This document is a legal filing by Ghislaine Maxwell's defense team objecting to the unsealing of specific docket entries (143, 173, 199, 164, and 230) in the civil case brought by Virginia Giuffre. The defense argues that these documents contain sensitive information regarding non-parties ('Does'), inadmissible hearsay, and prejudicial materials such as flight logs and police reports that were improperly filed to bias the court. The filing emphasizes the need to protect the privacy of non-parties and the integrity of ongoing criminal investigations into Jeffrey Epstein's conduct.
This document is a Palm Beach Police Department Case Report and Persons System Report regarding Jeffrey Epstein and Ghislaine Maxwell, covering investigations from 2001 to 2005. It details intelligence on the recruitment of young female college students from Palm Beach Atlantic College for massages, surveillance of Epstein's residence at 358 El Brillo Way, and numerous trash pulls that yielded sexually suggestive items and correspondence. The report also documents interviews with potential victims and witnesses, noting allegations of inappropriate touching and the presence of underage girls, though some investigations were initially marked as unfounded or for intelligence purposes.
This document is an AT&T Wireless invoice for Jeffrey E. Epstein for the billing period ending May 02, 2004. It details extensive call logs including domestic calls primarily between New York and Florida, as well as international activity involving France, the UK, Brazil, and Belgium. The invoice specifically documents a trip to St. Thomas, US Virgin Islands (CHTAMSTTHS VI), between April 6 and April 8, 2004, evidenced by 'Roamer Usage' logs.
This document contains email correspondence between the US Attorney's Office (SDNY) and defense counsel Glen McGorty of Crowell & Moring LLP regarding a cooperating witness (Mr. [Redacted]). The emails arrange proffer interviews via WebEx and discuss the witness's potential testimony at Ghislaine Maxwell's trial in November 2021. Key topics of interest for the prosecution include Epstein's relationship with Customs and Border Protection (CBP) in the Virgin Islands, specifically whether Epstein provided favors (such as trips to his island) to CBP agents in exchange for bypassing standard immigration processing for himself and his guests.
This document is a UBS Business Services Account statement for '116 EAST 65TH STREET LLC' (Friendly name: 116 LLC) for April 2016. It details significant financial activity, including over $14 million in deposits (checks) and a subsequent transfer of approximately $14.2 million out to Ghislaine Maxwell. The statement also itemizes debit card activity by 'G. Maxwell' for personal and household expenses in New York City, establishing her direct control and usage of the LLC's funds.
A letter dated November 23, 2016, from Ghislaine Maxwell to UBS wealth managers Scott Stackman and Lyle Casriel. The letter authorizes the transfer of $14.2 million (in cash and PSDYX securities) and the entire balances of three additional accounts from her name to an entity titled 'Angara Trust'. Specific account numbers are redacted.
This document is an email chain from July and August 2019 involving attorney Jonathan M. Albano (representing Oath Inc.) and an Assistant US Attorney from the SDNY. The correspondence concerns 'US v. Gatto' and a motion by Oath Inc. to intervene to obtain materials. Albano specifically requests to file the Second Circuit's July 3, 2019 decision in 'Brown v. Maxwell' (a case involving unsealing documents related to Ghislaine Maxwell and Jeffrey Epstein) as supplemental authority, linking the legal standards of public access between the two cases.
This document is an email dated July 26, 2019, containing a US Marshals Intake Form request for Jeffrey Epstein. It lists his case identifiers (Court Number 19 Cr. 490, USAO Number 2018R01618, USMS Number 76318-054), arrest date (July 6, 2019), and date of birth.
An email chain from September 2019 forwarding an earlier exchange from August 14, 2019. Richard Frankel of T&M Protection Resources emailed an FBI Supervisory Special Agent asking if the cameras in the jail were working on the date of Jeffrey Epstein's death and if videos were stored. The FBI agent responded that they could not comment on the matter at that time.
This document is an email chain from December 2019 between an FBI agent in the New York office and 'Ted' at the U.S. Attorney's Office for the Southern District of New York (USANYS). The primary subject is scheduling a 'quick status call on Epstein' for the afternoon of December 5, 2019. The discussion confirms a call time of 4:30 PM.
This document is a motion filed by Ghislaine Maxwell's defense team on October 18, 2021, requesting the court to preclude the introduction of Government Exhibits 251, 288, 294, 313, and 606. The defense argues these items—including specific photographs, sex toys ('Twin Torpedos') seized in 2005, and a 'Household Manual'—are irrelevant, lack proper evidentiary foundation, or are unfairly prejudicial under Federal Rules of Evidence 401 and 403. The motion contends that these items do not prove any material fact regarding the charges against Maxwell and serve only to confuse issues or introduce character flaws of Jeffrey Epstein.
This document is an email thread from July 31 to August 7, 2019, between attorney Michael Bachner and an Assistant U.S. Attorney from the Southern District of New York. The correspondence concerns scheduling a status call regarding the 'Epstein investigation' following a previous meeting held in mid-July. The final email confirms a brief 10-minute call for August 7, 2019.
This document is an email chain from July 31 to August 7, 2019, between attorney Michael Bachner (Bachner & Associates) and an Assistant U.S. Attorney for the Southern District of New York regarding the 'Epstein investigation'. The correspondence involves scheduling a status discussion, referencing a previous meeting held in mid-July. The final email indicates Bachner missed a scheduled call on August 7 because a prior meeting ran late.
