An internal email from an Assistant United States Attorney at the Southern District of New York (SDNY) sent on November 28, 2021, the day before the opening statements in the trial of United States v. Ghislaine Maxwell. The email serves as a morale booster for the prosecution team, explicitly contrasting the SDNY's willingness to prosecute 1994 crimes with prosecutors in Florida (a reference to the Epstein plea deal). It provides logistical details for staff wishing to attend the opening at the courthouse at 40 Foley Square.
An internal email from an Assistant United States Attorney in the Southern District of New York sent on November 28, 2021, rallying colleagues before the opening of the Ghislaine Maxwell trial. The email contrasts the SDNY's willingness to prosecute historical crimes with prosecutors in Florida, asserts that Maxwell sexually exploited underage girls, and provides logistical details for staff wishing to attend the opening statements at 40 Foley Square.
A letter from US Attorney Damian Williams to Ghislaine Maxwell's defense team dated November 24, 2021, detailing the production of discovery materials. The production includes Jencks Act and Giglio materials for potential trial witnesses, as well as courtesy materials for individuals the government does not currently intend to call. The letter also clarifies protective order designations for the enclosed documents.
This document contains the Declaration of Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New York, in support of the Federal Bureau of Prisons' motion for summary judgment regarding FOIA requests filed by The New York Times Company concerning Jeffrey Epstein's incarceration and death. The declaration details the prosecutions of correctional officers Tova Noel and Michael Thomas for falsifying records related to Epstein's suicide, and Nicholas Tartaglione for a quadruple homicide, arguing that releasing certain records would interfere with these pending cases. Attached as Exhibit A is the Indictment of Tova Noel and Michael Thomas, and as Exhibit B is the Superseding Indictment of Nicholas Tartaglione.
This document is a legal letter dated December 28, 2020, from Ghislaine Maxwell's defense attorney, Christian Everdell, to the US Attorney's Office (SDNY). The letter formally requests a Bill of Particulars to clarify the allegations in the Superseding Indictment, specifically asking for the real names of Minor Victims 1-3, precise dates and locations of alleged grooming and sexual abuse, details regarding travel in 1996 (NM and FL/NY), and specifics concerning perjury allegations from 2016 depositions.
This document is a Search and Seizure Warrant issued by the U.S. District Court for the Southern District of New York (signed by Magistrate Judge James L. Cott). It authorizes law enforcement to search six binders containing CDs that were seized on July 11, 2019, from blue and black suitcases. The search is authorized to find evidence of sex trafficking of minors (18 U.S.C. 1591) and conspiracy (18 U.S.C. 371), specifically looking for photographs of victims, communications, and access data.
This document is an email chain from September 2019 between an Assistant United States Attorney for the Southern District of New York and an official from the New Mexico Attorney General's Office. They coordinate a scheduled phone call to 'touch base regarding the Epstein case.' The call was set for Thursday, September 12, 2019.
This document is an email chain from October to November 2021 between the US Attorney's Office for the Southern District of New York (USANYS) and a witness named Lisa (likely a medical expert given mentions of 'patients' and 'Daubert' briefings). They are coordinating travel logistics for an in-person meeting in New York on November 12-13 and discussing trial preparation. The witness mentions a personal trip to Italy in mid-November and arranges Amtrak travel and hotel accommodation (Hotel 50 Bowery) with government reimbursement guidelines.
This document is a formal response from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team regarding 22 specific discovery requests made on October 13, 2020. The government addresses requests for Epstein's diary, the 'Billionaires Playboy Club' manuscript, flight logs (implied in broader requests but not itemized), and the identities of minor victims, often denying immediate production based on Rule 16 restrictions or asserting that materials have already been produced. The letter also discusses the handling of potential 'Brady' and 'Giglio' materials, stating that impeachment evidence will be produced closer to trial.
This document is an email thread from July 31 to August 7, 2019, between defense attorney Michael Bachner and the US Attorney's Office for the Southern District of New York (USANYS) regarding the Epstein investigation. The USANYS attorneys express urgency, noting they have been 'holding in abeyance a grand jury date' and refuse Bachner's request to delay a discussion until August 14. The parties eventually agree to speak at 2:30 PM on August 7, 2019.
A cover letter from the Federal Bureau of Prisons to Danielle Ivory of The New York Times regarding FOIA Request No. 2019-05665. The letter explains the partial release of records related to a civil case, noting that 434 pages were withheld entirely and others redacted due to law enforcement proceedings, privacy concerns, and internal deliberations.
This document contains various inmate records for Jeffrey Edward Epstein (Register No. 76318-054), including housing history, disciplinary data (none found), and custody classification. It also includes a press release from the U.S. Department of Justice confirming his death by apparent suicide on August 10, 2019, at the Metropolitan Correctional Center in New York. Additionally, the file contains financial transaction logs showing money received by Epstein and redacted staff schedules from late July and early August 2019.
This document is a 'Subpoena Rider' issued by the Federal Bureau of Investigation (FBI) to the New York Department of State, Division of Corporations. It requests all Articles of Incorporation and related information for two specific entities: 'Nine East 71st Street Corporation' (associated with addresses in NYC) and 'Maple, Inc' (associated with an address in St. Thomas, USVI). The document provides instructions to forward records to the FBI's New York office and mentions Carmelo Burgos of the Albany Division for service.
