This document is a blank Declaration of Custodian of Records form intended to authenticate an AT&T Wireless invoice dated May 5, 2004, for account number 0043811863 belonging to Jeffrey E. Epstein. It is prepared for use in an investigation and prosecution by the United States Attorney's Office for the Southern District of New York. The form cites Federal Rules of Evidence but has not yet been signed or dated by a declarant.
This document contains an email chain forwarding a Notice of Electronic Filing (NEF) from the U.S. District Court (SDNY) regarding the case USA v. Maxwell (1:20-cr-00330-AJN). The NEF details a court order by Judge J. Nathan dated December 8, 2020, which denies Ghislaine Maxwell's request to summon Warden Heriberto Tellez to testify about her confinement conditions. However, the order mandates that the Government submit written updates every 60 days regarding Maxwell's access to legal materials and ability to communicate with counsel.
This document is an email thread from an Assistant U.S. Attorney in the Southern District of New York. The emails document attempts to contact a redacted individual regarding the 'Epstein case' in late December 2019 and early January 2020. The sender notes leaving messages with a receptionist and following up with another message.
This document is a Search and Seizure Warrant issued by the U.S. District Court for the Southern District of New York (signed by Magistrate Judge James L. Cott). It authorizes law enforcement to search six binders containing CDs that were seized on July 11, 2019, from blue and black suitcases. The search is authorized to find evidence of sex trafficking of minors (18 U.S.C. 1591) and conspiracy (18 U.S.C. 371), specifically looking for photographs of victims, communications, and access data.
This document is an email chain between attorney Joe Nascimento and an Assistant U.S. Attorney from the SDNY regarding the Epstein investigation. The correspondence begins on July 6, 2019, after a client (formerly represented by Nascimento's deceased partner Alan Ross) was served with a grand jury subpoena. The emails discuss scheduling multiple meetings in West Palm Beach, explicitly mentioning a 'proffer' meeting requested for September 4th, 2019, and logistics affected by a hurricane.
An email exchange from November 2019 between an Assistant U.S. Attorney for the Southern District of New York and another individual. They are sharing and reacting with disbelief ('jesus.', 'Really?') to NY Post articles detailing public instances of the 'Epstein didn't kill himself' meme, specifically incidents involving an airport paging system and printed messages on beer cans.
This document is an email chain from January 2020 between Gary Bloxsome (Blackfords LLP) and prosecutors from the U.S. Department of Justice, Southern District of New York (SDNY). The SDNY formally requests a 'consensual, voluntary law enforcement interview' with Bloxsome's client, HRH The Duke of York (Prince Andrew), regarding the investigation into Jeffrey Epstein and his associates. Bloxsome confirms he represents the Duke and arranges a preliminary telephone call for January 10, 2020.
This document is a chain of emails between the U.S. Department of Justice (SDNY) and Gary Bloxsome of Blackfords LLP in early January 2020. The DOJ formally requests a voluntary law enforcement interview with Bloxsome's client, HRH The Duke of York (Prince Andrew), regarding his relationship with Jeffrey Epstein. The correspondence confirms Blackfords' representation of the Duke and arranges a preliminary telephone discussion for January 10, 2020.
This document is a Notice of Electronic Filing from the U.S. District Court (SDNY) regarding the case USA v. Maxwell. The filing is a Court Order dated December 8, 2020, in which Judge Nathan denies Ghislaine Maxwell's request to summon Warden Heriberto Tellez to testify regarding her conditions of confinement. The order mandates that the Government provide written updates on Maxwell's conditions, specifically regarding legal access, every 60 days.
This document is an email chain from July 2019 between the FBI and SDNY regarding the Epstein investigation (Case USvEpstein-2018R01618). It details the coordination of a 'game plan' meeting involving a forensic accountant and the transfer of financial evidence (specifically subpoena returns from American Express and Deutsche Bank) burned onto discs by a contractor named Hamilton.
This document is a letter dated September 9, 2019, from the U.S. Attorney's Office (SDNY) to Florence Hutner at the Office of the Chief Medical Examiner regarding Jeffrey Epstein's autopsy report. The USAO provides proposed redactions to the Epstein autopsy file and requests that the OCME withhold this letter, the attached redacted report, and a previous letter from August 28, 2019, from any third-party disclosure to preserve the integrity of an ongoing investigation. The letter references materials shared between the FBI, MCC, and OCME.
An email dated October 20, 2020, from an Assistant United States Attorney (SDNY) to a redacted recipient (likely at the MDC). The email coordinates the delivery of a hard drive containing new discovery materials for Ghislaine Maxwell via FedEx and requests confirmation upon delivery to the defendant.
This document is an email thread from July 31 to August 7, 2019, between defense attorney Michael Bachner and the US Attorney's Office for the Southern District of New York (USANYS) regarding the Epstein investigation. The USANYS attorneys express urgency, noting they have been 'holding in abeyance a grand jury date' and refuse Bachner's request to delay a discussion until August 14. The parties eventually agree to speak at 2:30 PM on August 7, 2019.
