This document is a Notice of Motion filed on July 6, 2023, by attorneys for James E. Staley in the U.S. District Court for the Southern District of New York. It requests the dismissal of an amended stockholder derivative complaint involving JPMorgan Chase & Co. The filing outlines the legal basis (Rules 12(b)(6) and 23.1(b)) and sets the schedule for subsequent responses and replies.
This document is an Affidavit of Service filed in the Supreme Court case (No. 24-1073) of Ghislaine Maxwell v. United States. Rina Danielson certifies that on May 9, 2025, she served the 'Brief of Amicus Curiae National Association of Criminal Defense Lawyers in Support of Petitioner' to attorneys for both Maxwell (David Oscar Markus) and the United States (Solicitor General D. John Sauer). The service was performed via Priority Mail and email, with physical copies also sent to the Court via Federal Express.
This document is a Notice of Withdrawal of Motion for Partial Summary Judgment filed on April 8, 2016, in a Florida Circuit Court case between Bradley J. Edwards/Paul G. Cassell and Alan M. Dershowitz. The plaintiffs withdraw their motion pursuant to a confidential settlement agreement but explicitly state that their client, Virginia Giuffre, reaffirms her allegations and that the withdrawal is not an admission that her allegations were mistaken. They concede that filing certain allegations in a separate Crime Victims' Rights Act case was a 'tactical mistake' that caused distractions.
This document is a Motion for Limited Appearance filed on June 4, 2009, in the case of Jane Doe 101 v. Jeffrey Epstein in the Southern District of Florida. Attorney Robert D. Critton, Jr. moves for the admission of Jay P. Lefkowitz of Kirkland & Ellis LLP to appear as co-counsel for Jeffrey Epstein. The document includes certificates of service to opposing counsel and a certificate of good standing for Lefkowitz from the District of Columbia court.
This document is an internal FBI email chain dated December 13, 2019, forwarding an automated 'Person Lookout Query' hit for Ghislaine Maxwell. The alert indicates that a record for Maxwell was accessed at 'CIS-WASH DC, CIS HQ FDNS' (likely USCIS Fraud Detection and National Security) via a query using a TECS ID.
An internal Bureau of Prisons (BOP) email sent on August 16, 2019, regarding the August 2019 Executive Staff Meeting. The email notes a significant change in plans, cancelling a Philadelphia trip in favor of Washington, DC, and adding 'Executive Staff Briefings to ODAG' (Office of the Deputy Attorney General) on August 20, 2019. This change occurred shortly after Jeffrey Epstein's death in BOP custody on August 10, 2019.
This document is an email thread among Bureau of Prisons (BOP) executive staff dated August 15-16, 2019, shortly after Jeffrey Epstein's death in BOP custody. The emails detail a sudden change in plans ('4th quarter audible'), cancelling a planned meeting in Philadelphia to instead convene in Washington, DC, to brief a new liaison from the Office of the Deputy Attorney General (ODAG). The correspondence outlines logistical changes, including hotel and meeting locations, and instructs staff to update briefing materials for the ODAG meeting scheduled for August 20, 2019.
This document is a U.S. Department of Justice Employee Locator Information form (Form DOJ-233) submitted by Jona A. Noel on October 25, 2018. The form lists the employee's residence in the Bronx, New York, and identifies a redacted individual described as a 'Significant Other' as the emergency contact, also located in the Bronx. Specific contact details such as street addresses and phone numbers are redacted.
This document is a formal memorandum from the Federal Bureau of Prisons (BOP) responding to an Office of Inspector General (OIG) draft report dated June 15, 2023, concerning the custody and death of Jeffrey Epstein at MCC New York. The BOP addresses eight specific recommendations, concurring with some regarding camera maintenance and lieutenant rounds, but disagreeing with others related to cellmate assignment policies and the assertion that staffing shortages caused the negligence leading to Epstein's suicide. The BOP explicitly states that the failure to conduct rounds was due to employee misconduct/negligence rather than understaffing, noting that the unit was fully staffed at the time.
This document is a status update memorandum dated November 19, 2024, from the Federal Bureau of Prisons (FBOP) to the Office of Inspector General (OIG). It details the FBOP's progress in implementing recommendations arising from the OIG's 2023 investigation into the custody and death of Jeffrey Epstein at MCC New York. Key updates include policy changes regarding single-cell placement for at-risk inmates, suicide prevention protocols, improved staffing measures (including a new Automated Staffing Tool), and enhanced security camera reporting requirements.
This document is a status update from the Federal Bureau of Prisons (FBOP) to the Office of Inspector General (OIG) responding to recommendations made after the investigation into Jeffrey Epstein's custody and death. It details procedural changes regarding cellmate assignments after suicide watch, single-cell tracking (introducing Form BP-A1121), staffing shortage mitigation (including a new Automated Staffing Tool and hiring incentives), and security camera maintenance protocols. The document includes a template for the 'Single-Cell Review Form' and a directive for monthly security camera reporting effective June 1, 2024.
This document is a status update from the Federal Bureau of Prisons (BOP) to the Office of Inspector General (OIG) dated June 30, 2025, responding to recommendations made in the June 2023 OIG report on the custody and death of Jeffrey Epstein. The BOP addresses several recommendations concerning suicide watch protocols, cellmate assignments, inmate whereabouts accountability, staffing shortages, and security camera systems. The document outlines ongoing revisions to various Program Statements (policies) and discusses budgetary constraints affecting staffing incentives.
