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@@ -0,0 +1,48 @@
+From:
+To:
+Ce:
+Subject: FW: Jeffrey Epstein / Private Jets
+Date: Tue, 07 Jul 2020 19:24:48 +0000
+FYI
+From: I
+Sent: Tuesday, July 07, 2020 15:10
+To: l
+Subject: FW: Jeffrey Epstein / Private Jets
+He called and I asked him to send me an email.
+From: Michael Lyon <1
+Sent: Tuesday, July 7, 2020 3:02 PM
+To: "
+Subject: Jeffrey Epstein / Private Jets
+Hello l
+My name is Michael Lyon in Pittsfield Massachusetts. I am an owner of an aviation company (Lyon Aviation Ing) that flies
+people around the world in private jets. I have worked with a Customs Agent out of Albany NY in the past, L
+One of the tips I provided
+• was on or about February 7th or 8th 2015. We transported a lone woman
+of Massachusetts to St. Thomas on February 07th 2015 from Boston and returned her on February 10th 2015. We found
+this odd that this woman was flying privately, because she didn't appear to be able to afford this flight that may have costs
+$35,000. I suspected this woman might have or be transporting drugs. She was questioned for several hours by ST
+Thomas Customs on her return. The only info gathered was that she was an escort and not drug related. This woman was
+transported to and from St. Thomas on a private helicopter to a nearby island.
+Being in the private flying arena for 35 years one tends to learn patterns and flight requests. I was always keenly aware of
+one particular "Charter Broker" (Dan Ryan, owner of BIG FLY INC. I
+1) who appeared to be working for the
+same person (many years) and filling numerous requests to the island of St. Thomas from all different parts of the USA. A
+"Charter Broker" doesn't own or operate aircraft, but represents clients in finding aircraft for their particular missions.
+This particular flight that we performed on behalf of Dan Ryan always stuck in my head. One reason was the frequency of
+the requests to the same island and because these were great revenue requests. I always thought these flights were for
+someone in the St. Thomas region bringing in many guests and had to be quite wealthy.
+After the Epstein story broke the news, 1 instantly remembered the Boston St. Thomas flight and knew with almost certainty
+that Dan Ryan was the "CHARTER BROKER" fulfilling the requests to transport people into and of out of St. Thomas on
+behalf of Jeffrey Epstein or his representatives. I'm sure Dan will have passenger names and where he was being paid
+from. Again the requests originated in many parts of the USA and Los Angeles was one of the more favorite routes. I do
+prefer my name NOT be used if inquiring with Dan, but always happy to discuss with your agency.
+My contact is:
+Michael Lyon
+Lyon Aviation Inc
+Pittsfield Massachusetts
+EFTA00084270
+
+Home - Lyon Aviation - Air Charter Services
+Leading Private jet charter since 1980 with personal attention and
+service; safe, reliable, privately-owned flee...
+EFTA00084271
\ No newline at end of file
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@@ -0,0 +1,18 @@
+From:
+To:
+(USANYS)" <
+USANYS)
+[Contractor]" <
+(USANYS)"
+Bcc:
+Subject: FW: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Affidavit
+Date: Tue, 06 Oct 2020 23:49:13 +0000
+Embedded: FW: _Activity_in_Case_1:20-cr-00330-AJN_USA_v. Maxwell_Affidavit.msg
+Sender:
+Subject: FW: Activity in Case 1:20-cт-00330-AJN USA v. Maxwell Affidavit
+Message-Id:
+To:
+To:
+To:
+DUTLOOK.COM>
+EFTA00104551
\ No newline at end of file
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+}
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@@ -0,0 +1,61 @@
+To:
+From:
+Sent:
+jeeproject @yahoo.com|
+G. Max|
+Sat 1/1/4501 5:00:00 AM (UTC)
+Subject: I rang her to see if she had seen anyone for you - this is her reply - want to do anything w/it /her
+
+
+‹blockquote type=cite class=cite cite>to:
+From: "G. Max" <l
+Subject: Re: see you in new york
+<
+sgt;
+uk>
+At 03:50 PM 2/7/2004 -0600, you wrote:
+‹blockquote type=cite class=cite cite›hi ghislaine,
+it was good to hear from you the other day anbsp; i thought i'd fill you in on my situation and see how
+we can work together.
+
+i am still dancing, anbsp; pilates-ing and teaching. i am very interested to keep training jeffery as we
+work well together and i enjoy working with him.
+I understand he likes to work with a variety of beautiful, talented young women and i think that training
+with lots of people can be a very good thing. inbsp; i understand what i am looking for in other people to
+train / work with him,
+and it's quite a tali order, which is why i know that you need some help you find
+people. anbsp; they don't come along every day.
+
+i need to use my time effectively; to continue with my dance classes, learning, training and also earning
+money to pay for it all,
+if 1 am looking for girls i will need to go to a wide variety of classes, whereas at the moment i tend to
+stick to the one's i like. (not necessarily the one's to find suitable girls).
+
+so if you want me to be actively looking, then we will need to reach a financial arrangement as this will
+be my job. or if you just want me to let you know if i come across someone suitable on my travels, then
+what will you pay me for this? as
+i am effectively 'doing myself out of a job'.
+
+i would just like to have a good idea of where i stand, and if i will be getting more work from you, or
+if you can put me in touch with other people who may want a trainer. or if i can make 'looking for other
+people' my main source of income.
+
+as i am here properly now, i have bills and rent to pay, i need to find something somewhat stable.
+
+i can be available to travel, but if i am 'on call' i need to know and be paid accordingly,
+
+i have a couple of girls in mind, so let me know what arrangement we will have, and i will do my
+best to help.
+i am appreciative of any work you can throw my way.
+i look forward to seeing
+you
+you're back in nyc. give my best to rainy england!
+
+love
+
+X
+br>
+.s. do you want a lesson?
wrote:
+There is an article in the Daily News re: the MCC tapes, which states that | US Attorney Spokesman confirmed
+the stunning revelation that the footage was not preserved. Do you know what this refers to?
+Co-Chief, Narcotics Unit
+From:
+To:
+Cc:
+(USANYS) [Contractor] <
+Sent: Wednesday, December 18, 2019 5:22 PM
+(USANYS) <
+(USANYS) <
+(USANYS) 4
+(USANYS) <
+(USANYS) <
+_(USANYS) Y
+[USANYS) <
+Subject: RE: question about Tartaglione and Epstein; video from MCC
+(USANYS) •
+EFTA00079509
+
+Got it. Thanks.
+From:
+(USANYS) {
+Sent: Wednesday, December 18, 2019 5:21 PM
+To:
+(USANYS) [Contractor] ‹
+Cc:
+(USANYS) <
+(USANYS) <
+P:
+(USANYS) <
+(USANYS) <
+(USANYS) <
+_ (USANYS) 4
+KUSANYS) ‹
+Subject: Re: question about Tartaglione and Epstein; video from MCC
+No. Since he was there, he knows that after we provided that initial response to defense, they told us it was their
+understanding that it was preserved. The judge asked us to look into it which we said we were in the processing of
+doing.
+Co-Chief, Narcotics Unit
+On Dec 18, 2019, at 17:00
+|(USANYS) [Contractor] <
+> wrote:
+Jon Bandler of Lohud was at the Tartaglione and is seeking clarification on something that came up about Epstein
+when Tartaglione was his cellmate. Any guidance we can provide?
+From: Bandler, Jonathan <
+Sent: Wednesday, December 18, 2019 4:23 PM
+To:
+(USANYS) [Contractor] <
+(USANYS)
+Subject:
+Hi. I was in court this afternoon on Tartaglione and peripherally his lawyer raised the fact that it doesn't appear that
+any video was preserved of the cell from Epstein's earlier attempted suicide.
+I'd like to have clarified
+response. He told the judge: "It's our understanding...that the video no
+longer exists, it was not preserved."
+Does that mean there was video but there is no longer?
+Have all avenues at restoring/preserving video from outside that cell been exhausted?
+Thanks
+Jon
+EFTA00079510
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/b76608e38d83fa74be453ee61b4342cd331313a8193a047250072f7acc32d8c7.md b/vision-joined/ds9-parsed-01/b76608e38d83fa74be453ee61b4342cd331313a8193a047250072f7acc32d8c7.md
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@@ -0,0 +1,121 @@
+UNITED STATES ATTORNEY'S OFFICE
+Southern District of New York
+U.S. ATTORNEY GEOFFREY S. BERMAN
+FOR IMMEDIATE RELEASE
+Tuesday, November 19, 2019
+http://www.justice.gov/usao/nys
+CONTACT: U.S. ATTORNEY'S OFFICE
+Jim Margolin, Nicholas Biase
+(212) 637-2600
+DOJ OIG
+FBI
+Martin Feely, Adrienne Senatore,
+Amy Thoreson
+(212) 384-2100
+CORRECTIONAL OFFICERS CHARGED WITH FALSIFYING RECORDS
+ON AUGUST 9T" AND 10T' AT THE METROPOLITAN
+CORRECTIONAL CENTER
+Defendants Allegedly Created Records Falsely Attesting to Required Checks of Inmates the
+Defendants Never Did in the Special Housing Unit on the Night Inmate Jeffrey Epstein
+Committed Suicide
+Geoffrey S. Berman, the United States Attorney for the Southern District of New York,
+Michael Horowitz, Inspector General for the Department of Justice ("DOJ OIG"), and William
+F. Sweeney Jr., Assistant Director-in-Charge of the New York Field Office of the Federal
+Bureau of Investigation ("FBI"), announced today the unsealing of an indictment charging
+federal correctional officers TOVA NOEL and MICHAEL THOMAS with making false records
+and conspiring to make false records and to defraud the United States by impairing the lawful
+functions of the Metropolitan Correctional Center ("MCC"), a Manhattan detention facility that
+houses federal inmates. NOEL and THOMAS surrendered this morning. The case is assigned to
+Southern District of New York U.S. District Judge
+U.S. Attorney Geoffrey S. Berman said: "As alleged, the defendants had a duty to ensure
+the safety and security of federal inmates in their care at the Metropolitan Correctional Center.
+Instead, they repeatedly failed to conduct mandated checks on inmates, and lied on official forms
+to hide their dereliction. These defendants will now be held accountable for shirking their
+responsibilities and concealing their conduct."
+Inspector General Michael Horowitz said:
+FBI Assistant Director William F. Sweeney Jr. said:
+EFTA00106012
+
+According to the Indictment' filed today in Manhattan federal court:
+On August 10, 2019, NOEL and THOMAS repeatedly failed to complete mandated
+counts of prisoners under their watch in the MCC's Special Housing Unit ("SHU"). Instead, for
+substantial portions of their shifts, NOEL and THOMAS sat at their desk, browsed the internet,
+and moved around the common area of the SHU. To conceal their failure to perform their duties,
+NOEL and THOMAS repeatedly signed false certifications attesting to having conducted
+multiple counts of inmates that they did not do. As a result of those false statements, the MCC
+believed prisoners in the SHU were being regularly monitored when, in fact, as a result of the
+defendants' conduct, no correctional officer conducted any count or round of the SHU from
+approximately 10:30 p.m. on August 9 until approximately 6:30 a.m. on August 10, at which
+time, NOEL and THOMAS discovered the body of MCC inmate Jeffrey Epstein, who had
+committed suicide while unobserved earlier that morning.
+Background on Relevant Individuals & Entities
+The MCC is a federal administrative detention facility located in Manhattan that is run by
+the Federal Bureau of Prisons. The MCC employs correctional officers, whose primary duty is
+to ensure the care, custody, and control of the inmate population of the MCC. NOEL has been
+employed as a correctional officer at the MCC since approximately 2016, and THOMAS has
+been employed as a correctional officer at the MCC since approximately 2007. Both NOEL and
+THOMAS were regularly assigned to work shifts in the SHU at the MCC.
+Correctional officers assigned to guard inmates in the SHU - and throughout the MCC -
+are required to conduct institution-wide counts of inmates at regular, scheduled intervals to
+ensure that each inmate is alive and accounted for within the MCC. Two officers are required to
+complete the institutional count for each housing unit, including the SHU, and are further
+required to document their performance of the count on an official MCC form called a count slip.
+In addition to the institutional count, MCC correctional officers assigned to the SHU are required
+to complete rounds every thirty minutes to ensure that each inmate is alive and accounted for
+within his cell. Correctional officers working in the SHU are required to complete a form
+documenting the date and time of each 30-minute round in each area of the SHU.
+Un July o, 2019, Epstein was arrested and detained at the MCC on sex trafficking
+charges, and was subsequently assigned to the SHU due to risk factors for suicidality and safety
+concerns. After an apparent suicide attempt on July 23, 2019, Epstein was transferred to suicide
+watch and then psychological observation. Upon being moved back to the SHU on July 30,
+2019, the MCC took steps to guard against future suicide attempts by Epstein, including by
+assigning Epstein to the cell closest to the correctional officers' desk. Conducting the required
+institutional counts and thirty-minute rounds in the SHU were also part of the MCC's procedures
+for ensuring the safety of inmates, including Epstein.
+The Events of August 9-10, 2019
+On August 9, 2019, NOEL was assigned to work in the SHU from 4:00 p.m. on August 9,
+' As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment
+set forth herein, constitute only allegations, and every fact described therein should be treated as an allegation.
+EFTA00106013
+
+2019, to 8:00 a.m. on August 10, 2019. THOMAS was assigned to work with NOEL in the SHU
+from 12:00 a.m. until 8:00 a.m. on August 10, 2019. From 4:00 p.m. on August 9 to 8:00 a.m.
+on August 10, the officers on duty in the SHU, including NOEL and THOMAS, were
+responsible for conducting five institutional counts at 4:00 p.m. and 10:00 p.m. on August 9, and
+at 12:00 a.m., 3:00 a.m., and 5:00 a.m. on August 10. NOEL and THOMAS were also
+responsible for completing forms attesting to the completion of each of those counts. In fact,
+NOEL, and then NOEL and THOMAS, repeatedly failed to complete mandated counts in the
+SHU. Instead for substantial portions of their 12:00-8:00 a.m. shifts, NOEL and THOMAS sat at
+their desk, browsed the internet, and moved around the common area of the SHU. During that
+time period, NOEL and THOMAS were the only correctional officers assigned to the SHU.
+Aside from two other officers who briefly visited the common area of the SHU, as confirmed by
+video surveillance, no one else entered the SHU, no one conducted any counts or rounds
+throughout the night, and no one entered the area in which Epstein was housed.
+To conceal their failure to complete their duties, NOEL signed false certifications
+attesting to having conducted counts of inmates at 4:00 p.m. and 10:00 p.m., and NOEL and
+THOMAS signed false certifications attesting to having conducted counts of inmates at 12:00
+a.m., 3:00 a.m., and 5:00 a.m. when, in truth and in fact, they never conducted such counts. As a
+result of those false reports, the MCC believed prisoners in the SHU were being regularly
+monitored and accounted for when, in fact, no correctional officer conducted any count or round
+of the SHU from approximately 10:30 p.m. on August 9 until approximately 6:30 a.m. on August
+10, at which time, NOEL and THOMAS discovered the body of Epstein, who had committed
+suicide by hanging himself earlier that morning while unobserved.
+*
+NOEL, 31, and THOMAS, 41, are each charged with one count of conspiring to defraud
+the United States by impairing, obstructing, and defeating the lawful functions of the MCC, and
+to make false records, which carries a maximum sentence of five years in prison. NOEL is also
+charged with five counts of making false records, and THOMAS is also charged with three
+counts of making false records, each of which carries a maximum sentence of five years in
+prison.
+The statutory maximum and mandatory penalties are prescribed by Congress and are
+provided here for informational purposes only, as any sentencing of the defendants would be
+determined by the judge.
+Mr. Berman praised the outstanding investigative work of the Office of the Inspector
+General and the FBI.
+This case is being handled by the Office's Public Corruption Unit. Assistant U.S.
+Attorneys Rebekah Donaleski and Nicolas Roos are in charge of the prosecution.
+The charges contained in the Indictment are merely accusations. The defendants are
+presumed innocent unless and until proven guilty.
+19-XXX
+###
+EFTA00106014
\ No newline at end of file
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+CDR
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+LENE DO HOT CROSS
+CRIME SCENE DO LOT CROSS
+SCENE DO NOT CROSS
+CRIME SCENE DO BOT CROSS
+
+09800000 ANdS
+EFTA00060294
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@@ -0,0 +1,321 @@
+From: "Stoddart, Allison" < Allison.Stoddart@wilmerhale.com>
+To: '
+Cc: "Sahni, Anjan"
+Cc: Sahni, Anjan ;
+(USANYS) <
+Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+EXTERNAL SENDER
+Hi Allison,
+In addition to the records we've been discussing, we'd also like to request account ownership documents for account #
+Q78859008. I'm available for a call today if it would be helpful to discuss that before our meeting this evening.
+Thanks,
+Alison
+From: Stoddart, Allison
+Sent: Saturday, November 20, 2021 4:53 PM
+To:
+Cc: Sahni, Anjan
+Cc: Sahni, Anjan ;
+(USANYS) <
+EFTA00068520
+
+Pil
+Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+EXTERNAL SENDER
+Hi Allison,
+Thanks very much for following up on this. I'm free for a call at any point after 12 p.m. tomorrow.
+Thanks,
+Alison
+From: Stoddart, Allison
+Sent: Saturday, November 20, 2021 11:48 AM
+To:
+Cc: Sahni, Anjan ;
+(USANYS) <
+Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Hi Alison,
+Apologies for the email over the weekend. We were wondering if you have time for a quick call tomorrow to follow up on
+our Wednesday meeting. Let us know if there are some times that might work.
+Thanks,
+Allison
+From:
+Sent: Friday, November 19, 2021 5:33 PM
+To: Stoddart, Allison
+Cc: Sahni, Anjan ;
+(USANYS) <|
+P;
+Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+EXTERNAL SENDER
+Hi Allison,
+Thanks very much. Let me look into it, and I'll let you know if Zoom is an issue, but otherwise let's plan for that.
+Best,
+Alison
+From: Stoddart, Allison
+Sent: Friday, November 19, 2021 11:51 AM
+To:
+Cc: Sahni, Anjan
+Cc: Sahni, Anjan ; l
+P;
+(USANYS) 4|
+Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+EXTERNAL SENDER
+Thanks, yes. Let's plan to meet at 7. I'm heading to court now and will circulate a webex invitation later today. Thanks very
+much.
+From: Stoddart, Allison
+Sent: Wednesday, November 17, 2021 8:15 AM
+To:
+Cc: Sahni, Anjan ;
+(USANYS) <|
+1<
+Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Alison -
+Does tonight still work for a call with Pat? I know you're tied up during the day, but he is available from 6-9pm tonight.
+Thanks,
+Allison
+From: Stoddart, Allison
+Sent: Monday, November 15, 2021 6:20 PM
+To: "
+Cc: Sahni, Anjan ;
+(USANYS) <|
+Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Thanks, Alison. Pat has been traveling, but returning tomorrow. I'll pass your schedule along, and I expect to get back to
+you tomorrow with some possible times.
+Thanks,
+EFTA00068522
+
+Allison
+From:
+Sent: Monday, November 15, 2021 6:16 PM
+To: Stoddart, Allison
+Cc: Sahni, Anjan
+Sent: Wednesday, November 10, 2021 8:35 PM
+To:
+Cc: Sahni, Anjan ;
+(USANYS) <|
+Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Hi Alison,
+Apologies for not responding sooner. I am still trying to confirm timing, but looking at next week, not tomorrow.
+Thanks,
+Allison
+From:
+Sent: Wednesday, November 10, 2021 7:48 PM
+To: Stoddart, Allison
+Cc: Sahni, Anjan ;
+(USANYS) <
+Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+EXTERNAL SENDER
+Hi Allison,
+Just checking in on timing, in case we're meeting tomorrow. If not, no worries, next week is fine.
+Thanks,
+EFTA00068523
+
+Alison
+From: Stoddart, Allison
+Sent: Tuesday, November 9, 2021 8:43 PM
+To:
+Cc: Sahni, Anjan
+Cc: Sahni, Anjan ;L
+P;
+(USANYS) <
+Subject: Re: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+EXTERNAL SENDER
+Are there times on Thursday afternoon or evening that would work? I can move a few things around if he is available.
+Otherwise, I'm available anytime next week in the the morning from 7:30-8:30, or in the evening from 5:30 p.m. onwards,
+or anytime on the weekend. Thanks very much for your help arranging the meeting.
+On Nov 9, 2021, at 7:23 PM, Stoddart, Allison wrote:
+Thanks, Alison. Pat is traveling on Friday and Monday unfortunately. I know jury selection is scheduled to be underway
+next week, but if tomorrow doesn't work, would there be times next week that might?
+Thanks,
+Allison
+From:
+Sent: Tuesday, November 9, 2021 6:32 PM
+To: Stoddart, Allison
+Cc: Sahni, Anjan ;
+(USANYS) ‹
+P:
+Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+EXTERNAL SENDER
+Thanks very much. We'll be in court most of the day for a hearing tomorrow, but is there a time on Friday that would
+Hi Allison,
+work?
+EFTA00068524
+
+Thanks,
+Alison
+From: Stoddart, Allison
+Sent: Tuesday, November 9, 2021 3:50 PM
+To:
+Cc: Sahni, Anjan ;
+(USANYS) 4|
+1 <
+Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Hi Alison,
+When we last spoke, we discussed setting up a call with your team and Pat McHugh. Would tomorrow afternoon work
+for that call?
+Thanks very much,
+Allison
+From:
+Sent: Wednesday, October 27, 2021 9:02 AM
+To: Stoddart, Allison
+Cc: Sahni, Anjan ;
+(USANYS) <
+Pil
+Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+EXTERNAL SENDER
+Hi Allison,
+Thanks— would 3 p.m. work for a call today?
+From: Stoddart, Allison
+Sent: Wednesday, October 27, 2021 7:48 AM
+To:
+Cc: Sahni, Anjan ;
+(USANYS) ‹
+Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Hi Alison,
+We wanted to provide an update on the trial witness topic. Do you have any time this afternoon or tomorrow for a brief
+call?
+Thanks,
+Allison
+From: Stoddart, Allison
+Sent: Monday, October 18, 2021 9:05 PM
+To:
+Cc: Sahni, Anjan ;
+(USANYS) <
+EFTA00068525
+
+PiC
+Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Great. Thanks, Alison. Appreciate it.
+Allison
+From:
+Sent: Monday, October 18, 2021 8:58 PM
+To: Stoddart, Allison
+Cc: Sahni, Anjan ;
+(USANYS) <
+P;
+Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+EXTERNAL SENDER
+Hi Allison,
+Thanks, that's not a problem. I'm attaching a broadly worded subpoena to the bank, but please let me know if you'd like
+me to direct this more specifically to a particular entity or officer.
+Thanks,
+Alison
+From: Stoddart, Allison
+Sent: Monday, October 18, 2021 8:57 AM
+To:
+Cc: Sahni, Anjan ;|
+(USANYS) Y
+1 <
+P:
+Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Alison, Maurene, Lara,
+Following up on our last discussion, JPMorgan is working on identifying a witness for trial. Are you able to provide
+JPMorgan with a trial appearance subpoena?
+Thanks very much,
+Allison
+Allison Stoddart | WilmerHale
+7 World Trade Center
+250 Greenwich Street
+New York, NY 10007 USA
++1 212 295 6401 (t)
+allison.stoddart@wilmerhale.com
+From:
+Sent: Friday, October 8, 2021 12:15 PM
+To: Stoddart, Allison
+Cc: Sahni, Anjan < Anjan.Sahni@wilmerhale.com>;
+(USANYS) <
+EFTA00068526
+
+1<
+Pil
+Subject: Re: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+EXTERNAL SENDER
+Hi Allison,
+I'm traveling for work for much of next week, but I'm available for a call anytime on Monday, or at 9 a.m. on Tuesday. I'm
+also available for a call this afternoon anytime from 4 pm onwards if that's easier.
+Thanks.
+On Oct 8, 2021, at 11:18 AM, Stoddart, Allison wrote:
+Thanks, Alison. Could we find some time early next week to discuss? Are there certain windows that would work on
+your end?
+Thanks,
+Allison
+Allison Stoddart | WilmerHale
+7 World Trade Center
+250 Greenwich Street
+New York, NY 10007 USA
++1 212 295 6401 (t)
+allison.stoddart@wilmerhale.com
+From:
+Sent: Friday, October 8, 2021 10:01 AM
+To: Sahni, Anjan ; Stoddart, Allison < Allison.Stoddart@wilmerhale.com>
+Cc:|
+(USANYS) <
+Subject: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+EXTERNAL SENDER
+Anjan, Allison,
+Hope you're both doing well. Following up on our last conversation, we wanted to send along a few documents in
+order to facilitate our conversation about identifying an appropriate witness from JP Morgan. Attached is a zip file
+containing a few draft exhibits. We are still working on finalizing exhibits, but we thought it made sense to start the
+conversation about this sooner rather than later. Please let us know if you have any questions or if a call would be
+useful.
+Thanks,
+Alison
+EFTA00068527
+
+Assistant United States Attorney
+Southern District of New York
+One Saint Andrew's Plaza
+New York, NY 10007
+(212) 637-2225
+EFTA00068528
\ No newline at end of file
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@@ -0,0 +1,8 @@
+I/M companion assumed duties from staff on 7/23/19 @ 7 am until 7/24/19 @ 8: 45 am (S/W)
+Epstein was transferred to psych observation on 7/24/19 @ 8:45 am until 7/30/19 at 8:15 am (I/M companion was utilized).
+Associate Warden
+MCC New York
+New York. NY 10007
+CONFIDENTIAL
+SDNY_00009685
+EFTA00139396
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+ "sha": "b7f19e59493ade216578574ceedf5ed705e872f138a04d4638ae5d955d9d4f43"
+}
diff --git a/vision-joined/ds9-parsed-01/b7f19e59493ade216578574ceedf5ed705e872f138a04d4638ae5d955d9d4f43.md b/vision-joined/ds9-parsed-01/b7f19e59493ade216578574ceedf5ed705e872f138a04d4638ae5d955d9d4f43.md
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+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+In Re Grand Jury Subpoena,
+19 Misc. 149 (CM)
+Conference
+New York, N.Y.
+April 9, 2019
+11:45 a.m.
+Before:
+HON. COLLEEN MCMAHON,
+Chief District Judge
+APPEARANCES
+GEOFFREY S.
+BERMAN
+United States Attorney for the
+Southern District of New York
+Assistant United States Attorney
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212)
+805-0300
+EFTA00072627
+
+1
+2
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+THE COURT: This is 19 Misc. 149, In Re Grand Jury
+Subpoena. I've had one conference with the government in this
+matter. You want to put your appearance on the record.
+MR.
+- Yes. Good morning, your Honor.
+for the government.
+THE COURT: Mr.
+I now know a lot more
+about what's going on than I did the last time we were
+together. My question is this: I'll be very up-front with
+you. I want to make sure I'm not in a Chemical Bank kind of
+situation, so I would like to know about contacts between the
+United States Attorney's Office and the Boies Schiller firm
+prior to the issuance of the subpoena on the subject of your
+investigation.
+MR.
+- Yes, your Honor. So with respect to
+this investigation, the investigation was opened in late
+November or early December, either on Friday, November 30, or
+Monday, December 3.
+THE COURT: OK.
+MR.
+: In the initial days and weeks of the
+investigation, we endeavored to identify information about the
+subject of the investigation, including, among other things,
+possible victims who we should speak to. In the process of
+doing so, we identified certain counsel that were identified as
+representing victims or witnesses either in public filings or
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+EFTA00072628
+
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+in media reports. Boies Schiller was among those plaintiff
+attorneys. So following the opening of the investigation, we
+were in touch with Boies Schiller, among other plaintiff and
+witness counsel, in connection with their representation of
+witnesses or victims.
+With respect to Boies Schiller in particular, we
+quickly came to learn during the investigation that they had at
+the time either active or recently completed civil litigation
+and so asked them, as is our standard practice, told them, I
+should say, that we expected to make document requests. They
+generally advised us that they believed there was a protective
+order that would govern at least some of the materials, and
+that is why we ultimately made the application to the Court.
+THE COURT: OK. That's all I needed to know. I want
+to make two little changes in this opinion, and if you come
+back in an hour, you'll have it.
+MR.
+THE COURT: All right.
+MR.
+Thank you, your Honor.
+THE COURT: And we are granting your request.
+MR.
+Understood. Thank you, your Honor.
+THE COURT: OK.
