Email from an SDNY Assistant U.S. Attorney to Gary Bloxsome (lawyer, likely for Prince Andrew based on context of 2020 Epstein/Maxwell investigation and MLAT/London references) regarding 'Sensitive Correspondence.' The email provides a blank proffer agreement, outlines the legal elements of making false statements under 18 U.S.C. § 1001, and discusses protections under the MLAT process for a potential voluntary interview. It also confirms a negotiation period extension until August 10, 2020.
An email from an Associate U.S. Attorney at the Southern District of New York (SDNY) dated March 10, 2020. The sender requests a colleague to compile Epstein-related press releases, charges, and other public documents, referencing a meeting held a couple of weeks prior. The subject line references 'Epstein FOIAs'.
An internal email dated June 8, 2020, sent to Geoffrey Berman (USANYS) from a Co-Chief of the Public Corruption Unit. The email shares a Fox News article reporting that Attorney General Barr confirmed the DOJ wants Prince Andrew to provide evidence in the Epstein investigation.
This document contains an email chain from November 29-30, 2018, between the FBI New York Field Office and the U.S. Attorney's Office for the Southern District of New York (SDNY). The correspondence was triggered by a Miami Herald article regarding Jeffrey Epstein's previous non-prosecution agreement. An Assistant US Attorney (Human Trafficking Co-Coordinator) flagged the article, noting it sounded like Epstein cooperated in a financial fraud case. Subsequently, the FBI gathered information on the 'Jeff Epstein matter' and scheduled a conference call with the SDNY for 3:30 PM on November 30, 2018, to determine the way forward.
This document is an email chain from September and October 2020 between Marc A. Weinstein (Hughes Hubbard & Reed) and an Assistant US Attorney from the SDNY. The SDNY requested a specific deposition transcript from a 2009 lawsuit against Jeffrey Epstein involving a plaintiff represented by Jack Scarola. Weinstein coordinated with Scarola to ensure there were no protective orders preventing disclosure before providing the transcript to the SDNY on behalf of the Epstein Estate.
A formal letter dated October 2, 2020, from the U.S. Attorney's Office (SDNY) to the Metropolitan Detention Center (MDC). The letter encloses discovery materials for inmate Ghislaine Maxwell (Inmate #02879-509) related to case 20 Cr. 330 (AJN) and requests that she be granted access to these materials.
An email chain from February 2021 between the US Attorney's Office for the Southern District of New York (SDNY) and another office (likely Southern District of Florida). SDNY requests a specific document ('Box #1 P-003679 Thru P-003680') from the 'SDFL Epstein file' referenced in a privilege log connected to the CVRA lawsuit. The responding office cites technical issues with vendor scans and a reduced 25% in-office work schedule, necessitating a staff member to drive in specifically to locate the physical document.
This document is an email dated October 4, 2021, from an Assistant United States Attorney (SDNY) to the defense team for Ghislaine Maxwell (Everdell, Cohen, Sternheim, Menninger, Pagliuca). The email serves as a transmittal notice for an additional discovery production in the case US v. Maxwell (20 Cr. 330). The prosecutor notes that digital files are being sent via USAfx and a physical CD is being sent to the Metropolitan Detention Center (MDC) for Ms. Maxwell.
This document is an email chain from June 2021 between US Attorney's Office (SDNY) staff regarding a FOIA disclosure related to Tova Noel and Michael Thomas, the guards on duty during Jeffrey Epstein's death. The correspondence details an internal request to delay the document production by one week to verify that Noel and Thomas had satisfied the interview requirements of their Deferred Prosecution Agreements (DPAs). The chain confirms that 'The Times' (NYT) consented to the delay, the Court granted it, and the staff coordinated a review of 'newsworthy' items in the production while deciding not to notify the Epstein Estate.
This document is a court order from the United States District Court for the Southern District of New York in the case against Ghislaine Maxwell, dated November 18, 2021. Judge Alison J. Nathan orders that courtroom sketch artists are prohibited from drawing exact likenesses of 'Protected Witnesses' (those testifying under pseudonyms or first names) to protect their identities. The word 'PROPOSED' in the title is struck through, indicating the judge adopted this as a final order.
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 November 21, 2021, from an Assistant United States Attorney (SDNY) to defense attorneys Laura Menninger and Jeff Pagliuca. The email transmits attachments containing proposed redactions regarding 'Witness-3' (also referred to as Accuser-3 and MV-3 in filenames) related to case filings (Case 20cr330, United States v. Ghislaine Maxwell).