This document is an email chain from March 2021 concerning discovery and evidence review in the US v. Maxwell case. The correspondence primarily involves Laura Menninger (defense counsel) and an Assistant United States Attorney, discussing the availability and indexing of highly confidential physical evidence and images held by the FBI. Delays in providing answers and access to evidence are noted, with discussions around FBI team availability and the completeness of existing evidence inventories.
This document is an email chain from late December 2020 discussing disparities in counsel and discovery access for Ghislaine Maxwell (detained at MDC) and Justin Rivera (detained at MCC). Judge Engelmayer requested a declaration from the Bureau of Prisons to explain why Maxwell's accommodations were 'strikingly different and far superior' to Rivera's, citing differences in case complexity, housing situations, and inmate populations at the respective facilities. The emails detail the efforts to draft this declaration and address specific questions and concerns regarding the document's content and timeline.
This document is an email chain from April 2021 between the US Attorney's Office (SDNY) and Marc Weinstein (counsel for the Epstein Estate). The SDNY is inquiring whether the estate asserts attorney-client privilege over a specific computer seized by the Palm Beach Police Department in 2005, noting that the estate had previously asserted privilege over devices seized by the FBI in 2019. The chain includes scheduling logistics for a conference call to discuss these document requests.
Defense counsel Laura Menninger objects to government redactions in the case US v. Maxwell. Menninger argues that 'Accuser-2's' diary entries are not confidential as they were shared on a NY Times podcast and do not implicate Maxwell. The letter also argues against redacting information about another accuser (name redacted) who has publicized her allegations via Netflix and podcasts, referencing the 'Kramer notes', and discusses sealing issues related to Maxwell's deposition in a separate civil case ruled on by Judge Preska.
This document is a legal memorandum filed by Ghislaine Maxwell's defense team on January 25, 2021, seeking to suppress evidence obtained via subpoena from the law firm Boies Schiller Flexner. The defense argues that the government made false representations to Judge McMahon to bypass a civil protective order and obtain confidential deposition transcripts, alleging collusion between the civil plaintiff's lawyers (Boies Schiller) and federal prosecutors. The document details the history of the civil defamation case, specific deposition questions regarding sexual acts and Epstein, and the procedural history of the protective order modification.
This document is an email thread from November 2019 involving Parvin Moyne of Akin Gump. Moyne updates the recipient on an internal review of bank communications regarding Jeffrey Epstein, specifically identifying a 2013 email from Epstein's accountant Harry Beller containing a chart of Epstein's J.P. Morgan accounts. This chart revealed previously unknown accounts (Butterfly Trust) and banker relationships (Ted Serure, Laurie Cameron) prior to Epstein's asset transfer to Deutsche Bank. The email also notes upcoming document production regarding Darren Indyke's cash withdrawals.
An email chain from August 8-9, 2019 (the days immediately preceding Jeffrey Epstein's death) involving an Assistant US Attorney from the SDNY and the FBI. The correspondence concerns scheduling a 'proffer' (interview/cooperation session) with a redacted female individual and coordinating with her attorney for the following week. The subject line is 'Florida'.
This document set contains immigration records for Ghislaine Maxwell, specifically regarding an H1B 'Nonimmigrant Worker' visa sponsored by Jeffrey Epstein (listed as Chairman). The documents include an I-797 Notice of Action approving the petition from November 1992 to November 1995, an I-94 Departure Record from September 1995, and a copy of Maxwell's passport visa page with multiple US entry stamps between 1993 and 1995 showing travel to New York, Miami, and Dallas.
This document is an internal email chain among the US Attorney's Office for the Southern District of New York (SDNY) regarding the opening of the *United States v. Ghislaine Maxwell* trial in November 2021. An Assistant US Attorney sends a motivational message to the team, contrasting SDNY's willingness to prosecute old crimes with Florida prosecutors, and provides logistical details for the trial opening at the 40 Foley courthouse. Colleagues respond with well-wishes.
An internal email chain among SDNY prosecutors and staff immediately preceding the opening statements of the Ghislaine Maxwell trial in November 2021. The emails contain strong motivational language, explicitly contrasting the SDNY's willingness to prosecute historical crimes with the perceived failure of Florida prosecutors in the past. It provides specific logistical details for the trial opening, including courtroom numbers and schedules.
An email thread from November 28, 2021, among SDNY staff regarding the opening of the *United States v. Ghislaine Maxwell* trial. An Assistant US Attorney sends a motivational message to the office, contrasting SDNY's willingness to prosecute historical sex crimes with prosecutors in Florida (a reference to the earlier Epstein non-prosecution deal). The email provides logistical details for the trial opening at 40 Foley Square, including courtroom numbers and overflow rooms.
This document is an email chain between Jeff Jocks (attorney for Interlochen Center for the Arts) and the US Attorney's Office for the Southern District of New York (USANYS) spanning from February 2020 to May 2021. USANYS subpoenaed Interlochen for records regarding Jeffrey Epstein and Ghislaine Maxwell, specifically inquiring about tuition payments made by Epstein or his entities for students. Jeff Jocks confirmed on October 30, 2020, that Interlochen only retains tuition records for seven years and that 'nothing in their files reflects any payments by Epstein or Epstein entities.'
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