+(Adjourned)
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+EFTA00072629
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/b859649d10880acacad030c3a12bb03ebc9ab25fc617444ba230f66afa03b50b.md b/vision-joined/ds9-parsed-01/b859649d10880acacad030c3a12bb03ebc9ab25fc617444ba230f66afa03b50b.md
new file mode 100644
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@@ -0,0 +1,50 @@
+From: "I
+To: "l
+Ce: "l
+(USANYS)" ≤
+(USANYS)" ≤
+(USANYS)" ≤
+(USANYS)"
+(USANYS)" <
+Subject: Re: Epstein FOIA Update
+Date: Sat, 10 Apr 2021 13:07:48 +0000
+Sounds good. Thanks,
+Sent from my iPhone
+On Apr 10, 2021, at 8:29 AM,
+| (USANYS) 4
+> wrote:
+Thanks,
+. Will review the transcript and then we can find a time to meet early in the week. It may make
+sense to meet first as a smaller group with you/
+the substantive case teams.
+i to best understand the lay of the land and then loop in
+Sent from my iPhone
+On Apr 9, 2021, at 7:21 PM,
+| (USANYS) <
+→ wrote:
+All,
+I'm writing to bring everyone up to speed in the Epstein FOIA. We had a pretty rough, approximately 2 hour oral
+argument today before Judge Engelmayer. It may be easier to share the transcript (which I have same-day ordered and
+will circulate once received) and/or to talk things through on a call. In sum, the Court is very skeptical of the breadth of
+the 7(A) withholdings here and will enter an Order on Monday directing that the withheld documents be produced to
+the Court for in camera review. In connection with that, the Court will direct that any material withheld under 7(A) in
+connection with the Tartaglione case be specifically marked out as such (as compared to the broader set of material
+withheld on account of its likelihood of interference with Noel). Basically, the Court has concerns that too much has
+been withheld on the theory of interference with the criminal cases and will undertake its own assessment of the
+withholding of the documents.
+The Court was also interested in exactly how much of the withheld materials have been produced to the Noel
+defendants under Rule 16, and it sounds like it will ask us to make specific representations about precisely which
+documents have been produced in Noel.
+Also, as you will see from the transcript, the Court directed that I communicate to Audrey that he wants her to
+consider this case and to evaluate whether it is necessary to confer with Main Justice on the FOIA response here
+(specifically whether more documents might be produced on reconsideration). In particular, the Court perceived a
+possibility that the recent change in administration could have some bearing on this. I plan to communicate this to
+Audrey as soon as we have the transcript (I've asked for that piece of it tonight).
+EFTA00072513
+
+As noted I will follow up once I have the transcript and will also circulate the Court's Order when it comes out on
+Monday. I think it would probably make sense to have a call thereafter and will circulate an invite for early next week. I
+am also available to speak over the weekend if anyone would like to talk sooner.
+Thanks,
+Assistant United States Attorney
+EFTA00072514
\ No newline at end of file
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@@ -0,0 +1,28 @@
+From:
+To: "Tyrrell, Edward (USANYS)" <
+Cc: "
+Subject: RE: travel approval request
+Date: Thu, 04 Apr 2019 00:02:31 +0000
+Importance: Normal
+Ed,
+For the same case as below, United States v. Epstein, 2018R01618, an investigation relating to enticement of minors for
+sexual activity, Alison and I would like to please request permission to travel for approximately three days next week for
+meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down Tuesday night and
+return on Friday, though we will shorten the timeframe if scheduling allows.
+Please let us know if any other information would be helpful, and thanks very much.
+Alex.
+From: |
+Sent: Thursday, March 14, 2019 18:32
+To: Tyrrell, Edward (USANYS) 4
+Cc:
+Subject: travel approval request
+Ed,
+| and I would like to please request permission for travel for United States v. Epstein, 201801618, an
+investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West Palm
+Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return on Saturday.
+Please let us know if any other information would be helpful, and thanks as always.
+Alex.
+Assistant U.S. Attorney
+Southern District of New York
+212.637.2415
+EFTA00067127
\ No newline at end of file
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+AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant
+UNITED STATES DISTRICT COURT
+for the
+Southern District of New York
+In the Matter of the Search of
+Case No.
+See Attachment A
+)
+)
+SEARCH AND SEIZURE WARRANT
+To:
+Any authorized law enforcement officer
+An application by a federal law enforcement officer or an attorney for the government requests the search
+of the following person or property located in the
+Southern
+District of
+New York
+(identify the person or describe the property to be searched and give its location):
+See Attachment A
+The person or property to be searched, described above, is believed to conceal (identify the person or describe the property
+to be seized):
+See Attachment A
+The search and seizure are related to violation(s) of (insert statutory citations):
+Title 18, United States Code, Sections 371 and 1591
+I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
+property.
+YOU ARE COMMANDED to execute this warrant on or before
+July 21, 2019
+• in the daytime 6:00 a.m. to 10 p.m.
+of at any time in the day or night as I find reasonal cause has been
+established.
+Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
+taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
+place where the property was taken.
+The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
+inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
+• Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court. _
+USMJ Initials
+• I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
+of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
+searched or seized (check the appropriate box) •for
+days (not to exceed 30).
+Duntil, the facts justifying, the later specific date of
+Date and time issued:
+City and state:
+New York, NY
+Judge's signature
+Hon. Barbara Moses, U.S. Magistrate Judge
+Printed name and title
+EFTA00100423
+
+AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)
+Return
+Date and time warrant executed:
+Case No.:
+Inventory made in the presence of :
+Inventory of the property taken and name of any person(s) seized:
+Copy of warrant and inventory left with:
+Certification
+I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
+to the Court.
+Date:
+Executing officer's signature
+Printed name and title
+EFTA00100424
+
+ATTACHMENT A
+1. The Subject Devices to Be Searched
+The Subject Devices are particularly described as compact discs stored in containers
+marked with FBI evidence numbers 15, 16, 17, 18, and 22, seized from the residence located at 9
+East 71st Street, New York, New York, on or about July 7, 2019.
+II. Items to Be Seized
+A. Evidence, Fruits, and Instrumentalities of the Subject Offenses
+This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of
+violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors), and 371 (sex
+trafficking conspiracy) (the "Subject Offenses") described as follows:
+1.
+of the Subject Offenses;
+Any documents or communications with or regarding victims or potential victims
+2. Any photographs of victims or potential victims of the Subject Offenses;
+3.
+Any nude, partially nude, or sexually suggestive photographs of individuals who
+appear to be teenage girls, or younger;
+Motion pictures, films, videos, and other recordings of visual or written depictions
+of minors engaged in sexually explicit conduct, as defined in 18 U.S.C. § 2256(2);
+Kecords or other items that evidence ownership, control, or use of, or access to
+devices, storage media, and related electronic equipment used to access, transmit, or store
+information relating to the Subject Offenses, including, but not limited to, sales receipts,
+warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved
+usernames and passwords, user profiles, e-mail contacts, and photographs;
+6.
+Any child erotica, defined as suggestive visual depictions of nude minors that do
+not constitute child pornography as defined by 18 U.S.C. § 2256(8).
+B. Review of ESI
+Law enforcement personnel (including, in addition to law enforcement officers and agents,
+ind depending on the nature of the ESt and the status of the investigation and related proceedings
+ttorneys for the government, attorney support staff, agency personnel assisting the government i
+this investigation, and outside technical experts under government control) will create a forensic
+image of the Subject Devices (if practicable) and review the ESI contained therein for information
+responsive to the warrant.
+In conducting this review, law enforcement personnel may use various techniques to
+determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such
+techniques may include, for example:
+2017.08.02
+EFTA00100425
+
+• surveying directories or folders and the individual files they contain (analogous to
+looking at the outside of a file cabinet for the markings it contains and opening a drawer
+believed to contain pertinent files);
+• conducting a file-by-file review by "opening" or reading the first few "pages" of such
+files in order to determine their precise contents (analogous to performing a cursory
+examination of each document in a file cabinet to determine its relevance);
+• "scanning" storage areas to discover and possibly recover recently deleted data or
+deliberately hidden files; and
+• performing electronic keyword searches through all electronic storage areas to
+determine the existence and location of data potentially related to the subject matter of
+the investigation"; and
+• reviewing metadata, system information, configuration files, registry data, and any
+other information reflecting how, when, and by whom the computer was used
+Law enforcement personnel will make reasonable efforts to search only for files,
+I.A of this Attachment. However, law enforcement personnel are authorized to conduct
+omplete review of all the ESI from seized devices or storage media if necessary to evaluate it
+contents and to locate all data responsive to the warrant.
+• Keyword searches alone are typically inadequate to detect all relevant data. For one thing,
+keyword searches work only for text data, yet many types of files, such as images and videos, do
+not store data as searchable text. Moreover, even as to text data, there may be information properly
+subject to seizure but that is not captured by a keyword search because the information does not
+contain the keywords being searched.
+2
+2017.08.02
+EFTA00100426
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/b8b654a253705c6bbc4378accbcea052a3301361dfd0ef8b66d38e60d9dc27bd.md b/vision-joined/ds9-parsed-01/b8b654a253705c6bbc4378accbcea052a3301361dfd0ef8b66d38e60d9dc27bd.md
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@@ -0,0 +1,50 @@
+From: "
+To: Sigrid McCawley <
+Ce: "l
+(USANYS)" <
+Subject: RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Date: Tue, 04 May 2021 14:00:59 +0000
+Understood - thanks very much for letting us know, Sigrid.
+From: Sigrid McCawley <
+Sent: Tuesday, May 4, 2021 9:18 AM
+To:|
+(USANYS) <
+Cc:
+Subject: RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Just as a follow up. I just heard back from [
+Tand she said her strong preference is as early as possible in the fall - early
+September would be her preference. |
+Land her husband are going through the process of trying to adopt a baby and
+the birth mother is due in early November (and of course babies can sometimes come a bit earlier). The birth mother has
+not finalized the match so this is a fluid situation but
+_wants to make sure she is able to be there when the baby is
+born and of course care for her newborn immediately following the birth. I will keep you updated but C
+strong
+preference is for as early as possible.
+All my best,
+Sigrid
+Sigrid McCawley
+Partner
+BOIES SCHILLER FLEXNER LuP
+www.bsfllp.com
+From: |
+| (USANYS) [mailto:!
+Sent: Monday, May 3, 2021 6:34 PM
+To: Sigrid McCawley 4
+Cc:|
+Subject: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Sigrid,
+]
+P;
+Please see the attached order regarding the trial date in this case. We will update you when we have more information.
+Thanks,
+EFTA00085269
+
+Assistant United States Attorney
+United States Attorney's Office
+The information contained in this electronic message is confidential information intended only for the use of the named recipients) and may contain information that, among
+other protections, is the subject of attomey-client privilege, attomey work product or exempt from disclosure under applicable law. If the reader of this electronic message is not
+the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distribution, copying or other use
+of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this
+electronic message and then deleting this electronic message from your computer. [v. 1 08201831BSF]
+EFTA00085270
\ No newline at end of file
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new file mode 100644
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@@ -0,0 +1,25 @@
+From:
+To:
+Subject: Monday AM Suicide Watch/Psych Observation Update
+Date: Mon, 29 Jul 2019 11:29:25 + 0000
+Importance: Normal
+Monday AM Suicide Watch/Psych Observation Update
+Suicide Watch
+None
+Psych Observation
+EFTA00140692
+
+1. Epstein #76318-054
+Pending Bedspace for SHU
+1. Lopez #20472-038
+Very respectfully,
+Forensic Psychologist
+LT, U.S. Public Health Service
+U.S. Department of Justice
+Federal Bureau of Prisons
+Metropolitan Correctional Center
+150 Park Row
+New York, New York 10007
+"This message is intended for official use and may contain SENSITIVE information. If this message contains SENSITIVE
+information, it should be properly delivered, labeled, stored, and disposed of according to policy."
+EFTA00140693
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/b93c88f5e9f0c817f2cf136bd84946d7b6ad8f34a8e27f76fd60a3a26b267785.md b/vision-joined/ds9-parsed-01/b93c88f5e9f0c817f2cf136bd84946d7b6ad8f34a8e27f76fd60a3a26b267785.md
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@@ -0,0 +1,228 @@
+FD-302 (Rev. 5-8-10)
+- 1 of 5-
+FEDERAL BUREAU OF INVESTIGATION
+, OFFICIAL RECORD
+- Decumini purlic ants home digitally signed
+( All sigrades have been vailed by a
+Date of entry
+01/13/2021
+DAVID MULLEN was interviewed via video conference. Present on the video
+call was Assistant United States Attorneys
+and
+along with Paralegal
+. Detective
+and Special Agent
+. After being advised of the identities of the above listed
+individuals and the nature of the interview, MULLEN provided the following
+information:
+MULLEN had received a type written letter from the media but threw it
+away.
+MULLEN had worked at a restaurant "DANIEL" right down the street from
+JEFFREY EPSTEIN's residence. MULLEN had talked with a headhunter and wanted
+to leave working at the restaurant. This was approximately 14/15 years
+ago.
+GHISLAINE MAXWELL contacted MULLEN before he met EPSTEIN. MULLEN met
+MAXWELL at her residence in Manhattan for a tasting. MAXWELL told him
+something like, "We are looking for a chef...traveling cook...cook
+breakfast, lunch, dinner". MULLEN then sat down with EPSTEIN and he offered
+MULLEN the job. MULLEN was given an apartment as part of his salary.
+MULLEN worked for EPSTEIN for approximately 1.5 years before leaving
+approximately 15 years ago.
+EPSTEIN's chef before MULLEN had a BBQ joint in Manhattan. MULLEN
+thought EPSTEIN financed this chef to open the BBQ joint. MULLEN had heard
+from other members of EPSTEIN's staff and MAXWELL that if MULLEN did well,
+EPSTEIN would take care of him.
+MULLEN was required to travel anytime he was asked and to be ready at any
+time. MULLEN did not go to EPSTEIN's Paris residence but flew to France and
+visited friends while there. MULLEN traveled between EPSTEIN's island,
+Zorro Ranch, Palm Beach, and the 71ªt street residence. MULLEN also traveled
+Investigation on 10/29/2020
+at New York, New York, United States (, Other (Video))
+File #
+5OD-NY-3027571
+Date drafted 01/05/2021
+by
+This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency; it and its contents are not
+to be distributed outside your agency.
+EFTA00090348
+
+FD-302a (Rev. 5-8-10)
+50D-NY-3027571
+Continuation of FD-302 of (U) Interview of DAVID MULLEN
+, On
+10/29/2020
+_, Page
+2 of 5
+with EPSTEIN to Martha's Vineyard. The travel was very sporadic. The
+island and Zorro Ranch were set up for the holidays. MULLEN thought that
+they would be there for approximately 3 weeks to a month at a time.
+Working at EPSTEIN's Manhattan residence, MULLEN was there to be on call
+in the downstairs kitchen where the staff lived. MULLEN would make EPSTEIN
+peanut butter and jelly sandwiches and take upstairs to him upon his
+request. MULLEN's work hours were usually 9 to 5. If there were guests,
+MULLEN was responsible for cooking for the luncheon.
+Working on EPSTEIN's island, MULLEN was on call 24/7. MULLEN was
+responsible to cook for guests and any requests. MULLEN would go to the
+main island of St. Thomas via boat for food.
+Working at EPSTEIN's Zorro Ranch in New Mexico, MULLEN stayed at a
+residence a couple miles from the property. MULLEN was responsible for
+cooking breakfast, lunch, and dinner.
+Working at EPSTEIN's Palm Beach residence, MULLEN described it was the
+same routine as working at the other residences.
+When they traveled to Martha's Vineyard they only stayed for a couple of
+hours. MULLEN had stayed with the pilots. MULLEN thought they may have
+been there way to somewhere else.
+MULLEN reported to MAXWELL and she would tell MULLEN "the ropes" like
+where to sit and not sit on the plane and what to do and what not to do.
+There were different house managers at EPSTEIN's different residences who
+would tell MULLEN what to do if there were guests around. MULLEN had very
+little conversations with EPSTEIN. EPSTEIN usually conversed with MULLEN
+when he did not like the food. EPSTEIN was very short with his answers;
+EPSTEIN was not rude to MULLEN. MULLEN also received information from
+and other house staff.
+MAXWELL told MULLEN how to look and how to dress. MAXWELL told MULLEN to
+be ready at any time. MAXWELL told MULLEN not to be late or he would be
+fired. MAXWELL told MULLEN to have anything ready at anytime. There was a
+certain type of bread that MULLEN was responsible for getting while in New
+York. MULLEN was told not to interact and socialize with the guests.
+EFTA00090349
+
+FD-302a (Rev. 5-8-10)
+50D-NY-3027571
+Continuation of FD-302 of (U) Interview of DAVID MULLEN
+, On
+10/29/2020
+, Page
+3 of 5
+MAXWELL let MULLEN know when and where he was supposed to be. MAXWELL
+sometimes traveled with them in the beginning.
+would also have the
+information on where and when MULLEN was supposed to be somewhere. MULLEN
+thought that
+was the main contact person for about 6 to 8 months.
+There would be a car service to take MULLEN to his apartment from
+LaGuardia or New Jersey.
+The New York housekeepers and MULLEN were together in Florida when a
+hurricane happened. They stayed behind then took a commercial airline back.
+When in New York, MULLEN would show up at 9am. MULLEN would check the
+food in the refrigerator and check in with the house people. MULLEN would
+go downstairs and wait for a phone call to prepare food. Sometimes he did
+not get a call. MULLEN would check in at 5pm with the house staff and would
+cook when they wanted something.
+and
+(known to law enforcement
+as
+) would be around more and MULLEN would cook for them.
+From what MULLEN understood,
+was EPSTEIN's girlfriend.
+worked for MAXWELL at MAXWELL's house.
+was a liaison to
+EPSTEIN. There was a shift to
+running the house. This was something
+MULLEN noticed as MAXWELL was not around as much. During the end of MULLEN
+working for EPSTEIN, he did not see MAXWELL.
+MULLEN made lunch for AL GORE. MULLEN also cooked for the former prime
+minister of Israel. MULLEN made lunch for him and flew with him and his
+wife.
+It was known that EPSTEIN would get massages. MULLEN would see traffic
+come in and they would go to another room. Usually after a massage, EPSTEIN
+would want a peanut butter and jelly sandwich or fruit snack. MULLEN was
+told by likely
+or house staff that he would have to have food ready
+at a certain time after a massage. In New York, MULLEN would take the
+elevator to get to the kitchen. MULLEN knew there were massages in New York
+because he was told to have snacks ready. The house was secretive. MULLEN
+would talk to the security guard and he would let MULLEN know if someone was
+coming to the house for food. MULLEN would be downstairs watching TV
+waiting until he was needed. MULLEN was not aware who was making the
+massage appointments. MULLEN saw more people in Florida because they came
+through the kitchen.
+EFTA00090350
+
+FD-302a (Rev. 5-8-10)
+50D-NY-3027571
+Continuation of FD-302 of (U) Interview of DAVID MULLEN
+., On
+10/29/2020
+_, Page
+4 of 5
+When in Florida, MULLEN spent most of the time in EPSTEIN's house.
+MULLEN stayed at the house adjacent to EPSTEIN's main house. MULLEN would
+wake up, make sure there were muffins in the home, and prepare food as
+needed. MULLEN would have to have lunch ready, along with dinner, and have
+10am and/or 3pm snacks ready.
+., and another young woman who
+was around would go to the movies at night. Anyone else that was around
+would also go to the movies. MULLEN was done working after he served
+dinner. A lot of people came in through the door next to the kitchen -
+there were a lot of people who came in for massages. MULLEN was told by
+either
+or house staff that the women were there for a massage.
+Massages were every day in the morning and afternoon. MULLEN stated they
+looked like 18-22-year-old women. All of them appeared to have been coming
+to the house prior to MULLEN working for EPSTEIN as they knew their way
+around the house. MULLEN would make the females something to eat if they
+wanted. The females would leave with the person that brought them. The
+younger people/younger women all knew what to do. MULLEN never saw anyone
+upset and never saw an exchange of cash. MULLEN saw
+set up rides for
+them and show them to where they needed to go. MULLEN saw the same people.
+MULLEN talked with some of them, but his jobs was to be the chef and not
+their friends from what he had been told. MULLEN assumed those that came to
+the house were from Florida; sometimes they came via taxi cab. Sometimes
+there were two ladies at the house, with one upstairs while the other one
+stayed downstairs waiting for the other one. They appeared carefree and
+relaxed. MULLEN thought some of them were "working girls" meaning
+"prostitution". MULLEN based this on their body language and how they
+spoke. This was just a feeling MULLEN had. MULLEN stated, "I mean who gets
+that many massages a day". MULLEN did not think they would be under 18
+years old because he thought if they were younger they would have been at
+school. MULLEN felt they looked like they could get in a bar - if MULLEN
+would have been a bouncer he would have let them into the bar.
+It would be a simple conversation from
+• another woman, or
+house member who would tell MULLEN that people would be visiting or coming
+to give a massage. They would also tell MULLEN when a physical therapist or
+chiropractor was coning to the house.
+• would greet them. MULLEN
+would let
+know via text sometimes
+and
+would direct them
+upstairs.
+MULLEN would see them for about an hour at the house.
+and
+the other woman, who MULLEN described as having a dark complexion and dark
+EFTA00090351
+
+FD-302a (Rev. 5-8-10)
+50D-NY-3027571
+Continuation of FD-302 of (U) Interview of DAVID MULLEN
+, On
+10/29/2020
+, Page
+5 of 5
+hair, would talk with them in the kitchen and walk them upstairs we well.
+, and the other woman were always at the house.
+MULLEN's impression was that EPSTEIN was getting a massage. MULLEN felt
+that a massage every day seemed strange but if a person had that kind of
+money he could do what he wanted, like having them 2 to 3 times a day.
+MULLEN never asked
+about it. There was an appointment book that
+was kept by the phone so MULLEN could see what was going on for the day.
+The phone in the kitchen was rarely used but that was where the appointment
+book was kept. MULLEN did not know who scheduled the appointment.
+MULLEN would have certain muffins and fruit that was always around. When
+a girl came downstairs after a massage, he would make whatever she asked and
+if he had it in the refrigerator.
+Agent Note: At this point in the interview a break was taken. When everyone
+reconvened, MULLEN was confronted about the inconsistencies from this
+interview and his prior interview with the FBI. The interviewing team
+expressed concern to MULLEN over his lack of truthfulness during this
+interview and informed him he had the right to have counsel. MULLEN replied
+that he was trying to be as truthful as possible. MULLEN apologized if his
+answers were different than they were 15 years ago. MULLEN stated he was
+trying to be transparent and wished he never worked for EPSTEIN. MULLEN
+then stated he would like to be supplied with counsel and the interview
+concluded.
+EFTA00090352
\ No newline at end of file
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+SPECIAL HOUSING UNIT
+30 MINUTE CHECK SHEET
+L-TIER
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+7:00-7:30 PM
+7:30-8:00 PM
+8:00-8:30 PM
+8:30-9:00 PM
+9:00-9:30 PM
+9:30-10:00 PM
+10:00-10:30 PM
+10:30-11:00 PM
+11:00-11:30 PM
+11:30-12:00 PM
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+I/Z21134
+DAY WATCH
+OPERATIONS
+LIBUTENANT
+EVENING WATCH
+OPERATIONS
+LIEUTENANT
+A staff member must observe all inmates confined in a continuous locked down status, such as administrative
+detention or disciplinary segregation, at least once in the first 30 minute period of the hour (example, 12:00
+а.m. - 12:30 a.m.) followed by another round in the second 30 minutes period of the same hour (example,
+12:30 am - 1:00 a.m.). thus ensuring an inmate is observed at least twice per hour, These rounds-are to be
+conducted on an irregular schedule and no more than 40 minutes apart. All observations must be
+MCO NEW YORK
+SPECIEL HOUSING UNIT
+SIGNATURE
+REVIEWED BY MORNING WATCH LIEUTENANT
+CAPTAIN
+EFTA00121502
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/b982f80545d5e63dfbe6444d0ca69b17b098fb905179fc82f7d925d473827393.md b/vision-joined/ds9-parsed-01/b982f80545d5e63dfbe6444d0ca69b17b098fb905179fc82f7d925d473827393.md
new file mode 100644
index 0000000000000000000000000000000000000000..b7319b77197aabc013a055c98dc606f416725c95
--- /dev/null
+++ b/vision-joined/ds9-parsed-01/b982f80545d5e63dfbe6444d0ca69b17b098fb905179fc82f7d925d473827393.md
@@ -0,0 +1,27 @@
+To:
+Wed 7/24/2019 1:21:42 PM
+Subject: Wednesday AM Suicide Watch/Psych Observation Update
+Wednesday AM Suicide Watch/Psych Observation Update
+Inmate Epstein #76318-054 is being removed from Suicide Watch and stepped down to Psychological
+Observation.
+Suicide Watch
+None
+Psych Observation
+1. Epstein #76318-054
+Very respectfully,
+Forensic Psychologist
+LT, U.S. Public Health Service
+U.S. Department of Justice
+Federal Bureau of Prisons
+Metropolitan Correctional Center
+CONFIDENTIAL
+8668H
+SDNY_00012895
+
+New York, New York 10007
+"This message is intended for official use and may contain SENSITIVE information. If this message
+contains SENSITIVE information, it should be properly delivered, labeled, stored, and disposed of
+according to policy."
+CONFIDENTIAL
+SDNY_00012896
+EFTA00139988
\ No newline at end of file
diff --git a/vision-joined/ds9-parsed-01/b9a1ef33d40001ff90e0737dbf675f71e896b3d9d8ac2dc48681106d4d17a539.json b/vision-joined/ds9-parsed-01/b9a1ef33d40001ff90e0737dbf675f71e896b3d9d8ac2dc48681106d4d17a539.json
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+ "sha": "b9a1ef33d40001ff90e0737dbf675f71e896b3d9d8ac2dc48681106d4d17a539"
+}
diff --git a/vision-joined/ds9-parsed-01/b9a1ef33d40001ff90e0737dbf675f71e896b3d9d8ac2dc48681106d4d17a539.md b/vision-joined/ds9-parsed-01/b9a1ef33d40001ff90e0737dbf675f71e896b3d9d8ac2dc48681106d4d17a539.md
new file mode 100644
index 0000000000000000000000000000000000000000..69ebdcdfc61484855bf73cfbfa16b90ddb0830d0
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@@ -0,0 +1,169 @@
+From: "Tyrrell, Edward (USANYS)" {
+To: "
+1" <
+Cc: "Duncan, Michele (USANYS)" {
+
+Subject: Re: travel approval request
+Date: Sat, 15 Feb 2020 02:14:47 +0000
+›, "Perez, Cynthia (USANYS)"
+Approved
+Sent from my iPad
+On Feb 14, 2020, at 6:30 PM,
+> wrote:
+Hi Ed,
+Our last interview for this trip to Los Angeles is scheduled for Friday, February 28th. Instead of flying back that
+ight, would it be okay with you if I booked my return flight for Monday? I'd like to stay the weekend in
+'alifornia. The flight prices look the same, and I would of course handle any other expenses from the weeken
+in California on my own.
+Thanks,
+Alison
+Sent from my iPhone
+On Feb 12, 2020, at 10:55 PM, Tyrrell, Edward (USANYS) <
+• wrote:
+Approved
+Sent from my iPad
+On Feb 12, 2020, at 9:14 PM,
+→ wrote:
+Ed,
+Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
+permission for the team to travel next week for three interviews in Los Angeles on February 26, 27, and 28 (we have
+at least one interview on each of those days). We expect to be traveling, respectively, some combination of the 25th
+to the 29th. Also similar to prior trips, we'd like to request approval to get a conference room for one of those dates
+(the 26th).
+thank you,
+Alex.
+EFTA00105407
+
+From:
+Sent: Tuesday, January 21, 2020 14:49
+To: Tyrrell, Edward (USANYS) <
+Cc:
+.Alleyne (
+Subject: RE: travel approval request
+P; Darlene A.
+Ed,
+Similar to prior requests in connection with the Epstein investigation (2018R01618), but with an added international
+element, we'd like to please request permission for the team to travel next week for an interview near Stockholm,
+Sweden, next week on January 29th and/or 30th. We expect to be traveling, respectively, some combination of the
+27th (overnight) to the 31st, depending on when the interview ends up being scheduled, and we'll put final dates on
+our formal applications. Also similar to prior trips, we'd like to request approval to get a conference room for one of
+those days at a hotel for the interview itself.
