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This document contains FBI evidence logs (FD-340/FD-597) from March 2011 documenting the receipt of 20 photographs and notes from a cooperating witness regarding Jeffrey Epstein. The photos (grainy photocopies) depict locations including Paris (Dec 2000), Epstein's 'Zorro' Ranch in New Mexico, and a New York apartment. The file also includes a 2008 subpoena to Cingular/AT&T and a 2008 letter from US Attorney R. Alexander Acosta denying a request for information based on Grand Jury secrecy rules.
This document is a transcript of an interview, or 'proffer,' of Ghislaine Maxwell conducted by the United States Department of Justice on July 24, 2025. The interview involves legal counsel for Maxwell and various US government representatives, primarily focusing on the terms and conditions of a proffer agreement, emphasizing that it is not a cooperation agreement and outlines the immunity and exceptions related to false statements.
This document is a heavily redacted version of Jeffrey Epstein's 'Black Book' (contact list) from approximately 2004-2005. It contains an alphabetical listing of high-profile individuals, politicians, celebrities, and business associates, along with sections for specific locations (Palm Beach, NY, Paris, etc.) and services (Massage, Medical, Aviation). The final page contains significant handwritten notes identifying key witnesses, staff members (chefs, drivers), and specific allegations regarding the procurement of women ('Scout for young females') and interactions with underage girls.
This document contains scanned telephone message books from the Palm Beach State Attorney's Office (likely Barry Krischer's office) spanning from 2005 to 2009. The messages document high-frequency communication between the State Attorney ('BK' or 'Mr. K') and Epstein's defense team (Alan Dershowitz, Jack Goldberger, Bruce Lyons), as well as significant media inquiries regarding Epstein's indictment, prison sentence, and potential charges in the Virgin Islands. A critical handwritten note advises 'No don't give to Feds our case unless they take all,' highlighting the jurisdictional tension between state and federal prosecutors.
This document contains a plea agreement for Jeffrey E. Epstein, detailing charges of felony solicitation of prostitution and procuring a person under 18 for prostitution, along with his sentence and conditions. It also includes several handwritten message slips, some addressed to 'Mr. Epstein' or 'Jeffrey' and others to 'Mr. Maxwell' or 'Ghislaine Maxwell', containing phone numbers and short messages.
This document contains a sworn statement from Juan P. Alessi dated November 21, 2005, detailing his experiences working for Jeffrey Epstein, particularly focusing on Ghislaine Maxwell's role as manager of Epstein's global households and his girlfriend. It also includes a letter from the Town of Palm Beach Police Department Chief Michael S. Reiter to State Attorney Barry E. Krischer dated May 1, 2006, transmitting investigation documents related to Epstein, Sarah Kellen, and Haley Robson, and expressing strong concerns about the State Attorney's office's handling of the cases.
This document is a Deferred Prosecution Agreement (DPA) between the United States and Tova Noel, a Bureau of Prisons employee charged in connection with the events surrounding Jeffrey Epstein's death. Noel admits to knowingly falsifying count and round slips at the Metropolitan Correctional Center (MCC) on August 9 and 10, 2019. The agreement defers prosecution for six months pending her good behavior, 100 hours of community service, and cooperation with investigators (FBI, DOJ-OIG), after which the indictment will be dismissed if conditions are met.
This document is a Notice of Appearance (Form AO 458) filed in the United States District Court for the Southern District of New York on November 20, 2019. Attorney Jason E. Foy officially enters his appearance as counsel for Tova Noel in Case Number 19 Crim 830. The document includes the attorney's contact information in Hackensack, New Jersey.
Defense counsel Marc Fernich writes to Judge Berman to supplement Jeffrey Epstein's bail request, arguing against the government's stance that Epstein's wealth creates an irrebuttable presumption for detention. The letter proposes a forensic accounting by Joel Podgor, notes that Epstein's brother Mark is willing to secure a bond with his >$100 million net worth, clarifies Epstein's sex offender registration status in New Mexico, defends against claims regarding an expired Austrian passport, and argues that Epstein's return to the US despite media pressure proves he is not a flight risk.
