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EFTA00037470.pdf
This document is a formal notification from the UK National Crime Agency (NCA) to the FBI, dated June 30, 2020. It discusses allegations against Clare Guinness (Lady Clare Iveagh), specifically her alleged close contact with Jeffrey Epstein and an allegation of sexual abuse against a redacted individual. The NCA requests the FBI's view on whether an internal review by the NSPCC charity, where Iveagh holds a presidency, would interfere with the US investigation.
EFTA00037207.pdf
This document is an email chain from January 3, 2020, forwarding an automated notification from the CBP/DHS TECS system. The notification alerts an FBI agent in New York that a 'Person Lookout Query' was triggered for Ghislaine Maxwell. The record was accessed by a user in the Drug Intelligence Unit in Washington, D.C.
EFTA00032215.pdf
This document is a series of email chains between attorney Michael Bachner and government prosecutors (including one named Alex) regarding an 'Attorney Proffer' for a client referred to as Ms. [Redacted]. The correspondence, dating from February to June 2020, discusses the logistics of scheduling interviews, which were complicated by the onset of the COVID-19 pandemic. Key details emerging from the proffer discussions include the client admitting to visiting Epstein's New York and Palm Beach properties, as well as staying at Epstein's Paris apartment with her husband on one occasion. No flight logs or aircraft data are contained in this document.
EFTA00031952.pdf
This document is an email chain from December 4, 2020, involving defense attorney Christian Everdell of Cohen & Gresser LLP and prosecutors from the US Attorney's Office (USANYS). The correspondence concerns a draft letter regarding a briefing schedule to be sent to Judge Nathan in the Ghislaine Maxwell case. The top email indicates approval of the draft ('Fine with me') from one of the recipients.
EFTA00031906.pdf
This document is an email chain from May 28, 2021, regarding the case U.S. v. Ghislaine Maxwell. Defense attorney Christian Everdell of Cohen & Gresser LLP emailed Judge Nathan's chambers to submit Ms. Maxwell's Omnibus Reply Memorandum in support of supplemental pretrial motions related to the S2 Superseding Indictment. The memorandum was filed under seal, while the cover letter was filed publicly. The email was subsequently forwarded internally within the US Attorney's Office (USANYS).
EFTA00030861.pdf
This document is an email chain and legal correspondence between Ghislaine Maxwell's defense team (Cohen & Gresser) and the US Attorney's Office (SDNY) regarding discovery disputes in January 2021. Defense attorney Christian Everdell lists eight specific issues, including the urgent need for a hard drive for Maxwell to review evidence in prison, missing subscriber info for AT&T documents, and specifically noting that the first 27 pages of flight logs produced by pilot David Rodgers ('Rodgers000001-000027') were missing. The defense also inquires about a Daily Beast article referencing a cell-site simulator affidavit that they believe was not properly unsealed.
EFTA00030756.pdf
This document is an email dated December 8, 2020, from attorney Christian R. Everdell of Cohen & Gresser LLP to Judge Nathan. The email serves as a cover letter for the submission of a 'Renewed Bail Motion' and associated exhibits (A-E) in the case of U.S. v. Ghislaine Maxwell, filed under seal pursuant to a court order.
EFTA00029942.pdf
This document is an email chain from March 2021 involving Ghislaine Maxwell's defense team (Cohen & Gresser LLP) and the US Attorney's Office (USANYS). Attorney Christian Everdell raises seven specific discovery issues, including the inability of Maxwell to access files on disks via the prison computer, missing attachments for over 109,000 emails, and significant metadata discrepancies where files extracted from Epstein's devices show modification dates (July 2020) well after his death and device seizure. The email specifically requests metadata overlays to correct these issues and inquires about a gap in document production numbers.
EFTA00029574.pdf
This document is an email thread from November 2021 involving the transmission of Defense Rule 16 Disclosure documents from Christian Everdell (Cohen & Gresser LLP) to the US Attorney's Office for the Southern District of New York (USANYS). The attachments include certifications from AT&T and FedEx, FedEx invoices, Interlochen records, a release regarding A. Farmer, and the Epstein Non-Prosecution Agreement (NPA). The thread shows internal USANYS staff coordinating to save these files to a shared drive.
EFTA00028646.pdf
This document is a chain of emails between Ghislaine Maxwell's defense team (Cohen & Gresser; Haddon, Morgan & Foreman) and the US Attorney's Office (SDNY) regarding discovery production disputes in Spring 2021. Key issues include technical difficulties Maxwell faced in reviewing digital evidence at the MDC prison (specifically reading disks vs. hard drives), missing attachments for over 109,000 emails, and metadata discrepancies for 'carved' or deleted files recovered from Jeffrey Epstein's devices. The correspondence details the logistical back-and-forth regarding file formats, USAfx transfers, and the potential need for judicial intervention (Judge Nathan) to force the MDC to accept specific hard drives.
EFTA00028272.pdf
This document is an email thread from November 2021 between the US Attorney's Office (USANYS) and defense counsel Christian Everdell (Cohen Gresser). Everdell submitted a Defense Rule 16 Disclosure letter. The internal USANYS emails discuss saving this document to the shared drive (specifically the 'USvEpstein-2018R01618' folder) and organizing discovery materials into subfolders like 'AT&T' and 'Federal Express'.
EFTA00027864.pdf
This document is an email chain from March 2021 between Ghislaine Maxwell's defense team (Cohen & Gresser) and US prosecutors (USANYS). The defense raises seven specific technical issues regarding discovery, including the need to provide evidence on hard drives rather than disks for the prison computer, over 100,000 emails missing attachments, and metadata discrepancies where files extracted from Jeffrey Epstein's devices show creation dates after his death (July 2020). The email also mentions videos from SDFL and PBPD investigations.