+Also based on our discussion earlier we'll be mindful of looking for domestic (or domestic-flagged) carrier flights, as
+well as the costs of any alternatives, in looking at possible specific bookings. Thanks as always for your help and
+input on that.
+thank you,
+Alex.
+From: |
+Sent: Wednesday, December 11, 2019 09:58
+To: Tyrrell, Edward (USANYS) 4
+Cc:|
+Alleyne (
+Subject: RE: travel approval request
+P; Darlene A.
+Ed,
+Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
+permission for the team to travel next week for an interview (or possibly interviews) in Los Angeles on December 16
+and/or 17. We expect to be traveling, respectively, some combination of the 15th to the 18th. Also similar to prior
+trips, we'd like to request approval to get a conference room for one of those days.
+thank you,
+Alex.
+From: |
+Sent: Tuesday, November 05, 2019 16:53
+To: Tyrrell, Edward (USANYS) <
+Cc:
+.Alleyne
+Subject: RE: travel approval request
+Ed,
+P; Darlene A.
+Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
+permission for the team to travel next week for an interview in Los Angeles on November 14. We expect to be
+EFTA00105408
+
+traveling, respectively, some combination of the 13th to the 15th (and no conference room necessary for this trip).
+thanks,
+Alex.
+From:
+Sent: Tuesday, October 22, 2019 13:55
+To: Tyrrell, Edward (USANYS) 4
+Cc: Duncan, Michele (USANYS) •
+P:
+P; Darlene A. Alleyne
+Subject: RE: travel approval request
+Ed,
+Similar to prior requests in connection with the Epstein investigation (2018R01618), we'd like to please request
+permission to travel next week for an interview in West Palm Beach on November 4. It will just be me and Maurene,
+and we'll travel some combination of the 3rd to the 5th. And also same as last time, we'd like to ask permission to
+reserve a conference room at the hotel on that Monday for the interview, please.
+thanks very much,
+Alex.
+From:
+Sent: Wednesday, June 12, 2019 14:51
+To: Tyrrell, Edward (USANYS) |
+Cc: Duncan, Michele (USANYS) <
+Subject: RE: travel approval request
+Ed,
+Again in connection with the Epstein investigation (2018R01618), we'd like to please request permission to travel
+next week for a victim interview in Los Angeles. As of now we tentatively expect to fly down Wednesday and return
+no later than Friday (and will keep the timeframe as short as scheduling allows). The trip will be some combination
+of me, Alison, and/or Maurene, as previously. And also same as last time, we'd like to ask permission to reserve a
+conference room at the hotel on Thursday for the interview, please.
+thanks very much,
+Alex.
+From:
+Sent: Friday, May 24, 2019 14:57
+To: Tyrrell, Edward (USANYS) 4
+Cc: Duncan, Michele (USANYS) <
+Subject: RE: travel approval request
+Ed,
+Again in connection with the Epstein investigation, we'd like to please request permission to travel for approximately
+three days next week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to
+EFTA00105409
+
+fly down Tuesday night and return on Wednesday or Thursday (and will keep the timeframe as short as scheduling
+allows).
+Unfortunately we're still trying to pin down timing for interviewing the victims, so depending on the timing it will
+either be me and Alison or Alison and Maurene, but we wanted to ask for permission now either way so we weren't
+doing it super last minute after the holiday on Tuesday. And also same as last time, we'd like to ask permission to
+reserve a conference room at the hotel for the interviews, please.
+thanks very much,
+Alex.
+From:
+Sent: Wednesday, April 03, 2019 20:57
+To: Tyrrell, Edward (USANYS) <
+Subject: RE: travel approval request
+Thank you
+From: Tyrrell, Edward (USANYS) <
+Sent: Wednesday, April 03, 2019 20:46
+To:
+Cc:
+P; Duncan, Michele (USANYS) <
+Subject: Re: travel approval request
+Approved
+Sent from my iPad
+On Apr 3, 2019, at 8:02 PM,
+• wrote:
+Ed,
+For the same case as below, United States v. Epstein, 2018R01618, an investigation relating to enticement of minors
+for sexual activity, Alison and I would like to please request permission to travel for approximately three days next
+week for meetings and interviews in West Palm Beach, Florida. As of now we tentatively expect to fly down
+Tuesday night and return on Friday, though we will shorten the timeframe if scheduling allows.
+Please let us know if any other information would be helpful, and thanks very much.
+Alex.
+From: |
+Sent: Thursday, March 14, 2019 18:32
+To: Tyrrell, Edward (USANYS) ‹
+Cc:|
+Subject: travel approval request
+Ed,
+land I would like to please request permission for travel for United States v. Epstein, 2018R01618, an
+investigation relating to enticement of minors for sexual activity, for two days of meetings and interviews in West
+EFTA00105410
+
+Palm Beach and/or Fort Lauderdale, Florida. As of now we're hoping to fly down next Wednesday night and return
+on Saturday.
+Please let us know if any other information would be helpful, and thanks as always.
+Alex.
+Assistant U.S. Attorney
+Southern District of New York
+212.637.2415
+EFTA00105411
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/b9c3cf4afc393b084a6151d5587b3b1130b3094c1206f1b68e91d0ba7d0768d0.md b/vision-joined/ds9-parsed-01/b9c3cf4afc393b084a6151d5587b3b1130b3094c1206f1b68e91d0ba7d0768d0.md
new file mode 100644
index 0000000000000000000000000000000000000000..9968fba570676f53bf7940649444b603a5a4fb56
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@@ -0,0 +1,15 @@
+From: "
+To:
+[Contractor]" <
+Subject: Images reviewed from device NYC024362
+Date: Fri, 30 Oct 2020 01:21:11 +0000
+Hil
+I ran out of space on my desktop, so I went ahead and loaded the Responsive - Confidential photos and videos from
+device NYC024362 to the share drive. I've saved them here: 1Usa.doj.gov\cloud\NYS|StAndrews)Shared\USvEpstein-
+2018R01618\Investigation\Confidential Images & Videos from Epstein Devices in NY & VI\NYC024362 Responsive Images
+CONFIDENTIAL ONLY
+Would you please make sure all of these files are included with the production of Responsive and Confidential photos and
+videos? And if it's doable, my preference would be to save all of the Responsive - Confidential files from these devices in
+the "Confidential Images & Videos from Epstein Device sin NY & VI" folder on the share, with a subfolder for each device,
+please.
+EFTA00076290
\ No newline at end of file
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@@ -0,0 +1,517 @@
+NITED STATES DISTRICT COUR
+OUTHERN DISTRICT OF NEW YORI
+-- X
+UNITED STATES OF AMERICA,
+V.
+GHISLAINE MAXWELL,
+20 Cr. 330 (AJN)
+Defendant.
+-- X
+MEMORANDUM OF GHISLAINE MAXWELL
+IN SUPPORT OF HER MOTION FOR A SEVERANCE OF AND SEPARATE TRIAL
+ON COUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT
+Jeffrey S. Pagliuca
+Laura A. Menninger
+HADDON, MORGAN & FOREMAN P.C.
+150 East 10th Avenue
+enver, CO 8020
+Phone: 303-831-736
+Mark S. Cohen
+Christian R. Everdell
+COHEN & GRESSER LLP
+800 Third Avenue New
+York, NY 10022
+Phone: 212-957-7600
+Bobbi C. Sternheim
+Law Offices of Bobbi C. Sternheim
+33 West 19th Street - 4th Floor
+New York, NY 10011
+Phone: 212-243-1100
+Attorneys for Ghislaine Maxwell
+EFTA00091875
+
+TABLE OF CONTENTS
+TABLE OF CONTENTS
+TABLE OF AUTHORITIES
+INTRODUCTION
+OVERVIEW OF THE ALLEGATIONS.....
+A. Counts One through Four (the "Mann Act Counts") …
+B. Counts Five and Six (the "Perjury Counts")
+APPLICABLE LAW
+A.
+Joinder of Offenses..
+B.
+Severance of Offenses
+ANALYSIS
+..i
+.. ii
+1
+...2
+.. 2
+... 2
+3
+..3
+..5
+.. 6
+A. The Perjury Counts Are Improperly Joined Under Rule 8(a) and Must Be Severed.
+... 6
+B. The Perjury Counts Should Be Severed Under Rule 14(a) Because Their Inclusion Will
+Substantially Prejudice Ms. Maxwell at Trial
+..9
+CONCLUSION
+13
+Certificate of Service
+15
+EFTA00091876
+
+TABLE OF AUTHORITIES
+Cases
+Drew v. United States, 331 F.2d 85 (D.C. Cir. 1964)..
+..6
+United States v. Blakney, 941 F.2d 114 (2d Cir. 1991)
+4
+United States v. Botti, No. 3:08-cr-00230 (CSH), 2009 WL 3157582 (S.D.N.Y. Sept. 25, 2009)
+• 4,9
+United States v. Bradford, 487 F. Supp. 1093 (D. Conn. 1980).
+United States v. Brown, No. 07-0296-1, 2008 WL 161146 (E.D. Pa. Jan. 16, 2008).
+United States v. Burke, 789 F. Supp. 2d 395 (S.D.N.Y. 2011).
+United States v. Chevalier, 776 F. Supp. 853 (D. Vt. 1991).
+. 5
+4,7
+.. 5, 6, 12
+.. 6
+United States v. Halper, 590 F.2d 422 (2d Cir. 1978).
+United States v. Jackson, 562 F.2d 789 (D.C. Cir. 1977).
+.. passim
+..5
+United States v. Lewis, 626 F.2d 940 (D.C. Cir. 1980) .
+6
+United States v. Martinez, Nos. S2 92 Cr. 839 (SWK), 1993 WL 322768 (S.D.N.Y. Aug. 19,
+1993)
+United States v. Mitan, No. CRIM.A 08-760-01, 2009 WL 2328870 (E.D. Pa. July 28, 2009) 5, 9
+4, 7
+4,8
+United States v. Potamitis, 739 F.2d 784 (2d Cir. 1984)
+United States v. Ramos, No. 06 Cr. 172 (LTS), 2009 WL 1619912
+(S.D.N.Y. Jun. 5, 2009)
+United States v. Randazzo, 80 F.3d 623 (1st Cir. 1996)
+.. 5,6, 11
+4
+United States v. Rivera, 546 F.3d 245 (2d Cir. 2008)..
+.. 4
+United States v. Sampson, 385 F.3d 183 (2d Cir. 2004)
+. 5
+United States v. Turoff, 853 F.2d 1037 (2d Cir. 1988)
+United States v. Walker, 142 F.3d 103 (2d Cir. 1998).
+3, 5,10
+5
+United States v. Werner, 620 F.2d 922 (2d Cir. 1980) ..
+United States v. Winchester, 407 F. Supp. 261 (D. Del. 1975).
+3,4,10
+. 5
+ii
+EFTA00091877
+
+Statutes
+18 U.S.C. $ 1623
+18 U.S.C. § 2422
+18 U.S.C. § 2423(a)
+Rules
+Fed. R. Crim. P. 8(a)
+Fed. R. Crim. P. 14(a).
+Rule of Professional Conduct 3.7
+.. 3
+...2
+.. 2
+- passim
+• passim
+. 14
+ili
+EFTA00091878
+
+INTRODUCTION
+Ms. Maxwell, pursuant to Fed. R. Crim. P. 8(a) and 14, requests that the Court enter an
+order severing Counts Five and Six of the Superseding Indictment ("Indictment") from Counts
+One through Four because these Counts have been improperly joined and a joint trial would
+result in substantial prejudice to Ms. Maxwell.
+Counts Five and Six of the Indictment allege that Ms. Maxwell made materially false
+statements at two civil depositions in 2016 that were part of a defamation action brought against
+her more than twenty years after the conduct alleged in Counts One through Four supposedly
+took place (1994-1997). The plaintiff in the defamation action,
+made
+wild and false accusations that she had been sexually trafficked by Epstein and Ms. Maxwell to
+dozens of famous politicians, professors, foreign leaders, and others. When Ms. Maxwell denied
+these allegations as false,
+sued for defamation. Discovery conducted in the defamation
+action established that
+stories, sold to tabloids for large sums of money, were in fact
+false. Those accused by Ms.
+Professor Alan Dershowitz, for example, denounced her as
+a "serial liar." Regardless, Ms.
+is not one of the three accusers identified in Counts One
+through Four of the Superseding Indictment and her claims relate to a different time period
+entirely. Allowing Counts Five and Six to be tried along with Counts One through Four will
+significantly prejudice Ms. Maxwell because it will allow the government to introduce testimony
+of alleged sexual abuse that purportedly occurred outside of the time period alleged in Counts
+One through Four, despite the fact that Ms. Maxwell (unlike Jeffrey Epstein) was never
+criminally charged with that conduct. As a result, the jury may convict Ms. Maxwell of Counts
+One through Four based on an improper inference of criminal propensity.
+Furthermore, the Court and the jury and the Court will have to resolve numerous complex
+legal and factual issues in connection with the perjury charges that will lengthen and complicate
+1
+EFTA00091879
+
+the trial, raise a substantial risk of juror confusion, and may operate to deprive Ms. Maxwell of
+her counsel of choice. Accordingly, the Court should sever Counts Five and Six.
+OVERVIEW OF THE ALLEGATIONS
+A. Counts One through Four (the "Mann Act Counts")
+Counts One and Three of the Indictment allege that Ms. Maxwell conspired with Jeffrey
+Epstein and "others known and unknown" to violate two separate provisions of the Mann Act.
+Count One alleges that Ms. Maxwell conspired with Epstein to entice "one or more individuals"
+to travel in interstate and foreign commerce to engage in "sexual activity for which a person can
+be charged with a criminal offense" in violation of 18 U.S.C. § 2422. Indictment 991 9-10. Count
+Three alleges that Ms. Maxwell conspired with Epstein to transport "an individual" in interstate
+and foreign commerce to engage in "sexual activity for which a person can be charged with a
+criminal offense" in violation of 18 U.S.C. § 2423(a). Id. 99 15-16.
+Counts One and Three each allege four identical overt acts in furtherance of the
+conspiracy involving three accusers.' Id. 9Y 11, 17. All of the overt acts allegedly occurred at
+unspecified times "between in or about 1994 and in or about 1997" in New York, Florida, New
+Mexico, and London, England. Id.
+Counts Two and Four charge Ms. Maxwell with substantive violations of
+18 U.S.C. §$ 2422 and 2423(a). Id. 99l 13, 19. Counts Two and Four allege offenses as to
+Accuser-1 only, not Accusers-2 or -3. Id. Like Counts One and Three, Counts Two and Four are
+based on conduct that allegedly occurred at unspecified times between 1994 and 1997. Id. Ml 13,
+19.
+B. Counts Five and Six (the "Perjury Counts")
+' The indictment refers to the accusers as Minor Victim-1, Minor Victim-2, and Minor Victim-3.
+We will refer to them as Accuser-1, Accuser-2, and Accuser-3.
+2
+EFTA00091880
+
+Counts Five and Six of the Indictment allege that Ms. Maxwell committed perjury in
+violation of 18 U.S.C. § 1623 by testifying falsely at two separate civil depositions—
+one on
+April 22, 2016 (Count Five) and the other on July 22, 2016 (Count Six). Id. 91 21, 23.
+APPLICABLE LAW
+A. Joinder of Offenses
+Rule 8(a) of the Federal Rules of Criminal Procedure provides, in relevant part,
+(a) Joinder of Offenses. The indictment or information may charge a
+defendant in separate counts with 2 or more offenses if the offenses
+charged--whether felonies or misdemeanors or both--are of the same or
+similar character, or are based on the same act or transaction, or are
+connected with or constitute parts of a common scheme or plan.
+Rule 8(a) sets forth three different circumstances in which separate offenses may be
+properly joined in the same indictment; namely, when the offenses: (1) "are of the same or
+similar character," (2) "are based on the same act or transaction," or (3) "are connected with or
+constitute parts of a common scheme or plan." Fed. R. Crim. P. 8(a). Although charging
+separate offenses in the same indictment and allowing them to be tried together "inevitably
+involves some danger of prejudice" to the defendant, Rule 8 permits joinder of offenses in
+circumstances where "gains in trial efficiency outweigh the recognized prejudice that accrues to
+the accused." United States v. Turoff, 853 F.2d 1037, 1042-43 (2d Cir. 1988); see also United
+States v. Werner, 620 F.2d 922, 928 (2d Cir. 1980) (purpose of Rule 8 is to promote "trial
+convenience and economy of judicial and prosecutorial resources"); United States v. Halper, 590
+F.2d 422, 430 (2d Cir. 1978) ("efficiency and economy" are the "customary justifications for
+joinder").
+In conducting a Rule 8(a) analysis, "no one characteristic is always sufficient to establish
+"similarity" of offenses ….. and each case depends largely on its own facts." United States v.
+3
+EFTA00091881
+
+Blakney, 941 F.2d 114, 116 (2d Cir. 1991) (quotations and citation omitted). "'Similar" charges
+include those that are 'somewhat alike,' or those 'having a general likeness" to each
+other." United States v. Rivera, 546 F.3d 245, 253 (2d Cir. 2008) (quoting Werner, 620 F.2d at
+926). Offenses are "connected" or part of a "common scheme or plan" if the counts "grow out of
+related transactions." United States v. Randazzo, 80 F.3d 623, 627 (Ist Cir. 1996). By contrast,
+offenses are not "connected" and joinder is inappropriate when "[c]ommission of one of the
+offenses neither depended upon nor necessarily led to the commission of the other; proof of the
+one act neither constituted nor depended upon proof of the other." Halper, 590 F.2d at 429.
+Similarly, offenses that are separated by time and location, and were allegedly committed
+under different circumstances, are not sufficiently connected to warrant joinder. See United
+States v. Martinez, Nos. S2 92 Cr. 839 (SWK), 1993 WL 322768, at *8-*9 (S.D.N.Y. Aug. 19,
+1993) (granting severance of firearm possession and narcotics conspiracy counts where firearm
+was seized in different location over four months after narcotics conspiracy ended "under
+circumstances having no bearing on either the alleged narcotics conspiracy, or any of
+[defendant's] coconspirators"); United States v. Brown, No. 07-0296-1, 2008 WL 161146, at *5
+(E.D. Pa. Jan. 16, 2008) (granting severance where a firearm possession count was unrelated
+"both physically and temporally" to the narcotics counts in the indictment (emphasis original)).
+Although the Second Circuit has recognized that it is generally permissible to join
+"underlying substantive crimes with perjury counts" where the false declarations "concern the
+substantive offenses," United States v. Potamitis, 739 F.2d 784 (2d Cir. 1984), joinder is not
+appropriate when the perjury or false statement allegations do not relate to, or have only a
+speculative connection to, the other charges in the indictment. See United States v. Botti, No.
+3:08-cr-00230 (CSH), 2009 WL 3157582, at *5 (S.D.N.Y. Sept. 25, 2009) (severing structuring
+4
+EFTA00091882
+
+counts alleging false statements to IRS agent from separate corruption counts due to "speculative
+nature of the link" between the structuring and corruption offenses); United States v. Mitan, No.
+CRIM.A 08-760-01, 2009 WL 2328870, at *3 (E.D. Pa. July 28, 2009) (joinder improper where
+alleged perjury did not arise from same transaction or comprise part of common plan with fraud
+counts in indictment).
+If one or more counts are improperly joined in an indictment, the court must sever the
+misjoined counts. United States v. Bradford, 487 F. Supp. 1093, 1097 & n.5 (D. Conn. 1980)
+("The remedy for the misjoinder is the severance of the misjoined count.") (citing United States
+v. Jackson, 562 F.2d 789, 797 n. 10 (D.C. Cir. 1977)); United States v. Winchester, 407 F. Supp.
+261 (D. Del. 1975) (a finding of misjoinder requires the court to sever the offenses as a matter of
+course "without regard to the merits of defendant's claims of prejudice" under Rule 14).
+B. Severance of Offenses
+Fed. R. Crim. P. 14 provides, in relevant part,
+(a) Relief. If the joinder of offenses ... appears to prejudice a defendant or
+the government, the court may order separate trials of counts, sever the
+defendants' trials, or provide any other relief that justice requires.
+Rule 14(a) allows a district court to grant severance even if joinder is proper under Rule
+8. United States v. Burke, 789 F. Supp. 2d 395, 398 (S.D.N.Y. 2011) (citing Turoff, 853 F.2d at
+1043). To prevail on a motion to sever, a defendant must show that failure to sever will cause
+"substantial prejudice." United States v. Ramos, No. 06 Cr. 172 (LTS), 2009 WL 1619912, at * 1
+(S.D.N.Y. Jun. 5, 2009) (citing United States v. Sampson, 385 F.3d 183, 190 (2d Cir. 2004)).
+The prejudice must be "sufficiently severe to outweigh the judicial economy that would be
+realized by avoiding multiple lengthy trials." United States v. Walker, 142 F.3d 103, 110 (2d
+Cir. 1998).
+5
+EFTA00091883
+
+Prejudice sufficient to justify severance under Rule 14 may exist when: (1) the defendant
+might become embarrassed or confounded in presenting separate defenses, (2) the jury might use
+evidence of one of the crimes charged to infer a criminal disposition to commit the other crime
+or crimes charged, or (3) the jury might cumulate evidence of the various crimes charged to find
+guilt on a count, which if considered separately, it would not so find. Halper, 590 F.2d at 440
+(citing Drew v. United States, 331 F.2d 85, 88 (D.C. Cir. 1964)); United States v. Chevalier, 776
+F. Supp. 853, 857 (D. Vt. 1991) (citing United States v. Lewis, 626 F.2d 940, 945 (D.C. Cir.
+1980)). The decision to sever is "committed to the sound discretion of the district court" and is
+"virtually unreviewable" on appeal. Ramos, 2009 WL 1619912, at *1; Burke, 789 F. Supp. 2d at
+398.
+ANALYSIS
+A. The Perjury Counts Are Improperly Joined Under Rule 8(a) and Must Be
+Severed
+The Perjury Counts (Counts Five and Six) were improperly joined and should be severed
+from the Mann Act Counts (Counts One through Four) as a matter of law. The Perjury Counts
+and the Mann Act Counts are entirely separate offenses that involve different time periods,
+different alleged victims, and different substantive charges. The Mann Act Counts are confined,
+purposefully, to a very narrow time period and allege that Ms. Maxwell enticed and transported
+minors to engage in illegal sexual activity from 1994 to 1997. Indictment 99l 9, 13, 15, 19. The
+Perjury Counts allege that Ms. Maxwell purportedly made false statements in 2016 in a civil
+defamation action that concerned allegations of purported sexual abuse in a later time period
+(1999-2002) for which Ms. Maxwell has never been charged criminally. Id. 9l 21, 23; Ex. A at
+3-5. The plaintiff in the defamation action,
+is not one of the three
+accusers referred to in the Mann Act Counts. Similarly, the people we believe to be the three
+6
+EFTA00091884
+
+accusers were not part of the subject matter of the defamation action, nor were they deposed as
+witnesses in that case. The Perjury Counts therefore are not "of the same or similar character,"
+nor are they "based on the same act or transaction" as the Mann Act Counts and cannot be
+joined. Fed. R. Crim. P. 8(a); see Halper, 590 F.2d at 430 (temporally and factually distinct
+Medicaid fraud and tax evasion offenses were not based on same transaction, nor were they "of
+the same or similar character" simply because both involved attempts to submit false information
+to government agencies).
+Furthermore, the perjury offenses purportedly occurred more than twenty years after the
+offenses alleged in the Mann Act Counts. There is no allegation that Ms. Maxwell continued
+conspiring with Epstein, or engaged in any misconduct at all, in the intervening time period. In
+fact, the government did not charge Ms. Maxwell in connection with the investigation that led to
+Epstein's Non-Prosecution Agreement in 2007, or in its 2019 indictment of Epstein, which
+charged Epstein with sex trafficking offenses from 2002-2005. Joinder is improper when the
+offenses are separated by such a significant time period and do not relate to each other. See
+Martinez, 1993 WL 322768, at *8-*9 (joinder of firearm possession and narcotics conspiracy
+counts improper under Rule 8(a) where firearm was seized in different location over four months
+after narcotics conspiracy ended "under circumstances having no bearing on either the alleged
+narcotics conspiracy, or any of [defendant's] coconspirators"); Brown, 2008 WL 161146, at *5
+(joinder improper under Rule 8(a) where a firearm possession count was unrelated "both
+physically and temporally" to narcotics counts in indictment (emphasis original)).
+The Perjury Counts and the Mann Act Counts are also not "parts of a common scheme or
+plan." Fed. R. Crim. P. 8(a). As a general matter, perjury, false statements, and obstruction of
+justice offenses are sufficiently connected to and appropriately joined with underlying
+7
+EFTA00091885
+
+substantive crimes when the false declarations "concern the substantive offenses." Potamitis,
+739 F.2d at 791. Such cases typically involve situations where the defendant was aware that he
+was being investigated and either lied to the grand jury or made false statements to law
+enforcement officers in an effort to thwart the existing investigation into the other offenses with
+which he was charged. See, e.g., id. at 789-90 (joinder of perjury, false statements, and
+obstruction of justice counts proper where defendant made false statements to FBI agents and
+perjured himself in the grand jury); see also id. at 791 (collecting cases).
+Here, the circumstances are very different and joinder is not appropriate. The
+government does not allege that Ms. Maxwell lied to the grand jury or the FBI to derail its
+investigation into the conduct underlying the Mann Act Counts. Instead, it alleges that Ms.
+Maxwell made false statements in two depositions in an unrelated civil defamation action which
+occurred in April and July 2016. Moreover, although the government alleges that some of the
+questions posed at the depositions related to some of the alleged victims in this case (Indictment
+99I 2, 8), the questions were tangential to the defamation action, which was based on Ms.
+Maxwell's denial of a purported conspiracy with Epstein from 1999-2002 involving Ms.
+The alleged false statements underlying the Perjury Counts therefore do not "concern" the Mann
+Act Counts and cannot be joined as part of a "common scheme or plan." Potamitis, 739 F.2d at
+791.
+The government makes only a half-hearted, and ineffective, attempt to allege a
+connection between the Perjury Counts and the Mann Act Counts sufficient to satisfy Rule 8(a).
+Paragraph 2 of the Indictment alleges:
+[In an effort to conceal her crimes, MAXWELL repeatedly lied when questioned
+about her conduct, including in relation to some of the minor victims described
+herein, when providing testimony under oath in 2016.
+8
+EFTA00091886
+
+(Indictment I| 2; accord id. 9| 8.) As discussed in Ms. Maxwell's Memorandum in Support of her
+Motion to Dismiss Counts Five and Six, because the statements at issue are not perjurious, the
+questions asked were confusing, ambiguous, and improperly formed. None of the questions, or
+any answers, were material to any issue in the defamation action. There were no "crimes"
+concealed by Ms. Maxwell's answers which were both true and reflective of the poor
+questioning by the plaintiff's lawyers. The Government does not articulate how statements like:
+"I don't know what you are talking about," an admission that Ms. Maxwell "could not make a
+list" upon demand, her lack of knowledge about undefined "devices" or "toys" could possibly
+"conceal her crimes." Accordingly, the government's purported connection between the Perjury
+Counts and the Mann Act Counts defies logic and is insufficient to permit joinder under Rule
+8(a). See Botti, 2009 WL 3157582, at *5 (joinder improper due to "speculative nature of the
+link" between structuring counts alleging false statements to IRS agent and separate corruption
+counts); Mitan, 2009 WL 2328870, at *3 (joinder improper where alleged perjury arose from
+false statement in connection with defendant's bail application, not an attempt to "cover up"
+underlying scheme to defraud with which defendant was charged).
+B. The Perjury Counts Should Be Severed Under Rule 14(a) Because Their
+Inclusion Will Substantially Prejudice Ms. Maxwell at Trial
+Even if the Court finds that joinder is proper under Rule 8, the Court should nevertheless
+exercise its discretion to sever Counts Five and Six under Rule 14(a) because of the substantial
+prejudice to Ms. Maxwell and these proceedings. A joint trial of the Perjury Counts will require
+a full-blown re-litigation of the defamation action, which will result in a collateral matter taking
+over the trial. Substantial amounts of evidence that would be inadmissible and irrelevant as to
+the Mann Act Counts will, necessarily, be presented in order to prove the Perjury Counts. For
+example, there will need to be a collateral trial on whether
+statements
+9
+EFTA00091887
+
+about an alleged conspiracy from 1999-2002 were in fact lies, even though the Mann Act Counts
+have nothing to do with
+and are based on an entirely separate time period. The jury will
+also need to be instructed on the elements of civil defamation and the various defenses, and they
+will need to evaluate whether the alleged perjurious statements were material to the defamation
+action. At the time the defamation case was dismissed, more than 50 substantive motions were
+pending before the District Court. Resolution of the materiality question would necessarily
+involve adjudicating those motions. Accordingly, joining the Perjury Counts would substantially
+lengthen the trial and unnecessarily complicate the factual issues put before the jury; it would not
+serve the goals of trial efficiency and judicial economy, which joinder is supposed to promote.
