A letter from Fordham Law Professor Bruce A. Green to Judge Richard Berman clarifying the record regarding a previous court hearing. Green asserts that contrary to comments made in court, he has never served as legal counsel for Jeffrey Epstein or his estate, although he did serve as an expert witness for Alan Dershowitz in a separate defamation case (Giuffre v. Dershowitz).
This document is a reply filed by Bradley J. Edwards in support of his motion to quash a subpoena served on him by Ghislaine Maxwell in the case of Giuffre v. Maxwell. Edwards argues that the subpoena imposes an undue burden on him as a non-party and opposing counsel, seeking information that is already in Maxwell's possession, privileged, irrelevant, or available from other sources. The brief details the history of related litigation, including the CVRA case and a defamation suit against Alan Dershowitz, to support the argument that the subpoena is harassing and unnecessary.
A status update letter dated November 2, 2020, from attorney Mariann Meier Wang to Judge Debra Freeman regarding three civil cases against the Estate of Jeffrey Epstein (Indyke et al.). The letter informs the court that the plaintiffs have registered with the Epstein Victims Compensation Program and requests that the cases remain stayed pending resolution through that program.
A status update letter dated August 14, 2020, from attorney Mariann Meier Wang to Judge Debra Freeman regarding three civil cases against the Estate of Jeffrey Epstein (Indyke et al.). The letter informs the court that the plaintiffs are currently presenting their claims to the Epstein Victims Compensation Program and requests that the court cases remain stayed pending the outcome of this alternative dispute resolution process.
Legal correspondence from Plaintiff's attorney Daniel Mullkoff to Judge Debra Freeman regarding the case Davies v. Indyke et al. The letter argues that the Defendants improperly raised a new argument concerning the New Mexico statute of limitations for the first time in a reply brief and contends that the Plaintiff's claims regarding sexual abuse by Jeffrey Epstein in New Mexico are timely under the discovery rule.
A legal letter dated March 16, 2020, from attorney Mariann Meier Wang to Judge Debra Freeman in the case Davies v. Indyke et al. The letter requests a one-week extension for briefing deadlines regarding a motion to dismiss, citing disruptions caused by COVID-19 response measures. Opposing counsel Bennet J. Moskowitz consented to the request.
This document is a legal letter dated February 6, 2020, from attorney Mariann Meier Wang to Judge Debra Freeman regarding discovery schedules in three lawsuits (Jane Doe 15, Mary Doe, and Davies) against the Estate of Jeffrey Epstein. The plaintiffs advocate for standard discovery timelines (120 days), while the Defendants (Co-Executors Indyke and Kahn) request longer periods (140-160 days) citing the complexity of managing over twenty pending cases against the Estate. The letter also touches on the status of settlement discussions in the Davies case, noting that the voluntary compensation program has not yet been approved.
A letter from plaintiff's attorney Mariann Meier Wang to Magistrate Judge Debra Freeman in the case of Davies v. Indyke et al., dated January 27, 2020. The letter proposes a briefing schedule for a motion to dismiss. Judge Freeman endorsed the letter with a handwritten order on January 28, 2020, directing counsel to provide an update on settlement discussions before the court sets a briefing schedule.
A letter dated January 27, 2020, from attorney Mariann Meier Wang to Magistrate Judge Debra Freeman regarding the case Davies v. Indyke et al. The letter seeks clarification on procedural requirements following the referral of the case and proposes a briefing schedule for the Defendants' motion to dismiss, with dates ranging from February to March 2020. It references prior court filings from January 21 and January 22, 2020.
This document contains an email chain from April 19, 2023, between Daniel Ruzumna (attorney for the Epstein Estate) and an FBI Special Agent regarding the discovery of potential Child Sexual Abuse Material (CSAM). Attorneys reviewing approximately 1,100 videos from Epstein's files for civil litigation discovered a video depicting topless women, reportedly shared with Epstein by a convicted sex offender. The attorneys halted their review and contacted the FBI for guidance on how to proceed.
This document is an email from April 2023 sent by Daniel Ruzumna, an attorney for the Epstein Estate, to a federal agent. Ruzumna reports that during a court-ordered review of approximately 1,100 videos from Epstein's files, co-counsel discovered a video potentially containing child pornography, which had been sent to Epstein by a convicted sex offender. The review was immediately halted, and the Estate sought guidance from federal authorities.
This document is a legal letter dated October 19, 2023, from a coalition of 17 State Attorneys General (led by New Mexico AG Raúl Torrez) to Judge Jed S. Rakoff regarding the case Doe v. JPMorgan Chase Bank, N.A. The Attorneys General object to Section 1.25 of the proposed settlement, which attempts to release 'sovereign or government' claims. They argue this language improperly interferes with their authority to bring parens patriae actions under the Trafficking Victims Protection Act (TVPA) on behalf of trafficking victims, contrasting this with the Deutsche Bank settlement which did not contain such a release.
This document is an 'Access to Justice' email newsletter from Law360 dated April 20, 2020. It aggregates various legal news stories, primarily focused on the impact of the COVID-19 pandemic on the justice system, including court closures, remote hearings, and bankruptcy issues. It is relevant to the Epstein files because it contains a summary of a recent Eleventh Circuit ruling that the Crime Victims' Rights Act protections do not arise until after a formal criminal charge is filed, which is described as a blow to Epstein's victims.
