This affidavit by attorney Bradley Edwards details difficulties in discovery for a civil case against Jeffrey Epstein (Case 10-81111). It alleges that key witnesses Ghislaine Maxwell and Jean Luc Brunel evaded depositions by falsely claiming to be out of the country. Crucially, it lists specific individuals for whom Epstein paid legal fees to prevent them from testifying against him, explicitly labeling Sarah Kellen as a 'procurer of girls' and Nadia Marcinkova as a 'live-in sex slave', while also identifying his personal pilots and household staff.
This document is a legal Opinion & Order from the Southern District of New York in the case of Mary Doe v. the Executors of Jeffrey Epstein's Estate. The court granted the executors' motion to dismiss the plaintiff's request for punitive damages. The judge ruled that New York law applies to the case because the torts occurred in New York, and under New York's Estates, Powers and Trusts Law (EPTL § 11-3.2(a)(1)), punitive damages cannot be awarded against the personal representatives of an estate.
An email from an Assistant US Attorney (SDNY) dated July 6, 2020, discussing the logistics of property transported with Ghislaine Maxwell. While her personal effects (clothes, jewelry, phone) were released to her defense counsel, the US Marshals requested that specific security footage from the local jail where she was held be picked up from 500 Pearl Street and stored in files, as the Bureau of Prisons (BOP) refused to keep it.
This document is an internal DOJ/prosecution email chain dated July 1, 2020, discussing the logistics of the imminent arrest of Ghislaine Maxwell ('GM') in the District of New Hampshire ('DNH'). The officials discuss the timing of the arrest relative to court presentment deadlines (1 PM cutoff) and coordinate when to hold a press conference and unseal the indictment, explicitly referencing the procedure used during Jeffrey Epstein's arrest as a precedent.
This document is a letter from attorney Scott A. Srebnick to Judge Paul G. Gardephe regarding the prison conditions of Michael Avenatti at MCC-New York. The letter details Avenatti's placement in the Special Housing Unit (SHU) on the 10-South floor (formerly El Chapo's cell), citing extreme cold, isolation, and lack of resources as impediments to trial preparation. The defense requests Avenatti be moved to the general population and granted standard access to legal materials and communication. The text alludes to 'recent issues at the institution,' likely a reference to Jeffrey Epstein's suicide at the same facility months prior.
This document is an email chain dated August 10, 2019. An individual from the US Attorney's Office (USANYS) forwards a Wall Street Journal news alert to a redacted recipient with the message 'In case you didnt see it'. The news alert reports that financier Jeffrey Epstein was found dead in jail while awaiting trial on sex-trafficking charges.
This document is an internal email thread from December 28, 2020, within the U.S. Attorney's Office for the Southern District of New York (USANYS). A contractor circulates a New York Daily News article titled 'Jeffrey Epstein's final days at NYC jail revealed by inmates,' which discusses Epstein and an individual named Efrain Reyes. The email is forwarded to ensure awareness among staff members.
An email thread dated July 25, 2019, discussing a New York Times article reporting that Jeffrey Epstein was found unconscious in his jail cell with neck marks in a possible suicide attempt. The initial email pastes the article text, highlighting quotes from an anonymous law enforcement official, and the response simply confirms with 'Yup'.
An email exchange between New York Times reporter Mihir Zaveri and an unidentified official (likely DOJ/BOP based on context). Zaveri inquires about reports that Jeffrey Epstein was found injured in his cell following a possible suicide attempt or assault on July 24, 2019. The official responds on July 25 stating they cannot confirm and have no comment.
This document is an automatic email reply dated December 28, 2020, from a USANYS employee. The subject line references a New York Daily News article about Jeffrey Epstein's final days in NYC jail. The body of the email indicates the sender is on leave for the week but checking email, with contact details for urgent matters redacted.
This document is an email chain from July 12-14, 2019, between defense attorney Reid Weingarten and Assistant U.S. Attorneys regarding the case U.S. v. Epstein. The correspondence begins with the government filing its reply in support of detention and opposing bail. Subsequent emails discuss scheduling a meeting between counsel, with Weingarten mentioning his visit to Epstein ('the client') at the jail on the evening of July 14th.
An email thread from December 2008 between attorney Katherine Ezell and an Assistant U.S. Attorney concerning Jeffrey Epstein's work release. Ezell inquires whether providing victim addresses to be programmed as 'off-limits' on Epstein's GPS device would inadvertently reveal those locations to him. The AUSA confirms that address information will not be disclosed to Epstein and details that the Palm Beach Sheriff's Office (PBSO) monitors his programmed travel routes.
An email chain from November 25, 2008, between an Assistant U.S. Attorney and an FBI agent regarding Jeffrey Epstein's work release case file. The officials discuss surveillance of Epstein's home, noting the presence of specific vehicles, and express concern that Epstein might attempt to flee ('run') in the coming days. They also mention monitoring for any information about planes leaving.
