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EFTA00023768.pdf
This document is a discovery request letter from attorney Jason E. Foy, representing Tova Noel (a guard charged in relation to Jeffrey Epstein's death), to the US Attorney's Office. The letter demands 31 specific items, including Noel's personnel files, SHU logs from the time of Epstein's death (August 2019), surveillance records of broken cameras, and internal memos regarding Epstein's need for a cellmate. It also notably asks for the identity of the author of a specific 4Chan message and records related to other inmate deaths at the MDC.
EFTA00022483.pdf
This document is an email chain from late September 2021 involving an Assistant United States Attorney from the Southern District of New York. The discussion concerns a 'photo sourcing project' for trial preparation, resulting in the attachment of a spreadsheet titled 'Photos_for_Trial_Prep_with_Location_Info.xlsx' containing evidence item numbers and CD locations. The timing suggests this is related to preparations for the Ghislaine Maxwell trial.
EFTA00021978.pdf
This document is an email dated November 7, 2021, from an Assistant United States Attorney (SDNY) to a colleague. The email concerns the drafting of a 'joint letter regarding juror questionnaires' (likely related to the Ghislaine Maxwell trial given the timeframe). The sender asks the recipient to input data received from the defense into the draft and emphasizes the need to finish in time for the defense to review it that afternoon.
EFTA00021944.pdf
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.
EFTA00021034.pdf
A letter from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense counsel dated November 23, 2021, accompanying a discovery production. The production includes JPMC records, phone records, and other documents designated as confidential under a protective order. The letter clarifies labeling protocols for confidential materials to distinguish them from classified documents.
EFTA00020358.pdf
This document is an email from an Assistant United States Attorney (SDNY) to defense attorneys Chris, Mark, and Jeff, dated July 2, 2020. It serves as formal notification that their client (identified via attachments as Ghislaine Maxwell) was arrested by the FBI that morning in Bradford, New Hampshire. The email attaches the indictment and arrest warrant and outlines the immediate legal steps, including her transport for processing and an expected remote court presentation in the District of New Hampshire later that afternoon.
EFTA00019976.pdf
This document is a Grand Jury Subpoena issued by the U.S. Attorney for the Southern District of New York to MoneyGram International on August 16, 2019. It commands MoneyGram to produce records regarding money transfers and money orders related to specific, heavily redacted individuals or entities. The subpoena cites federal statutes related to sex trafficking (18 U.S.C. § 1591), coercion of minors (18 U.S.C. § 2422(b)), and conspiracy (18 U.S.C. §§ 371, 1594(c)).
EFTA00019966.pdf
This document is a Grand Jury Subpoena issued by the U.S. Department of Justice (SDNY) to Wells Fargo Bank on August 16, 2019, six days after Jeffrey Epstein's death. It commands the bank to produce extensive financial records regarding redacted individuals and entities, citing federal statutes related to sex trafficking (18 U.S.C. § 1591), coercion of minors (18 U.S.C. § 2422), and conspiracy. The subpoena requests all account documents, wire transfers, and correspondence from account inception to the present.
EFTA00019958.pdf
An email dated August 8, 2019, from an Assistant US Attorney in the Southern District of New York to a DOJ official in the USVI. The email submits a search warrant application and exhibits regarding the US Virgin Islands. It notes that a female Special Agent (the affiant) is copied on the email and is available to speak with Judge Miller the following day.
EFTA00019652.pdf
This document is an email chain from July 2021 involving an Assistant United States Attorney for the Southern District of New York. The emails discuss logistical arrangements for a witness interview scheduled for July 29, 2021, specifically regarding the Ghislaine Maxwell case. The correspondence highlights legal constraints, noting that they 'cannot pay for interviews' and discussing travel requests (Fact_Witness_Travel_Request.docx) for the witness.
EFTA00019615.pdf
This document package contains a response from TransUnion to the FBI dated September 1, 2020, providing credit reports for three individuals in response to a Grand Jury Subpoena issued by the SDNY on August 25, 2020. The subpoena relates to an investigation into violations of 18 U.S.C. §§ 371 (Conspiracy), 1343 (Wire Fraud), and 1346 (Honest Services Fraud). The actual credit reports and the names of the individuals being investigated are heavily redacted.
EFTA00019530.pdf
An email dated November 30, 2018, sent by an Assistant United States Attorney from the Southern District of New York regarding 'Epstein'. The email contains several attachments related to case 08-Civ-80736 (likely the CVRA lawsuit in Florida) and the Non-Prosecution Agreement (NPA).
EFTA00019407.pdf
A legal letter from attorneys Michael C. Miller (Steptoe) and Martin G. Weinberg to the US Attorney's Office (SDNY) dated August 20, 2019. The attorneys, representing Jeffrey Epstein's estate, formally request evidence regarding his death in custody, including video recordings, entry logs, and guard logs from the MCC for the period of August 9-10, 2019. The letter cites statements by AG William Barr regarding 'serious irregularities' at the facility and declares the defense's intent to conduct an independent investigation.