This document is a letter dated November 20, 2021, from the U.S. Department of Justice to Ghislaine Maxwell's defense team regarding the production of discovery materials. The government provided Jencks Act and Giglio materials for potential trial witnesses, as well as witness statements for individuals they did not currently intend to call to testify. The letter also clarifies confidentiality designations under a Protective Order.
An email exchange dated November 12, 2021, between officials at the Southern District of New York (SDNY). A Deputy Chief of the Public Corruption Unit requests a copy of 'GX-52G', and a colleague replies attaching that file along with defense motions related to Ghislaine Maxwell and FBI 302 reports from a 2009 obstruction case.
This document is an email chain from January and February 2020 between Roberta Kaplan (Kaplan Hecker & Fink LLP) and an Assistant United States Attorney from the Southern District of New York. The correspondence concerns a 'Touhy letter' submitted by Kaplan requesting documents from the Department of Justice for use in pending litigation against Jeffrey Epstein's estate. The US Attorney's office acknowledges receipt of the request.
An email update from the US Attorney's Office (SDNY) regarding the Epstein investigation dated September 3, 2019. It reports that interviews in Florida were postponed due to weather and details the results of attempting to interview two inmates housed across from Epstein's cell in the MCC; one declined and the other claimed to have slept through the incident.
This document is a letter from U.S. Attorney Damian Williams to the defense counsel for Ghislaine Maxwell, dated October 25, 2021. It details the production of discovery materials, including Jencks Act and Giglio materials, for potential trial witnesses and others the government does not currently intend to call. The letter also clarifies a labeling change for confidential documents to avoid confusion with classified materials, replacing 'confidential' stamps with references to the Protective Order.
This document is an email chain from November 29-30, 2018, between Assistant United States Attorneys in the Southern District of New York (SDNY). Following the publication of the Miami Herald's exposé (likely the 'Perversion of Justice' series), the prosecutors discuss 'additional digging' and the possibility of reopening the investigation into Jeffrey Epstein because his conduct 'touched on New York.' A meeting is scheduled to determine the way forward.
An email dated October 28, 2021, from an Assistant United States Attorney (SDNY) to defense counsel (including Laura Menninger and Christian Everdell) regarding the case US v. Maxwell (20 CR 330). The email serves to transmit the Government's reply brief in support of its motions in limine and notes that a redacted version will be filed publicly on October 29.
A legal filing (Nolle Prosequi) from November 2021 in the Southern District of New York effectively dismissing charges against Tova Noel and Michael Thomas (the guards on duty when Jeffrey Epstein died). The document states that the defendants successfully completed a six-month deferred prosecution agreement entered into in May 2021, including community service and good behavior. Consequently, the Government recommended, and Judge Analisa Torres ordered, the disposal of the case.
This is a Deferred Prosecution Agreement for Michael Thomas, a prison guard charged in connection with the falsification of records at the Metropolitan Correctional Center on August 9-10, 2019 (the night of Jeffrey Epstein's death). Thomas admits to willfully creating false 'count and round slips' for the Special Housing Unit. In exchange for 100 hours of community service, cooperation with the DOJ-OIG/FBI, and six months of good behavior, the government agrees to dismiss the indictment.
This document is an internal email chain from the U.S. Attorney's Office for the Southern District of New York (SDNY) dated November 23, 2021. It details the receipt of a voice message tip from an individual claiming to have information about Ghislaine Maxwell and asserting they are a friend of George Soros. The USANYS staff confirmed that the protocol for such tips is to forward them to the FBI case agents.
This document is an email chain between Ghislaine Maxwell's defense counsel (Christian Everdell) and the US Attorney's Office (SDNY) regarding discovery disputes in January 2021. The defense raises issues about defective hard drives provided to Maxwell in prison, missing pages from pilot David Rodgers' flight logs (specifically pages 1-27), and requests unredacted FBI reports from 2006. The government responds that the 'missing' flight log pages are accounted for in a separate document, asserts that redactions in the FBI report were original to the files found on Epstein's devices, and denies requests for grand jury subpoenas.
A subpoena issued by the US District Court (SDNY) on September 30, 2021, commanding AIC Title Service, Inc. to produce all records relating to aircraft N750A and N722JE from January 1, 2008, to the present. The subpoena is issued in connection with the criminal case United States v. Ghislaine Maxwell.
This document is an email chain from September and October 2021 between the US Attorney's Office (SDNY) and AIC Title Service. The correspondence concerns a subpoena for records related to aircraft N722JE. Bruce Marshall, General Counsel for AIC, transmits the response files to the AUSA, following initial processing by Document Specialist Callie Meier.
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