This document contains an email chain and Amazon receipts from November 2020 regarding the purchase and preparation of a laptop for Ghislaine Maxwell ('Maxwell Laptop'). The U.S. Attorney's Office (SDNY) purchased an HP Pavilion laptop, DVD drive, and Microsoft Office software. The emails detail the technical modifications made to the laptop to meet Bureau of Prisons (BOP) standards, specifically the physical removal of Wi-Fi, Bluetooth, and Ethernet capabilities, to allow Maxwell to review discovery materials at the Metropolitan Detention Center (MDC).
This document is an email chain between Glen McGorty of Crowell & Moring LLP and the US Attorney's Office for the Southern District of New York regarding the scheduling and preparation for a second proffer interview with a witness (Mr. [Redacted]). The prosecutors specifically intend to question the witness about his relationship with a U.S. Customs and Border Protection employee in St. Thomas who had the witness's number in their phone, and what the witness knows about that CBP employee's interactions with Jeffrey Epstein. A proffer agreement was signed and executed in early October 2020.
This document is a chain of emails between the US Attorney's Office (SDNY) and Jeff Jocks, an attorney representing the Interlochen Center for the Arts. The correspondence, dating from February to November 2020, concerns a subpoena seeking information on Jeffrey Epstein and Ghislaine Maxwell. Specifically, the US Attorney sought records of tuition payments made by Epstein or his entities for students. Ultimately, Jocks confirmed that Interlochen only retains tuition records for 7 years and their files contained no record of payments by Epstein.
This document is an email from an Assistant United States Attorney for the Southern District of New York, dated February 18, 2020. The sender informs a colleague that they and another redacted individual are traveling to Pensacola the following day to interview a person identified as Jeffrey Epstein's houseman from the 1990s through 2002.
An internal email from a USANYS paralegal specialist dated September 28, 2021, listing government exhibits (GX) pulled for a case. The list includes photos of Jeffrey Epstein, Ghislaine Maxwell, and an individual identified as 'CA', as well as records related to FedEx, AT&T, Mar-A-Lago, and a search warrant in Palm Beach (PB). The email references a prior call regarding these files.
An email chain from October 27, 2020, involving an Assistant United States Attorney (SDNY) submitting an application for a search warrant to Judge Wang. The correspondence includes a request from the court to flatten PDF attachments and a correction by the AUSA regarding an error where Judge Nathan was named instead of Judge Wang in the initial documents. An agent is noted as being available to swear out the warrant.
This document is a legal memorandum filed by Ghislaine Maxwell's defense team arguing against the government's motion for detention and requesting release on bail. The defense argues that the COVID-19 pandemic poses a severe health risk and impedes defense preparation, and asserts that Maxwell is not a flight risk, citing her presence in the U.S. since Epstein's arrest. They propose a $5 million bond secured by UK property and strict conditions including home confinement and GPS monitoring.
This document is an email thread from February to October 2020 between the US Attorney's Office (SDNY) and Jeff Jocks, counsel for the Interlochen Center for the Arts. The US Attorney issued a subpoena regarding Jeffrey Epstein and Ghislaine Maxwell, specifically seeking records of tuition payments made by Epstein or his entities for students. Interlochen's counsel ultimately confirmed that they only retain tuition records for 7 years and found no records of payments by Epstein or his entities in their files.
This document is an email chain between the US Attorney's Office (SDNY) and Jeff Jocks, attorney for Interlochen Center for the Arts, spanning February to October 2020. The US Attorney issued a subpoena regarding Jeffrey Epstein and Ghislaine Maxwell, specifically inquiring about tuition payments made by Epstein or his entities for students. Jeff Jocks ultimately confirmed that Interlochen only retains tuition records for 7 years and that their files contained no record of payments by Epstein or his entities.
Defense counsel Bobbi Sternheim requests Judge Nathan to release the names of 600 potential jurors to attorneys only, prior to voir dire, to facilitate background research and ensure a fair trial. The letter cites precedent involving juror misconduct (US v. Parse) and a recent order from the Charlottesville 'Unite the Right' civil case (Sines v. Kessler) where juror names were released to counsel despite high publicity and security concerns. The document includes the cited order from the Western District of Virginia as Exhibit A.
This document is a chain of email correspondence between attorney Joe Nascimento (of Ross Amsel Raben Nascimento, PLLC) and federal prosecutors (USANYS) regarding a cooperating witness in the Epstein investigation. The correspondence begins in July 2019, immediately following the service of a grand jury subpoena to Nascimento's client, who was previously represented by Nascimento's deceased partner, Alan Ross. The emails detail the scheduling of meetings (proffers) in West Palm Beach, confirm the client's cooperation, and include check-ins following major events like Hurricane Dorian and the arrest of Ghislaine Maxwell in July 2020.
An email dated August 2, 2021, from an Assistant US Attorney in the Southern District of New York to attorneys with '@epllc.com' email addresses. The email notifies the recipients of a recent order by Judge Nathan regarding Local Criminal Rule 23.1, emphasizing that it applies to attorneys associated with the case, including attorneys for witnesses. The document likely pertains to the Ghislaine Maxwell trial proceedings.
