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2022.08.02%20Memorandum%20Of%20Law.pdf
This document is a Supplemental Brief filed on August 1, 2022, by the Co-Executors of the Estate of Jeffrey Epstein (Indyke and Kahn) in the Superior Court of the Virgin Islands. The brief supports a Motion to Dismiss Ghislaine Maxwell's complaint seeking indemnification from the Estate. The Co-Executors argue that because Maxwell was convicted of intentional criminal acts (sex trafficking and conspiracy) in the Southern District of New York on June 29, 2022, public policy prohibits enforcing any contract or equitable doctrine that would indemnify her for the financial consequences of her crimes.
2021.04.13%20Reply%20Motion.pdf
This document is a 'Plaintiff's Reply to Co-Executors' Brief' filed on April 13, 2021, in the Superior Court of the Virgin Islands by Ghislaine Maxwell's legal team. Maxwell argues that her indemnification case against the Estate of Jeffrey Epstein should not be transferred to the Complex Litigation Division nor assigned to the same judge handling the 'CICO action' (Government v. Indyke). She asserts that her case does not meet the criteria for complex litigation and shares no common facts or claims with the government's racketeering case against the executors.
2021.04.02%20Notice%20of%20Appearance.pdf
This document is a Notice of Appearance filed on April 2, 2021, in the Superior Court of the Virgin Islands for Case No. ST-20-CV-155 (Ghislaine Maxwell v. Estate of Jeffrey Epstein et al.). Attorney Gordon C. Rhea enters his appearance as counsel for Defendant Richard D. Kahn, who is an Executor of the Estate of Jeffrey E. Epstein. The document includes a Certificate of Service confirming the filing was served electronically to attorneys Kyle Waldner, Christopher Kroblin, Shari N. D’Andrade, and Carol Thomas-Jacobs.
EFTA00034092.pdf
Bureau of Prisons Daily Activity Report for MCC New York dated August 6, 2019, covering activities on August 5, 2019. The report highlights significant staffing shortages resulting in vacated posts across all shifts (Morning, Day, Evening), including in the Special Housing Unit (SHU). It notes an inmate (name redacted) placed in SHU pending SIS investigation and an inmate on suicide watch with a companion, occurring shortly before Jeffrey Epstein's death.
EFTA00028110.pdf
This document contains a series of email correspondence from 2019 involving an Assistant U.S. Attorney from the Southern District of New York requesting travel authorization for the 'United States v. Epstein' investigation (Case ID 2018R01618). The emails detail multiple trips planned for West Palm Beach, Florida, and Los Angeles, California, specifically for the purpose of conducting meetings and interviewing victims related to the enticement of minors for sexual activity. The document establishes a timeline of investigative activity occurring in March, April, May, June, and November of 2019.
EFTA00016932.pdf
This document contains a series of internal emails (likely Department of Justice/SDNY) ranging from March 2019 to December 2019 regarding travel approvals for the 'United States v. Epstein' investigation (Case 2018R01618). The emails detail multiple trips by an investigative team (Assistant U.S. Attorneys and agents) to West Palm Beach, Florida, and Los Angeles, California, to conduct interviews with victims and witnesses. Detailed flight information is provided for a December 2019 trip to Los Angeles, utilizing Delta and JetBlue.
EFTA00016865.pdf
This document is the Last Will and Testament of Jeffrey E. Epstein, executed on January 27, 2012. It directs the transfer of all his property to 'The Jeffrey E. Epstein Trust One' (a pour-over will) and appoints Darren K. Indyke, Joseph Pagano, and Lawrence Newman as Executors, with Jes Staley and Andrew Farkas named as successors. The will includes broad powers for the Executors and a strict 'in terrorem' clause to disinherit any beneficiary who contests the validity of the will or the trust.