This document is an email chain dated July 25, 2019, between the United States Marshals Service (USMS) and the Federal Bureau of Prisons (BOP). The USMS expresses frustration regarding a lack of information from MCC New York's Warden and Assistant Warden following an 'incident' involving high-profile prisoner Jeffrey Epstein (likely his July 23 injury). A BOP official responds, connecting the USMS with an Associate Warden who can provide the requested information.
This document is an email chain dated July 25, 2019, between the US Marshals Service (USMS) and the Federal Bureau of Prisons (BOP). The USMS is urgently seeking information regarding an 'incident' involving Jeffrey Epstein at MCC New York, noting that the facility's Warden and Assistant Warden were uncooperative. A BOP Acting SDAD/CPD responds by directing the USMS to an Associate Warden who has been cc'd to provide the necessary information.
This document is a chain of emails between the Federal Bureau of Prisons (BOP), the DOJ Office of the Inspector General (OIG), and implied recipients at the FBI and SDNY, dated January 8-14, 2020. The correspondence concerns the initiation of a 'Board of Inquiry' to review operations at MCC New York following Jeffrey Epstein's death, specifically examining camera operations, staffing, and special housing policies. A key focus of the OIG report mentioned is the investigation into why Epstein was not assigned a new cellmate after the departure of inmate Reyes.
This document consists of an email chain from September 2020 between the US Department of Justice Attaché in London (John T. McNeil) and the SDNY regarding an investigation into Jeffrey Epstein. The correspondence concerns a potential witness who is currently abroad and has recently made a statement to the UK Metropolitan Police regarding past abuse by Epstein. The officials discuss jurisdictional issues, OIA approval, logistics for interviewing the witness, and whether the witness has connections to UK government functions or 'Witness PA' (likely Prince Andrew).
This document is a legal memorandum filed on December 20, 2019, in the case of Plaintiff (Redacted, generally known as Virginia Giuffre) v. Alan Dershowitz. The Plaintiff seeks leave to amend her complaint to add a battery claim under the newly effective New York Child Victims Act and a Wiretap Act claim regarding an unauthorized recording Dershowitz made of a settlement conference with her attorney, David Boies. The filing argues that the amendment should be allowed as there is no undue delay, bad faith, or futility, and notes that Dershowitz's defamatory statements have intensified.
This document is an email chain from August to October 2020 between attorneys Gloria Allred and Mariann Wang and federal investigators (FBI/SDNY). The correspondence concerns scheduling interviews for several new potential victims of Jeffrey Epstein and Ghislaine Maxwell. The emails contain specific summaries of allegations for victims identified by initials (AR, DM, JRC, EH), including incidents in NY, FL, Paris, and DC ranging from 2000 to 2017, and a specific mention of an interaction with Prince Andrew at a townhouse in 2010.
This document contains the 2015 US Individual Income Tax Return (Form 1040) and New York State Resident Income Tax Return (Form IT-201) for Ghislaine Maxwell. It includes various schedules and forms reporting income from dividends, interest, partnerships (including The Blackstone Group and Cargometrics), capital gains/losses, foreign assets, and deductions. The return shows an adjusted gross income of $243,496, a total tax of $30,286, and a substantial overpayment applied to 2016 estimated taxes.
This document is an FY 2021 funding request from the Southern District of New York for $200,000 to support the investigation into Ghislaine Maxwell following Jeffrey Epstein's death. The funds are requested for database hosting ($100k) and travel ($100k) to interview at least 50 victims and manage voluminous records. The document also notes potential civil forfeiture actions against Epstein's properties valued at over $100 million.
A letter from the Federal Bureau of Prisons to New York Times reporter Danielle Ivory denying a FOIA request for documents regarding inmate Jeffrey Epstein. The BOP withheld all records citing multiple exemptions, specifically noting exemption (b)(7)(A) due to active and on-going law enforcement proceedings.
This document is a formal Freedom of Information Act (FOIA) request submitted on December 12, 2019, by New York Times reporter Danielle Ivory to the Bureau of Prisons. The request seeks detailed records regarding Jeffrey Epstein's time at the Metropolitan Correctional Center (MCC) prior to his death on August 10, 2019, specifically asking for logs of his phone calls, emails (via Corrlinks), visitor logs, and his approved lists for visitors, emails, and calls. The reporter requests expedited processing and a fee waiver, citing extreme public interest and the need to shed light on government operations following Epstein's death in federal custody.
This document is the Curriculum Vitae (CV) of Lisa M. Rocchio, Ph.D., a clinical psychologist specializing in trauma, forensic assessment, and ethics. It details her education, clinical experience, academic appointments at Brown University, and extensive list of publications and presentations on trauma psychology. The document also highlights her professional advocacy work, including meetings with Rhode Island Senators and Representatives regarding mental health reform.
This document is a 'Second Supplemental Privilege Log' from the case Jane Doe v. United States, listing internal DOJ, FBI, and USAO communications withheld from civil discovery. The log chronicles the timeline of the Jeffrey Epstein investigation from late 2006 to August 2008, detailing the internal deliberations regarding the Non-Prosecution Agreement (NPA), plea negotiations, and the drafting of the indictment. It reveals critical details such as internal disagreements over plea terms, Epstein's refusal to plead to anything other than 'assault on the plane,' Jay Lefkowitz's admission that he never intended Epstein to register as a sex offender, and the government's struggles with victim notification and harassment by Epstein's defense team.
This document is an email from Joseph DiPiero of Akin Gump to an undisclosed recipient (likely the SDNY based on attachment names) dated December 13, 2019. It serves as a transmittal for an additional production of documents from Deutsche Bank in response to a July 11, 2019 subpoena. The email references attached files including a submission PDF and an Excel appendix.
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