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050.pdf
Legal correspondence filed on April 15, 2021, in the case of United States v. Noel and Thomas (the guards on duty during Jeffrey Epstein's death). Assistant US Attorneys Lonergan and Roos inform Judge Torres of trial availability dates for the defendants in late 2021 and request an exclusion of time under the Speedy Trial Act.
047.pdf
Formal letter from U.S. Attorney Geoffrey Berman to Judge Richard Berman dated August 19, 2019, confirming Jeffrey Epstein's death by suicide while in custody on August 10, 2019. The letter requests the court approve an order of nolle prosequi to dismiss the indictment due to the defendant's death and reaffirms the office's commitment to the victims.
EFTA00038450.pdf
A formal request letter dated March 2, 2020, from the U.S. Attorney's Office (SDNY) to USAA Bank regarding Case Number C2002421770. The DOJ requests that USAA keep bank accounts associated with Ghislaine Maxwell (noted as a/k/a Ghislaine Borgerson) and Scott Borgerson open for a period of six months, stating that closing them would impact an ongoing criminal grand jury investigation.
EFTA00037897.pdf
A formal preservation request letter dated December 12, 2018, from the U.S. Attorney for the Southern District of New York (Geoffrey Berman) to Oath Holdings, Inc. The letter directs Oath to preserve all content, including emails and Google Drive files, associated with specific redacted accounts for 90 days pursuant to 18 U.S.C. § 2703(f)(1) for an ongoing investigation.
EFTA00032021.pdf
This document is a letter from the U.S. Department of Justice to Ghislaine Maxwell's defense team, dated September 15, 2021. It serves as notice that the government intends to call FBI Computer Forensic Examiner Stephen [Redacted] as an expert witness to testify regarding the extraction of data from seized electronic devices. The letter also reiterates previous government requests from 2020 and early 2021 for reciprocal discovery and expert witness notices from the defense.
EFTA00032003.pdf
This document is a formal letter dated June 10, 2021, from U.S. Attorney Audrey Strauss (SDNY) to the Legal Department of the Metropolitan Detention Center (MDC) in Brooklyn. The letter concerns the case United States v. Ghislaine Maxwell (20 Cr. 330) and encloses discovery materials for Maxwell (Inmate 02879-509), requesting that she be granted access to them. The names of the specific Assistant U.S. Attorneys involved are redacted.
EFTA00031609.pdf
A letter from the U.S. Department of Justice to attorney Mark Manley regarding his client's anonymity in the *United States v. Ghislaine Maxwell* case. The government states they do not intend to call the client as a witness but cannot guarantee the client's name will not appear in public trial exhibits or testimony. The letter notably asserts that UK privacy laws do not apply in this jurisdiction and clarifies that the client is not considered a victim of child sexual exploitation in this specific case.
EFTA00031440.pdf
This document is a discovery production letter from the U.S. Attorney's Office for the Southern District of New York to Ghislaine Maxwell's defense team, dated April 14, 2021. It details the production of a single photograph (Bates number SDNY_GM_02753398) designated as 'Confidential' under a Protective Order. The letter is signed by U.S. Attorney Audrey Strauss, with the specific Assistant U.S. Attorneys' signatures redacted.
EFTA00031437.pdf
A discovery letter from the U.S. Department of Justice to Ghislaine Maxwell's defense team dated April 14, 2021. The letter documents the production of a single item, a photograph (Bates SDNY_GM_02753398), which is designated as confidential under a July 2020 Protective Order. The specific names of the Assistant U.S. Attorneys signing the document are redacted.
EFTA00031435.pdf
This document is a discovery letter dated April 14, 2021, from the U.S. Attorney's Office (SDNY) to the defense counsel for Michael Thomas, one of the guards charged in connection with Jeffrey Epstein's death. The letter lists produced discovery materials including FBI reports and MCC documents, and provides statistical data from the Bureau of Prisons regarding disciplinary actions for log falsification and a list of inmate deaths at MCC and MDC over the last ten years, specifically listing Jeffrey Epstein's cause of death as 'Hanging' on August 10, 2019.
EFTA00030992.pdf
This document is a discovery letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team, dated August 21, 2020. It outlines the production of various evidentiary materials, including Boies Schiller documents, emails, search warrant photos, Jeffrey Epstein's deposition recordings (2010), travel records, and SORNA records. The letter explicitly notes that 'highly confidential' materials containing sexualized images are being provided only to counsel, not the defendant, and refuses to produce a separate FBI obstruction file regarding a redacted former employee of Epstein deemed irrelevant to the case.
EFTA00029981.pdf
A letter dated November 9, 2020, from the U.S. Attorney's Office (SDNY) to the Legal Department at the Metropolitan Detention Center in Brooklyn. The letter transmits the password for a drive containing discovery materials related to the case United States v. Ghislaine Maxwell. The password and specific attorney names are redacted.