EFTA00016841.pdf
This document contains Jeffrey E. Epstein's Last Will and Testament (2001) and four subsequent Codicils (1st, 2nd, 3rd, and 5th). The will leaves all property to the 'Jeffrey E. Epstein 2001 Trust One'. Over time, the codicils change the appointed Executors (moving from Schantz/Hoffman to Jarecki/Cayne/Newman), designate Darren Indyke as successor, and increase executor compensation from $100,000 to $500,000. The 5th Codicil references a 'Fourth Codicil' dated September 5, 2007, which is not included in this specific packet.
EFTA00015880.pdf
This document is an email chain from December 2020 between officials at the US Attorney's Offices in New York (SDNY) and New Hampshire (USANH), the FBI, and the NYPD. The discussion concerns whether to extend the court seal on a 'Triggerfish' warrant (likely a cell-site simulator used for tracking) related to Ghislaine Maxwell in the District of New Hampshire (DNH). The officials agree that they cannot justify extending the seal and decide to let it lapse.
EFTA00013610.pdf
This document is an email chain from September 21, 2007, regarding the finalization of Jeffrey Epstein's plea deal. Attorney Lilly Ann Sanchez writes to a redacted government official (who is on vacation) urging them to resolve an outstanding issue so they can sign the deal 'as soon as today.' She expresses concern that 'Alex' (likely Alexander Acosta) has not read all defense submissions and notes that the recipient is the only one left in the chain of command capable of resolving the matter.
EFTA00010620.pdf
This document outlines the complete FAA registration history for a Gulfstream G550 (Serial Number 5173). The chain of ownership tracks the aircraft from its manufacturer (Gulfstream) to Chevron U.S.A. (as N401HB), then to Plan D LLC (as N415LM and N212JE), and finally to N550GP LLC (as N550GP). Lawrence Visoski, known as Jeffrey Epstein's pilot, appears prominently as the Manager for both Plan D LLC and Six G Aviation LLC during the 2017-2020 ownership period, signing for flight declarations and bills of sale. The file contains specific international flight declarations, including a 2017 trip to St. Thomas (USVI) and a 2021 trip to Naples, Italy.
EFTA00008120.pdf
This document is an excerpt from a book about massage therapy, specifically focusing on the art of receiving and giving massage. It covers terminology, finding a therapist, preparing for a session, setting the mood, and detailed instructions on massage techniques and body mechanics. The text provides practical advice for both clients and amateur practitioners.
EFTA00004070.pdf
FBI FD-302 notes from a July 2019 interview with a victim who met Jeffrey Epstein at age 17 through her sister. She details traveling with Epstein to New York, Florida, New Mexico, Paris, and the Virgin Islands, describing a 'mind control' environment where Epstein paid for her life while subjecting her to sexual assaults, including rape. The document includes descriptions of numerous photographs provided by the victim showing Epstein in various locations with different individuals, including Ghislaine Maxwell and Jean Luc.
EFTA00002698.pdf
This document is a cover sheet for an '80% Design Development Progress Package' created by the architectural firm Gensler for Little St. James Island. Dated June 4, 2009, the package outlines renovations including cabanas, pavilions, a pool, and a screening room, with specific mentions of revised 3D views and landscape plans.
EFTA00002697.pdf
This document is the cover page for an architectural design package titled 'Little St. James Island: Cabanas, Pavilions, Pool & Screening Room,' prepared by the architecture firm Gensler. Dated June 4, 2009, it represents an '80% Design Development Progress Package' and lists revisions including 3D views, landscape plans, and screening room finishes.
DOJ-OGR-00015992.tif
This document is a flight log detailing flights of aircraft N908JE (a G-1159B Gulfstream) from October 17, 2000, to November 19, 2000. It lists dates, departure and arrival locations, flight numbers, miles flown, and passengers/remarks for each flight, with Jeffrey Epstein ('JE') and various other individuals frequently listed as passengers. The log is signed by 'David Regen' as the pilot.
DOJ-OGR-00015249.tif
This document is a list of academic and professional engagements, likely by a single individual, spanning from 1989 to 1993. It details various conferences, lectures, seminars, and organizational affiliations across numerous universities, legal associations, and psychological societies in the United States, Canada, Australia, and Europe. The entries include the year, event name, and associated institutions or locations.