This document contains a series of emails from January 2021 between the US Attorney's Office (SDNY) and the DOJ Attaché at the US Embassy in Paris. They discuss the ongoing French investigation into Jean-Luc Brunel, who was in custody at the time. Key topics include the French authorities' request for evidence from the Epstein investigation (specifically photos and database records using facial recognition), the drafting of Mutual Legal Assistance Treaty (MLAT) requests, and the French judiciary's insistence on reciprocity before sharing their own evidence with the US. The emails also mention the existence of photos of Brunel within seized Epstein evidence and the potential cooperation of two adult victims abused in Paris.
This document is an email chain between Ghislaine Maxwell's defense attorney, Bobbi Sternheim, and prison officials (likely BOP) regarding the conditions of Maxwell's confinement in January 2021. Sternheim complains about Maxwell being delivered late to legal calls (VTCs), being ordered to clean toilets without gloves, petty inspections for 'crumbs' on her bed, and intrusive physical searches that increase COVID risks. The prison official responds that delays were due to institutional emergencies and asserts that searches comply with BOP Program Statements.
This document is an email chain between an FAA LEAP Special Agent and an SDNY Assistant US Attorney from Aug-Sept 2021. The FAA agent provides a comprehensive history of aircraft registrations, sales, and shell companies (Plan D, JEGE, Hyperion, Air Ghislaine) linked to Jeffrey Epstein, Ghislaine Maxwell, and their associates Larry Visoski and Darren Indyke. The report includes specific flight movements for N212JE (Gulfstream G550) in July 2019 (Paris to Teterboro to Georgia) around the time of Epstein's arrest.
This document is a series of emails from July 2019 between defense attorney Michael Bachner and the SDNY/FBI regarding the Epstein investigation. The correspondence coordinates a 'reverse proffer' meeting where the government intends to persuade Bachner's female client to cooperate to avoid potential arrest. Bachner explicitly notifies the government that his client intends to invoke her Fifth Amendment privilege if called to testify before a Grand Jury.
This document is a chain of emails from July 2019 between defense attorney Michael Bachner and the US Attorney's Office (SDNY) regarding the Epstein investigation. The correspondence discusses scheduling a 'reverse proffer' meeting and addresses a Grand Jury subpoena for Bachner's client, who intends to invoke their Fifth Amendment privilege. The prosecution (SDNY) challenges the blanket invocation of the Fifth Amendment and shares the 2007 Epstein Non-Prosecution Agreement (NPA) and a blank proffer agreement with the defense.
This document is an email chain from August 1-2, 2019, between Colleen Mullen of The Bloom Firm and Assistant United States Attorneys (SDNY). Mullen informs the prosecutors that her firm represents two women who allege they were fraudulently recruited and forcefully sexually assaulted by Jeffrey Epstein at his New York residence in June 2004. The emails discuss scheduling a conference call to discuss these allegations, while Mullen emphasizes her clients' desire to remain anonymous and their fear that they were secretly filmed during the assaults.
An email chain from August to October 2019 between attorney Jack Scarola and an Assistant US Attorney from the SDNY. Scarola introduces a victim who was molested by Jeffrey Epstein in Florida starting at age 14 and received lingerie gifts from him. The prosecutors express strong interest in interviewing the victim and offer to travel to Florida to do so, following up multiple times to arrange the meeting.
An email chain from October 3, 2019, involving an Assistant United States Attorney for the Southern District of New York. The AUSA requests statistics on human trafficking victims interviewed over the past year. A respondent asks if 'numbers from Epstein' should be included, and the AUSA confirms they should be included.
This document contains an email chain between Marc A. Weinstein of Hughes Hubbard & Reed LLP (representing the Epstein Estate) and officials at the US Attorney's Office (USANYS) from January 24-27, 2020. The correspondence primarily concerns the production of documents related to Epstein's prior trusts and wills in response to a Grand Jury subpoena, specifically referencing Bates numbers GJ_000198 through GJ_000459. Additionally, the emails discuss the US Virgin Islands Attorney General's motion to intervene in the estate administration and a clarification regarding a public announcement involving 'Geoff' and state look-back civil suit laws.
This document is an email chain spanning from February to October 2020 between Jeff Jocks (attorney for Interlochen Center for the Arts) and the US Attorney's Office for the Southern District of New York. The US Attorney's Office served a subpoena regarding records for Jeffrey Epstein and Ghislaine Maxwell, specifically inquiring if Epstein or his entities made tuition payments for any students. Jeff Jocks ultimately confirmed that Interlochen retains tuition records for seven years and found no evidence of payments from Epstein or his entities.
This document is an email chain from September 2020 between Marc Weinstein (Hughes Hubbard & Reed) and an Assistant US Attorney from the SDNY. The correspondence concerns the SDNY's request for a 2009 deposition transcript of a plaintiff represented by attorney Jack Scarola in a lawsuit against Jeffrey Epstein. Weinstein coordinates with the SDNY and Scarola to ensure no protective orders prevent the disclosure before ultimately providing the transcripts.
This document is an email chain from October and November 2020 between Crowell & Moring LLP attorneys (representing a redacted witness) and the SDNY US Attorney's Office. The correspondence coordinates a second proffer interview for the witness, scheduled for November 12, 2020, which will include FBI agents. The focus of the interview is specifically on the witness's knowledge of Jeffrey Epstein's interactions with US Customs and Border Protection (CBP) in the Virgin Islands, including whether CBP employees helped Epstein avoid standard entry processing and if Epstein provided favors (such as trips to his island) to CBP staff. A specific CBP employee in St. Thomas is mentioned as having the witness listed in their phone contacts.
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