+See Turoff, 853 F.2d at 1042-43; Werner, 620 F.2d at 928; Halper, 590 F.2d at 430.
+A joint trial with the Perjury Counts would also substantially prejudice Ms. Maxwell
+because it would necessarily introduce allegations of purported sex abuse from 1999-2002 for
+which Ms. Maxwell has never been charged criminally and which is well outside of the time
+period alleged in the Mann Act Counts. The Palm Beach Police Department thoroughly
+investigated allegations of Epstein's sexual abuse in the early-mid 2000s and did not find any
+evidence against Ms. Maxwell. The documents produced in discovery show that none of the
+more than 30 alleged victims who were interviewed in that investigation testified that they met,
+talked to, or identified Ms. Maxwell as someone involved with Epstein's alleged scheme.
+Moreover, had the government credited Ms.
+allegations against Ms. Maxwell, it would
+no doubt have charged Ms. Maxwell in the 2019 indictment, which charged Epstein alone with
+sex trafficking offenses from 2002-2005. It did not. Allowing the government to introduce
+purported evidence of an uncharged and unsubstantiated conspiracy with Epstein through the
+vehicle of the Perjury Counts would be extremely prejudicial and create a substantial risk that the
+10
+EFTA00091888
+
+jury would convict Ms. Maxwell on the Mann Act Counts based on a false inference of criminal
+propensity. Similarly, it would create a substantial risk that the jury will confuse the legal and
+factual issues pertinent to the Perjury Counts and convict Ms. Maxwell without independently
+considering those counts. See Ramos, 2009 WL 1619912, at *2 (severing "temporally distinct"
+drug counts involving a different controlled substance from other drug counts because of "the
+potential for jury confusion, or improper propensity inferences, with respect to the drug-related
+aspects of the original charges*).
+Furthermore, the government's decision to allege violations only in the narrow 1994-
+1997 time period was deliberate—it did so, in part, to try to avoid the impact of Epstein's 2007
+Non-Prosecution Agreement ("NPA"). In its opposition to Ms. Maxwell's initial bail
+application, the government argued that the NPA did not protect Ms. Maxwell from prosecution
+principally because the Indictment did not charge conduct covered by the NPA, which the
+government argues "was limited by its terms to conduct spanning from 2001 to 2007, a time
+period that post-dates the conduct charged in the Indictment." (Dkt. 22 at 5-6),= The
+government now wants it both ways. It has confined the allegations in the Indictment to the
+earlier time frame to try to prevent a legal challenge that would result in the dismissal of the
+Mann Act Counts, but at the same time it seeks to introduce conduct from the later time period
+by joining the Perjury Counts. The government should not be permitted to do so.
+In addition, joinder of the Perjury Counts would prejudice Ms. Maxwell because it could
+impact the ability of Ms. Maxwell's counsel of choice to participate in the criminal trial. The
+Perjury Counts will involve complicated legal issues about permissible deposition questions,
+whether the answers to the poorly formulated questions would have been allowed, the role of a
+2 The defense disputes that the coverage of the NPA is so limited. See Motion to Dismiss
+Indictment for Breach of Non-Prosecution Agreement.
+EFTA00091889
+
+lawyer in a deposition, and a legal opinion about what was "material" in the context of the civil
+proceeding. It is unclear how the Government intends to address these issues, however, a trial
+with the perjury counts will necessarily involve litigating a complicated defamation action within
+a criminal trial, making the trial of this case unnecessarily lengthy and confusing. By May,
+2017, shortly before the civil defamation case was dismissed, the matter had generated over 900
+docket entries. Approximately 50 substantive motions relating to the admissibility of expert
+testimony, deposition testimony, and the admissibility of evidence remained unresolved. Judge
+Sweet had yet to rule on evidentiary challenges to thousands of deposition questions and answers
+contained in dozens of bankers boxes wheeled into his courtroom on dollies. A trial involving
+the perjury counts may well involve revisiting all of these unresolved issues.
+Inclusion of the Perjury Counts injects into this case the performance and credibility of
+Ms. Maxwell's lawyers and may require Ms. Maxwell's counsel of choice to testify. Presumably,
+this would result in disqualification of lawyers who have represented Ms. Maxwell for over five
+years from the entire trial, even though there is no reason why their testimony would be required
+in connection with the Mann Act Counts. See, Rule of Professional Conduct 3.7.
+Severance is still appropriate even though the government alleges that some of the
+questions posed at the depositions related to some of the alleged victims in this case. Indictment
+I9L 2, 8. Even if the government uses some minimal amount of overlapping evidence to prove
+both the Perjury Counts and the Mann Act Counts, the miniscule gain in efficiency of
+introducing proof is far outweighed be the much larger inefficiency of substantially lengthening
+and complicating the trial and by the risk of substantial prejudice to the defendant discussed
+above. See Burke, 789 F. Supp. 2d at 398 (severing witness tampering charges from RICO
+conspiracy charges in the interests of judicial economy, despite fact that government would have
+12
+EFTA00091890
+
+to present "some overlapping proof" and "five limited overlapping witnesses" to prove both
+charges).
+Finally, severance is appropriate because a joint trial including the Perjury Counts will
+necessarily introduce into the trial the issue of Ms. Maxwell's credibility, even if she decides to
+assert her Fifth Amendment right not to testify. By alleging that Ms. Maxwell lied about sexual
+and other salacious topics, the Government is explicitly putting its very big thumb on the
+credibility scale. The Government will attempt to argue to the jury that Ms. Maxwell lied about
+the allegations in the Perjury Counts and that Ms. Maxwell is a liar in general. This is a tool not
+normally afforded to the accuser in a criminal case. It will be difficult, if not impossible, for Ms.
+Maxwell to lodge appropriate objections and the Court to make appropriate rulings and provide
+limiting instructions on the evidence. There is a substantial risk that the jury will convict Ms.
+Maxwell on Counts One-Four because her credibility was attacked in connection with the
+Perjury Counts. In short, a joint trial on Counts One through Six guarantees a mess. The Court
+should therefore sever the Perjury Counts under Rule 14(a).
+CONCLUSION
+For the reasons set forth above, the Court should sever the Perjury Counts (Counts Five
+and Six) from the Mann Act Counts (Counts One through Four) and order that they be tried
+separately, pursuant to Rules 8(a) and 14 of the Federal Rules of Criminal Procedure.
+Dated: January 25, 2021
+13
+EFTA00091891
+
+Respectfully submitted,
+s/ Jeffrey S. Pagliuca
+Jeffrey S. Pagliuca (pro hac vice)
+Laura A. Menninger
+HADDON, MORGAN & FOREMAN P.C.
+150 East 10th Avenue
+Denver, CO 80203
+Phone: 303-831-7364
+Mark S. Cohen
+Christian R. Everdell
+COHEN & GRESSER LLP
+800 Third Avenue
+New York, NY 10022
+Phone: 212-957-7600
+Bobbi C. Sternheim
+Law Offices of Bobbi C. Sternheim
+33 West 19th Street - 4th Floor
+New York, NY 10011
+Phone: 212-243-1100
+Attorneys for Ghislaine Maxwell
+14
+EFTA00091892
+
+Certificate of Service
+I hereby certify that on January 25, 2021, I electronically filed the foregoing
+Memorandum of Ghislaine Maxwell in Support of Her Motion for a Severance of and Separate
+Trial on Counts Five and Six of the Superseding Indictment with the Clerk of Court using the
+CM/ECF system which will send notification of such filing to the following:
+U.S. Attorney's Office, SDNY
+One Saint Andrew's Plaza
+New York, NY 10007
+s/ Nicole Simmons
+15
+EFTA00091893
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/ba40095579d59959e3608e5f988f59f5d5de446692c2937acdd784d44922b3a4.md b/vision-joined/ds9-parsed-01/ba40095579d59959e3608e5f988f59f5d5de446692c2937acdd784d44922b3a4.md
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@@ -0,0 +1,43 @@
+From:
+To:
+| (NY) (FBI)" ‹
+Cc: '
+Subject: FW: RE:
+Date: Fri, 31 May 2019 14:13:27 +0000
+Importance: Normal
+Hi
+Hope you had a good flight back. Any luck with the calls to
+contact info, it's below.
+Thanks,
+? In case you're looking for the email with
+From:
+To:
+Cc:
+Subject: RE:
+Sent: Tuesday, May 14, 2019 12:11 PM
+• (NY) (FBI) <
+After a lot of back and forth, we've gotten the best contact number for l
+L, which was one of the ones on your list -
+it's
+(It's our understanding that she's not currently represented, though of course if she wants to have
+counsel, as with everyone else, she can obtain an attorney or we can also assist in getting her appointed counsel. And
+also similarly, we can jump on a call with her to explain the basics too if that's helpful, but also happy to just have you
+guys make initial contact and then us meet her in person.)
+So it's fine to call her, and she should know that we have an investigation and that we were planning to be in touch,
+though as always we're playing a game of telephone on our end so hard to know for sure. If you're able to make contact
+with her, I think it would make sense to explain what's happening generally but hopefully see if we can go out to California
+to meet with her sometime this month.
+Quick background on her
+Epstein, who met her while she was in high
+school, but in reality she apparently was one of his victims. We don't believe she's ever been interviewed by law
+enforcement, and her name shows up in just one 302 - 1
+I states that Epstein bought |
+and that|
+I was also a recruiter.
+Happy to chat further if that's useful, otherwise green light to give her a call.
+thanks,
+Assistant U.S. Attorney
+Southern District of New York
+EFTA00039890
+
+EFTA00039891
\ No newline at end of file
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@@ -0,0 +1,1996 @@
+Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 1 of 23
+Bates Range
+Box #1
+P-000001
+thru
+P-000039
+Box #1
+P-000040
+thru
+P-000549
+PRIVILEGE LOG
+Description
+File folder entitled "CORR RE GJ
+SUBPOENAS** containing correspondence
+related no various gran and suben note anc
+Privilege(s) Asserted
+6(e)
+Work Product
+Box #1
+P-000550
+thru
+P-000621
+D handwritten notes
+File folder entitled "Ritz Compact Flash SW"
+containing copies of a sealed search warran
+pplication, warrant, and supporting document
+Box #1
+P-000622
+thru
+P-000693
+File folder entitled "PNY Technologies Compact
+Flash SW" containing copies of a sealed search
+warrant application, warrant, and supporting
+documents
+Box #1
+P-000694
+thru
+P-000781
+Box #1
+P-000782
+thru
+P-000803
+Box #1
+P-000804
+thru
+P-000854
+File folder entitled "JE Corporations" containing
+attorney research on Epstein-owned corporations
+and prior litigation
+File folder entitled "Capital One"
+containing subpoena and correspondence
+File folder entitled "DTG Operations/Dollar
+Rent-a-Car" containing subpoena and responsive
+6(e)
+Work Product
+Contains documents subject
+to investigative privilege
+Also contains documents
+ubject to privacy rights o
+ictims who are not parties t
+6(e)
+Contains information subject
+to investigative privilege
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+this litigation
+6(e)
+Contains information subject
+to investigative privilege
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+Work Product
+Contains information subject
+to investigative privilege
+6(e)
+Also contains documents and
+information subject to privacy
+rights of victims who are noi
+Page 1 of 23
+EFTA00065065
+
+Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 2 of 23
+Bates Range
+Box #1
+P-000855
+thru
+P-000937
+Box #1
+P-000938
+thru
+P-000947
+Box #1
+P-000948
+thru
+P-000982
+Description
+File folder entitled "JP Morgan Chase"
+containing subpoena, correspondence, and
+responsive documents
+File folder entitled "Washington Mutual"
+containing subpoena, correspondence, and
+responsive documents
+File folder entitled "Computer Search &"
+containing legal research on computer search and
+handwritten notes on indictment preparation
+Privilege(s) Asserted
+6(e)
+Contains documents and
+information subject to
+investigative privilege
+6(e)
+Contains documents and
+information subject to
+investigative privilege
+Work Product
+Attorney-Client
+Contains information subject
+to investigative privilege.
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+Box #1
+P-000983
+thru
+P-001007
+File folder entitled "Attorney Notes from
+Document Review" containing typed and
+handwritten attorney (
+notes, targe
+etters, correspondence re grand jury subpoen
+Box #1
+P-001008
+thru
+P-001056
+File folder entitled "Notes from Fed Ex Records"
+containing handwritten and typed attorney
+notes and screen shots of FedEx
+subpoena response electronic file
+Box #1
+P-001057
+thru
+P-001959
+Box #1
+P-001960
+Thru
+P-002089
+File folder entitled "Colonial Bank Records"
+containing records received in response to grand
+6(e)
+Contains information subject
+to investigative privilege.
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+this litigation
+Work Product
+6(e)
+Contains information subject
+to investigative privilege.
+Also contains information
+this litigation
+6(e)
+ontains information subje
+, investigative priviles
+6(e)
+Contains information subject
+correspondence
+Page 2 of 23
+EFTA00065066
+
+Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 3 of 23
+Bates Range
+Box #1
+P-002090
+Thru
+P-002169
+Box #1
+P-002170
+Thru
+P-002246
+Box #1
+P-002247
+Thru
+P-002265
+Box #1
+P-002266
+Thru
+P-002386
+Description
+File folder entitled "Epstein Corporate Records:
+OLY-51, OLY-52, OLY-53, OLY-54" containing
+subpoenas, records received in response to
+subpoenas, and related correspondence
+File folder entitled "Colonial Bank" containing
+subpoenas, correspondence related to subpoenas,
+records received in response to subpoenas
+File folder entitled "JEGE & Hyperion from
+Goldberger OLY-46 & OLY-47" containing
+documents received in response to subpoenas
+Indictment preparation bınder containing:
+Grand jury subpoena log, evidence/activity
+summary chart, witness/victim names and contact
+ist, attorney (
+ortions of state investigative file, attorne
+"Additional victims"
+Box #1
+P-002387
+Thru
+P-002769
+Box #1
+P-002770
+Thru
+P-003211
+Indictment preparation binder containing:
+Grand jury subpoena log, evidence/activity
+summary chart, witness/victim names and contact
+D handwritten notes, 302s,
+portions of state investigative file, attorney
+Typed notes, relevant pieces of grand
+jury materials, telephone records/flight records
+analysis charts, victim/witness photographs,
+records, NCICs, and related materials for
+persons identified as Jane Does #15, 16, 17, 18,
+19, Past Employees, Misc. Witnesses
+vitness/victim list with identifying information.
+exual activity summary, telephone call summar
+chart, attorney C
+) handwritten notes
+02s, portions of state investigative file, attorney
+Privilege(s) Asserted
+6(e)
+Contains information and
+documents subject to
+investigative privilege
+6(e)
+Contains information and
+documents subject to
+investigative privilege
+6(e)
+Contains information and
+documents subject to
+investigative privilege
+Work product
+6(e)
+Contains information and
+documents subject to
+investigative privilege. Also
+contains information and
+documents subject to privacy
+rights of victims who are not
+parties to this litigation
+Work product
+6(e)
+Contains information and
+documents subject to
+investigative privilege. Also
+contains information and
+documents subject to privacy
+rights of victims who are not
+parties to this litigation
+Work product
+6(e)
+investigative privilege. Also
+8
+Page 3 of 23
+EFTA00065067
+
+Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 4 of 23
+Bates Range
+Box #1
+P-003212
+Thru
+P-003545
+Description
+Indictment preparation binder containing meta-
+analysis charts of telephone/flight/grand jury
+information for a number of victim/witnesses,
+and
+Box #1
+P-003546
+Thru
+P-003552
+FBI Reports of March 2008 interviews of
+additional witness/victim located in New York
+Privilege(s) Asserted
+Work product
+6(e)
+Contains information and
+documents subject to
+investigative privilege. Also
+contains information and
+documents subject to privacy
+rights of victims who are not
+parties to this litigation
+Work product
+6(e)
+Contains information and
+documents subject to
+investigative privilege. Alsc
+Box #1
+P-003553
+Thru
+P-003555B
+Box #1
+P-003556
+Thru
+P-003562
+Box #1
+P-003563
+Thru
+P-003629
+Box #1
+P-003630
+Thru
+P-003633
+Box #1
+P-003634
+Thru
+P-003646
+Printout of filenames from Federal Expres
+ubpoena response with Attorney notation
+Document entitled "Identified Numbers" with
+accompanying handwritten attorney list compiled
+from grand jury materials and attorney analysis of
+records
+Folder entitled "Flight Manifests" containing
+manifests received pursuant to grand jury
+subpoena
+File folder entitled "Recent Attorney Notes"
+containing handwritten attorney (
+) notes
+regarding document review and case strategy
+File folder bearing victim name containing FBI
+interview report from May 2008, telephone
+activity report with attorney d
+handwritten notes, related grand jury material
+parties to this litigation
+Work product
+6(e)
+Work product
+6(e)
+Contains information subject
+to investigative privilege
+6(e)
+Contains information and
+documents subject to
+investigative privilege
+Work product
+6(e)
+Investigative privileg
+Deliberative process
+Allomey-cient privilege
+Investigative privilege
+Also contains information and
+risis of victims who are not
+Page 4 of 23
+EFTA00065068
+
+Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 5 of 23
+Bates Range
+Box #1
+P-003647
+Thru
+P-003651
+Description
+File folder entitled "Summary of Sexual Activity"
+containing chart bearing handwritten title "Sexual
+Activity - Summary" with meta-analysis of
+information, sorted by name of each
+victim/witness, including name and identifying
+information of each victim/witness
+File folder entitled "Victim Civil Suits"
+Privilege(s) Asserted
+Work product
+6(e)
+Investigative privilege
+Deliberative process
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+parties to this litigation
+Not privileged.
+Produced to counsel for
+Petitioners
+Work product
+Box #1
+P-003652
+Thru
+P-003663
+Box #1
+P-003664
+Thru
+P-003678
+Box #1
+P-003679
+Thru
+P-003680
+Box #1
+P-003681
+Thru
+P-003687
+Box #1
+P-003688
+Thru
+P-003693
+Box #1
+P-003694
+Thru
+P-003711
+File folder entitled "Research re JE Websites"
+containing attorney research
+File folder entitled "
+containing attorney (
+((N.Y. AUSA)"
+handwritten notes
+File folder entitled "Dr.
+containing
+attorney
+1) memo to expert witness and
+handwritten attorney notes
+File folder entitled "L
+Interview" containing
+attorney handwritten notes of interview, and
+attorney handwritten notes regarding potential
+charges
+File folder entitled "Research re Travel for
+Work product
+Work product
+Investigative privilege
+Work product
+Investigative privilege
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+Work product
+6(e)
+Box #1
+P-003712
+parties to this litigation
+Investigative privilege
+Page 5 of 23
+EFTA00065069
+
+Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 6 of 23
+Bates Range
+Box #1
+P-003713
+Thru
+P-003746
+Box #1
+P-003747
+Thru
+P-003751
+Box #1
+P-003752
+Thru
+P-004295
+Box #1
+P-004296
+Thru
+P-004350
+Description
+File folder entitled "D
+T containing grand
+jury subpoenas, motion and order to compel
+testimony, and correspondence regarding same
+File folder entitled
+containing
+subpoena and correspondence regarding same
+File folder entitled "PBPD Investigative File"
+obtained via subpoena
+Privilege(s) Asserted
+6(e)
+Documents under seal
+pursuant to court order
+6(e)
+6(e)
+Investigative privilege
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+parties to this litigation
+Work product
+6(e)
+Investigative privilege
+Also contains information and
+documents subject to privacy
+ights of victims who are noi
+parties to this litigation
+Work product
+Box #1
+P-004351
+Thru
+P-004381
+Box #1
+P-004382
+Thru
+P-004478
+Box #1
+P-004479
+Thru
+P-004551
+Box #1
+P-004552
+Thru
+P-004555
+File folder entitled "
+53909-004" containing attorney research related
+File Folder entitled "FEDEX containing
+documents obtained via subpoena
+File Folder entitled "State of Delaware Records"
+containing documents obtained in preparation for
+indietment
+File folder entitled "Jet Blue Records" containing
+documents obtained via subpoena
+6(e)
+Investigative privilege
+6(e)
+Investigative privilege
+Work product
+6(e)
+Work product
+Box #1
+P-004556
+Thru
+P-004560
+File folder entitled "FL EMPLOYMENT
+RECORDS ses aliased a arced on targets
+Page 6 of 23
+EFTA00065070
+
+Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 7 of 23
+Bates Range
+Box #1
+P-004561
+Thru
+P-004565
+Box #1
+P-004566
+Thru
+P-004716
+Description
+Filed folder entitled "
+containing attorney (
+of interview
+handwritten notes
+File folder entitled "
+RECORDS 23-0001 THROUGH 23-" containing
+documents obtained via subpoena
+Box #1
+P-004717
+Thru
+P-004722
+Box #1
+P-004723
+Thru
+P-004725
+Box #1
+P-004726
+Thru
+P-004819
+Box #1
+P-004820
+Thru
+P-004959
+Box #1
+P-004960
+Thru
+P-005059
+File folder entitled
+containing attorney research regarding witness
+File folder entitled "BEAR STEARNS
+RESEARCH" containing attorney research
+regarding potential witness and subpoena
+recipient
+File folder entitled "LAWSUITS INVOLVING
+EPSTEIN CORP'S" containing attorney research
+regarding Epstein's past personal and business
+litigative practices
+Filed folder entitled "SEC RECORDS"
+containing attorney research regarding Epstein
+financial relationships
+File folder entitled "Message Pads" containing
+selected items from evidence obtained via
+subpoena
+Privilege(s) Asserted
+Work product
+Investigative privilege
+6(e)
+Work product
+Investigative privilege
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+parties to this litigation
+Work product
+Investigative privilege
+Work Product
+Investigative privilege
+Work Product
+Investigative privilege
+Work Product
+Investigative privilege
+Work Product
+6(e)
+Investigative privilege
+parties to this litigation
+Work Product
+Box #1
+P-005060
+Thru
+P-005081
+Box #1
+P-005082
+Thru
+P-005083
+File folder bearing name of victim/witness
+containing correspondence with counsel for
+victim/witness, attorney witness outline with
+attorney handwritten notes, attorney handwritten
+notes regarding witness reports and case
+preparation
+File folder entitled "New York Trip" containing
+attorney notes re witness interview
+nvestigative privileg
+Page 7 of 23
+EFTA00065071
+
+Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 8 of 23
+Bates Range
+Box #1
+P-005108
+Thru
+P-005193
+Box #1
+P-005194
+Thru
+P-005300
+Description
+P-005084 thru P-005107 are non responsive
+documents and have been removed
+File folder entitled D
+attorney research on select expert, use of experts
+at trials in child exploitation cases, and additional
+File folder entitled "Extra Copies" containing
+neta-analysis chart and 302's of victim/witnesse
+ised in preparing indictment packag
+Box #1
+P-005301
+Thru
+P-005331
+Box #1
+P-005332
+Thru
+P-005341
+Box #1
+P-005342
+Thru
+P-005387
+Box #1
+P-005388
+Thru
+P-005442
+File folder entitled 4
+STATEMENT" containing transcript obtained via
+subpoena
+File folder entitled 1
+• containing
+attorney research on select expert, including
+attorney handwritten notes
+File folder entitled "Info re Planes" containing
+correspondence regarding subpoenas and
+documents received in response to subpoenas
+File folder entitled "Police Reports & PC
+Affidavit" containing portions of police reports
+with attorney notes, related phone records, a list
+entitled "Victims" with identifying information
+and attorney handwritten notes, photographs and
+information, and additional attorney
+research regarding Epstein sexual activity
+File folder entitled "[Victim name] Transcript of
+Interview & GJ Transcript"
+Privilege(s) Asserted
+Work product
+Investigative privilege
+Work product
+6(e)
+Investigative privilege
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+parties to this litigation
+6(e)
+Investigative privilege
+Work product
+Investigative privilege
+6(e)
+Investigative privilege
+Work product
+6(e)
+Investigative privilege
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+parties to this litigation
+Box #1
+P-005443
+Thru
+P-005496
+Box #1
+P-005497
+Thru
+P-005556
+File folder entitled "Bear Stearns Subpoena
+Resp" containing material received in response
+parties to this litigation
+6(e)
+Investigative privilege
+Page 8 of 23
+EFTA00065072
+
+Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 9 of 23
+Bates Range
+Box #1
+P-005557
+Thru
+P-005576
+Box #1
+P-005578
+Thru
+P-005583
+Box #1
+P-005584
+Thru
+P-005606
+Description
+U.S. Attorney's Office Criminal Case File Jacket
+containing file opening documents, expert
+witness payment documents
+U.S. Attorney's Office Asset Forfeiture Case File
+Jacket containing file opening and file closing
+documents
+File folder entitled "6001 Immunity Request"
+containing internal memoranda seeking witness
+immunity and correspondence with counsel for
+witness regarding same
+Privilege(s) Asserted
+Work product
+Deliberative process
+Work product
+Deliberative process
+6(e)
+Work product and
+deliberative process (as to
+internal memoranda)
+Investigative privilege
+Box #2
+P-005607
+Thru
+P-005914
+File folder entitled "MASTER PHONE
+RECORDS" containing meta-analysis of all
+phone, travel, and grand jury data for all
+victim/witnesses for indictment preparation
+Box #2
+P-005915
+Thru
+P-005977
+File folder bearing name of victim/witness
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+parties to this litigation
+Work product
+6(e)
+Investigative privilege
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+parties to this litigation
+Work product
+6(e)
+Investigative privilege
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+parties to this litigation
+Work product
+Box #2
+P-005978
+Thru
+P-006050
+File folder bearing name of victim/witness
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+Box #2
+P-006051
+Thru
+P-006065
+parties to this litigation
+Work product
+File folder bearing name of victim/witness
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+Page 9 of 23
+EFTA00065073
+
+Case 9:08-cv-80736-KAM Document 212-1
+Entered on FLSD Docket 07/19/2013 Page 10 of
+Bates Range
+Box #2
+P-006066
+Thru
+P-006220
+Description
+File folder entitled "JANE DOE #4" containing
+meta-analysis of all phone, travel, and grand jury
+data related to that victim/witness for indictment
+preparation
+Box #2
+P-006221
+Thru
+P-006222
+File folder entitled *JANE DOE #12" containing
+meta-analysis of all phone, travel, and grand jury
+data related to that victim/witness for indictment
+preparation
+Box #2
+P-006223
+Thru
+P-006522
+File folder entitled "CORRECTED PHONE
+RECORDS 5/31/07" containing meta-analysis of
+all phone, travel, and grand jury data related to all
+victims/witnesses for indictment preparation
+Box #2
+P-006523
+Thru
+P-006802
+File folder entitled "[Victim Name] Phone
+ecords" containing telephone records receive
+n response to subpoer
+Box #2
+P-006803
+Thru
+P-006860
+Privilege(s) Asserted
+Work product
+6(e)
+Investigative privilege
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+parties to this litigation
+Work product
+6(e)
+Investigative privilege
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+parties to this litigation
+Work product
+6(e)
+Investigative privilege
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+parties to this litigation
+Work product
+6(e)
+Investigative privilege
+Also contains information and
+documents subject to privacy
+rights of victims who are not
+parties to this litigation
+Work product
+6(e)
+Investigative privilege
+Box #2
+P-006861
+Thru
+P-007785
+File folder entitled "Lists of Identified Phone
+Numbers" containing charts of information culled
+from grand jury materials, interviews, and other
+investigation, with attorney handwritten notes
+and information to issue follow-up grand jury
+subpoena
+File folder entitled "EPSTEIN/
+ICELL
+PHONE RECORDS" containing documents
+received via subes and vich ihiney handwriten
+Investigative privilege
+Also contains internation any
+ights of victims who are noi
+Page 10 of 23
+EFTA00065074
+
+Case 9:08-cv-80736-KAM Document 212-1
+Entered on FLSD Docket 07/19/2013 Page 11 of
+Bates Range
+Box #2
+P-007786
+Thru
+P-008120
+Description
+Folder entitled "OLY GRAND JURY LOG:
+ubpoenas. correspondence rega
+poenas, Corespondence rear containe
+records received in response to tapering.
