SOUTHERN DISTRICT OF NEW YORK
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EFTA00029439.pdf
This document is an email dated December 19, 2019, from an Assistant U.S. Attorney in the Southern District of New York to colleagues. It details a phone call with counsel for the Epstein estate trustees, who are requesting a meeting with a senior official (redacted, referred to as 'she') to negotiate the resolution of the government's civil forfeiture claims and discuss the proposed victims' compensation fund. The trustees seek to 'elevate' the discussion beyond the line assistants.
EFTA00029427.pdf
This document is an internal email chain within the Southern District of New York (SDNY) dated December 19, 2019. An Assistant U.S. Attorney reports on a call with counsel for the Trustees of the Epstein estate, who requested a meeting with a senior SDNY official (name redacted) to negotiate the resolution of the government's civil forfeiture claims and discuss a proposed victim compensation fund. The email highlights that the line assistants lack the authority to negotiate these terms.
EFTA00029425.pdf
This document is an internal email chain among the US Attorney's Office for the Southern District of New York (SDNY) regarding the opening of the *United States v. Ghislaine Maxwell* trial in November 2021. An Assistant US Attorney sends a motivational message to the team, contrasting SDNY's willingness to prosecute old crimes with Florida prosecutors, and provides logistical details for the trial opening at the 40 Foley courthouse. Colleagues respond with well-wishes.
EFTA00029423.pdf
This document is an email chain from November 2021 between the US Attorney's Office (SDNY) and defense attorneys (Christian Everdell, Laura Menninger, Jeff Pagliuca), likely regarding the Ghislaine Maxwell trial. The correspondence concerns proposed redactions for filings related to 'Witness-3' and includes an attachment referencing a letter to Judge Nathan. Christian Everdell requests a quick phone call with the prosecutor during the exchange.
EFTA00029422.pdf
An internal email chain among SDNY prosecutors and staff immediately preceding the opening statements of the Ghislaine Maxwell trial in November 2021. The emails contain strong motivational language, explicitly contrasting the SDNY's willingness to prosecute historical crimes with the perceived failure of Florida prosecutors in the past. It provides specific logistical details for the trial opening, including courtroom numbers and schedules.
EFTA00029421.pdf
An email thread from November 28, 2021, among SDNY staff regarding the opening of the *United States v. Ghislaine Maxwell* trial. An Assistant US Attorney sends a motivational message to the office, contrasting SDNY's willingness to prosecute historical sex crimes with prosecutors in Florida (a reference to the earlier Epstein non-prosecution deal). The email provides logistical details for the trial opening at 40 Foley Square, including courtroom numbers and overflow rooms.
EFTA00029307.pdf
This document is an internal email chain between Assistant United States Attorneys for the Southern District of New York dated September 10, 2019. The discussion concerns a scanned note written by Jeffrey Epstein, which the attorneys interpret as a 'list of grievances' regarding his confinement conditions. The emails identify a redacted individual as a guard and mention a specific complaint that a person named 'Noel' served Epstein burnt food.
EFTA00029286.pdf
An email chain from a Deputy US Marshal regarding Ghislaine Maxwell's confinement and transport conditions during her trial (USA v. Maxwell). The email explains that Maxwell is transported first daily due to enhanced security measures to avoid delaying other proceedings. It also clarifies that the USMS does not provide extra clothing or utensils, noting that the lunch provided by MDC Brooklyn generally does not require utensils.
EFTA00029277.pdf
This document is an email chain between attorney Scott Richman (representing Mark Epstein) and an Assistant United States Attorney from the Southern District of New York. The emails detail a scheduling conflict regarding a meeting originally thought to be on October 28 or October 31, 2019, which caused confusion as Mark Epstein was flying in from Florida. The meeting was eventually rescheduled for November 7, 2019, and the most recent email from November 25, 2019, indicates Mark Epstein and his attorney were present at the building waiting for the meeting.
EFTA00029275.pdf
This document is an email thread from February 10, 2020, between Assistant U.S. Attorneys regarding the Epstein/Maxwell investigation. The discussion focuses on managing concerns from witnesses' counsel regarding confidentiality following public comments made about Prince Andrew on January 27. The emails mention that two potential witnesses who worked for Maxwell/Epstein have expressed willingness to be interviewed, while another witness has already met with prosecutors multiple times. There is also a reference to reviewing depositions related to Ghislaine Maxwell.
EFTA00029241.pdf
A letter from defense attorney Christian R. Everdell to Judge Alison J. Nathan dated April 8, 2021, regarding the case United States v. Ghislaine Maxwell. The letter requests permission for defense counsel to bring electronics and specific legacy media equipment (VCR, cassette players, etc.) into the courthouse for an evidence view scheduled for mid-April 2021.
EFTA00029187.pdf
This document is an email chain dated May 21, 2021, between the U.S. Attorney's Office for the Southern District of New York (USANYS) and the DOJ Office of Inspector General (OIG). The correspondence coordinates the language of a public letter announcing a deferred prosecution agreement with the two guards charged with falsifying records on the night of Jeffrey Epstein's suicide. The emails confirm that the guards agreed to be interviewed by OIG and that OIG had no objections to the USANYS stating that an OIG investigation was ongoing.
EFTA00029185.pdf
This document is an email from May 2021 containing an internal DOJ 'Urgent Matter Report' (UMR). The report details the decision by the USAO-SDNY to offer deferred prosecution agreements (DPAs) to Tova Noel and Michael Thomas, the correctional officers on duty when Jeffrey Epstein committed suicide in August 2019. The agreement requires them to admit guilt regarding falsified records, perform community service, and cooperate with the OIG investigation into the institutional failures at the MCC.