This document is a declaration filed on August 8, 2023, by attorney Christopher J. Orrico of Grant & Eisenhofer P.A. requesting admission pro hac vice in the JP Morgan Chase & Co. Derivative Litigation (Case No. 1:23-CV-03903). Orrico attests to his good standing in New York and Connecticut and confirms he has no criminal or disciplinary record. He represents the Operating Engineers Construction Industry and Miscellaneous Pension Fund in this matter.
Ghislaine Maxwell, appearing pro-se, responds to the Defendants' (Estate of Jeffrey Epstein and executors) motion to dismiss her case for failure to prosecute. She argues that she has complied with court orders despite the constraints of incarceration and seeks indemnification for legal expenses based on Virgin Islands common law, corporate law, and the NES LLC operating agreement. She asserts that public policy and the "unclean hands" of the executors should not bar her claims.
A court order from the Superior Court of the Virgin Islands dated September 19, 2023, dismissing Ghislaine Maxwell's complaint against the Estate of Jeffrey Epstein, executors Indyke and Kahn, and NES, LLC. The dismissal was granted based on a failure to prosecute or alternatively to compel the plaintiff to appear pro se. The order is signed by Presiding Judge Harold W.L. Willocks.
This document is a Notice of Entry of Order from the Superior Court of the Virgin Islands, filed on February 15, 2023. It notifies Ghislaine Maxwell (Plaintiff) and various attorneys that an order was entered regarding case ST-2020-CV-00155, a debt action against the Estate of Jeffrey Epstein, his executors (Indyke and Kahn), and NES, LLC.
A Notice of Entry of Order from the Superior Court of the Virgin Islands filed on September 8, 2022. The document concerns a debt action (Case ST-2020-CV-00155) brought by Ghislaine Maxwell against the Estate of Jeffrey Epstein, his executors (Indyke and Kahn), and NES, LLC. The notice informs the listed attorneys that an order dated September 7, 2022, has been entered into the record.
This document is a legal brief filed by Ghislaine Maxwell in the Superior Court of the Virgin Islands against the Estate of Jeffrey Epstein. Maxwell argues that Virgin Islands public policy does not prevent her from seeking indemnification (reimbursement) for legal fees and security costs incurred due to her employment with Epstein, despite her criminal conviction in New York (SDNY). She asserts claims based on contract promises, common law joint tortfeasor indemnity, and corporate indemnity laws regarding her role at NES, LLC.
Court order from the Superior Court of the Virgin Islands dated July 1, 2022, in the case of Ghislaine Maxwell v. Estate of Jeffrey E. Epstein. Staff Master Joseph T. Gasper schedules a remote status conference for July 29, 2022, to discuss case management, including a pending motion to intervene by the VI Government and a motion to dismiss by the Estate. The document references delays requested by Maxwell's counsel due to her criminal case in the Southern District of New York.
A court order from the Superior Court of the Virgin Islands dated February 22, 2022, in the case of Ghislaine Maxwell v. Estate of Jeffrey E. Epstein et al. (Case No. ST-2020-CV-00155). Judge Harold W.L. Willocks ordered a status conference to be held via Zoom on March 9, 2022. The defendants include Epstein's estate, his executors Darren Indyke and Richard Kahn, and NES, LLC.
This document is a legal brief filed on March 29, 2021, by the Co-Executors of the Estate of Jeffrey Epstein (Darren K. Indyke and Richard D. Kahn) in the Superior Court of the Virgin Islands. The brief argues against designating Ghislaine Maxwell's lawsuit for legal fee indemnification as 'complex' litigation and opposes consolidating it with a separate government 'CICO action' (Case No. ST-2020-CV-00014). The Executors contend that Maxwell's case is a simple single-issue dispute, whereas the CICO action involves complex allegations of a multi-decade criminal enterprise.