+Privilege(s) Asserted
+Work product
+6(e)
+Investigative privilege
+Box #2
+P-008121
+Thru
+P-008139
+Box #2
+P-008140
+Thru
+P-008298
+Handwritten flight logs received in response to
+subpoena
+Grand jury presentation folder containing
+parties to this litigation
+6(e)
+Investigative privilege
+Work product
+6(e)
+Box #2
+P-008299
+Thru
+P-008363
+summary of activity
+File folder entitled "FINAL AGREEMENTS"
+containing subfolder entitled "Agrmts Filed in
+State Court" (P-008300-P-008327 [not being
+withheld as privileged - have been produced to
+pposing counsell); signed Non-Prosecution
+greement, Addendum, and operative portion of
+12/19/2007 S
+008343 [not being withheld as privileged - have
+been produced to opposing counsel]); subfolder
+entitled "12/19/07.
+containing unredacted copies of that letter (P-
+parties to this litigation
+Box #2
+P-008364
+Thru
+P-008382
+Box #2
+P-008383
+Thru
+P-008516
+File folder entitled "
+Immunity Request"
+containing internal memoranda, Justice
+Department documentation, and subpoena
+regarding immunity request
+victim reference list, grand jury subpoena log
+6(e)
+Work Product
+eliberative Proce
+ivestigative priviles
+Work product
+6(e)
+Also contains information and
+locuments subject to privac
+ights of victims who are no
+Page 11 of 23
+EFTA00065075
+
+Case 9:08-cv-80736-KAM Document 212-1
+Entered on FLSD Docket 07/19/2013 Page 12 of
+Bates Range
+Box #2
+P-008517
+Thru
+P-008535
+Box #2
+P-008536
+Thru
+P-008542
+Box #2
+P-008543
+Thru
+P-008549
+Box #2
+P-008550
+Thru
+P-008615
+Description
+6/25/2007 Letter from 4
+[pursuant to Court's Order, not being withheld as
+rivileged - will be produced to opposing counse
+upon lift of stay by 11" Circuit
+Handwritten attorney notes to prepare for
+interview of Jane Doe #2
+Privilege(s) Asserted
+Handwritten attorney notes regarding May 8,
+2007 grand jury presentation
+File folder entitled "Most Recent Indictment &
+Good Cases" containing draft indictment and
+legal research
+Box #2
+P-008616
+Thru
+P-008686
+Box #2
+P-008687
+Thru
+P-008776
+File folder entitled "FBI Summary Charts"
+containing chart prepared at direction of AUSA,
+containing victim names, identifying information,
+summary of activity, and other information
+relevant to indictment
+File folder entitled "[Victim name]/Jane Doe #4"
+containing phone records and meta-analysis of all
+phone, travel, and grand jury data related to that
+victim/witness for indictment preparation
+Box #2
+P-008777
+Thru
+P-008808
+File folder entitled "[Victim name]/Jane Doe #5"
+containing handwritten notes and meta-analysis
+of all phone, travel, and grand jury data related to
+that victim/witness for indictment preparation
+Work product
+Investigative Privilege
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Work product
+6(e)
+Investigative privilege
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Work product
+6(e)
+Investigative privilege
+Deliberative process
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Work product
+Attorney-Client Privilege
+6(e)
+Investigative privilege
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Work product
+6(e)
+'ontains information an
+ocuments subject to privac
+ights of victims who are no
+arties to this sui
+6(e)
+Investigative privilege
+Contains information subject
+to privacy rights of victims
+ho are not parties to this sui
+Page 12 of 23
+EFTA00065076
+
+Case 9:08-cv-80736-KAM Document 212-1
+Entered on FLSD Docket 07/19/2013 Page 13 of
+Bates Range
+Box #2
+P-008809
+Thru
+P-008847
+Box #2
+P-008848
+Thru
+P-008862
+Box #2
+P-008863
+Thru
+P-008890
+Box #2
+P-008891
+Thru
+P-009103
+Box #2
+P-009104
+Thru
+P-009111
+Box #2
+P-009112
+Thru
+P-009113
+Description
+File folder entitled "[Victim name]/Jane Doe #6"
+containing meta-analysis of all phone, travel, anc
+grand jury data related to that victim/witness fo
+indictment preparation
+File folder entitled "[Victim name]/Jane Doe #7"
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+File folder entitled "[Victim name]/Jane Doe #8"'
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+File folder entitled "Certified Copy of State Case"
+containing certified copy of Epstein state criminal
+cases and change of plea transcript [not being
+withheld as privileged - copy provided to
+File folder entitled "Meeting Timeline"
+ontaining Villafaña typed notes summarizin
+request of
+meetings with opposing counsel peared ate
+correction and typed guideline estimate
+11/26/2008 Email from
+re Jeffrey Epstein
+(work release)
+[pursuant to Court's Order, not being withheld as
+privileged - will be produced to opposing counsel
+to Col.
+M. Gauger at PBSO re Epstein work release with
+attachment [not being withheld as privileged -
+Privilege(s) Asserted
+Work product
+6(e)
+Investigative privilege
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Work product
+6(e)
+Investigative privilege
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Work product
+6(e)
+Investigative privilege
+Work product
+Deliberative process
+Box #2
+P-009114
+Thru
+P-009115
+Box #2
+P-009116
+Thru
+P-009125
+re Jeffrey Epstein (victim notification)
+[pursuant to Court's Order, not being withheld as
+rivileged - will be produced to Crosing counse
+" Circuit|
+Page 13 of 23
+EFTA00065077
+
+Case 9:08-cv-80736-KAM Document 212-1
+Entered on FLSD Docket 07/19/2013 Page 14 of
+Bates Range
+Box #2
+P-009126
+Thru
+P-009134
+Box #2
+P-009135
+Thru
+P-009141
+Box #2
+P-009141A
+Thru
+P-009141C
+Box #2
+P-009142
+Thru
+P-009152
+Box #2
+P-009153
+Thru
+P-009156
+Box #2
+P-009157
+Thru
+P-009208
+Box #2
+P-009209
+Thru
+P-009213
+Description
+File folder entitled "[Victim name]/Jane Doe #9"
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness fo
+indictment preparation
+File folder entitled "[Victim name]/Jane Doe
+#13" containing meta-analysis of all phone,
+travel, and grand jury data related to that
+victim/witness for indictment preparation
+File folder entitled "[Victim name]/Jane Doe
+#12" containing meta-analysis of all phone,
+travel, and grand jury data related to that
+victim/witness for indictment preparation
+File folder entitled "A
+containing meta-analysis of all phone, travel, and
+grand jury data related to that individual for
+indictment preparation
+File folder entitled "f
+containing meta-analysis of all phone, travel, and
+grand jury data related to that individual for
+indictment preparation
+File folder entitled "[Victim name]/Jane Doe #1"
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+File folder entitled "[Victim name]/Jane Doe #2"
+Containing meta real is of al petitives, and
+indictment preparation
+Privilege(s) Asserted
+Work product
+6(e)
+Investigative privilege
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Work product
+6(e)
+Investigative privilege
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Work product
+6(e)
+Investigative privilege
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Work product
+6(e)
+Investigative privilege
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Work product
+6(e)
+Investigative privilege
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Work product
+Page 14 of 23
+EFTA00065078
+
+Case 9:08-cv-80736-KAM Document 212-1
+Entered on FLSD Docket 07/19/2013 Page 15 of
+Bates Range
+Box #2
+P-009214
+Thru
+P-009271
+Box #2
+P-009272
+Thru
+P-009354
+Box #2
+P-009355
+Thru
+P-009403
+Box #2
+P-009404
+Thru
+P-009536
+Box #2
+P-009537
+Thru
+P-009574
+Box #2
+P-009575
+Thru
+P-009603
+Box #2
+P-009604
+Thru
+P-009711
+Box #2
+P-009712
+Thru
+P-009819
+Box #2
+P-009820
+Thru
+P-009965
+Box #2
+P-009966
+Thru
+P-010096
+Description
+File folder entitled "[Victim name]/Jane Doe #3"
+containing meta-analysis of all phone, travel, and
+grand jury data related to that victim/witness for
+indictment preparation
+File folder entitled "Purpose of Travel Cases"
+containing attorney research and handwritten
+notes
+File folder entitled "Interstate Commerce Cases"
+containing attorney research and handwritten
+notes
+File folder entitled "Attorney Conflict Research"
+containing attorney research and handwritten
+notes
+File folder entitled "Mann Act/Travel to Have
+Sex w/Minor" containing attorney research and
+handwritten notes
+File folder entitled "Travel Act" containing
+attorney research and handwritten notes
+File folder entitled "Florida
+Prostitution/Lewdness Statutes" containing
+attorney research and handwritten notes
+Booklet entitled "Attorney General Guidelines for
+Victim and Witness Assistance" [not being
+withheld as privileged - produced to opposing
+File folder entitled "Corporate Liability Rsrch"
+containing attorney research and handwritten
+notes
+File folder entitled "Research re Knowledge of
+Privilege(s) Asserted
+Work product
+6(e)
+Investigative privilege
+Contains information subject
+to privacy rights of victims
+who are not parties to this suit
+Work product
+Work product
+Work product
+Work product
+Work Product
+Work Product
+Work Product
+Work Product
+6(e)
+Page 15 of 23
+EFTA00065079
+
+Case 9:08-cv-80736-KAM Document 212-1
+Entered on FLSD Docket 07/19/2013 Page 16 of
+Bates Range
+Box #2
+P-010097
+Thru
+P-010276
+Box #2
+P-010277
+Thru
+P-010394
+Box #2
+P-010395
+Thru
+P-010488
+Box #2
+P-010489
+Thru
+P-010509
+Box #2
+P-010510
+Thru
+P-010525
+Box #2
+P-010526
+Thru
+P-010641
+Box #2
+P-010642
+Thru
+P-01650
+Box #2
+P-010651
+Thru
+P-010659
+Box #2
+P-010660
+Thru
+P-010757
+Description
+File folder entitled "Money Laundering"
+containing attorney research and handwritten
+notes
+File folder entitled "1960 & Aiding/Abetting"
+containing attorney research and handwritten
+notes
+File folder entitled "18 USC $ 2255 Cases"
+containing attorney research and handwritten
+notes
+File folder entitled "Research re Overt Acts &
+Witness Testimony" containing attorney research
+and handwritten notes
+File folder entitled "Extradition" containing
+attorney research and handwritten notes
+File folder entitled "Rsrch re Crime Victims
+Rights" containing attorney research, handwritten
+notes, draft victim notification letter, and draft
+correspondence to
+(Also contains a November 28, 2007 letter from
+and a November
+29, 2007 letter from
+Court's Order, these will be produced to opposing
+counsel upon lift of stay by 11" Circuit)
+File folder entitled "Immunity" containing
+ittorney research on granting immunity to
+witnesses
+File folder entitled "Research re G.J. Transcript"
+remaining intoney research gradiary praditio
+with subpoena
+Homey research and suspendence related.,.
+subpoen:
+Privilege(s) Asserted
+Work Product
+Work Product
+Work Product
+Work Product
+Work Product
+Work Product
+Deliberative Process
+Work Product
+Work Product
+6(e)
+Deliberative process
+Work Product
+6(e)
+Page 16 of 23
+EFTA00065080
+
+Case 9:08-cv-80736-KAM Document 212-1
+Entered on FLSD Docket 07/19/2013 Page 17 of
+Bates Range
+Box #2
+P-010758
+Thru
+P-010793
+Box #2
+P-010794
+Thru
+P-010829
+Box #2
+P-010830
+Thru
+P-010853
+Box #2
+P-010854
+Thru
+P-010876
+Box #2
+P-010877
+Thru
+P-010920
+Box #2
+P-010921
+Thru
+P-011049
+Box #2
+P-011050
+Thru
+P-011212
+Box #2
+P-011213
+Thru
+P-011237
+Box #2
+P-011238
+Thru
+P-011319
+Box #2
+P-011320
+Thru
+P-011361
+Box #2
+P-011362
+Thru
+P-011374
+Description
+File folder entitled "Original Proposed Ind."
+containing draft indictment
+File folder entitled "Epstein" containing sample
+indietments and attorney research re potential
+charges with attorney notes
+File folder entitled "1591 & Money Laundering"
+containing attorney research and handwritten
+notes
+Privilege(s) Asserted
+Work Product
+6(e)
+Deliberative process
+Work Product
+Work Product
+Work Product
+File folder entitled "Knowledge of Age"
+containing attorney research and handwritten
+notes
+File folder entitled "2423(b) Constitutionality and
+Purpose of Travel" containing attorney research
+and handwritten notes
+File folder entitled "Mistake not a
+Defense" containing attorney research and
+handwritten notes
+File folder entitled "Research re 'Pandering'"'
+containing attorney research and handwritten
+notes
+File folder entitled "Research re Grand Jury
+Instructions" containing attorney research ano
+handwritten notes
+File folder entitled "Telephone = Facility of
+Commerce" containing attorney research and
+handwritten notes
+File folder entitled "Def of Prostitution"
+containing attorney research and handwritten
+Work Product
+Work Product
+Work Product
+Work Product
+Work Product
+6(e)
+Work Product
+Work Product
+Page 17 of 23
+EFTA00065081
+
+Case 9:08-cv-80736-KAM Document 212-1
+Entered on FLSD Docket 07/19/2013 Page 18 of
+Bates Range
+Box #2
+P-011375
+Thru
+P-011456
+Box #2
+P-011457
+Thru
+P-011626
+Box #3
+P-011627
+Thru
+P-011662
+Box #3
+P-011663
+Thru
+P-011698 and
+P-012189 thru
+P-012361
+(gap was
+scanning error)
+Box #3
+P-011699
+Thru
+P-011777
+Box #3
+P-011778
+Thru
+P-011788
+Box #3
+P-011789
+Thru
+P-011879
+Box #3
+P-011880
+Thru
+P-011922
+Description
+File folder entitled "Relevant Florida Statutes"
+containing attorney research and handwritten
+notes
+File folder entitled "Unit of Prosecution
+Research" containing attorney research and
+handwritten notes
+File folder entitled "Attorney Notes" containing
+attorney handwritten and typed notes
+Privilege(s) Asserted
+Work Product
+Work Product
+Work Product
+File folder entitled "Drafts" containing draft
+indictments with attorney handwritten notes, draft
+internal memoranda, relevant witness interview
+reports and grand jury material and attorney
+handwritten notes
+6(e)
+Investigative Privilege
+Contains information subject
+to privacy rights of victims
+who are not parties to this
+6(e)
+Work product
+Deliberative process
+Work product
+File folder entitled "6/9/09 Signed Indictment"
+containing signed indictment package dated
+6/9/2009 with corrections
+File folder entitled "6/12/09 Victim Notif. Log"
+containing chart with victim contact information
+und attorney notes regarding dates and type ol
+contacts
+File folder entitled "Breach Memo" containing
+memorandum analyzing breach of Non-
+Prosecution Agreement with attachments
+Work product
+Deliberative process
+overt act summary charts for indictment
+Work product
+Attorney-client privilege
+Deliberative process
+6(e)
+Page 18 of 23
+EFTA00065082
+
+Case 9:08-cv-80736-KAM Document 212-1
+Entered on FLSD Docket 07/19/2013 Page 19 of
+Bates Range
+Box #3
+P-011923
+Thru
+P-011966
+Box #3
+P-011967
+Thru
+P-012016
+Description
+Folder entitled "Responses to Arguments from JE
+Counsel" containing:
+7/13/2007 letter from
+to
+with
+handwritten
+attorney (
+notes:
+6/25/2007 letter from
+to
+and
+handwritten attorney (
+6/25/2007 email from
+and
+with
+notes;
+to
+entitled Thoughts on
+¡letter"
+notes
+regarding main themes raised by Epstein counsel
+Composition bog territe Operation nee
+regarding investigation and case strategy
+Privilege(s) Asserted
+Work product
+Deliberative process
+6(e)
+Attorney-Client Privilege
+Work product
+Investigative privilege
+6(e)
+'ontains information subjec
+o privacy rights of victim
+who are not parties to this
+6(e)
+Box #3
+P-012017
+Thru
+P-012055
+Box #3
+P-012056
+Thru
+P-012088
+Box #3
+P-012089
+Thru
+P-012129
+Box #3
+P-012130
+Thru
+P-012150
+Box #3
+P-012151
+Thru
+P-012167
+Motion of Jeffrey Epstein to Intervene and to
+Quash Grand Jury Subpoenas and Incorporated
+Memorandum of Law
+Affidavit of
+Esq. in Support of
+Motion of Jeffrey Epstein to Intervene and to
+Quash Grand Jury Subpoenas
+6(e)
+6(e)
+Declaration of !
+6(e)
+x Parte Declaration Number One in Support c
+'nited States' Response to Motion to Quas
+Subpoenas
+Page 19 of 23
+EFTA00065083
+
+Case 9:08-cv-80736-KAM Document 212-1
+• Entered on FLSD Docket 07/19/2013 Page 20 of
+Bates Range
+Box #3
+P-012168
+Thru
+P-012170
+Box #3
+P-012171
+Thru
+P-012173
+Description
+Ex Parte Declaration Number Two in Support of
+United States* Response to Motion to Quash
+Subpoenas
+Supplement to Ex Parte Declaration Number One
+in Support of United States' Response to Motion
+to Quash Subpoenas
+Box #3
+P-012174
+Thru
+P-012176
+Box #3
+P-012177
+Thru
+P-012178
+Box #3
+P-012179
+Thru
+P-012188
+Draft of September 2009 letter from
+to
+regarding breach of Non
+Prosecution Agreement with handwritten attorney
+) notes
+Undated handwritten attorney (
+notes
+regarding negotiations and allegations
+File Folder entitled "FBI G.J. Log" containing
+copy of FBI grand jury subpoena log with
+attorney (L
+Privilege(s) Asserted
+6(e)
+Investigative Privilege
+6(e)
+Investigative Privilege
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+this litigation
+Work Product
+Attorney-Client Privilege
+Deliberative Process
+Work Product
+Attorney-Client Privilege
+Deliberative Process
+6(e)
+Investigative Privilege
+Also contains information
+subject to privacy rights of
+victims who are not parties to
+6(e)
+Work Product
+Box #3
+P-012362
+Thru
+P-012451
+File folder entitled "Key Documents" containing
+correspondence between AUSA and case agent
+regarding indictment prep questions, victim
+identification information, corrections to draft
+indictment, indictment preparation timeline, key
+Box #3
+P-012451
+Thru
+P-012452
+File folder entitled "Victim List" containing list
+of victims with dates of birth and age informatior
+Page 20 of 23
+EFTA00065084
+
+Case 9:08-cv-80736-KAM Document 212-1
+Entered on FLSD Docket 07/19/2013 Page 21 of
+Bates Range
+Box #3
+P-012453
+Thru
+P-012623
+Description
+Complete indictment package marked "Originals
+12/12/07"
+Privilege(s) Asserted
+Work-produet
+Deliberative process
+6(e)
+Also contains documents
+subject to investigative
+privilege
+Also contains documents
+subject to privacy rights of
+victims who are not parties to
+this litigation
+Also contains documents
+subject to privacy rights of
+victims who are not parties to
+Box #3
+P-012624
+Thru
+P-012653
+Box #3
+P-012654
+Thru
+P-012864
+Box #3
+P-012865
+Thru
+P-013226
+Box #3
+P-013227
+Box #3
+P-013226
+Thru
+P-013230
+Box #3
+P-013231
+Thru
+P-013239
+Folder entitled "(Victims) Additional 302's"
+containing reports of interviews conducted in
+June 2007, October 2007, and March 2008.
+3-ring binder entitled "Child Molesters:
+A
+Behavioral Analysis" with attorney d
+handwritten notes
+Indictment preparation binder containing:
+witness/victim list with identifying information,
+sexual activity summary, telephone call summary
+chart, attorney (
+302c portions of state investigative file, attorney
+yped notes, relevant pieces of gran
+ury materials, telephone records/flight record
+analysis charts, victim/witness photographs,
+records, NCICs, and related materials for
+persons identified as Jane Does #9, 10, 11, 12, 13,
+14
+April 23, 2008 Memo from
+I to
+Office of Professional Responsibility re Self
+Sipic Crit 21.200 Letter is one previously
+to
+Office of Professional Responsibility re Self
+April 22, 2008 Letter from A
+Work Product
+Deliberative Process
+6(e)
+Also contains documents
+subject to investigative
+privilege
+Also contains documents
+subject to privacy rights of
+victims who are not parties to
+this litigation
+Privacy Act
+Privacy Act
+Privacy Act
+Page 21 of 23
+EFTA00065085
+
+Case 9:08-cv-80736-KAM Document 212-1
+Entered on FLSD Docket 07/19/2013 Page 22 of
+Bates Range
+Box #3
+P-013240
+Thru
+P-013247
+Box #3
+P-013248
+Thru
+P-013251
+Box #3
+P-013252
+Thru
+P-013253
+Box #3
+P-013254
+Thru
+P-013257
+Box #3
+P-013258
+Thru
+P-013259
+Box #3
+P-013260
+Thru
+P-013262
+Description
+April 21, 2008 Letter from
+h to
+Office of Professional Responsibility re Self
+Reporting with attachments
+Emails between
+Assistant
+General Counsel, Executive Office for United
+States Attorneys, and 1
+Assistant U.S. Attorney, Southern District of
+Florida, regarding Formal Notice of Office-wide
+Recusal of Southern District of Florida dated
+August 24 and August 29, 2011
+Emails between
+Assistant
+General Counsel, Executive Office for United
+States Attorneys, and 1|
+Assistant U.S. Attorney,
+Southern District of
+Florida, regarding Recusal matter, dated July 28,
+August 3, and August 24, 2011
+Emails between
+Assistant
+General Counsel, Executive Office for United
+States Attorneys, and
+Assistant U.S. Attorney, Southern District of
+Florida, regarding Formal Notice of Office-wide
+Recusal of Southern District of Florida dated
+August 24 and August 29, 2011
+Emails
+between
+Assistant
+General Counsel, Executive Office for United
+States Attorneys, and
+, First
+Assistant U.S. Attorney, Southern District of
+Florida, regarding Formal Notice of Office-wide
+Recusal of Southern District of Florida dated July
+28 and August 3, 2011
+Email from
+Assistant General
+Counsel, Executive Office for United States
+Attorneys, to Wifredo Ferrer (U.S. Attorney.
+SDFL), Robert O'Neill (U.S. Attorney, MDFL).
+•. (FAUSA, SDFL), and
+MDFL) regarding Formal
+Notice of Office-wide Recusal of Southern
+District of Florida dated August 24, 2011. CC's
+KODAG). [
+(USAEO),
+(USAEO),
+(USAEO), I
+|(USAEO)
+Privilege(s) Asserted
+Privacy Act
+Attorney-Client Privilege
+Attorney-Client Privilege
+Attorney-Client Privilege
+Attorney-Client Privilege
+Attorney-Client Privilege
+Page 22 of 23
+EFTA00065086
+
+Case 9:08-cv-80736-KAM Document 212-1
+Entered on FLSD Docket 07/19/2013 Page 23 of
+Bates Range
+Box #3
+P-013263
+Thru
+P-013271
+Box #3
+P-013272
+Thru
+P-013278
+Description
+Emails between
+Assistant
+General Counsel, Executive Office for United
+States Attorneys, and |
+First
+Assistant U.S. Attorney, Southern District of
+Florida, regarding recusal of Southern District of
+Florida, dated July 29, 2011, with attached
+memorandum from
+to
+summarizing Jeffrey
+Epstein Investigation
+Emails between
+Executive Office
+for United States Attorneys,
+Southern District of Florida, seeking advice
+regarding office-wide recusal, dated December 16
+and 17, 2010, with attached letter from Paul
+Cassell to Wifredo A. Ferrer, dated December 10,
+2010
+Privilege(s) Asserted
+Attorney-Client Privilege
+Deliberative Process
+Work Product
+Attorney-Client Privilege
+Page 23 of 23
+EFTA00065087
\ No newline at end of file
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@@ -0,0 +1,86 @@
+From: Christian Everdell <
+To:
+Subject: [EXTERNAL] RE: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion
+Date: Mon, 22 Nov 2021 20:35:36 +0000
+Yes, we'll take care of the Witness-3 response now. I assume the Court will take care of its own order.
+From:
+Sent: Monday, November 22, 2021 3:30 PM
+To: Christian Everdell
+Subject: RE: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion
+Hey Chris,
+I think all that's left is your response on Witness-3, and then the Court's order.
+We'll circulate our proposed redactions to the Dietz/Loftus briefing tomorrow after the conference.
+Thanks,
+From: Christian Everdell •
+Sent: Monday, November 22, 2021 2:47 PM
+To:
+Subject: [EXTERNAL] RE: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion
+Will do. Taking care of it now.
+From:
+Sent: Monday, November 22, 2021 2:42 PM
+To: Christian Everdell
+Subject: RE: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion
+Hey Chris - yes, and you can also file your response on GX-52. (Our original letter is already on the docket at 457.)
+From: Christian Everdell
+Sent: Mondav. November 22, 2021 2:40 PM
+To:
+Subject: [EXTERNAL] FW: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion
+We now file our response to the birth certificate motion, right?
+From: NYSD_ECF_Pool@nysd.uscourts.gov
+Sent: Monday, November 22, 2021 2:03 PM
+To: CourtMail@nysd.uscourts.gov
+Subject: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion
+EFTA00086357
+
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-
+mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits attorneys of
+record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents
+filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other
+users. To avoid later charges, download a copy of each document during this first viewing. However, if the
+referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of New York
+Notice of Electronic Filing
+The following transaction was entered by
+Case Name:
+USA v. Maxwell
+Case Number:
+1:20-cr-00330-AJN
+Filer:
+USA
+Document Number: 488
+on 11/22/2021 at 2:03 PM EST and filed on 11/22/2021
+Docket Text:
+LETTER MOTION addressed to Judge Alison J. Nathan from
+dated November 18, 2021 re: Authenticate birth
+certificates . Document filed by USA as to Ghislaine Maxwell.
+1:20-cr-00330-AJN-1 Notice has been electronically mailed to:
+Bobbi C Sternheim
+Christian R. Everdell
+David Boies, "
+Jeffrey S. Pagliuca
+CaseView.ECF@ usdoj.gov, USANYS.ECF@ USDOJ.GOV
+CaseView.ECF@usdoj.gov, USANYS.ECF@USDOJ.GOV
+caseview.ect@usdoj.gov, usanys.ect@usdoj.gov
+ecf@sternheimlaw.com
+_autodocket@cohengresser.com
+NYC_ Managing_Clerk@bsfllp.com
+Katielynn Boyd Townsend
+CaseView.ECF@usdoj.gov, USANYS.ECF@ USDOJ.GOV
+Laura A. Menninger
+Mark Stewart Cohen
+CaseView.ECF@usdoj.gov. USANYS.ECF@USDOJ.GOV
+EFTA00086358
+
+Patrick J. Smith
+Sigrid S. McCawley
+1:20-cr-00330-AJN-1 Notice has been delivered by other means to:
+The following document(s) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1008691343 [Date=11/22/2021] [FileNumber=26830188
+-0] [26e81b320da409ccaa60e71b81a05379e51c46a710a011ba99578fc0d3cOabeba
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diff --git a/vision-joined/ds9-parsed-01/ba9d3eba5c65feded00d86ecb7834945b74230fc74fee7d89a35b00307b54e1d.md b/vision-joined/ds9-parsed-01/ba9d3eba5c65feded00d86ecb7834945b74230fc74fee7d89a35b00307b54e1d.md
new file mode 100644
index 0000000000000000000000000000000000000000..c8eb2281163c7c96df1af70a16212dec2686dc92
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@@ -0,0 +1,342 @@
+UNITED STATES DEPARIMENT OF JUSTICE
+METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
+DAILY LIEUTENANT'S LOG
+Shift-Day-Date: M/W Friday,
+August 09, 2019
+Beginning Count: 759
+Daily
+Sensitive Infornation:
+M/W
+I/M
+I/M
+o Suicide each hate cantonn
+I/M
+Ramos
+#85428-054 pending bed space (SHU)
+TIME
+CHRONOLOGICAL EVENTS
+12:00 AM
+Lieutenant
+assumes duties as
+Operations
+Lieutenant.