EFTA00029182.pdf
An email dated January 28, 2019, from the Deputy Chief of the Public Corruption Unit at the U.S. Attorney's Office for the Southern District of New York. The subject is 'Epstein' and the sender asks a redacted recipient to 'swing by' if they have a minute.
EFTA00029179.pdf
An internal email chain from the U.S. Attorney's Office for the Southern District of New York dated November 14, 2019. A Public Affairs officer alerts colleagues that CNN has learned a decision or announcement regarding charges in the Epstein/MCC case (likely referring to the guards involved in his death) is expected the following week. The forwarding official questions the source of this information.
EFTA00029177.pdf
This document is an email chain between US Attorneys in the Southern District of New York dated July-August 2020. They are discussing the extent of Ghislaine Maxwell's involvement and mention in the original Southern District of Florida (SDFL) investigation, specifically reviewing grand jury testimony and search warrants. The text quotes an agent's testimony stating Maxwell met 'Jane Doe Number One' at Mar-a-Lago and introduced her to Epstein, after which she began providing massages.
EFTA00029100.pdf
This legal filing is a Reply Memorandum by Ghislaine Maxwell's defense team, arguing for the suppression of evidence and dismissal of charges based on government misconduct. The defense asserts that prosecutors misled Chief Judge McMahon about the extent of their prior coordination with civil attorneys (Boies Schiller Flexner) to obtain a grand jury subpoena, thereby circumventing a civil protective order. The document details a specific meeting on February 29, 2016, where civil attorneys 'pitched' the prosecution of Maxwell and provided documents, including flight records (though the specific flight data is not listed in this text), which the prosecution later failed to disclose to the judge.
EFTA00029074.pdf
This document is an email chain from the United States Attorney's Office for the Southern District of New York (SDNY) dated November 29, 2018. It details the internal discussion and decision to immediately open a new investigation into Jeffrey Epstein following the publication of a Miami Herald article. Key officials discuss bringing in the FBI-NY sex crimes squad, retrieving old FBI files, and issuing an immediate subpoena to establish jurisdiction ('stake claim').
EFTA00029063.pdf
This document is an email chain from June 2021 between staff at the US Attorney's Office for the Southern District of New York (USANYS). They discuss seeking and subsequently obtaining a one-week extension from the Court (Judge PAE) for a FOIA disclosure related to 'Noel/Thomas' (referring to the deferred prosecution agreements of Epstein guards Tova Noel and Michael Thomas). The extension was requested to review recently completed interviews to ensure the guards met the requirements of their agreements; the plaintiff ('The Times') consented to the delay.
EFTA00029061.pdf
This document is an internal email chain discussing a Uniform Message Report (UMR) regarding deferred prosecution agreements for two correctional officers, Tova Noel and Michael Thomas. These officers were charged with making false statements and obstructing the lawful function of the MCC in connection with Jeffrey Epstein's suicide on August 10, 2019. The agreements require their cooperation with an OIG investigation, admission of guilt, and community service.
EFTA00029020.pdf
This document is an internal DOJ/US Attorney's Office email chain from June 2021 discussing a data security incident ('spill') related to the Ghislaine Maxwell prosecution. A contractor (employed by CACI) improperly uploaded 5.5 GB of discovery material, which included under-age victim names and other PII from the Jeffrey Epstein case, to Sharefile.com instead of the secure USAfx system. The correspondence confirms the data contained sensitive victim information, discusses the lack of disciplinary action for one individual, and notes that a involved contractor was leaving CACI for unrelated reasons.
EFTA00029018.pdf
This document is an internal email thread from June 2019 within the US Attorney's Office for the Southern District of New York (SDNY). An Assistant U.S. Attorney expresses concern and confusion that the Civil Division is processing a FOIA request related to the Jeffrey Epstein investigation, explicitly stating that the criminal investigation was 'still covert' at that time. The responder indicates they are 'checking' on the situation.
EFTA00028974.pdf
This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on March 15, 2021, supporting a motion to dismiss counts 1-4 of the superseding indictment. The defense argues that the indictment lacks specificity regarding names, dates, and details of the allegations, preventing Maxwell from preparing an adequate defense. The filing criticizes the government for using vague categories like 'Minor Victims' and 'multiple minor girls' without clarification and cites legal precedents to argue that the lack of specificity violates due process.
EFTA00028929.pdf
This document is a Reply Memorandum filed by Ghislaine Maxwell in the United States District Court, Southern District of New York, requesting the suppression of evidence obtained from a government subpoena to Boies Schiller and dismissal of counts five and six. It includes a Table of Contents, Table of Authorities citing various legal cases and rules, and a Table of Exhibits detailing communications and notes related to the case from 2016 to 2021, many involving AUSAs and individuals like Peter Skinner, Stan Pottinger, Brad Edwards, and Sigrid McCawley. The memorandum argues that the government misled the court and that the evidence should be suppressed due to due process violations.
EFTA00028903.pdf
This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on March 15, 2021, supporting a motion to dismiss counts one through four of her indictment as time-barred. The defense argues that the 2003 Amendment to 18 U.S.C. § 3283, which extended the statute of limitations, cannot be applied retroactively because Congress explicitly rejected a retroactivity provision. Additionally, the defense contends that the Mann Act offenses charged (enticement to travel and transportation of a minor) do not 'necessarily entail' the sexual abuse of a child, and thus the extended statute of limitations under § 3283 does not apply.
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