing, spanning dates from 2006 to 2020.
This document is an email chain from July 2021 between the US Attorney's Office (SDNY) and a CBP Task Force Officer named Raymond Sanicola. The correspondence concerns the retrieval of travel records for Jeffrey Epstein and Ghislaine Maxwell (referred to by name variations). A key finding noted by the CBP officer is that outbound travel records were not recorded in the CBP database between 1990 and 2000, limiting the data available for that period. The CBP officer attaches a consolidated spreadsheet of available crossings to the email.
An email chain from August 14, 2019 (four days after Epstein's death), discussing the logistics of sending a specific Victim Notification System (VNS) notice to registrants in the Epstein case (2018R01618). SDNY US Attorney Geoffrey Berman specifically requested a non-standard, two-paragraph notice. Staff at the SDNY and EOUSA discussed technical workarounds to remove standard closing paragraphs from the letters to comply with this request.
An email from an Assistant US Attorney in the Southern District of New York to the legal defense team of Ghislaine Maxwell (including Christian Everdell and others) dated October 8, 2021. The email serves as notification for an additional discovery production in the case US v. Maxwell (20 Cr. 330) and discusses logistical arrangements for providing digital evidence to Ms. Maxwell at the Metropolitan Detention Center (MDC).
An email from an Assistant US Attorney in the Southern District of New York dated October 7, 2021. The email discusses a draft '3500 Cover Letter' (referring to Jencks Act material) and an attachment named 'Maxwell_Cover_Letter', likely related to the Ghislaine Maxwell trial. The sender asks for review regarding language about a redacted individual.
An email dated November 22, 2021, from an Assistant United States Attorney in the Southern District of New York to defense attorneys Christian Everdell, Jeff Pagliuca, and Laura Menninger. The email discusses the procedure for filing redacted versions of legal documents related to birth certificates, exhibit GX-52, and a motion to quash, referencing Docket Numbers 473, 474, and 476. The sender proposes a sequence for filing cover letters and redacted motions to the Court.
This document is an internal email dated November 20, 2021, sent by an Assistant United States Attorney for the Southern District of New York to their legal team. The email concerns a 'Jury instructions letter' and includes an attachment titled '2021-11-20,_GM,_edits_to_limiting_instructions_v3.docx', likely related to the prosecution of Ghislaine Maxwell ('GM'). The sender asks for comments on the attached draft.
This document is an email chain from October 2021 between an Assistant United States Attorney (SDNY) and a support staff member. The AUSA is seeking access to an expired NBC News video interview titled 'How British teen model was lured into Jeffrey Epstein's web.' The respondent notes the video is not in their monitoring system but offers to reach out to contacts at NBC to obtain a copy for internal use.
This document is an email dated April 29, 2021, from an Assistant United States Attorney (SDNY) to Judge Nathan's chambers regarding the case US v. Maxwell (Ghislaine Maxwell). The email transmits a letter from the Metropolitan Detention Center (MDC) legal counsel in response to a court order from earlier that day, noting that the letter was not filed electronically because the MDC is not a formal party to the case.
This document is an email chain from September 24, 2021, between members of the US Attorney's Office for the Southern District of New York (USANYS), likely regarding the Ghislaine Maxwell trial (indicated by the attachment 'GM_defense.pptx'). An Assistant US Attorney circulates a draft PowerPoint related to the 'defense closing,' explicitly mentioning the inclusion of a 'fake photo' as a suggested exhibit. The team is rushing to finalize the slides so a staff member named Sunny can print them before the end of the day.
An email dated October 19, 2021, from an Assistant US Attorney (SDNY) to a colleague regarding 'Defense MIL 4'. The sender requests a discussion on how to respond to the defense's motion, noting the recipient had briefed a similar issue previously. The email includes an attachment titled '4._Motion_to_Exclude_Accuser-3_Evidence.pdf', likely relating to the Ghislaine Maxwell trial.
An email thread from July 2020 between the US Attorney's Office (SDNY) and unknown recipients regarding the case US v. Maxwell. An Assistant US Attorney provides the grand jury return for a superseding indictment, noting it is unsealed and was presented to Judge Nathan. A subsequent email requests the immediate docketing of the indictment on ECF to ensure notice is given before the defendant's upcoming arraignment.
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