+operational
+w/exception of Control
+announcement conducted via the
+and/or Radio. Restraint Equipment Cage inventory conducted. All
+equipment accounted for. Metal
+Detector checks conducted. All
+operative w/the exception of Rear Gate/Facilities/R&D.
+Roof Check
+completed. All secure. Temporary Chit Inventory: #1:2; #2:5; #3:5;
+#4:6; #5:5; #6:0; Hosp: 0
+12:00
+AM
+Institution Count in progress
+12:00
+AM
+NYPD Phone Check #1142
+12:09
+AM
+Body Alarm testing in progress
+12:16 AM
+Body alarm testing completed
+12:30
+AM
+Watch Calls cont.
+12:35
+Good Verbal count announced
+Clear Institution count announced
+Institution Count in progress
++1 TRTY TRANS (return): Jones #06178-104 to IN
+Good Verbal count announced
+3:29
+AM
+Clear Institution count announced
+5:00 AM
+Institution Count in progress
+5:40
+AM
+Good Verbal count announced
+Clear Institution count announced
+Relieved of duties by Lt.
+as D/W Operations Lieutenant
+SEnt mere coned duang my tear of duty:
+The following Inmate(s) were placed in Administrative Detention:
+Reg: Number
+Unit
+Time
+SHU: 77/5
+BC
+T759
+SHU
+71/5
+759
+760
+760
+77/5
+77/5
+760
+760
+77/5
+77/5
+AD Order
+Ops It.
+Ending Count: 760 SHU: 77; 10-South: 05; SHU OBS: 00;
+Local Hosp: 00; H/A OBS: 02; B/A OBS: 00; Dry Cell: 00;
+H/A (PBS) ; 01; H/A (PCLAS): 00
+EFTA00061381
+
+UNITED STATES DEPARTMENT OF JUSTICE
+METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
+DAILY LIEUTENANT'S LOG
+SHIFT-DAY-DATE: D/W - Friday, August 09, 2019
+Beginning Count: 760
+D/W
+Daily Sensitive Information:
+I/M
+on Suicide Watch w/inmate companion
+I/M
+on Psych obs. w/inmate companion.
+I/M
+on DRY Cell w/staff watch in R&D.
+8:00 AM
+Lieutenant
+assumes duties as the Day Watch Operations
+Lieutenant. The fire alarm and pump system is inoperable at this
+time. Fire Watch is in Progress. Unable to conduct PREA
+announcement over the Institution Public Address System, due to,
+system malfunction. Restraint Equipment Cage inventory conducted.
+All equipment accounted for. Metal Detector checks conducted. All
+operative w/the exception of Rear Gate.
+Roof Check completed.
+All secure. Temporary Chit Inventory: #1:0; #2:5; #3:5; #4:6;
+#5:6; #6:5; Hosp: 0
+Daily Hand Stamp :DJBE/LEFT HAND
+8:00
+AM
+NYPD Phone Check #2286
+8:10
+AM
+Body Alarm Test Initiated.
+8:30
+AM
+AM Census Conducted
+8:38
+AM
+50501-054 BOOTH E01-506L to PRE REMOVE, 55210-053 BUSSEY E02-5130
+to PRE REMOVE. 85993-054 REYES Z06-220UAD to PRE REMOVE -3
+8:50
+AM
+Body Alarm Testing Complete.
+8:58
+AM
+K12-069U to L HOSP USM -1
+10:00
+AM
+81219-054 RAMIREZ
+E08-562L
+FT REL
+-1
+10:24
+AM
+-1 I/M Cuyler #89936-053 from ES to GCT REL
+11:24
+AM
+79951-054 LORA
+new commit +1
+12:30
+PM
+PM Census Conducted
+12:35
+PM
+1:10
+PM
+2:41
+PM
+3:15
+PM
+3:45
+PM
+4:00 PM
+return from L-Hosp +1
+I/M
+off
+suicide watch
+- 1
+I/M Jones #06178-104 from IN to TREATY TRANS
+I/M
+placed on dry cell from ZA
+Institutional lockdown for count.
+Relieved of duties by It.
+E/W Operations Lieutenant.
+Visitation: ZA
+Innates
+Adults
+Children
+17
+20
+9
+ION SCANNING TESTED HITS: 0
+STG/High Alert phone calls monitored:
+WITSEC inquiry(s) was/were received during my tour of duty: 0
+The following Inmate(s) were placed in Administrative Detention: 0
+Name
+Reg Number
+Reason
+Unit
+TIME
+SHU: 77/5
+760
+77/5
+757
+756
+755
+754
+755
+756
+755
+76/5
+76/5
+76/5
+76/5
+76/5
+75/5
+Total
+46
+A/D Order
+Ops It
+Act Lt
+Ending Count: 755 ; SHU:75 ; 10-South: 05; SHU OBS: 00;
+Local Hosp: 00; H/A OBS: 02; B/A OBS: 00; Dry Cell: 01
+EFTA00061382
+
+UNITED STATES DEPARTMENT OF JUSTICE
+METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
+DAILY LIEUTENANT'S LOG
+SHIFT-DAY-DATE: E/W - Friday, August 9, 2019
+Beginning Count: 755
+Daily Sensitive Information.
+I/M
+E/W
+I/M
+on Psych Obs w/inmate companion.
+on PSYCH OBS. W/inmate companion.
+I/M
+on Suicide watch w/inmate companion.
+I/M
+on suicide watch w/ inmate companion.
+I/M
+on Dry cell w/staff watch in R&D
+TIME
+CHRONOLOGICAL EVENTS
+Lieutenant
+assumes duties as the Evening Watch
+Operations Lieutenant. Unable to conduct PREA announcement over the
+Institution Public Address System, due to, system malfunction.
+4:00
+PM
+Restraint Equipment Cage inventory conducted. All equipment
+accounted for. Metal Detector checks conducted. All operative
+w/the exception of Rear Gate.
+Roof Check completed. All secure.
+Temporary Chit Inventory: #1:4; #2:4; #3:5; #4:5; #5:5; #6:3;
+4:00
+PM
+Institution count in progress.
+4:01
+PM
+NYPD Phone Check #2624
+4:08
+Body alarm testing in progress.
+4:37 PM
+Body alarm testing completed
+5:00 PM
+Good verbal count
+5:03 PM
+Clear institutional count.
+6:00
+PM
+Watch call in progress
+6:34 PM
+I/M Hemmingway #14728-053 from ZA to ES
+6:39 PM
++1 I/M Matthews #91753-054 from BAIBOND to RA
+6:47 PM
+I/M Reid #85609-054 from ZA to GS
+7:45 PM
+Trash run in progress
+8:12
+PM
++1 I/M Carreon #82858-198
+from BAILBOND to RA
+8:21 PM
+| I/M
+and
+from ZA to Suicide
+watch
+8:28 PM
+I/M Garcia-Pena #79043-054 from KN to ZA Introduction of tobacco
+8:36 PM
++1 I/M Mutimura #76329-054 from REL to RA
+8:42 PM
+Trash run complete
+10:00 PM
+Institutional count in progress.
+10:41 PM
+Good verbal count announced.
+10:43 PM Clear institutional count announced.
+12:00 AM
+Relieved of duties by
+as the M/W Lieutenant.
+INMATES
+32
+VISITING: KN
+ADULTS
+32
+CHILDREN
+7
+STG/High Alert phone calls monitored:
+WITSEC inquiry(s) was/were received during ay tour of duty: 0
+The following Inmate(s) were placed in Administrative Detention: 0
+NAME
+REG NUMBER
+REASON
+331
+UNIT
+KN
+TIME
+8:28 PM
+SHU: 75/5
+B/C
+755
+SHU
+75/5
+755
+75/5
+755
+| 74/5
+756
+73/5
+757
+71/5
+72/5
+758
+758
+172/5
+TOTAL
+71
+A/D ORDER
+YES
+EFTA00061383
+
+Ops. It.
+Act. It.
+UNITED STATES DEPARTMENT OF JUSTICE
+METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
+DAILY LIEUTENANT'S LOG
+[Ending Count: 758
+¡ SHU: 72; 10-South: 05; SHU OBS: 00;
+Local Hosp: 00; H/A OBS: 04; B/A OBS: 00; Dry Cell: 01;
+B/A SHU: 00
+EFTA00061384
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bab382206c89805bb7fe9a3bdd2827c782e7726d94b5b0d093c268ab5557c286.md b/vision-joined/ds9-parsed-01/bab382206c89805bb7fe9a3bdd2827c782e7726d94b5b0d093c268ab5557c286.md
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@@ -0,0 +1,29 @@
+From: Michael Vincent <
+To: "1
+Subject: ABC TV interview request
+Date: Mon, 27 Jan 2020 22:22:31 +0000
+Dear
+As discussed, I'm a senior reporter with the Australian Broadcasting Corporation's 730 program. We're the ABC's flagship
+current affairs TV program, similar to PBS' Newshour and the BBC's Newsnight. We broadcast to millions across the
+country and the Asia-Pacific, and have a large digital footprint too.
+I'm writing on behalf of the show to request an interview with the US Attorney for the Southern District of New York
+Geoffrey Berman regarding the ongoing investigation into the conduct of Jeffrey Epstein. Australia is already home to one
+key Jeffrey Epstein victim and there may well be others who are unaware that the USDOJ is continuing its investigations
+into the actions of others in Mr Epstein's circle.
+We could send a camera to him and it would take no more than 15 minutes of his time.
+I look forward to hearing from you.
+Thanks in advance
+Michael Vincent
+7.30
++61434686977
+@MVincentOZ
+Michael.vincent@abc.net.au
+-
+Please consider the environment before printing this e-mail.
+The information contained in this email and any attachment is confidential and may contain legally privileged or
+copyright material. It is intended only for the use of the addressee(s). If you are not the intended recipient of this
+email, you are not permitted to disseminate, distribute or copy this email or any attachments. If you have
+received this message in error, please notify the sender immediately and delete this email from your system. The
+ABC does not represent or warrant that this transmission is secure or virus free. Before opening any attachment
+you should check for viruses. The ABC's liability is limited to resupplying any email and attachments.
+EFTA00074118
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bab4bdee5c361872d72e443cf4b5936336e5e13585709c76cdc2ced6e8a5a5a3.md b/vision-joined/ds9-parsed-01/bab4bdee5c361872d72e443cf4b5936336e5e13585709c76cdc2ced6e8a5a5a3.md
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@@ -0,0 +1,35 @@
+From: "
+To: "
+(USANYS)"
+- (NY) (OGA) (FBI)" <
+(OIG)" <
+Subject: RE:
+Interview
+Date: Tue, 20 Aug 2019 02:10:23 +0000
+- (OIG)"
+1. (NY) (FBI)" ≤
+- (NY) (FBI)"
+(USANYS)" <
+Sure, the issue is that these folks are calling from the MCC, with their grand jury date tomorrow, and so we need to lock in
+dates relatively quickly. Can you send us any non-Epstein investigation related scheduling conflicts for the next week so
+we can try to work around them? And if there's a resources issue, let us know if there's anything we can do and I'd be
+happy to go to bat to try to get whatever you need. Thanks!
+From:
+- (NY) (OGA) <
+Sent: Monday, August 19, 2019 9:04 PM
+To: [
+1. (OIG) ‹
+1. (OIG) <
+| (USANYS) <
+(NY) (FBI) <|
+]. (NY) (FBI) <
+(USANYS) <
+Subject:
+Interview
+Can we all coordinate to check availability before we keep scheduling, especially since we need oig and fb
+resent. And even more so if we have multiple interviews the same day and time
+-
+On Aug 19, 2019 9:02 PM,
+(USANYS)" <
+> wrote:
+EFTA00094948
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bada2f4ed5502bc31780d4b87438745927e029a6446064877e4538bcee43076f.md b/vision-joined/ds9-parsed-01/bada2f4ed5502bc31780d4b87438745927e029a6446064877e4538bcee43076f.md
new file mode 100644
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@@ -0,0 +1,56 @@
+From: "Berman, Geoffrey (USANYS)" <
+To:
+Ce:
+(OPA)" <
+(OAG)" 4
+Subject: |
+Date: Sat, 10 Aug 2019 16:15:00 +0000
+(OAG)"
+Thanks. Geoff
+On Aug 10, 2019, at 11:57 AM,
+|(OPA) 4
+> wrote:
+Yes, the following:
+"I was appalled to learn that Jeffrey Epstein was found dead early this morning from an apparent
+suicide while in federal custody. Mr. Epstein's death raises serious questions that must be answered.
+I have ordered a full, thorough, and independent investigation be conducted into the circumstances
+of Mr. Epstein's death."
+From: Berman, Geoffrey (USANYS) <|
+Sent: Saturday, August 10, 2019 11:57 AM
+To:
+Cc=
+(OAG) ‹
+(OPA) <
+Subjecti
+Does the AG plan on issuing a statement? Geoff
+On Aug 10, 2019, at 11:06 AM,
+(OAG) 4
+Geoff. Is the FBI on scene yet?
+Tim
+On Aug 10, 2019, at 10:55 AM, Berman, Geoffrey (USANYS) ‹|
+Ok. Geoff
+On Aug 10, 2019, at 10:44 AM,
+|(OAG) <
+> wrote:
+• wrote:
+(OPA) <
+> wrote:
+Inmate Death at the MCC New York
+New York, NY: On Saturday, August 10, 2019, at approximately 6:30 a.m., inmate Jeffrey Edward Epstein
+was found unresponsive in his cell in the Special Housing Unit from an apparent suicide at the
+Metropolitan Correctional Center (MCC) in New York, New York. Life-saving measures were initiated
+immediately by responding staff. Staff requested emergency medical services (EMS) and life-saving
+efforts continued. Mr. Epstein was transported by EMS to a local hospital for treatment of life-
+threatening injuries, and subsequently pronounced dead by hospital staff. The FBI is investigating the
+incident.
+EFTA00077545
+
+Mr. Epstein was a 66-year-old male who arrived at MCC New York on July 6, 2019 under pretrial status
+after being indicted for sex trafficking of minors and conspiracy.
+MCC New York is an Administrative security facility that currently houses 763 male offenders in New York,
+New York.
+Additional information about the Federal Bureau of Prisons can be found at www.bop.gov.
+Director
+Office of Public Affairs
+U.S. Department of Justice
+EFTA00077546
\ No newline at end of file
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@@ -0,0 +1,77 @@
+OR ARTMENT UP
+JUSTICE
+PRISONS
+UNITEL TATES GOVERNMENT
+Memorandum
+FEDERAL BUREAU OF PRISONS
+Metropolitan Correctional Center
+July 23, 2019
+MEMORANDUM FOR ALL CONCERNED
+FROM:
+, Operations Lieutenant
+SUBJECT:
+Possible Suicide Attempt
+On July 23, 2019 at approx. 1:27 a.m., a call for assistance on the Special Housing Unit
+was announced by the Control Center. Upon my arrival I was informed that an inmate
+had attempted suicide and proceeded to cell, Z05-124LAD. I observed inmate
+Epstein, Jeffrey #76318-054 lying in the fetal position on the floor of his cell wearing a
+t-shirt and boxers. He was breathing heavily and was snoring. I called out to inmate
+Epstein and observed him flicker his eyes and continue snoring. His neck was red
+with no abrasions. I observed no further injuries to his person. An attempt was made
+to get the inmate to stand on his own with negative results. The inmate was placed in
+hand restraints and staff was directed to retrieve the stretcher. As inmate Epstein was
+being placed on the stretcher by responding staff, he would open his eyes and observe
+staff. When staff made eye contact with him, he would hurriedly shut his eyes. The
+inmate was taken to HA-Unit, dressed in the suicide smock and placed on suicide
+watch. While awaiting the arrival of an inmate companion, inmate Epstein sat on the
+edge of the bed and began moving forward as if he was attempting to fall over head
+first. When | looked away, he straightened up. As I turned to look at him again, he
+attempted the same act. I laid him down on the bed and directed him to cease his
+action or he would be placed in restraints for his safety. At that moment, he stated,
+"Okay, I won't do it again," and gave the thumbs up. Because of his unpredictable
+behavior, the decision was made to have a staff member observe inmate Epstein. !
+left HA-Unit in order to make staff notifications. Moments later, I spoke with Officer
+Clarke who stated that inmate Epstein was alert and had indicated that his cellmate,
+Tartaglione, Nicholas #78514-054 had attempted to kill him and had been harassing
+him. He stated that the inmate had indicated that he'd informed his attorney of this
+matter.
+I photographed and spoke with inmate Tartaglione, Nicholas #78514-054 who stated
+that he was asleep with his headphones on when he felt something hit his legs and
+said, "Jeff, what you're doing?" He didn't answer, so he got up, turned on the light and
+saw him with a string around his neck. He stated that he then called the guards and
+ASensitive Limited Official Use Onlya
+EFTA00122680
+
+' they ran down. Upon fu..ner questioning, inmate Tartaglione viated that he sleeps on
+the bottom bunk, but gave it to inmate Epstein because he's old. He stated that he
+sleeps on the floor on a mattress. He stated that when he got up, he couldn't
+remember if he sat up or stood up to check on Epstein. He stated that Epstein was
+sitting on the floor leaning to the side with his eyes opened, but wasn't responding. He
+stated that the last time he saw him he was snoring really loud.
+Inmate Epstein stated that he came in from a legal visit at approx. 8:00PM and staff
+handed him a copy of the Daily News. "Nick" was on the floor reading the Daily News.
+He stated that he had given it to him. He stated that Tartaglione mentioned that he'd
+been in court all day in Westchester and was carrying on. At that point, inmate
+Tartaglione paused as if he was making the story up as he went along, and stated that
+Tartaglione stated, "These fucking niggers. This place is inhumane, I wish I could
+report it.
+(Officer), that nigger hobbit mother fucker." He then turned to a page in
+the Daily News that had his picture on it and stated that Epstein was worth seventy
+seven million dollars. Epstein stated that he took his picture, balled it up and threw it in
+the garbage. I asked inmate Epstein what happened prior to staff's arrival. He stated
+that at approx. 1:00 AM, he'd gotten up to get a drink of water, as he gets up every
+thirty minutes. He remember walking back to his bunk and waking up with staff there
+in his cell.
+I asked if he'd waken up and seen staff, why didn't he respond when we
+were calling out to him? He stated that he only remembered hearing himself making a
+noise like snoring. When asked about the allegations against his cellmate, he stated
+that he was told, if he hurt him, staff wouldn't care.
+Duty medical,
+was notified and briefed. It was determined no further
+medical attention was needed. A medical assessment was not conducted at the time
+of this incident, due to the fact, there was no medical staff available after 10:00 PM.
+Upon the arrival of medical staff, inmate Epstein was examined and treated by,
+for a circular line of erythema at the base of the neck, one section on the front
+with marks of friction and a small erythema on his left knee.
+ASensitive Limited Official Use Only=
+EFTA00122681
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bb2e9bc309764fbeda770ae5f697ab203fec59e0d0dea5fea1cbf6ddd3d50ae4.md b/vision-joined/ds9-parsed-01/bb2e9bc309764fbeda770ae5f697ab203fec59e0d0dea5fea1cbf6ddd3d50ae4.md
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@@ -0,0 +1,47 @@
+From:
+To:
+(USANYS)" <
+Subject: RE: Epstein
+Date: Thu, 13 Jun 2019 13:32:39 +0000
+12:30p sounds good, your office?
+From:
+(USANYS) [mailto:
+Sent: Thursday, June 13, 2019 9:32 AM
+To:
+Subject: RE: Epstein
+How is 12:30 or, if not, 3:30?
+From:
+To:
+Sent: Thursday, June 13, 2019 9:26 AM
+| (USANYS) <
+Subject: RE: Epstein
+Let me know when can meet today, I'm free most of the day.
+From:
+(USANYS) [mailto:
+Sent: Wednesday, June 12, 2019 10:48 PM
+To: Watson, Sean P. (NY) (FBI)
+Subject: RE: Epstein
+Sounds good. I have a meeting at 11 tomorrow but am otherwise around.
+From: Watson, Sean P. (NY) (FBI)
+Sent: Wednesday, June 12, 2019 7:57 PM
+To:
+| (USANYS) <
+Subject: Re: Epstein
+I'm around the rest of the week. I'Il touch base tomorrow morning to confirm a time and place.
+Thanks,
+On Jun 12, 2019 5:35 PM, "I
+Hi Sean,
+(USANYS)" {
+> wrote:
+Hope you are well. Wondering if you have a few minutes this week to discuss Epstein in light of our expedited
+timetable of charging in the next few weeks. In particular, I was hoping to discuss (i) making sure we all review the
+remainder of the case file that is now up from Florida in advance of charging - my understanding is we are still waiting
+EFTA00102115
+
+for approval to have it scanned; (ii) making sure to get all the physical evidence from Florida and review it; and (iii) what
+plans are being made for surveillance and what will ultimately be an extensive operation around arrest time of
+multiple approaches, etc. Given that this all may go down pretty soon, I just wanted to be on the same page from a
+supervisory level in terms of getting everything done. I am out of the country the first three days of next week but if
+you have a brief time period to chat or meet in the next two days, that would be great.
+Best,
+EFTA00102116
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bb61036b04abbd023788a2db331c206b603b731b24a8e5d6fc9ef1f6f3740904.md b/vision-joined/ds9-parsed-01/bb61036b04abbd023788a2db331c206b603b731b24a8e5d6fc9ef1f6f3740904.md
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@@ -0,0 +1,16 @@
+From: '
+To:
+Cc:
+Subject: Memo
+Date: Fri, 12 Jul 2019 19:36:32 +0000
+Importance: Normal
+Attachments: 2019-07-12_JE_response_to_bail_release_request_draft_4_-_CLEAN.doex; 2019-07-
+12_JE_response_to_bail_release_request_draft_4.docx
+Revised version attached in both clean and track. The only suggestion not addressed is I
+about the trust account which I'II need more information from the team about to address.
+question/suggestion
+Public Corruption Unit
+U.S. Attorney's Office for the
+Southern District of New York
+Tel.
+EFTA00071672
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bb8857f6f63904825ceea70ed167e8e9c932c659bdcc03966fe7c2d47cf174f4.md b/vision-joined/ds9-parsed-01/bb8857f6f63904825ceea70ed167e8e9c932c659bdcc03966fe7c2d47cf174f4.md
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@@ -0,0 +1,92 @@
+From:
+To: Jill Greenfield <
+Cc: Louise Scott <
+Subject: RE: SDNY investigation [FFW-DOCS.FID6003375]
+Date: Thu, 30 Jul 2020 18:05:34 +0000
+Inline-Images: image002.png; image003 png; image004.jpg
+P, Kyle Phillips
+Jill,
+Thanks very much for being in touch, and we would welcome the opportunity to follow up on those topics. Would it work
+to schedule a call for Wednesday, August 12? We could do 4:00 p.m. London time (11:00 a.m. for us), if that would be
+convenient for you? And we can schedule it as a WebEx so we can see each other, if that's alright, or do it as a call if you
+prefer.
+thanks,
+From: Jill Greenfield <
+Sent: Thursday, July 30, 2020 12:51
+To:
+Cc: Louise Scott <
+P; Kyle Phillips <
+Subject: RE: SDNY investigation [FFW-DOCS.FID6003375]
+Thanks
+I have been in discussions with my client and we ought to be in a position to provide you with more information in the
+categories suggested. I am away next week but shall we schedule a call on my return, the week commencing 10th August?
+Kind regards,
+Jill
+Jill Greenfield
+Partner
+D:
+M:
+Click here for information relating to Covid-19 business impacts
+ff in
+From:
+Sent: Monday, July 20, 2020 4:19 PM
+EFTA00080953
+
+To: Jill Greenfield <
+Cc: Louise Scott <
+P; Kyle Phillips <
+Subject: RE: SDNY investigation
+Jill, Kyle,
+Following up on our recent WebEx discussion, and with apologies for the slight delay, we wanted to get you a list of initial
+categories of question that we think might assist in your discussion with your client, with the goal of then doing an
+attorney proffer, or attorney summary, and discussing possible next steps.
+We note that the below questions are simply general thoughts and suggestions-some may not need to be asked at all,
+others may prompt follow-up from you in the moment, etc. In any interviews with us, we ordinarily are guided both by
+the comfort level and the narrative of the witness, but we hope these give you a sense of what we would be interested
+in. We also note that we included questions about sexual contact because it is our very general understanding from you
+that abuse occurred, but we do not make any presumptions about what happened, if anything, separate from what your
+client recalls. On that note, as we've discussed, but to reiterate, if there are any questions or topics your client is
+uncomfortable addressing, there will be no pressure from us to do so, including at this early stage.
+With those caveats, possible questions are below, and please let us know if it would be useful for us to chat again before
+you talk with your client, or otherwise please let us know when it would next be appropriate to check in.
+Questions / topics:
+1) General background queries: Where did you grow up? How far did you go in school? What is your date of birth?
+How generally would you describe your upbringing and early professional life?
+2) How did you initially meet Ghislaine Maxwell and Jeffrey Epstein, and how old were you at that time? What was the
+nature of your work with them, and did the role change over time? How long did you work for Maxwell and/or
+Epstein?
+3) In general, what kinds of tasks did you perform for Maxwell or Epstein, and in what locations? Did you travel with
+either of them? When you weren't traveling with them, where did you reside? Did you ever reside with Maxwell or
+Epstein? If so, where - in what locations and at which properties?
+4) Did there come a time when Epstein and/or Maxwell engaged in sexual contact with you? If so, how did that happen
+the first time? Were there sexualized discussions or was there sexualized conduct leading up to any first incident?
+5) Were there other instances when you experienced sexual abuse or sexual contact while working for Maxwell? If so,
+how did those incidents occur? Did they occur with Epstein alone, or was Maxwell ever directly involved in the sexual
+contact? Did Maxwell ever observe, or was she present for, sexual contact that she herself was not participating in?
+Were any other individuals present or participating?
+6) Were you aware of any other girls or women who were subject to sexual abuse or contact by Epstein and/or Maxwell,
+and if so, who? Did you ever see Epstein or Maxwell involved in sexual or other intimate contact with other girls you
+believed or suspected may have been under the age of 18? And if so, under what circumstances (when, where, etc.)?
+7) How did your interactions with Epstein and Maxwell end? Did either of them contact you or attempt to contact you
+when Epstein was under investigation in 2006-08? Did either of them contact you or attempt to contact you during
+the New York investigation in 2018-20? If so, what was the nature of that contact? When is the last time you spoke
+with or otherwise interacted with Epstein and/or Maxwell?
+thank you,
+Assistant U.S. Attorney
+Southern District of New York
+EFTA00080954
+
+Fieldfisher, Riverbank House, L
+, London EC4R 3TТ.
+www.fieldfisher.com
+e do not intend to change our bank details. If you receive any communication that any of our bank details have changed, telephone us and speak to your conta
+our office before transferring any funds. We do not accept responsibility for monies paid into a wrong bank account in any circumstance
+This email and any attachments are confidential and may also be privileged. If you receive this message in error, please contact the sender immediately, destroy the
+email and any attachments and do not use, copy, store or disclose this email and any attachments for any purpose. Fieldfisher does not accept service of
+documents by electronic means without express prior agreement.
+For details about what personal information we collect and why, please see our Privacy Notice on our website at www.fieldfisher.com.
+Fieldfisher is the trading name of Fieldfisher LLP, a limited liability partnership registered in England and Wales (registered number OC318472) and is authorised
+and regulated by the Solicitors' Regulation Authority. A list of its members and their professional qualifications is available at its registered office, Riverbank House, L
+. London EC4R 3TT. We use the term partner to refer to a member of Fieldfisher LLP or an employee or consultant with equivalent standing or
+qualifications.
+EFTA00080955
\ No newline at end of file
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@@ -0,0 +1,10 @@
+From:
+Subject: RE: [EXTERNAL EMAIL] - Epstein image & video files
+Date: Tue, 20 Oct 2020 22:32:00 +0000
+Embedded: RE:_[EXTERNAL_EMAIL]_-_Epstein _image _&.