DOJ-OGR-00015246.tif
This document is a list of academic institutions, legal associations, and other organizations, along with events, grouped by year from 1974 to 1980. It appears to be a chronological record of affiliations, seminars, and conferences, potentially related to a professional's career or an institution's activities. The document also includes page numbering and a document identifier 'DOJ-OGR-00015246'.
DOJ-OGR-00022249.tif
This document is a flight log for the aircraft N908TE (a G-1159B) detailing flights from October 17, 2000, to November 19, 2000. It lists departure and arrival locations, flight numbers, and remarks that include names of individuals like JE, Shelley Lewis, GM, ET, Kelly Spamm, Gary Roxburgh, Ricardo Leloretta, Jessica, and Jessica Bajer, indicating their presence or involvement on these flights. The log is signed by David Rodega.
DOJ-OGR-00022247.tif
This document is a flight log for the aircraft N908JE (G-1159B) and simulator flights, detailing flights between June and August 2002. It records various routes across the US and Europe, listing crew members (JE, GM, ET, AP) and passengers including Sophie Biddle, Malenda Lunes, Shelley Lewes, Gary Roxburgh, and Jasmen Skrew. The log also includes notes on simulator training for emergency procedures and aircraft failures.
DOJ-OGR-00022240.tif
This document is a flight log detailing aircraft movements and passengers primarily for aircraft N908JE (G11593) over July, August, and September 1999. It records multiple flights, mostly to and from PBI (Palm Beach), with frequent passenger mentions of 'JE' (likely Jeffrey Epstein) and other individuals including 'SHELLEY,' 'CLAIRE HAZEL,' 'ADAM,' and 'TIFFANY.' The log also includes remarks on pilot maneuvers and total flight hours.
DOJ-OGR-00016029.jpg
This document is a flight log page (No. 114) signed by pilot David Rodgers covering flights from January 8, 2005, to March 14, 2005. It details movements of aircraft N909JE and N908JE to locations including Palm Beach, St. Thomas, JFK, Columbus (Ohio), and San Diego. The logs list passengers including Jeffrey Epstein (JE), Ghislaine Maxwell (GM), Sarah Kellen (SK), Jean-Luc Brunel (JLB), and others, with several names redacted.
DOJ-OGR-00015985.jpg
This document is a flight log for aircraft N908JE, a G-1159B model, covering flights from October 14, 1999, to November 22, 1999. The log, signed by pilot David Rodgers, details numerous trips between airports in Florida (PBI), New Jersey (TEB), the U.S. Virgin Islands (TIST), New Mexico (SAF), and California (VNY, SAN). The remarks section lists various passengers by name or initials, with 'JG' appearing on every flight, often accompanied by 'GM', 'ET', and other individuals such as Audrey Raimbault, Claire Hazel, and Shelly Anne Lewis.
DOJ-OGR-00015984.jpg
This document is a pilot's flight log for October and November 1999, signed by pilot David Rodgers. It details numerous flights primarily on aircraft N908JE, associated with Jeffrey Epstein, between various US cities (Teterboro, Palm Beach, Santa Fe) and St. Thomas, USVI. The log lists passengers for each flight, including individuals identified by the initials 'JE' (Jeffrey Epstein) and 'GM' (Ghislaine Maxwell), along with Paula Epstein, Claire Hazel, and many others.
DOJ-OGR-00015947.jpg
This document is a flight log from November 1994 to January 1995, signed by pilot David Rodgers. It records flights on aircraft N908JE and N988JG, primarily between Palm Beach (PBI), Teterboro (TEB), and other domestic and international destinations. The log details numerous passengers, including Jeffrey Epstein (JE), Ghislaine Maxwell (GM), Senator George Mitchell, Mark Epstein, Sophie Biddle, and Joel Pashcow, documenting their travel patterns and associations during this period.
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