Internal email from an Assistant U.S. Attorney (Ccing Alex Acosta) discussing a victims' lawyer's request to void Epstein's plea deal due to additional victims. The AUSA confirms they are bound by the agreement. The email also details a meeting with the Sheriff's Office where it was revealed Epstein's legal team (Goldberger, Starr) threatened to sue over unfavorable treatment, and that Epstein would be granted work release despite prior contradictions.
This document contains a November 2007 email thread involving the US Attorney's Office (Alex Acosta cc'd) discussing the logistics of Jeffrey Epstein's plea agreement and sentencing. Key topics include the strategic scheduling of the plea/sentencing on December 16th to 'reduce media frenzy,' the legal nuances of his 'sexual predator' designation, and the loophole allowing the Sheriff's Office (rather than State Corrections) to grant him work release. The emails also detail coordination with Epstein's lawyers (Lefkowitz and Goldberger) regarding victim notification and potential conflicts of interest.
This document is a transcript of a legal deposition or interrogation involving Ghislaine Maxwell, Todd Blanche, and David Markus. The discussion primarily revolves around Jeffrey Epstein's legal cases, including a 2007-2009 investigation in the Southern District of Florida, his non-prosecution agreement, and Maxwell's knowledge and involvement in these matters. Maxwell denies direct knowledge of certain events, her contact with law enforcement, or direct discussions with Epstein about his legal deals.
This document is page 12 of a legal filing (Case 21-770) dated April 19, 2021, in which Ghislaine Maxwell's defense team argues against the Government's narrative regarding her confinement. The defense claims that unsanitary conditions are caused by others, accuses the Government of a double standard and HIPAA violations for releasing Maxwell's vaccination status while keeping accusers anonymous, and asserts that her vaccination does not resolve issues regarding her ability to prepare for trial using 'ancient' technology.
This legal document, part of a court filing, argues that the U.S. Government's description of inmate Ms. Maxwell's prison conditions is false. It counters claims of amenities by detailing harsh realities such as sleep deprivation from guards' actions, solitary confinement, unsanitary conditions, and inadequate resources for trial preparation. The filing asserts the government's information is based on unreliable, multi-layered hearsay from prison staff to the prosecutor.
This document is a juror questionnaire from a legal case involving Ms. Maxwell, filed on March 9, 2022. Juror 50 indicates they have not formed an opinion about Ms. Maxwell that would impede impartiality, but they have heard about Jeffrey Epstein from CNN, specifically regarding his death and that he was in jail awaiting trial. The juror denies ever publicly stating or posting opinions about either individual.
This document is a court transcript from August 10, 2022, detailing the cross-examination of a witness named Kate. The questioning, led by Ms. Sternheim, focuses on Kate's correspondence with Jeffrey Epstein while he was in jail. Kate confirms the correspondence, admits she told Epstein she would send pictures (but denies actually sending them), and confirms she signed her letters with 'Best love always, Kate'.
This document is a redacted character reference letter filed on December 14, 2020, in support of Ghislaine Maxwell's bail application (Case 1:20-cr-00330-AJN). The unnamed author argues that Maxwell has strong ties to the US, including her husband, and expresses distress over her incarceration conditions, specifically citing over 150 days of solitary confinement. The author pledges to stay in contact and provide support if Maxwell is granted bail to help her prepare for trial.
This document is a court transcript page from August 10, 2022, detailing the direct examination of a witness named Carolyn. Carolyn testifies that she previously pleaded guilty to felony possession of a stolen Xbox and false verification to a pawnbroker, for which she served 52 days in jail. She also discusses her subsequent drug treatment and therapy, and her current medications for opioid addiction, including methadone and Xanax.
This document is a page from a forensic-psychiatric report filed in June 2022 regarding Ghislaine Maxwell. It details an interview with her lawyer and acquaintance, Leah Saffian, who describes Maxwell's mental deterioration, sleep deprivation, and cognitive struggles due to 'quasi-solitary confinement' and hostile conditions. Saffian asserts Maxwell is not a flight risk and emphasizes her critical role in reviewing the millions of discovery documents for her own defense.
This document is a portion of a juror questionnaire for Juror 50, filed on February 24, 2022, for a case involving Ms. Maxwell. The juror states they have not formed any opinions about Ms. Maxwell that would prevent them from being impartial. The juror confirms they have previously heard about Jeffrey Epstein from CNN, specifically recalling news of his death and that he was in jail awaiting trial.
This document is a page from a character reference letter filed in court on June 15, 2022, in support of Ghislaine Maxwell prior to her sentencing. The anonymous author, a family friend of over 60 years, describes the difficult upbringing of the Maxwell children under their 'narcissistic' father, Robert Maxwell, and highlights Ghislaine's intelligence and work ethic at Oxford. The letter appeals to the judge for leniency, noting Ghislaine's regret over meeting Jeffrey Epstein and the harsh conditions she has endured in jail, including sleep deprivation.
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