Internal DOJ/SDNY email thread dated June 19, 2019, circulating a Law360 article about Alan Dershowitz's legal bid to disqualify the law firm Boies Schiller Flexner from representing his accuser, Virginia Giuffre. The article details the conflict of interest allegations stemming from a 2015 interaction between Dershowitz and Boies Schiller partner Carlos Sires, and notes Judge Preska's decision to consider the motion. The email discussion confirms that the DOJ press office had not received inquiries from reporters about the case.
This document is an email from June 2019 forwarding a Law360 article about the legal battle between Alan Dershowitz and the law firm Boies Schiller Flexner LLP. The article details Dershowitz's attempt to disqualify the firm from representing his accuser, Virginia Giuffre, citing a conflict of interest stemming from a 2015 interaction with partner Carlos Sires. U.S. District Judge Loretta Preska ruled that Dershowitz could pursue the disqualification bid, reinstating a motion she had previously removed for procedural reasons.
This document is an email dated May 6, 2020, containing the text of a Law360 article. The article details a sentencing hearing for fraudster Terrance Morgan, during which U.S. District Judge Richard M. Berman severely criticized the Bureau of Prisons (BOP) for terrible conditions at NYC federal jails (MDC and MCC). Judge Berman, who presided over Jeffrey Epstein's case, expressed disappointment that Attorney General William Barr failed to conduct a thorough investigation of the BOP as pledged following Epstein's suicide.
This document is a digital calendar entry for an event titled 'Conference: Jeffrey Epstein' scheduled for July 18, 2019, at Courtroom 17B, 500 Pearl Street (SDNY Courthouse). The event was created the day prior, on July 17, 2019. The organizer and attendees of the meeting are redacted.
This document is an email chain from October 2021 between the Sacramento County Clerk/Recorder's office (Andrew B. Graham) and likely the U.S. Attorney's Office for the Southern District of New York. The correspondence concerns compliance with a court subpoena regarding a 'vital record' needed for an upcoming federal criminal trial (likely the Ghislaine Maxwell trial given the timeframe and context). Issues discussed include waiving fees for the record, the logistics of submitting a vital record application, and whether a county official must appear in person in New York to testify or if mailing the record is sufficient.
This document is a table of contents or index for a series of legal documents, including opinions, judgments, orders, and a non-prosecution agreement, spanning dates from 2007 to 2024. It references legal proceedings involving the U.S. Court of Appeals for the Second Circuit, the U.S. Attorney for the Southern District of Florida, the U.S. District Court for the Southern District of New York, and the Department of Justice Office of Professional Responsibility.
This is a legal letter dated August 5, 2025, from attorney Sigrid McCawley of Boies Schiller Flexner LLP to U.S. District Judges Berman and Engelmayer. The letter is written on behalf of victim Annie Farmer regarding the unsealing of grand jury transcripts for Jeffrey Epstein and Ghislaine Maxwell. The letter heavily criticizes the Department of Justice for failing to pursue further criminal investigations and notes that Maxwell is attempting to negotiate a pardon.
This document is page 115 of a court transcript (Document 782) filed on January 15, 2025, from the case USA v. Ghislaine Maxwell (1:20-cr-00330). It features the cross-examination of a witness named Rocchio, who is testifying about the clinical and legal definitions of 'grooming' versus 'normative behaviors.' The dialogue focuses on the necessity of 'intent to sexually abuse' to distinguish grooming tactics from normal relationship-building or parenting.
This is a memo dated August 5, 2025, from the law firm Boies Schiller Flexner LLP to federal judges Richard M. Berman and Paul A. Engelmayer. The firm, writing on behalf of victim Annie Farmer, responds to a notice about the potential unsealing of grand jury transcripts for Jeffrey Epstein and Ghislaine Maxwell. The memo strongly criticizes the U.S. Government for not pursuing further criminal investigations, despite admitting there were over a thousand victims, calling this inaction a 'cowardly abdication' of its duties.
Fordham law professor Bruce A. Green writes to Judge Richard M. Berman to correct a misunderstanding from an August 27, 2019, hearing in the case *United States v. Epstein*. Green clarifies that, contrary to the court's apparent understanding, he has never served as counsel for Epstein or his estate. He explains that his only involvement in a related matter was serving as an expert witness for Professor Dershowitz in a separate defamation case, a role that concluded in June 2019 and did not involve representation or advocacy.
This document is a 'Table of Authorities' from a legal filing in case 1:20-cr-00330-AJN, filed on December 18, 2020. It lists numerous U.S. federal court cases, dating from 1985 to 2019, that are cited as legal precedent in the main document. The cases cover various federal districts and circuits, with a significant number originating from courts in New York.
This document is the cover page for a legal filing titled "Ghislaine Maxwell's Motion to Consolidate Appeals," submitted to the United States Court of Appeals for the Second Circuit on September 10, 2020. The motion concerns two separate appeals involving Ghislaine Maxwell as the Defendant-Appellant: one from a civil case (15-CV-7433) brought by Virginia L. Giuffre, and another from a criminal case (20-CR-330) brought by the United States of America, both originating from the U.S. District Court for the Southern District of New York.
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