This is a Reply Brief filed by the Co-Executors of the Estate of Jeffrey Epstein (Indyke and Kahn) in response to a lawsuit by Ghislaine Maxwell. Maxwell is suing the Estate and NES, LLC for indemnification (payment of her legal fees) related to her criminal and civil cases in New York. The Co-Executors argue the case should be dismissed because: 1) The claim is 'unripe' as her underlying guilt or innocence hasn't been established; 2) Public policy forbids indemnifying criminal conduct; 3) The NES Operating Agreement explicitly allows the company to decline indemnification; and 4) The Statute of Frauds bars claims based on alleged oral promises.
This document is a Motion to Intervene filed by the Government of the US Virgin Islands in a civil case brought by Ghislaine Maxwell against the Estate of Jeffrey Epstein. The Government seeks to intervene to prevent Maxwell from using the Estate's assets to pay for her legal defense (indemnification), arguing that those assets should be preserved to satisfy a potential judgment in the Government's separate CICO (racketeering) lawsuit against the Estate. The document details Maxwell's evasion of subpoenas prior to her arrest, the Government's interest in the Estate's assets for victim restitution and penalties, and the allegation that Maxwell and the Estate are colluding rather than being true adversaries. While flight logs are mentioned as existing evidence of trafficking, no specific flight records are contained within this specific motion.
This document is a civil complaint filed on March 12, 2020, by Ghislaine Maxwell against the Estate of Jeffrey Epstein and its executors, Darren Indyke and Richard Kahn, as well as NES, LLC. Maxwell seeks indemnification for legal fees, security costs, and safe accommodation expenses she has incurred due to her prior employment with Epstein. The complaint alleges that Epstein repeatedly promised, both verbally and in writing (specifically in a 2004 letter), to support Maxwell financially and indemnify her, a practice he reportedly maintained during previous lawsuits in 2009 and 2017.
This document is 'Exhibit 2' filed in the Superior Court of the Virgin Islands on March 4, 2022, in case ST-2021-RV-00005. The content is a Wall Street Journal article from February 9, 2016, titled 'Legal Fees Cross New Mark: $1,500 an Hour'. The article discusses the rising billing rates of top corporate lawyers in the US, citing specific firms like DLA Piper, Proskauer Rose, and Kirkland & Ellis. It serves as evidence of market rates for legal services, likely submitted to support a fee application in the associated court case.
This affidavit by attorney Bradley Edwards details difficulties in discovery for a civil case against Jeffrey Epstein (Case 10-81111). It alleges that key witnesses Ghislaine Maxwell and Jean Luc Brunel evaded depositions by falsely claiming to be out of the country. Crucially, it lists specific individuals for whom Epstein paid legal fees to prevent them from testifying against him, explicitly labeling Sarah Kellen as a 'procurer of girls' and Nadia Marcinkova as a 'live-in sex slave', while also identifying his personal pilots and household staff.
This document is an appeal by Defendant Jeffrey Epstein against a Magistrate's Order compelling him to produce discovery materials, including correspondence with prosecutors, tax returns, and passport/travel records. Epstein argues that producing these documents violates his Fifth Amendment right against self-incrimination because he still faces a real threat of federal prosecution outside the Southern District of Florida, despite his Non-Prosecution Agreement (NPA). The filing also details privacy concerns for third parties (alleged victims), claims attorney work-product privilege over files selected by his defense counsel, and argues that his offer to stipulate to a high net worth renders the production of his tax returns unnecessary.
This document is an Omnibus Order from the US District Court for the Southern District of Florida dated February 4, 2010, in the civil case of Jane Doe No. 2 vs. Jeffrey Epstein. The Magistrate Judge rules on the Plaintiff's motions to compel answers to interrogatories, admissions, and production requests. The court upholds Epstein's Fifth Amendment privilege against self-incrimination regarding questions about his financial history, assets, and potential witnesses, but orders him to produce documents that are already known to the government (tax returns, passport, and documents provided to him during plea negotiations), ruling that these fall under the 'foregone conclusion' doctrine.
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