EFTA00027861.pdf
This document is an email chain from March 2021 between Ghislaine Maxwell's defense team (Cohen & Gresser LLP) and the US Attorney's Office (USANYS). The defense raises several technical discovery issues, including the inability of Maxwell to read discovery disks on the prison computer, missing email attachments, and corrupted metadata on files extracted from Jeffrey Epstein's devices (showing 2020 dates instead of original dates). The prosecution forwards these issues to their contractor (PAE) to address.
EFTA00025398.pdf
This document is an email chain from April 2020 between the DOJ's Office of Professional Responsibility (OPR) and the US Attorney's Office for the Southern District of New York (SDNY). OPR is seeking to interview 32 individuals regarding their historical contacts (2005-2008) with the Southern District of Florida (USAO-SDFL) and FBI Miami concerning the Epstein case. SDNY agrees to the interviews but requests that OPR avoid discussing the substance of the underlying criminal scheme or interactions with Epstein to avoid interfering with SDNY's active investigation, noting that any relevant statements must be handled as '3500 material' (Jencks Act). The correspondence lists the legal representation for the 32 individuals, noting the majority are represented by Brad Edwards.
EFTA00025010.pdf
This document is an unclassified FBI Intake record dated August 3, 2020, documenting an online tip from a complainant in New Mexico. The complainant alleges they were sex trafficked at age 13 in 1984 by their uncle and Jeffrey Epstein on a yacht in Lake Michigan. The tip explicitly names Donald Trump as a witness and participant, alleging he paid for sexual acts and was present when the complainant's uncle murdered their newborn child.
EFTA00024021.pdf
This document is an email chain from March 2021 related to the U.S. v. Ghislaine Maxwell case. Christian Everdell of Cohen & Gresser LLP submits reply memoranda and exhibits for pretrial motions to Judge Nathan's chambers and government prosecutors (USANYS), noting that documents are being filed under seal with redacted versions for the public docket.
EFTA00020434.pdf
This document is an email chain from March 2021 between Ghislaine Maxwell's defense team (Cohen & Gresser) and the US Attorney's Office. Defense attorney Christian Everdell outlines seven specific technical issues regarding discovery production, including the inability of Maxwell to view files on prison computers, missing email attachments, and corrupted metadata on over 110,000 documents extracted from Jeffrey Epstein's devices. The prosecution team discusses internally setting up a call with their vendor, PAE, to address these errors.
EFTA00020426.pdf
This document is an email chain from March 2021 between Ghislaine Maxwell's defense counsel (Christian Everdell) and the U.S. Attorney's Office (SDNY) regarding discovery disputes. The defense raises seven specific issues, including the inability of Maxwell to view files on prison computers, missing email attachments (over 109,000), metadata discrepancies suggesting files were created/modified after seizure, and gaps in Bates numbering. The prosecution responds by explaining technical limitations with the MDC (prison), asserting that metadata reflects the state of files upon FBI seizure or carving, and clarifying that certain images came from physical CDs seized from Epstein's residences in 2019 rather than electronic extractions.
EFTA00020243.pdf
An email dated April 30, 2021, from attorney Christian Everdell of Cohen & Gresser LLP to redacted recipients and copied to members of the defense team (Laura Menninger, Jeff Pagliuca, Bobbi Sternheim) and the US Attorney's Office (USANYS). The email serves to circulate an attached letter regarding 'Hard Drives' that was recently filed on the docket addressed to Judge Nathan.
EFTA00019029.pdf
This document contains an email thread from March 22, 2021, between Christian Everdell of Cohen & Gresser LLP and likely government prosecutors regarding the Ghislaine Maxwell case. The correspondence discusses a 'meet and confer' requirement ordered by Judge Nathan concerning redactions to 'Exhibit 11' and references a sealed document ('Exhibit H') from a civil docket before Judge Preska. The government (implied sender of the top email) asks Everdell if they wish to keep certain quotations redacted given they are sealed in the civil case.
EFTA00018370.pdf
This document appears to be an excerpt from a Curriculum Vitae or a disclosure list for Professor Gail S. Goodman, detailing her history of providing expert testimony in federal court. It lists specific criminal cases (US v. Defendant) alongside the jurisdiction (Washington DC, Portland, New Mexico, San Francisco) and the associated US Attorney's office, though the specific attorney names are redacted.
EFTA00016768.pdf
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.
EFTA00016175.pdf
This document is an email chain between officials from the SDNY U.S. Attorney's Office and likely the BOP/USMS regarding the arrest and detention of Ghislaine Maxwell on July 2, 2020. The correspondence discusses her immediate housing in New Hampshire, safety precautions citing 'the history here' (likely referencing Epstein), and the plan to transfer her to MDC Brooklyn. The emails confirm she was in a local facility in New Hampshire and scheduled for a virtual presentation.
EFTA00014585.pdf
An email chain originating from Christian Everdell of Cohen & Gresser LLP on October 1, 2020, forwarding a 'Letter to Government re Discovery' to redacted recipients. A subsequent email on October 2, 2020, asks the recipients if they have time to discuss the attached letter. The document relates to legal proceedings, likely the Ghislaine Maxwell case given Everdell's involvement, specifically regarding discovery issues with the government.
EFTA00013726.pdf
An email from an Assistant U.S. Attorney (USAFLS) dated March 23, 2008, reporting aggressive harassment by Jeffrey Epstein's private investigators against victims. The email details an incident where an investigator threatened a victim with releasing a compromising video on the internet, a threat the AUSA believes is a bluff. The sender requests intervention from officials in DC to stop these tactics while legal negotiations are ongoing, noting that Epstein is using the state case to improperly gather information on the federal investigation.
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