This document is an internal email chain from the U.S. Attorney's Office for the Southern District of New York regarding the opening of the trial *United States v. Ghislaine Maxwell* in late November 2021. The emails contain motivational messages to the prosecution team (specifically naming an 'Andrew'), logistical details for staff wishing to watch the proceedings, and a pointed criticism of Florida prosecutors regarding their handling of similar crimes.
A formal discovery request letter from Montell Figgins, attorney for Michael Thomas (one of the guards on duty when Jeffrey Epstein died), addressed to an Assistant US Attorney in the SDNY. The letter requests all materials (reports, photos, videos) created or possessed by the United States Inspector General regarding the incident. The letter cites Rule 16(a)(1)(C) and U.S. v. Bryan as legal basis for the request.
This document is a letter dated September 17, 2019, from Clara Moran, Chief Deputy Attorney General of New Mexico, to an Assistant US Attorney in the Southern District of New York. The letter accompanies a transfer of investigative materials—including police reports, witness interviews, and land leasing documents—related to Jeffrey Epstein's co-conspirators. Moran emphasizes that Epstein's death should not end the inquiry and offers continued cooperation to seek justice for survivors, noting that the conduct in their files occurred prior to New Mexico's 2008 human-trafficking statute.
This document is an internal email chain from June 2020 involving an Assistant US Attorney in the SDNY preparing for a Grand Jury presentation. The attorney requests the creation of presentation slides featuring specific excerpts from Ghislaine Maxwell's deposition transcripts (denying knowledge of underage recruitment and massages) and specific flight records from dates between 1994 and 1998.
A formal letter from David McCraw, General Counsel for The New York Times, to Judge Kenneth Karas arguing for the unsealing of judicial records in United States v. Tartaglione. The records concern Nicholas Tartaglione's request to be transferred from the MCC due to threats from guards, allegedly stemming from his witnessing of his former cellmate Jeffrey Epstein's attempted suicide. The NYT argues that public interest and First Amendment rights outweigh the Government's desire to keep the Bureau of Prisons' internal deliberations secret.
This document is a legal response filed on June 24, 2020, by Intervenors Julie Brown and the Miami Herald Media Co. arguing against Ghislaine Maxwell's objections to unsealing specific court documents (Dkt. Entries 143, 164, 172, 199, and 230). The Intervenors argue that Maxwell's privacy claims are unsubstantiated and do not outweigh the public interest in disclosure, particularly regarding allegations of sex trafficking and abuse of minors. The filing explicitly mentions that the documents in question include a 'Flight Log Summary Chart' and 'flight logs', police reports, and deposition transcripts, arguing that these should be made public.
This document contains an email exchange from February 6, 2020, between Maurene (an Assistant US Attorney for the SDNY) and Jeff Jocks (an attorney representing Interlochen Center for the Arts). The AUSA served a subpoena to Interlochen seeking information regarding Jeffrey Epstein and Ghislaine Maxwell, noting a confidentiality agreement regarding the request.
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.
This document is an email dated January 22, 2020, from an Assistant United States Attorney (SDNY) to an FBI agent. The prosecutor is inquiring about Jeffrey Epstein's flight logs and immigration records, specifically looking for travel to/from London between March 1994 and March 1995. The inquiry is linked to verifying the timeline of an unnamed female who was 17 years old during that period.
This document is an email from attorney Christian Everdell of Cohen & Gresser LLP to Judge Nathan, dated December 19, 2020. It serves as a transmittal for filing a Renewed Bail Motion Reply Memorandum and accompanying exhibits under seal in the case U.S. v. Ghislaine Maxwell (20 Cr. 330). Other defense counsel, including Bobbi Sternheim, Jeff Pagliuca, and Laura Menninger, are copied on the correspondence.
This document is a formal letter to Judge Alison J. Nathan dated November 23, 2020, written by a close confidant (name redacted) of Ghislaine Maxwell in support of her bail application. The author attests to Maxwell's character, honesty, and kindness, noting their close relationship and the fact that Maxwell has hosted the author's children without incident. Significantly, the author offers to co-sign a bond for US$3,500,000, stating that this sum represents their 'entirety of realisable family wealth' to ensure Maxwell's appearance in court.
This document is an email thread from November 24, 2021, related to the case US v. Maxwell (20cr330). It involves correspondence between the Chambers of Judge Alison J. Nathan and legal counsel (including Brian Burns, Patrick Smith, Jeff Pagliuca, and Laura Menninger) regarding the issuance of protective orders. An Assistant United States Attorney subsequently follows up with counsel to coordinate the transfer of materials via file sharing or thumb drive.
An email chain from December 2019 between attorney William Callahan (Unitel) and an Assistant U.S. Attorney for the SDNY. Callahan references a previous tele-conference regarding the 'Epstein Matter' and notes he needs 3-4 weeks to speak with a 'Subject' or their representative. The AUSA responds that they cannot discuss hypothetical representations but welcomes contact if Callahan officially represents someone with information relevant to the ongoing investigation.
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