+- video_files.msg
+Sender:
+Subject: RE: [EXTERNAL EMAIL] - Epstein image & video files
+Message-Id: <1d373dba-8390-4a4d-9803-2241e2a2b522@fbi.gov>
+Recipient: J
+EFTA00100791
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+ }
+ ],
+ "sha": "bc0778f0f69fc050bae0c760cda01ba040c097211f4062c6a150100b837acbd3"
+}
diff --git a/vision-joined/ds9-parsed-01/bc0778f0f69fc050bae0c760cda01ba040c097211f4062c6a150100b837acbd3.md b/vision-joined/ds9-parsed-01/bc0778f0f69fc050bae0c760cda01ba040c097211f4062c6a150100b837acbd3.md
new file mode 100644
index 0000000000000000000000000000000000000000..c62b902eaffe804e25e1c7401b34a191a99b1476
--- /dev/null
+++ b/vision-joined/ds9-parsed-01/bc0778f0f69fc050bae0c760cda01ba040c097211f4062c6a150100b837acbd3.md
@@ -0,0 +1,96 @@
+EDWARDS
+POTTINGER LLC
+Florida Office
+Bradley J. Edwards *0t
+Seth M. Lehrman "+
+Brittany N. Henderson *0
+Matthew D. Weissing *f
+425 North Andrews Avenue
+Suite 2
+Fort Lauderdale, FL 33301
+Telephone (954)524-2820
+Fax (954)524-2822
+October 21, 2020
+FOIA PRIVACY EXEMPTION
+VIA E-MAIL AND FEDEX
+The Honorable Geoffrey S. Berman
+United States Attorney for the
+Southern District of New York
+New York Office
+J. Stanley Pottinger ‡
+• ramina mite in Calmi
+• Admitted in Florida
+1 Bond Cried Gird Trial ayer
+Assistant United States Attorney
+86 Chambers Street, Third Floor
+New York, New York 10007
+Re:
+Request for Tangible and Documentary Evidence (Touhy Request)
+et al., SDNY Case No. 1:19-cv-07772
+Dear
+In follow up to our previous communications, please accept this as our formal written request for
+documentary and tangible evidence currently in the in the possession, custody, and control of the
+Department of Justice by way of the Southern District of New York relating to the sexual abuse of
+one of Jeffrey Epstein's many victims,
+' See United States ex rel. Touhy v. Ragen,
+340 U.S. 462 (1951). We make this written request pursuant to the Touhy regulations codified as
+28 C.F.R. § 16.21 et seq. Should you find there to be any deficiencies within this request, please
+notify us and we will do what is necessary to correct any such shortcomings.
+' To protect her anonymity, our client,
+has elected to proceed as a l
+we have referred to her herein using the pseudonym under which she has filed her lawsuit.
+As such,
+EFTA00089719
+
+Page 2
+We specifically seek copies of the following documents that we believe are currently in the
+possession of the Government:
+1) Photographs of L
+2) Videos of l
+3) Any and all correspondence between Jeffrey Epstein, his agents, employees, medical
+providers, or attorneys and
+4) Any and all records of purchases of gifts or anything of value purchased for or sent to
+5) Any and all records showing that a letter or package was sent via U.S. Mail, UPS, FedEx,
+or by any other means of shipping from Jeffrey Epstein, his agents, or his employees to
+6) Any and all records of payments made to medical providers on behalf of
+7) Any and all records of payments made to attorneys on behalf of |
+8) Any and all records of payments made to accountants on behalf of
+9) Any and all documents referencing
+residing atl
+10) Any and all documents including
+true name;
+11) Any and all lists including
+true name; and
+12) Any and all other documentary materials relating in any way to|
+Pursuant to the Touhy regulations set forth by the Department of Justice, the Deputy or Associate
+Attorney General assesses the following considerations in determining whether disclosure is
+warranted:
+(a)(1) Whether such disclosure is appropriate under the rules of procedure
+governing the case or mater in which the demand arose;
+(a)(2) Whether disclosure is appropriate under the relevant substantive law of
+privilege. This request satisfies both of these considerations. As explained
+previously, the requested non-privileged documentary evidence directly concerns
+the allegations in
+civil case.
+Due to the establishment of the Epstein Victim Compensation Program that is currently underway,
+seeks this information on an expedited basis in order to properly and completely
+present her claim for consideration, and if necessary, to continue to proceed by way of formal
+EFTA00089720
+
+Page 3
+litigation. The requested information is within the scope of ordinary practice and does not seek
+enforcement purposes that would interfere with ongoing law enforcement proceedings.
+• simply requests information in the Government's possession that will assist in the prosecution
+of her claims and ultimately, aid in her ability to finally obtain the justice that she deserves. To the
+extent that the requested materials can be made available to l
+| on an expedited basis, it
+would be greatly appreciated
+Please contact us at your earliest convenience to discuss the identity of
+at which time we are fully prepared to answer any questions that you may have.
+in more detail,
+Very truly yours,
+EDWARDS POTTINGER LLC
+BEe
+Bradley Edwards
+Brittany Henderson
+EFTA00089721
\ No newline at end of file
diff --git a/vision-joined/ds9-parsed-01/bc1da37faa72b826e07c82b5741ddd48fe1c0981909c5305e71de6326c4606cf.json b/vision-joined/ds9-parsed-01/bc1da37faa72b826e07c82b5741ddd48fe1c0981909c5305e71de6326c4606cf.json
new file mode 100644
index 0000000000000000000000000000000000000000..487b02bccc2d4cb180d9f6ed16ec5f3a2b0c78cd
--- /dev/null
+++ b/vision-joined/ds9-parsed-01/bc1da37faa72b826e07c82b5741ddd48fe1c0981909c5305e71de6326c4606cf.json
@@ -0,0 +1,33 @@
+{
+ "chars": 1487,
+ "failed_pages": [],
+ "ocr_model": "pdfkit_2000px_apple_vision_accurate_en_us",
+ "page_count": 2,
+ "pages": [
+ {
+ "bad_lines": 0,
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+ "failed": false,
+ "lines": 47,
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+ "model": "pdfkit_2000px_apple_vision_accurate_en_us",
+ "page": 1,
+ "status": "done",
+ "stderr_bytes": 0
+ },
+ {
+ "bad_lines": 0,
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+ "page": 2,
+ "status": "done",
+ "stderr_bytes": 0
+ }
+ ],
+ "sha": "bc1da37faa72b826e07c82b5741ddd48fe1c0981909c5305e71de6326c4606cf"
+}
diff --git a/vision-joined/ds9-parsed-01/bc1da37faa72b826e07c82b5741ddd48fe1c0981909c5305e71de6326c4606cf.md b/vision-joined/ds9-parsed-01/bc1da37faa72b826e07c82b5741ddd48fe1c0981909c5305e71de6326c4606cf.md
new file mode 100644
index 0000000000000000000000000000000000000000..c0a94f3f3815d4a98e06108da02c08131c8ca19a
--- /dev/null
+++ b/vision-joined/ds9-parsed-01/bc1da37faa72b826e07c82b5741ddd48fe1c0981909c5305e71de6326c4606cf.md
@@ -0,0 +1,58 @@
+Service Request #24975
+Raid just crashed
+Status: FBOP Assigned
+Priority: P3 (Next Day)
+Type: Service Contract
+Assigned To: Jeff Cranor, Jeff McKenzie, Justin
+Houston
+Customer: | FBOP MCC New York MS0109 (130104.001)
+Contact:
+Date Created: Aug 8, 2019
+Next Appt.:
+Service Location: Main Location
+150 PARK ROW
+NEW YORK, NY 10007
+Bill To: FBOP MCC New York MS0109 (130104.001)
+150 PARK ROW
+NEW YORK, NY 10007
+PO #:
+Additional Information & Custom Fields:
+Is this a emergency request: Yes. You must call
+Is the system in question under
+any warranty:
+What is the system in question :
+When was the problem first
+discovered:
+Today
+PO Number:
+Who reported the problem initally:
+Is this a consistent permittent
+CONSISTENT
+Is this problem effecting all users: YES
+Is there power to the device in
+question:
+YES
+Do you have a spare device te: Unknown
+Can you send a picture of the No
+device:
+Has any work been done in the No
+area involved:
+Can you describe what is or is not recording
+happening:
+Material Required For Request: PHONE SUPPORT
+Who Requested the service call :
+Detailed Description:
+Raid is showing 2 "S"s on the display. Hughwon is going to get new drives from computer services for the raid and replace them in the morning
+Schedule
+EFTA00117596
+
+When
+Aug 8 - 16, 2019, all-
+Assigned To
+Jeff Cranor, Justin Houston, Jeff McKenzie
+| Comment
+Jeff Cranor will be working on this. Get a case started with Qognify.
+Equipment - No Equipment
+No Comments
+Details - No Detail Items
+EFTA00117597
\ No newline at end of file
diff --git a/vision-joined/ds9-parsed-01/bc247c08b34b4e880348b8e17d2f6061a76831f084c9744e70b3ffa3f89cb5ee.json b/vision-joined/ds9-parsed-01/bc247c08b34b4e880348b8e17d2f6061a76831f084c9744e70b3ffa3f89cb5ee.json
new file mode 100644
index 0000000000000000000000000000000000000000..2e9240e1120285417df1fa4fe32626127632d441
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+++ b/vision-joined/ds9-parsed-01/bc247c08b34b4e880348b8e17d2f6061a76831f084c9744e70b3ffa3f89cb5ee.json
@@ -0,0 +1,129 @@
+{
+ "chars": 12496,
+ "failed_pages": [],
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+ "page_count": 10,
+ "pages": [
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+ },
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+ "status": "done",
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+ }
+ ],
+ "sha": "bc247c08b34b4e880348b8e17d2f6061a76831f084c9744e70b3ffa3f89cb5ee"
+}
diff --git a/vision-joined/ds9-parsed-01/bc247c08b34b4e880348b8e17d2f6061a76831f084c9744e70b3ffa3f89cb5ee.md b/vision-joined/ds9-parsed-01/bc247c08b34b4e880348b8e17d2f6061a76831f084c9744e70b3ffa3f89cb5ee.md
new file mode 100644
index 0000000000000000000000000000000000000000..9d8845da4f29a972b30be32bca5855b51b8f7dda
--- /dev/null
+++ b/vision-joined/ds9-parsed-01/bc247c08b34b4e880348b8e17d2f6061a76831f084c9744e70b3ffa3f89cb5ee.md
@@ -0,0 +1,339 @@
+NANTER FOR FRO
+MISSING &
+EXPLOITED
+CHILDREN
+CyberTipline Report 83658616
+Priority Level: 3
+(Additional information required to determine possible risk)
+Received by NCMEC on 12-15-2020 23:52:05 UTC
+All dates are displayed as MM-DD-YYYY
+Except for times provided in Additional Information sections, all time zones are displayed in UTC
+Executive Summary
+The following is a brief overview of information contained in this CyberTipline report:
+Incident Type: Child Sex Trafficking
+CMEC Incident Type is based on CME's review of the report OR a "Hash Match" of one or more uploaded files. NCME may not have viewed all
+uploaded files submitted by the reporting ESP
+The National Center for Missing & Exploited Children (NCMEC) was incorporated in 1984 by child advocates as a private, non-profit
+501(c)(3) organization to serve as a national clearinghouse and resource center for families, victims, private organizations, law
+enforcement, and the public on missing and sexually exploited child issues. To further our mission to help find missing children, reduce
+child sexual exploitation, and prevent future victimization, NCMEC operates the CyberTipline and Child Victim Identification Program.
+NCMEC makes information submitted to the CyberTipline and Child Victim Identification Program available to law enforcement and
+investigate and cannot verify the accuracy of the information submitted by reporting parties.
+EFTA00129101
+
+CyberTipline Report 83658616 | i
+Contents
+Section A: Reported Information
+Reporting Person
+Incident Information
+Other
+Section B: Automated Information Added by NCMEC Systems
+Explanation of Automated Information (in alphabetical order)
+Section C: Additional Information Provided by NCMEC
+NCMEC Note #1
+NCMEC Note #2
+NCMEC Note #3
+NCMEC Note #4
+Supplemental Files
+Section D: Law Enforcement Contact Information
+_CSTT_FBI (Alexandria)
+2
+8
+This Report is provided solely for informational purposes pursuant to NCMEC's nonprofit missior
+lease freat all information in this Report as confidentia
+EFTA00129102
+
+CyberTipline Report 83658616 |
+Section A: Reported Information
+The following information was submitted to the CyberTipline by the Reporting Person or Reporting ESP. The information appearing in
+Section A is information received in the original submission. The reporting of information in Section A, other than the "Incident Type"
+and "Incident Time," is voluntary and undertaken at the initiative of the Reporting Person or Reporting ESP.
+Reporting Person
+Submitter:
+Kathryn Dee
+Phone:
+IP Address:
+Received by NCMEC on 12-15-2020 23:52:05 UTC
+Incident Information
+Incident Type:
+Incident Time:
+Child Sex Trafficking
+12-15-2020 23:49:00 UTC
+Additional Information:
+Other
+Epsteins private group is still active and Jennifer Dee young is the ringleader. Who is Destiny
+in Tampa, FL,
+This concludes Section A. All of the information in this section was submitted electronically to the CyberTipline by the Reporting Person,
+NCMEC Call Center or Reporting ESP. The information appearing in Section A is information received in the original submission. The
+reporting of information in Section A, other than the "Incident Type" and "Incident Time," is voluntary and undertaken at the initiative of
+the Reporting Person or Reporting ESP.
+This Report is provided solely for informational purposes pursuant to NCMEC's nonprofit missior
+Please treat all information in this Report as confidentia
+EFTA00129103
+
+CyberTipline Report 83658616 | 2
+Section B: Automated Information Added by NCMEC Systems
+Upon receipt of a CyberTipline report, NCME Systems may conduct automated processes on the information submitted in Section A.
+The information found in Section B of this CyberTipline Report has been automatically generated by NCMEC Systems. If the
+CyberTipline Report was submitted by a member of the public, Section B will be blank.
+Explanation of Automated Information (in alphabetical order)
+Geo-Lookup: When a Reporting ESP voluntarily reports an IP address for the "Suspect," NCMEC Systems will geographically resolve
+the IP address via a publicly-available online query. The results of this lookup are displayed
+Geolocation data is approximate and may not display a user's exact location. Please be aware that the geolocation information provided
+is not exact but is providing a reliable estimate of location based on IP address(es) voluntarily provided by the reporting ESP.
+This concludes Section B
+This Report is provided solely for informational purposes pursuant to CMEC's nonprofit mission
+Please treat all information in this Report as confidential.
+EFTA00129104
+
+CyberTipline Report 83658616 | 3
+Section C: Additional Information Provided by NCMEC
+Section C contains information collected by NCMEC staff based on the information electronically submitted by the Reporting Person
+NOMEC Call Center or Reporting ESP. Section C may contain a variety of additional information, including data gathered from queries
+n publicly-available, open-source websites. Any queries conducted by NCMEC staff will be documented and any query results will b
+aved to the electronic filing system when possible. The CyberTipline cannot confirm the accuracy of information found in publi
+NCMEC Priority Level:
+NCMEC Classification*:
+NCMEC Date Processed:
+Made Available to Law Enforcement by NCMEC:
+3 (Additional information required to determine possible risk)
+Child Sex Trafficking
+12-17-2020 21:57:07 UTC
+Yes
+NCMEC Classification is based on NCME's review of the report OR a "Hash Match" of one or more uploaded files. NCME may not have viewed all
+uploaded files submitted by the reporting ESP.
+NCMEC Note #1
+CSTT-SEF 12-17-2020 21:35:13 UTC
+This CyberTipline Report was processed by the Child Sex Trafficking Team (CSTT) in the Case Analysis Division. Should you have any
+questions regarding this report, or need any technical assistance pertaining to child sex trafficking, please contact us at
+org.
+Any open source and/or public record searches conducted by NCMEC will be documented within this report and saved to the electronic
+filing system. The NCMEC cannot confirm the accuracy of information found in public records or whether the results are associated with
+any of the parties affiliated with this report.
+Please note, the reporting party's narrative appears to be disjointed and difficult to understand; therefore, I will only conduct
+deconfliction on relevant terms listed within the narrative, at this time. If you would like additional searches on the information listed
+within the narrative, please e-mail
+..org with this request.
+NCMEC Note #2
+CSTT-SEF 12-17-2020 21:38:56 UTC
+At this time I will conduct searches on the reported information.
+I searched for previous reports known to the Exploited Child Division and other NCMEC Databases (Sex Offender Tracking Team,
+Missing Children's Database and Attempted Abductions) on the following terms:
+I did not locate any results at this time.
+NCMEC Note #3
+is Report is provided solely for informational purposes pursuant to NCMEC's nonprofit missic
+ease treat all information in this Report as confidenti
+EFTA00129105
+
+CyberTipline Report 83658616 | 4
+CSTT-SEF 12-17-2020 21:41:09 UTC
+At this time I will conduct searches on the reporting party.
+I searched for previous reports known to the Exploited Child Division and other NCME Databases (Sex Offender Tracking Team,
+Missing Children's Database and Attempted Abductions) on the following terms:
+"Kathryn Dee"
+I did not locate any results at this time.
+WHOIS lookup for :WHOIS lookup for
+IP and Network lookup information:
+Address lookup
+canonical name
+120. sub-174-228-8. myvzw.com.
+aliases
+addresses
+Network Whois record
+Queried whois.arin.net with " n
+NetRange:
+CIDR:
+NetName:
+NetHandle:
+Parent:
+NetType:
+WIRELESSDATANETWORK
+NET-174-192-0-0-1
+NET174 (NET-174-0-0-0-0)
+Direct Allocation
+OriginAS:
+Organization: Cellco Partnership DBA Verizon Wireless (CLLC)
+RegDate:
+2008-12-16
+Updated:
+2012-03-02
+Ref:
+https://rdap.arin.net/registry/ip/174.192.0.0
+OrgName:
+Cellco Partnership DBA Verizon Wireless
+Orgid:
+CLLC
+Address:
+180 Washington Valley Road
+City:
+Bedminster
+This Report is provided solely for informational purposes pursuant to CMEC's nonprofit mission
+lease treat all information in this Report as confidential
+EFTA00129106
+
+SING d
+CyberTipline Report 83658616 | 5
+StateProv:
+NJ
+PostalCode:
+07039
+Country:
+US
+RegDate:
+2001-10-01
+Updated:
+2017-10-12
+Ref:
+https://rdap.arin.net/registry/entity/CLLC
+OrgAbuseHandle: ABUSE716-ARIN
+OrgAbuseName: Abuse
+OrgAbusePhone: +1-908-306-7000
+OrgAbuseEmail: abuse@verizonwireless.com
+OrgAbuseRef: https://rdap.arin.net/registry/entity/ABUSE716-ARIN
+OrgTechHandle: NDBM-ARIN
+OrgTechName: NDBM
+OrgTechPhone: +1-908-306-7000
+OrgTechEmail: VZWNDBMIPControl@VerizonWireless.com
+OrgTechRef: https://rdap.arin.net/registry/entity/NDBM-ARIN
+DNS records
+name class type data time to live
+120.sub-174-228-8.myvzw.com IN A
+7200s (02:00:00)
+sub-174-228-8.myvzw.com IN NS ns1.vzwdomain.com 7200s (02:00:00)
+sub-174-228-8.myvzw.com IN NS ns2.vzwdomain.com 7200s (02:00:00)
+sub-174-228-8.myvzw.com IN SOA server: njbbintdns1v.local email: vzw.net.dns@verizonwireless.com serial: 2009012822
+refresh: 86400 retry: 7200 expire: 1209600 minimum ttl: 900 7200s (02:00:00)
+myvzw.com IN NS ns1.vzwdomain.com 7200s (02:00:00)
+myvzw.com IN NS ns2.vzwdomain.com 7200s (02:00:00)
+myvzw.com IN A 207.68.174.238 7200s (02:00:00)
+myvzw.com IN SOA
+server: njbbintdns1v.local email: vzw.net.dns@verizonwireless.com serial: 2012104588 refresh: 43200
+retry: 7200 expire: 1209600
+minimum ttl: 10800 7200s (02:00:00)
+120.8.228.174.in-addr.arpa IN PTR 120.sub-174-228-8.myvzw.com 1446s (00:24:06)
+228.174.in-addr.arpa IN NS ns2.vzwdomain.com 7200s (02:00:00)
+20 020 0e 0200)
+228.174.in-addr.arpa IN NS ns1.vzwdomain.com 7200s (02:00:00)
+228.174.in-addr.arpa IN SOA server: njbbintdns1v.local email: vzw.net.dns@verizonwireless.com serial: 281 refresh: 86400
+retry: 7200 expire: 1209600 minimum ttl: 900 7200s (02:00:00)
+Traceroute
+Tracing route to 120.sub-174-228-8.myvzw.com
+hop rtt rtt rtt
+ip adress fully qualified domain
+name
+1
+2
+2
+3
+1
+1
+0
+0
+3
+1
+1
+169.254.158.58
+169.48.118.156
+169.48.118.136
+169.45.18.88
+50.97.17.53
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+ae9.er2.dfw2.us.zip.zayo.com
+ae24.cs2.dfw2.us.zip.zayo.com
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+zayo.vdms.er2.ord7.us.zip.zayo.com
+9
+10
+11
+12
+13
+*
+1
+•
+41
+•
+*
+39
+40
+69.82.18.181
+181.sub-69-82-18.myvzw.com
+This Report is provided ase treat all information in his Report as con deME's nonprofit mission.
+EFTA00129107
+
+CyberTipline Report 83658616 | 6
+14
+15
+16
+:
+:
+*
+:
+*
+Trace aborted
+Maxmind Geographic Results:
+Country: US
+Region:
+City:
+Postal Code:
+Latitude:
+Longitude:
+Metropolitan Code:
+ISP: Verizon Wireless
+Organization: Verizon Wireless
+Types: cellular
+Google Geographic Results:
+Country: US
+Latitude:
+Longitude
+Area: 170,554.7969 sq. km. (65,851.5755 sq. miles)
+NCMEC Note #4
+CSTT-SEF 12-17-2020 21:41:20 UTC
+The following Point of Contact has been sent a copy of this CyberTipline report:
+FBI:
+Federal Bureau of Investigation
+Emai
+Desk
+Cell:
+cc: FBlinnocenceLost@ic.fbi.gov
+Questions regarding Innocence Lost and national intelligence may be addressed to
+Supplemental Files
+The following is a list of supplemental files saved to the report by NCMEC
+CTT83658616.pdf
+This Report is provided solely for informational purposes pursuant to NCMEC's nonprofit mission
+Please treat all information in this Report as confidential
+EFTA00129108
+
+CyberTipline Report 83658616 | 7
+This concludes Section C
+If you need further information regarding the contents of this Report, please contact the Child Sex Trafficking Team at
+prg.
+This Report is provided solely for informational purposes pursuant to NCMEC's nonprofit mission
+Please treat all information in this Report as confidential
+EFTA00129109
+
+ISSING
+MPLOITE
+CyberTipline Report 83658616 | 8
+Section D: Law Enforcement Contact Information
+The report was made available to the Law Enforcement Agency listed below.
+CSTT_FBI (Alexandria)
+Investigator:
+Assigned Officer:
+Access VEN
+Title:
+City/State:
+ountry
+Alexandria, VA
+United States
+mail Address
+Time/Date was made available: 12-17-2020 21:55:00 UTC
+This concludes Section D
+This concludes CyberTipline Report 83658616
+This Report is provided solely for informational purposes pursuant to NCMEC's nonprofit mission
+Please treat all information in this Report as confidential
+EFTA00129110
\ No newline at end of file
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+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+- -
+UNITED' STATES OF AMERICA
+- V. -
+JEFFREY EPSTEIN,
+Defendant.
+SEALED
+INDICTMENT
+19 Cr.
+19 CRIM
+4.90
+COUNT ONE
+(Sex Trafficking Conspiracy)
+The Grand Jury charges:
+OVERVIEW
+1.
+As set forth herein, over the course of many
+years, JEFFREY EPSTEIN, the defendant, sexually exploited and
+• abused dozens of minor girls at his homes in Manhattan, New
+York, and Palm Beach, Florida, among other locations.
+2.
+In particular, from at least in or about 2002, up
+to and including at least in or about 2005, JEFFREY EPSTEIN, the
+defendant, enticed and recruited, and caused to be enticed and
+recruited, minor girls to visit his mansion in Manhattan, New
+York (the "New York Residence") and his estate in Palm Beach,
+Florida (the "Palm Beach Residence") to engage in sex acts with
+him, after which he would give the victims hundreds of dollars
+in cash. Moreover, and in order to maintain and increase his
+supply of victims, EPSTEIN also paid certain of his victims to
+recruit additional girls to be similarly abused by EPSTEIN. In
+EFTA00092059
+
+this way, EPSTEIN created a vast network of underage victims for
+him to sexually exploit in locations including New York and
+Palm Beach.
+3. The victims described herein were as young as 14
+years old at the time they were abused by JEFFREY EPSTEIN, the
+defendant, and were, for various reasons, often particularly
+vulnerable to exploitation.
+EPSTEIN intentionally sought out
+minors and knew that many of his victims were in fact under the
+age of 18, including because, in some instances, minor victims
+expressly told him their age.
+1. In creating and maintaining this network of minor
+victims in multiple states to sexually abuse and exploit,
+JEFFREY EPSTEIN, the defendant, worked and conspired with
+others, including employees and associates who facilitated his
+conduct by, among other things,
+contacting victims and
+scheduling their sexual encounters with EPSTEIN at the New York
+Residence and at the Palm Beach Residence.
+FACTUAL BACKGROUND
+5.
+During all time periods charged in this
+Indictment, JEFFREY EPSTEIN, the defendant, was a financier with
+multiple residences in the continental United States, including
+the New York Residence and the Palm Beach Residence.
+6.
+Beginning in at least 2002, JEFFREY EPSTEIN, the
+defendant, enticed and recruited, and caused to be enticed and
+2
+EFTA00092060
+
+recruited, dozens of minor girls to engage in sex acts with him,
+after which EPSTEIN paid the victims hundreds of dollars in
+cash, at the New York Residence and the Palm Beach Residence.
+In both New York and Florida, JEFFREY EPSTEIN,
+the defendant, perpetuated this abuse in similar ways. Victims
+were initially recruited to provide "massages" to EPSTEIN, which
+would be performed nude or partially nude, would become
+increasingly sexual in nature, and would typically include one
+or more sex acts. EPSTEIN paid his victims hundreds of dollars
+in cash for each encounter. Moreover, EPSTEIN actively
+encouraged certain of his victims to recruit additional girls to
+be similarly sexually abused. EPSTEIN incentivized his victims
+to become recruiters by paying these victim-recruiters hundreds
+of dollars for each girl that they brought to EPSTEIN. In so
+doing, EPSTEIN maintained a steady supply of new victims to
+exploit.
+The New York Residence
+8. At all times relevant to this Indictment, JEFFREY
+EPSTEIN, the defendant, possessed and controlled a multi-story
+private residence on the Upper East Side of Manhattan, New York,
+i.e., the New York Residence. Between at least in or about 2002
+and in or about 2005, EPSTEIN abused numerous minor victims at
+the New York Residence by causing these victims to be recruited
+to engage in paid sex acts with him.
+3
+EFTA00092061
+
+9.
+When a victim arrived at the New York Residence,
+she typically would be escorted to a room with a massage table,
+where she would perform a massage on JEFFREY EPSTEIN, the
+defendant. The victims, who were as young as 14 years of age,
+were told by EPSTEIN or other individuals to partially or fully
+undress before beginning the "massage." During the encounter,
+EPSTEIN would escalate the nature and scope of physical contact
+with his victim to include, among other things, sex acts such as
+groping and direct and indirect contact with the victim's
+genitals.
+EPSTEIN typically would also masturbate during these
+sexualized encounters, ask victims to touch him while he
+masturbated, and touch victims' genitals with his hands or with
+sex toys.
+10. In connection with each sexual encounter, JEFFREY
+EPSTEIN, the defendant, or one of his employees or associates,
+paid the victim in cash. Victims typically were paid hundreds
+of dollars in cash for each encounter.
+11.
+JEFFREY EPSTEIN, the defendant, knew that many of
+his New York victims were underage, including because certain
+victims told him their age. Further, once these minor victims
+were recruited, many were abused by EPSTEIN on multiple
+subsequent occasions' at the New York Residence. EPSTEIN
+sometimes personally contacted victims to schedule appointments
+at the New York Residence.
+In other instances,
+EPSTEIN directed
+EFTA00092062
+
+employees and associates, including a New York-based employee
+("Employee-1"), to communicate with victims via phone to arrange
+for these victims to return to the New York Residence for
+additional sexual encounters with EPSTEIN.
