Assistant United States Attorney (Name Redacted)
PersonRelationship Network
EFTA00032748.pdf
This document is an internal email thread among legal staff, likely within the Southern District of New York (SDNY), dated between September 30 and October 15, 2021. The discussion concerns the review of 'RTC' (Requests to Charge/Jury Instructions) for the Ghislaine Maxwell trial. An Assistant US Attorney requests a review before sending the draft to the defense, but the recipient declines a full review due to a heavy workload involving 23 other briefs, offering only specific help instead.
EFTA00015932.pdf
This document is an email chain between defense attorneys (Michael Bachrach and Bruce Barket) and the US Attorney's Office (USANYS). The attorneys are requesting records of statements made by inmate Mr. Tartaglione regarding Jeffrey Epstein's reported suicide attempt on July 22-23, 2019. The defense argues this is 'Rule 16' discovery material relevant to a 'penalty phase' (likely Tartaglione's capital case), while the government discusses the procedural requirements (Touhy regulations vs. Rule 16).
EFTA00009920.pdf
This document is an email chain between Ghislaine Maxwell's defense attorney, Bobbi Sternheim, and the US Attorney's Office (SDNY) regarding conditions at the Metropolitan Detention Center (MDC) in November 2020. Sternheim requests Maxwell be moved to an interior cell due to reports that the NYC Dept. of Design & Construction would be shutting off heat and water overnight for repairs. The Assistant US Attorney denies the request, stating that temperatures are being monitored and remain within BOP policy limits, and asserting that Maxwell's current placement is appropriate for safety and security.
United States v. Ghislaine Maxwell -- [Redacted] opens
Motivational message regarding the start of the Ghislaine Maxwell trial, criticizing Florida prosecutors' past handling, stating the charges relate to 1994 sex crimes, and providing logistical details for the courtroom.
Redactions
Discussion regarding proposed redactions to filings related to experts and sealing Exhibit B to the Government's motion. Outlines the process for filing redacted versions with the Court.
Response re Rule 17(c) subpoena
Attached is Maxwell's response to the motions to quash her Rule 17(c) subpoena.
co-conspirator statements/ GX 52
Here are the defense's very brief letter oppositions on these topics.
US v. Maxwell - 20 Cr. 330 - Letter re Minor Victim-3
Submission of Government's letter regarding Minor Victim-3 and proposed redactions. Mentions procedure for filing redacted version on docket.
ESI exhibits
Discussion regarding potential trial exhibits (ESI) found on a forensic image of a computer registered to 'gmax'. The computer was a clone from the Palm Beach house in 2005, taken by private investigators, and found by the FBI in NYC in 2019.
US v. Maxwell, 20 Cr. 330 (AJN)
Counsel, Please see attached. Thanks.
[Redacted]
I'll print also.
[Redacted] - meeting tomorrow
Arranging a meeting for the following day at 9:30am to discuss trial preparation. Sender attaches a subpoena for a witness to testify at a trial beginning Nov 29, 2021. Mentions arranging travel and hotel for the trial later.
metadata
Inquiry regarding the source device of attachment USGME01088996.doc: 'Can you tell what device this came from? Thanks.'
Severance opp
Sending draft of the opposition to Maxwell's motion to sever perjury counts for review.
Maxwell motions 2 of 3
Email contains an attachment named '1.25.2021_Filing_2.zip'. No body text is visible other than the signature block.
Application for corrected SW
Sender is attaching a draft affidavit for an amended warrant regarding three drives seized from Epstein's NY residence, along with four exhibits. They plan to schedule a time to swear out the warrant.
Draft SW
Attached
Stamped Indictment & Arrest Warrant
Notification of receipt of signed and stamped indictment and arrest warrant for Ghislaine Maxwell from the clerk's office.
Corrected Arrest Warrant
Attached—sorry again about that.
transcript
Email transmitting two PDF attachments: Maxwell,_Ghislaine_Transcript_(04-22-16).pdf and Maxwell,_Ghislaine_Transcript_(07-22-16).pdf
Call today
Requesting a quick call regarding questions relating to the Epstein case.
update
Notification that a witness (represented by a lawyer spoken to that afternoon) has agreed to cooperate with the investigation and prosecution of Ghislaine Maxwell. Mentions setting up an interview to cover topics previously off-limits.
MCC Press Release
Attached.
SHU Photos/Number of Steps
Requesting FBI photos of the SHU and measurements of steps from Epstein's cell to the guard desk. Also inquiring if a hard drive is needed for 'Thomas' phone'.
Protective Order
Sender attaches a proposed protective order discussed in a conversation earlier that morning and offers a call to discuss further.
US v. Gatto - Oath Inc. Motion to Intervene
Providing the Government's opposition to Oath Inc.'s motion to intervene.
[Redacted/Blank]
Link to Curbed article: https://www.curbed.com/2015/1/9/10004040/jeffrey-epstein-property-real-estate-holdings
Preservation Request
Good afternoon, Please see the attached preservation request. Thank you,
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