EFTA00019220.pdf
This document is an email thread from November 2021 among staff at the Southern District of New York (SDNY) regarding the opening of the trial *United States v. Ghislaine Maxwell*. An Assistant US Attorney sends a motivational email to colleagues, contrasting SDNY's willingness to prosecute historical sex crimes with prosecutors in Florida, and providing logistical details for the trial opening at the 40 Foley courthouse.
EFTA00018893.pdf
This document is an email chain between the defense team (including Christian Everdell, Jeff Pagliuca, and Menninger) and the US Attorney's Office (SDNY) regarding the Ghislaine Maxwell trial. The correspondence, dated November 6-7, 2021, coordinates the exchange of juror 'strike' lists and 'keeps' for a joint submission to the Court. Specific details include technical difficulties with Excel files and a specific agreement to allow jurors 127, 151, and 458 to proceed to voir dire.
EFTA00018267.pdf
This document is an email chain from November 2021 related to the case 'United States v. Maxwell'. An Assistant United States Attorney from the Southern District of New York forwards correspondence to USANYS personnel, originally sent to 'Nathan NYSD Chambers' (Judge Alison Nathan), attaching a joint letter regarding prospective juror questionnaires for the upcoming trial.
EFTA00018130.pdf
An email chain between an Assistant United States Attorney (SDNY) and another official regarding protocols for interviewing inmates. The discussion references the 'MCC case' and includes an attachment specifically titled 'Hammad_Memo_-_Epstein_Death_Investigation.msg', indicating the conversation concerns the investigation into Jeffrey Epstein's death. The correspondence details the use of 'Hammad memos' to authorize agents to interview inmates without counsel present.
EFTA00018005.pdf
An internal email from an Assistant US Attorney in the Southern District of New York dated September 22, 2021. The email discusses the review of evidence files including FBI files and FedEx records, mentions the discovery of 'Maxwell phone records,' and attaches a 'Household Manual' dated 2005 in preparation for an upcoming interview with the manual's source.
EFTA00016313.pdf
An email from an Assistant United States Attorney at the SDNY to FBI agents dated June 12, 2020, requesting a follow-up call regarding the investigation into Ghislaine Maxwell. The email specifically seeks information on Maxwell's active financial accounts, credit cards, a connection to UMB Bank, the status of returns from a subpoena issued on September 25, 2019, and recent SAR/CTR (Suspicious Activity Report) checks.
EFTA00016206.pdf
This document is a motion in limine filed by Ghislaine Maxwell's defense team on October 18, 2021, seeking to exclude evidence offered by the government under Rule 404(b) due to lack of proper notice. The defense argues the government failed to identify specific evidence or articulate a non-propensity purpose for its admission. The motion references disputed evidence including emails between Maxwell and 'influential men' regarding dates, testimony from a former Epstein employee (2005-06) regarding 'sexualized massages,' and various exhibits including flight logs (GX-661 & 662) and financial statements.
EFTA00015825.pdf
This document is an email chain between David Oscar Markus, representing Ghislaine Maxwell, and the US Attorney's Office (SDNY) regarding her appeal of a bail denial. The correspondence, dating from March 25 to April 10, 2021, covers Markus's request for unredacted docket entries, discussions on expediting the appeal process, and the filing of an unredacted Exhibit F under seal. The US Attorney confirms the existence of a protective order and agrees not to oppose expediting consideration of the appeal, provided the 10-day response window remains intact.
EFTA00014384.pdf
This document is an email dated June 26, 2020, from an Assistant United States Attorney in the Southern District of New York to a redacted recipient. The subject is 'transcript' and it includes two PDF attachments labeled as transcripts from June 19, 2019, and July 19, 2019.
EFTA00013342.pdf
This document is an email chain within the US Attorney's Office (SDNY) discussing a legal challenge in the case United States v. Rivera. The judge and defense counsel questioned why Ghislaine Maxwell (at MDC) received significantly greater access to laptops (13 hours/day vs 3) and video counsel visits than Justin Rivera (at MCC). The correspondence outlines the Bureau of Prisons' justification, attributing the disparity to Maxwell's protective custody status and massive discovery volume versus Rivera's general population housing.
EFTA00010619.pdf
This document is a heavily redacted email from an Assistant United States Attorney in the Southern District of New York, dated August 24, 2021. The email includes an attachment labeled 'USGME00444198_native.pdf' and is addressed to a recipient associated with 'USANYS'. The document appears to be part of a legal file or discovery production, marked with Bates number EFTA00010619.
EFTA00010454.pdf
This document is a Grand Jury Subpoena issued by the U.S. Department of Justice (SDNY) to FirstBank Puerto Rico. Although the cover letter is dated December 31, 2019, the subpoena itself is dated August 11, 2019 (the day after Jeffrey Epstein's death). It demands the production of all financial records, including 'Know Your Customer' files, statements, and transaction logs, for Jeffrey Epstein and the entity LSJE LLC from January 1, 2005, to the present, citing federal sex trafficking and conspiracy statutes.
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