EFTA00028260.pdf
A joint letter submitted to Judge Alison J. Nathan by the U.S. Attorney's Office and Defense Counsel in the case of United States v. Ghislaine Maxwell. The document outlines agreed-upon procedures and disagreements regarding the protection of witness identities during the upcoming trial, including the use of pseudonyms, voir dire protocols to screen jurors, specific jury instructions, and the use of physical binders for sealed exhibits to prevent public viewing. It includes a heavily redacted chart meant to map true witness names to their trial pseudonyms.
EFTA00028257.pdf
A letter from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense counsel dated November 9, 2021, regarding the production of discovery materials (Jencks Act and Giglio) for her trial. The letter explains that materials previously designated as 'confidential' are now marked with a specific reference to the Protective Order paragraphs to avoid confusion with classified document markings.
EFTA00028206.pdf
A letter dated November 6, 2021, from U.S. Attorney Damian Williams (SDNY) to the Legal Department of the Metropolitan Detention Center (MDC) in Brooklyn. The letter encloses witness materials relevant to the case United States v. Ghislaine Maxwell (20 Cr. 330) and requests that the inmate, Ghislaine Maxwell (ID 02879-509), be granted access to these materials. The specific names of the Assistant U.S. Attorneys signing the document are redacted.
EFTA00028045.pdf
This document is a discovery production letter dated October 1, 2020, from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team. It details the transfer of financial records from Deutsche Bank, JPMorgan Chase, Citibank, UBS, and American Express, many of which are designated as confidential. The letter specifically links Ghislaine Maxwell to various entities including the Terramar Project, Max Foundation, and Angara Trust via UBS records, and notes shared American Express records between Maxwell and Jeffrey Epstein.
EFTA00027711.pdf
A letter dated November 11, 2021, from the U.S. Attorney's Office for the Southern District of New York to the Metropolitan Detention Center. The letter provides the password for a hard drive containing discovery materials, witness materials, and government exhibits related to the case United States v. Ghislaine Maxwell.
EFTA00026851.pdf
This document packet contains a sealed Order and Grand Jury Subpoena from the Southern District of New York, issued in February 2020, directing the Interlochen Center for the Arts to produce student records. The investigation concerns 18 U.S.C. § 2423(a) (transportation of minors) and specifically seeks records of all students enrolled between January 1, 1994, and December 31, 1998. The court ordered the subpoena be kept secret for 180 days to prevent witness intimidation or evidence tampering.
EFTA00026750.pdf
This document is a letter from the U.S. Department of Justice to Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell. The Government argues for the entry of its proposed protective order regarding discovery materials, specifically opposing the defendant's request to publicly name victims who have previously spoken to the media and opposing restrictions on the Government's use of its own investigative materials. The document includes the full text of the proposed protective order, detailing how 'Confidential' and 'Highly Confidential' information (including sexualized imagery) must be handled by the defense.
EFTA00026715.pdf
A letter dated August 13, 2020, from Acting U.S. Attorney Audrey Strauss to the Legal Department of the Metropolitan Detention Center (MDC). The letter concerns the case United States v. Ghislaine Maxwell and provides a password (which is redacted in the document) for a drive containing discovery materials.
EFTA00025166.pdf
A cover letter from the U.S. Attorney's Office for the Southern District of New York, dated October 29, 2021, addressed to Ghislaine Maxwell at MDC Brooklyn. The letter serves to transmit enclosed discovery materials and Government Exhibits related to the case United States v. Ghislaine Maxwell (20 Cr. 330). The names of the Assistant US Attorneys are redacted.
EFTA00025066.pdf
This document is a letter dated October 11, 2021, from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense team. It formally notifies the defense that the government intends to refer to Jeffrey Epstein and other redacted individuals as co-conspirators during the trial, specifically for the purpose of admitting evidence under the co-conspirator hearsay exception. The letter is marked as Exhibit 1 and designated as confidential under a protective order.
EFTA00023045.pdf
A discovery cover letter dated July 21, 2021, from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team. The letter accompanies the production of 'FedEx Records' (Bates range SDNY_GM_02753552 to SDNY_GM_02759392) which are designated as confidential under a protective order. The document outlines the ongoing discovery obligations of the government.
EFTA00021941.pdf
This document is a formal letter from the U.S. Department of Justice (SDNY) to Ghislaine Maxwell's defense team, dated October 11, 2021. It serves to notify the defense that the Government intends to refer to Jeffrey Epstein and other redacted individuals as co-conspirators during the trial, pursuant to a court order. The letter is marked as Exhibit 1 and designated as confidential under a protective order.
EFTA00020846.pdf
A Grand Jury Subpoena dated February 6, 2020, issued by the US Attorney for the Southern District of New York to the Interlochen Center for the Arts. The subpoena demands records regarding donations, tuition payments, and campus visits by Jeffrey Epstein and Ghislaine Maxwell in connection with an investigation into violations of 18 U.S.C. § 2423(a) (transportation of minors). The return date for the documents was set for February 21, 2020.
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