This document is an email chain from late October and early November 2020 concerning the potential expert testimony of Dawn Hughes, a Clinical and Forensic Psychologist, for the federal case of United States v. Ghislaine Maxwell. Federal prosecutors contacted Dr. Hughes to inquire about her availability to testify, leading to discussions about scheduling and the exchange of her CV and engagement agreement. Roberta Kaplan, Esq. is also mentioned as a contact.
An email exchange dated July 31, 2019, regarding the case United States v. Jeffrey Epstein (19 Cr. 490). An Assistant US Attorney informs defense counsel (Martin Weinberg) that the Government's first discovery production has been loaded onto a hard drive and is ready for pickup at the SDNY office in an envelope marked for Michael Miller.
This document is an internal email chain from June 19, 2019, within the U.S. Attorney's Office for the Southern District of New York (SDNY), specifically the Public Corruption Unit. The discussion concerns 'ODAG Update Memos' (Office of the Deputy Attorney General). The Co-Chief of the unit notes that while previous memos were 'MC related' (potentially Michael Cohen) and went to 'Audrey', the current memo is 'on Epstein,' prompting a check on whether the recipient wants to review it first. The recipient confirms they wish to be kept in the loop.
This document is an email chain from November 2020 between the US Attorney's Office (SDNY) and recipients likely within the BOP/MDC (Nicole McFarland, Sophia Papapetru). The discussion concerns a letter to Judge Nathan regarding Ghislaine Maxwell's confinement conditions. Specific complaints raised include a staff member potentially exposed to COVID-19 continuing to work, a staff member taking unauthorized photos of Maxwell in her cell, and Maxwell's deteriorating mental health due to sleep deprivation and constant surveillance.
This document is an email chain dated August 14, 2020, involving the Chief of the Public Corruption Unit at the U.S. Attorney's Office for the SDNY and other redacted staff members. The emails coordinate a time for a conference call regarding 'OPR' and other issues. One email explicitly mentions a conflict due to a witness interview for 'Prutech' and a 5:00 PM call to 'discuss the priv [privilege] review for the Epstein devices.'
This document is an email chain from late November to December 1, 2020, between officials at the US Attorney's Office (SDNY). They are coordinating a legal response regarding Ghislaine Maxwell, specifically involving a 'joint letter' to the Court and interactions with the BOP and MDC legal team. The correspondence notes that 'Bobbi and Chris' (likely defense counsel) rejected a proposal, necessitating the drafting of a new letter and affidavit regarding a defense request concerning the MDC warden.
This document is an affidavit filed on December 1, 2020, by Assistant US Attorney Lara Pomerantz in the case against Ghislaine Maxwell. It certifies that the prosecution and defense conferred but failed to reach an agreement regarding the defense's request for the MDC Warden (Tellez) to report directly to the Court on Maxwell's conditions of confinement.
This document is an email dated June 15, 2020, from a Legal Assistant at the United States Attorney's Office for the Southern District of New York. It conveys stamped and signed Non-Disclosure Orders (NDOs) and Pen Register orders (PENs) that had been submitted to the Magistrate Court. The recipient and specific details of the attachments are redacted.
This document is an email dated July 2, 2020, from an Assistant United States Attorney in the Southern District of New York to an FBI official. The email attaches a detention memorandum for the case 'United_States_v._Maxwell' (Case 20 Cr. 330 AJN) and notes that the prosecution will address the circumstances of the arrest orally during upcoming arguments.
An email dated May 6, 2020, from an Assistant U.S. Attorney in the Southern District of New York regarding the status of various prosecution memos. The email lists documents related to charging co-conspirators (including an 86-page update), corporate prosecution, a redacted individual's prosecution, and a perjury/Ghislaine Maxwell (likely 'NM' refers to Noelle Dunphy or similar, or potentially 'New Matter' or 'New Mexico' though context suggests a person, possibly Maxwell) memo.
This document is an email chain between the US Attorney's Office (SDNY) and technical support staff regarding the processing of digital evidence seized from Jeffrey Epstein's New York mansion and Virgin Islands property. The correspondence details significant technical challenges in reviewing over 1 million documents, including issues with linking emails to attachments, incompatible load files, and disorganized data dumps. It confirms the seizure of approximately 40 devices and 60+ CDs from NY, over 25 devices (including servers) from the Virgin Islands, and hard drives dating back to a 2007 search.
This document is an email chain from early 2020 between attorneys at Kaplan Hecker & Fink LLP (representing a party litigating against Jeffrey Epstein's estate) and the US Attorney's Office for the Southern District of New York (USANYS). The correspondence involves the submission of a 'Touhy letter' by the private firm to request documents from the Department of Justice regarding Epstein. The emails track the initial request in January, the formal submission in February, and a follow-up check-in during April 2020.
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