+12. Additionally, and to further facilitate his
+ability to abuse minor girls in New York, JEFFREY EPSTEIN, the
+defendant, asked and enticed certain of his victims to recruit
+additional girls to perform "massages" and similarly engage in
+sex acts with EPSTEIN. When a victim would recruit another girl
+for EPSTEIN, he paid both the victim-recruiter and the new
+victim hundreds of dollars in cash. Through these victim-
+recruiters, EPSTEIN gained access to and was able to abuse
+dozens of additional minor
+girls.
+13. In particular, certain recruiters brought dozens
+of additional minor girls to the New York Residence to give
+massages to and engage in sex acts with JEFFREY EPSTEIN, the
+defendant. EPSTEIN encouraged victims to recruit additional
+girls by offering to pay these victim-recruiters for every
+additional girl they brought to EPSTEIN. When a victim-
+recruiter accompanied a new minor victim to the New York
+Residence, both the victim-recruiter and the new minor victim
+were paid hundreds of dollars by EPSTEIN for each encounter: In
+addition, certain victim-recruiters routinely scheduled these
+5
+EFTA00092063
+
+encounters through Employee-1, who sometimes asked the
+recruiters to bring a specific minor girl for EPSTEIN.
+The Palm Beach Residence
+14. In addition to recruiting and abusing minor girls
+in New York,
+JEFFREY EPSTEIN, the defendant, created a similar
+network of minor girls to victimize in Palm Beach, Florida,
+where EPSTEIN owned, possessed and controlled another large
+residence, i.e., the Palm Beach Residence. EPSTEIN frequently
+traveled from New York to Palm Beach by private jet, before
+which an employee or associate would ensure that minor victims
+were available for encounters upon his arrival in Florida.
+15. At the Palm Beach Residence, JEFFREY EPSTEIN, the
+defendant, engaged in a similar course of abusive conduct.
+When a victim initially arrived at the Palm Beach Residence, she
+would be escorted to a room, sometimes by an employee of
+EPSTEIN' s, including, at times, two assistants ("Employee-2" and '
+"Employee-3") who, as
+described herein, were also responsible
+for scheduling sexual encounters with minor victims.
+Once
+inside, the victim would provide a nude or semi-nude massage for
+EPSTEIN, who would himself typically be naked. During these
+encounters, EPSTEIN would escalate the nature and scope of the
+physical contact to include sex acts such as groping and direct
+and indirect contact with the victim's genitals. EPSTEIN would
+also typically masturbate during these encounters, ask victims
+EFTA00092064
+
+to touch him while he masturbated, and touch victims' genitals
+with his hands or with sex toys.
+16. In connection with each sexual encounter, JEFFREY
+EPSTEIN, the defendant, or one of his employees or associates,
+paid the victim in cash. Victims typically were paid hundreds
+of dollars for each encounter.
+17.
+JEFFREY EPSTEIN, the defendant, knew that certain
+of his victims were underage, including because certain victims
+told him their age. In addition, as with New York-based
+victims, many Florida victims, once recruited, were abused by
+JEFFREY EPSTEIN, the defendant, on multiple additional
+occasions.
+18. JEFFREY EPSTEIN, the defendant, who during the
+relevant time period was frequently in New York, would arrange
+for Employee-2 or other employees to contact victims by phone in
+advance of EPSTEIN's travel to Florida to ensure appointments
+were
+scheduled 'for when he arrived. In particular, in certain
+instances, Employee-2 placed phone calls to minor victims in
+Florida to schedule encounters at the Palm Beach Residence. At
+the time of certain of those phone calls, EPSTEIN and Employee-2
+were in New York, New York. Additionally, certain of the
+individuals victimized at the Palm Beach Residence were
+contacted by phone by Employee-3 to schedule these encounters.
+EFTA00092065
+
+19. Moreover,
+as in New York, to ensure a steady
+stream of minor victims, JEFFREY EPSTEIN, the defendant, asked
+and enticed certain victims in Florida to recruit other girls to
+engage in sex acts. EPSTEIN paid hundreds of dollars to victim-
+recruiters for each additional girl they brought to the Palm
+Beach Residence.
+STATUTORY ALLEGATIONS
+20. From at least in or about 2002, up to and
+including in or about 2005, in the Southern District of New York
+and elsewhere, JEFFREY EPSTEIN, the defendant, and others known
+and unknown, willfully and knowingly did combine, conspire,
+confederate, and agree together and with each other to commit an
+offense against the United States, to wit, sex trafficking of
+minors, in violation of Title 18, United States Code, Section.
+1591(a) and (b) .
+21. It was
+• a part and object of the conspiracy that
+JEFFREY EPSTEIN, the defendant, and others known and unknown,
+would and did, in and affecting
+: interstate and foreign commerce,
+recruit, entice, harbor, transport, provide, and obtain, by any
+means a person,
+and to benefit, financially and by receiving
+anything of value, from participation in a venture which has
+engaged in any such act, knowing that the person had not
+attained the age of 18 years and would be caused to engage in a
+8
+EFTA00092066
+
+commercial sex act, in violation of Title 18, United States
+Code, Sections 1591(a) and (b) (2).
+Overt Acts
+22. In furtherance of the conspiracy and to effect
+the illegal object thereof, the following overt acts, among
+others, were committed in the Southern District of New York and
+elsewhere:
+a.
+In or about 2004, JEFFREY EPSTEIN, the
+defendant, enticed and recruited multiple minor victims,
+including minor victims identified herein as Minor Victim-1,
+Minor Victim-2, and Minor Victim-3, to engage in sex acts with
+EPSTEIN at his residences in Manhattan, New York, and Palm
+Beach, Florida, after which he provided them with hundreds of
+dollars in cash for each encounter.
+b. In or about 2002, Minor Victim-1 was
+recruited to engage in sex acts with EPSTEIN and was repeatedly
+sexually abused by EPSTEIN at the New York Residence over a
+period of years and was paid hundreds of dollars for each
+encounter. EPSTEIN also encouraged and enticed Minor Victim-1
+to recruit other girls to engage in paid sex acts, which she
+did. EPSTEIN asked Minor Victim-1 how old she was, and Minor
+Victim-1 answered truthfully.
+c. In or about 2004, Employee-1, located in the
+Southern District of New York, and on behalf of EPSTEIN, placed
+9
+EFTA00092067
+
+a telephone call to Minor Victim-1, in order to schedule an
+appointment for Minor Victim-1 to engage in paid sex acts with
+EPSTEIN.
+d. In or about 2004, Minor Victim-2 was
+recruited to engage in sex acts with EPSTEIN and was repeatedly
+sexually abused by EPSTEIN at the Palm Beach Residerce over a
+period of years and was paid hundreds of dollars after each
+encounter. EPSTEIN also encouraged and enticed Minor Victim-2
+to recruit other girls to engage in paid sex acts, which she
+did.
+e. In or about 2005, Employee-2, located in the
+Southern District of New York, and on behalf of EPSTEIN, placed
+a telephone call to Minor Victim-2 in order to schedule an
+appointment for Minor Victim-2 to engage in paid sex acts with
+EPSTEIN.
+f. In or about 2005, Minor Victim-3 was
+recruited to engage in sex acts with EPSTEIN and was repeatedly
+sexually abused by EPSTEIN at the Palm Beach Residence over a
+period of years and was paid hundreds of dollars for each
+encounter. EPSTEIN also encouraged and enticed Minor Victim-3
+to recruit other girls to engage in paid sex acts, which she
+did. EPSTEIN asked Minor Victim-3 how old she was, and Minor
+Victim-3 answered truthfully.
+10
+EFTA00092068
+
+g. In or about 2005, Employee-2, located in the
+Southern District of New York, and on behalf of EPSTEIN, placed
+a telephone call to Minor Victim-3 in Florida in order to
+schedule an appointment for Minor Victim-3 to engage in paid sex
+acts with EPSTEIN.
+h. In or about 2004, Employee-3 placed a
+telephone call to Minor Victim-3 in order to schedule an
+appointment for Minor Victim-3 to engage in paid sex acts with
+EPSTEIN.
+(Title 18, United States Code, Section 371.)
+COUNT IWO
+(Sex Trafficking)
+The Grand Jury further charges:
+23. The allegations contained in paragraphs 1
+through 19 and 22 of this Indictment are repeated and realleged
+as if fully set forth within.
+24. From at least in or about 2002, up to. and
+including in or about 2005, in the Southern District of New
+York, JEFFREY EPSTEIN, the defendant, willfully and knowingly,
+in and affecting interstate and foreign commerce, did recruit,
+entice, harbor, transport, provide, and obtain by any means a
+person, knowing that the person had not attained the age of 18
+years and would be caused to engage in a commercial sex act, and
+did aid and abet the same, to wit, EPSTEIN recruited, enticed,
+harbored, transported, provided, and obtained numerous
+11
+EFTA00092069
+
+individuals who were less than 18 years old, including but not
+limited to Minor Victim-1, as described above, and who were then
+caused to engage in at least one commercial sex act in
+Manhattan, New York.
+(Title 18, United States Code, Sections 1591 (a),
+(b) (2), and 2.)
+FORFEITURE ALLEGATIONS
+25. As a result of committing the offense alleged in
+Count Two of this Indictment, JEFFREY EPSTEIN, the defendant,
+shall forfeit to the United States, pursuant to Title 18, United
+States Code, Section 1594 (c) (1), any property, real and
+personal, that was used or
+intended to be used to commit or to
+facilitate the commission of the offense alleged in Count Two,
+and any property, real or personal, constituting or derived from
+any proceeds obtained, directly or indirectly, as a result of
+the offense alleged in Count Iwo, or any property traceable to
+such property, and the following specific property:
+a.
+The lot of parcel of land, together with its
+buildings, appurtenances, improvements, fixtures, attachments
+and easements, located at 9 East İlst Street, New York, New
+York, with block number
+1386 and lot number 10, owned by
+Maple,
+Inc.
+12
+EFTA00092070
+
+Substitute Asset Provision
+26. If any of the above-described forfeitable
+property, as a result of any act or omission of the defendant:
+(a) cannot be located upon the exercise of due diligence;
+(b) has been transferred or sold to, or deposited with, a
+third person;
+(c) has been placed beyond the jurisdiction of the Court;
+(d), has been substantially diminished in value; or
+(e) has been
+commingled with other property which cannot
+be subdivided without difficulty;
+it is the intent of the United States, pursuant to 21 U.S.C.
+$ 853 (p)
+and 28 U.S.C. § 2461(C), to seek forfeiture of any
+other property of the defendant up to the value of the above
+forfeitable property.
+(Title 18, United States Code, Section 1594; Title 21,
+United States Code,
+Section 853(p); and
+Title 28, United States Code, Section 2461.)
+FOREPERSON
+A. Bume
+GEOFFREY
+• BERMAN
+United States Attorney
+13
+EFTA00092071
+
+Form No. USA-33s-274 (Ed. 9-25-58)
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+UNITED STATES OF AMERICA
+V.
+JEFFREY EPSTEIN,
+Defendant.
+INDICIMENT
+(18 U.S.C. SS 371, 1591 (a), (b) (2),
+and 2)
+GEOFFREY S. BERMAN
+United States Attorney
+Foreperson
+14
+EFTA00092072
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bc74d815741715cc3b4762c2f2f744163642d16ed26096f819e5bdc724108672.md b/vision-joined/ds9-parsed-01/bc74d815741715cc3b4762c2f2f744163642d16ed26096f819e5bdc724108672.md
new file mode 100644
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--- /dev/null
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@@ -0,0 +1,35 @@
+Case 1:15-cv-07433-LAP Document 1078-2 Filed 07/29/20 Page 1 of 2
+EXHIBIT B
+EFTA00101470
+
+Cafase 1520407333DARJND docume 1028-FilEde07 07322902 Painger F2
+DOCUMENT
+ELECTRONICALLY FILED
+DOC#:
+DATE FILED:7/23/2020
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+United States of America,
+-V-
+Ghislaine Maxwell,
+20-CR-330 (AJN)
+ORDER
+Defendant.
+ALISON J. NATHAN, Distriet Judge:
+The Defense has moved for an order "prohibiting the Government, its agents and counsel
+for witnesses from making extrajudicial statements concerning this case." Dkt. No. 27 at 1.
+The Court firmly expects that counsel for all involved parties will exercise great care to
+ensure compliance with this Court's local rules, including Local Criminal Rule 23.1, and the
+rules of professional responsibility. In light of this clear expectation, the Court does not believe
+that further action is needed at this time to protect the Defendant's right to a fair trial by an
+impartial jury. Accordingly, it denies the Defendant's motion without prejudice. But the Court
+warns counsel and agents for the parties and counsel for potential witnesses that going forward it
+will not hesitate to take appropriate action in the face of violations of any relevant rules. The
+Court will ensure strict compliance with those rules and will ensure that the Defendant's right to
+a fair trial will be safeguarded.
+SO ORDERED.
+Dated: July 23, 2020
+New York, New York
+ALISON J. NATHAN
+United States District Judge
+EFTA00101471
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bc8ca137e68a756b9a2584e0c0540e84dcba471e8b7df6dd53a658ac0518c31a.md b/vision-joined/ds9-parsed-01/bc8ca137e68a756b9a2584e0c0540e84dcba471e8b7df6dd53a658ac0518c31a.md
new file mode 100644
index 0000000000000000000000000000000000000000..8714c46087a9f9dbf11b0d84f479e3b91df8fefc
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+++ b/vision-joined/ds9-parsed-01/bc8ca137e68a756b9a2584e0c0540e84dcba471e8b7df6dd53a658ac0518c31a.md
@@ -0,0 +1,69 @@
+From: "
+To: "
+(USANYS)" <
+(USANYS)" *
+Subject: FW: Please see annexed Epstein Victim Letter
+Date: Tue, 10 Nov 2020 18:00:29 +0000
+Embedded: unnamed
+Inline-Images: image002.jpg
+"."
+| (USANYS)" ‹
+(USANYS)"
+The original iteration of this ended up going through
+see the attached thread. Among other issues, her counsel
+apparently advised a year ago that she was not in a position to be interviewed at the time, though it looks like
+referred
+it to FBI in any event. Just FYI
+From:
+(USANYS)
+Sent: Tuesday, November 10, 2020 12:50
+To:
+(USANYS)
+Cc:
+(USANYS) ;
+I (USANYS) ;
+(USANYS) ;
+(USANYS)
+Subject: FW: Please see annexed Epstein Victim Letter
+Please see the attached letter which appears to concern an Epstein/Maxwell victim. It was
+forwarded to civilian crime reports, but because it appears to concern a statutory victim of a case
+we have charged, CCR does not do anything (other than forward to l
+). If not a victim,
+please let us know and we will process. Thanks.
+From:
+(USANYS) [Contractor] <
+Sent: Tuesday, November 10, 2020 12:44 PM
+To:
+(USANYS) <
+Pi
+(USANYS)
+Subject: FW: Please see annexed
+received this letter. It is from a law firm and about a victim who may have been abused by Epstein and Maxwell.
+Best.
+From: Jennifer Freeman
+Sent: Tuesday, November 10, 2020 12:27 PM
+To:
+(USANYS) <
+Ce: Joyanna Silberg
+Subject: Please see annexed
+Stay well,
+Jennifer
+Jennifer Freeman
+Marsh Law Firm PLLC
+Direct Dial
+Skype for Business
+Recipient 2019 PowerPlay Advocacy Award
+Blog | Facebook | Twitter | Linkedin
+EFTA00081475
+
+CONFIDENTIALITY NOTICE: The information contained in this message and any attachment is confidential
+and may be subject to the attorney-client privilege, or otherwise protected from disclosure by applicable law.
+Any disclosure, distribution, copying, or use of the information contained in this message or any attachment by
+anyone other than the intended recipient, regardless of address or routing, is strictly prohibited. If you are not the
+intended recipient, please telephone or email the sender and delete this message and any attachment from your
+system.
+IF YOU ARE NOTA CLIENT: This material is general information of an educational nature and is not legal
+advice. This communication does not establish or constitute the retention of Marsh Law Firm PLLC for the
+provision of legal services, unless explicitly so stated herein. Any attached items, including the content of this e-
+mail, are offered "as is" with no guarantee as to their accuracy, timeliness, or completeness.
+EFTA00081476
\ No newline at end of file
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+}
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new file mode 100644
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@@ -0,0 +1,130 @@
+From: "
+Subject: RE: Subpoena CRIM1031692
+Date: Thu, 22 Aug 2019 23:37:24 +0000
+Yep
+From:
+Sent: Thursday, August 22, 2019 7:36 PM
+To:
+Subject: Fwd: Subpoena CRIM1031692
+4:30 Monday work for you?
+Sent from my iPhone
+Begin forwarded message:
+From:
+To: "
+Cc:|
+Date: August 22, 2019 at 6:36:54 PM EDT
+A
+Subject: RE: Subpoena CRIM1031692
+Of course. How about sometime between 12:30 and 1:45 PT?
+Thanks,
+From:
+Tol
+Cc:
+Sent: Thursday, August 22, 2019 10:39 AM
+Subject: Re: Subpoena CRIM1031692
+Thanks— can you let us know your availability for a call on Monday?
+Sent from my iPhone
+On Aug 22, 2019, at 1:10 PM,
+> wrote:
+Thanks
+I just left you a voice message saying your suggestion makes sense.
+Are you free for a two-minute return call to at least confer on your availability? I'll be at
+Thanks,
+until 1:30 ET.
+EFTA00080139
+
+From:
+Sent: Thursday, August 22, 2019 10:05 AM
+To:
+Cc:
+Subject: Re: Subpoena CRIM1031692
+I should add: if you think it would be productive to review those issues before we talk, let us know if you'd like to
+reschedule the call.
+Thanks,
+Sent from my iPhone
+On Aug 22, 2019, at 2:56 AM,
+a wrote:
+I look forward to speaking with you tomorrow (Thursday). Unless you'd prefer another number, I'II plan to call you at
+Also, as indicated I promised to provide some more information on how Amazon approaches the issues we've
+been discussing. I'm hopeful that this information will help provide a common baseline for further consideration of
+your request for expressive materials. I've attached several cases that discuss the need for a heightened showing of
+relevance and need before a bookstore, video provider, or library can be compelled to reveal expressive choices of its
+patrons. In our experience, prosecutors and government agencies typically are not permitted access to records of
+bookstores and libraries unless (1) a compelling need exists for the requested information, (2) a substantial nexus is
+demonstrated between the information sought and the subject of the criminal investigation, and (3) the government
+has exhausted other avenues to obtain the information in ways that do not burden First Amendment rights. See,
+e.g., Amazon.com LLC v. Lay, 758 F. Supp. 2d 1154 (W.D. Wash. 2010); In re Grand Jury Investigation of Possible
+Violation of 18 U.S.C. § 1461, 706 F. Supp. 2d 11 (D.D.C. 2009); In re Grand Jury Subpoena to Amazon.com, 246 F.R.D.
+570 (W.D. Wis. 2007); In re Grand Jury Subpoena to Kramerbooks & Afterwords Inc., 26 Media L. Rep. (BNA) 1599
+(D.D.C. 1998); Tattered Cover, Inc. v. City of Thornton, 44 P.3d 1044 (Colo. 2002) (en banc).
+I'm obviously not privy to the details of your investigation. And, to be clear, we don't rule out the possibility either
+that the subjects here do not have a protectable privacy interest or that sufficient grounds exist to compel
+production of the expressive materials you seek. I also want to assure you that we do not seek to interfere with your
+investigation in any way in expressing these concerns. Amazon routinely cooperates with law enforcement on a
+number of levels, and we will secure and not destroy any information we determine is responsive to your request.
+As I discussed with
+1. if your office ultimately decides to continue to pursue the expressive materials at issue, we
+might seek to enlist the assistance of the court with a motion to quash, preferably based upon a stipulated briefing
+schedule, to determine whether the requisite legal standards have been satisfied in this instance. But again, we
+don't not ruling out the possibility that sufficient grounds exist in this instance to compel production.
+Thanks,
+From:
+Sent: Tuesday, August 20, 2019 2:51 PM
+EFTA00080140
+
+To: l
+Cc:
+Subject: RE: Subpoena CRIM1031692
+Thanks, Thursday at 1:30 our time sounds good. We'll plan to speak with you then.
+Thanks,
+From:
+To:
+Sent: Tuesday, August 20, 2019 4:49 PM
+Subject: RE: Subpoena CRIM1031692
+Hi,
+PT (1:30pm ET) on Thursday work for you?
+Thanks,
+I have conflicts early and late tomorrow, but perhaps we could speak Thursday morning? Would 10:30am
+From:
+To:
+Cc:
+Sent: Tuesday, August 20, 2019 7:10 AM
+Subject: RE: Subpoena CRIM1031692
+Is there is a good time for a call tomorrow to discuss? I'm tied up between 2 and 5 EST, but otherwise available.
+Thanks,
+From:
+Sent: Thursday, August 15, 2019:43 PM
+To:
+Cc:
+Subject: RE: Subpoena CRIM1031692
+1 with apologies for shuttling you back and forth, due to my upcoming trial my colleague
+copied, will
+be in a better position to follow up with you. I updated her on our conversation, in particular that you expected to
+send us some authority for Amazon's prior position, and also that you were in the process of evaluating whether any
+First Amendment considerations were still active given the death of Mr. Epstein. I've also conveyed to her the issue
+you raised of the overbreadth of any request for all information for all accounts having ever shipped to, or billed in
+connection with, the listed addresses, and our interest in at the very least getting account information for any
+accounts that include those addresses—and, more generally, the records of items shipped to those addresses, to the
+EFTA00080141
+
+extent all such records were not included in the first production. Again, sorry to be switching given our lengthy
+conversation, but |
+I will better be able to be in touch with you in the coming days.
+thanks,
+From
+To:
+Sent: Wednesday, August 14, 2019 02:09
+Subject: Subpoena CRIM1031692
+It was good speaking to you yesterday. Are you available tomorrow (Wednesday) or Thursday for a follow-up call?
+My schedule is quite tight tomorrow so happy to do it Thursday, if you'd prefer.
+Thanks,
+Associate General Counsel, Litigation & Regulatory
+Amazon.com, Inc.
+2021 7th Avenue, Seattle, WA 98121
+
+< In re Grand Jury Subpoena to Amazon.com Dated August 7, 2006, 246 F.R.D. 570 (W.D. Wis. 2007) pdf»
+< In re Grand Jury Subpoena to Kramerbooks & Afterwords Inc., No. 98-135 (NHJ) & 98-138 (NHJ
+(D.D.C. Apr. 6, 1998).pdf>
+ wrote:
+Hope you're doing well. In connection with the Epstein investigation, we were wondering if you could possibly send
+us the search warrant affidavit and order for the Epstein residence. We understand that it was executed by local
+authorities before the case was brought to the FBI, but we understand you have a copy in the files, and we can't seem
+to locate it in the materials we've reviewed. If you could please email it to us, that would be a big help.
+Thanks in advance for your help, we really appreciate it.
+Best,
+Assistant United States Attorney
+Southern District of New York
+EFTA00078804
\ No newline at end of file
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@@ -0,0 +1,7 @@
+From:
+To: "Hudgens, Johanna Rae" -
+Subject: Automatic reply: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to
+Date: Sat, 03 Aug 2019 20:58:02 +0000
+I will be out of the office on vacation until Monday, August 12th. Although I will have access to email during my absence, my responses may be
+delayed. For urgent matters, please contact the other AUSA(s) on the case, or AUSA |
+EFTA00083924
\ No newline at end of file
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@@ -0,0 +1,21 @@
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+}
diff --git a/vision-joined/ds9-parsed-01/bd8911ed371667b050bc2eb25a70cca0c8706261ace7eb35a2890f4bf825dfcf.md b/vision-joined/ds9-parsed-01/bd8911ed371667b050bc2eb25a70cca0c8706261ace7eb35a2890f4bf825dfcf.md
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@@ -0,0 +1,10 @@
+From: Susan Shelling <
+To:
+Subject: [EXTERNAL] Subpoena Re Ghislane Maxwell case
+Date: Tue, 21 Sep 2021 21:00:46 +0000
+Apparently I took a deposit in the Epstein case in Palm Beach County several years ago. I got a subpoena today
+Re Maxwell. Whatever I did in the Epstein case was probably transcribed and you have the transcript. Other than
+that whatever notes I had were destroyed as it was more than 5 years ago. I have no memory of it whatsoever.
+Susan Shelling
+Sent from my iPhone
+EFTA00040847
\ No newline at end of file
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+DIGITALLY RECORDED
+SWORN STATEMENT
+OF
+OIG CASE #:
+2019-010614
+DEPARTMENT OF JUSTICE
+OFFICE OF THE INSPECTOR GENERAL
+AUGUST 12, 2019
+FENTON TRANSCRIPTION
+28720 Roadside Drive, Suite 250
+Agoura Hills, CA 91301
+Phone:
+991-8002
+EFTA00125466
+
+LIMITED OFFICIAL USE
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+APPEARANCES:
+2
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+WITNESS:
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+OFFICE OF THE INSPECTOR GENERAL
+BY:
+BY:
+OTHER APPEARANCES:
+EFTA00125467
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+MR.
+Today is Monday, August
+12. The following will be a voluntary
+interview of BOP Warden
+in
+furtherance of OIG investigation to be
+determined, for the purpose of transcription,
+will now identify all present in the interview.
+I'll ask everyone to say and spell their last
+name, as well as identify their working title
+and employer.
+I am Special Agent
+, Office of the Inspector General.
+MR. M: Special Agent Antonio M.
+I. with the FBI.
+MR.
+Warden,
+Federal Bureau of Prisons. Spelling of the
+name is first name is
+• last name is
+MR.
+Thank you. Warden
+MR.
+MR.
+Um-hum.
+-- you have reviewed and
+signed Department of Justice OIG Form 226-2
+which is Warnings and Assurances of Employees
+Request to Provide Information on a Voluntary
+EFTA00125468
+
+LIMITED OFFICIAL USE
+1
+Basis. Do you have any questions about this
+2
+form?
+3
+MR.
+No.
+4
+MR.
+Would you like time to
+5
+review it with an attorney, or would you like
+6
+an attorney here?
+7
+MR.
+For now, I don't need an
+8
+attorney.
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+MR.
+okay. Are you currently
+under the influence of any substances, or is
+there any reason to prevent you from fully
+understanding my questions and answering
+truthfully today?
+MR.
+: No.
+MR.
+I'll now swear you to the
+statements you're about to make. Please raise
+your hand and repeat after me.
+MR.
+MR.
+•: I,
+Hereby solemnly swear or
+affirm.
+MR.
+affirm.
+:
+Hereby solemnly swear or
+MR.
+I'm about to make.
+That the statements that
+4
+EFTA00125469
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+MR.
+about to make.
+That the statements I'm
+MR.
+Shall be the truth and the
+whole truth.
+MR.
+Shall be the truth and the
+whole truth.
+MR.
+Thank you, sir.
+MR.
+Um-hum.
+MR.
+Warden would you mind
+telling us a little bit about your career with
+BOP? When you started, how you became a
+Warden?
+MR.
+MR.
+ranks.
+MR.
+7:
+Uh --
+How you moved up the
+: I started out as a
+MR.
+Great.
+How long have you
+EFTA00125470
+
+LIMITED OFFICIAL USE
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+been the Warden?
+2
+MR.
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+: I've been here since May of
+2018.
+MR.
+Okay, great. Just, your
+role, you've done a lot of internal
+investigations with the prison and you've
+worked with the Department of Justice for --
+MR.
+Um-hum.
+MR.
+- moving forward, just as
+a note for the record, you're aware that
+failure to be honest with us today would be
+considered a criminal offense; correct?
+MR.
+Yes.
+MR.
+Okay, great. Let's talk a
+little bit about some overall policies at the
+prison to start with.
+MR.
+Okay.
+MR.
+So, actually let me back
+up. We're here today to talk about,
+specifically Jeffrey Epstein.
+MR.
+Um-hum.
+MR.
+: The inmate.
+MR.
+Um-hum.
+MR.
+Would you mind just
+telling us a little bit about when, your
+6
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+understanding of when he arrived and that type
+of, when he arrived, how he was placed, where
+he was placed, and the reasons behind that?
+MR.
+: I don't remember the
+specific date he arrived, but we didn't, what
+happened was, we weren't told that he was going
+to be coming to the institution.
+MR.
+Okay.
+MR.
+: When he initially came, he
+was dropped off on the weekend, and we didn't
+find out until Monday, myself, that he had been
+placed at the institution. And from then on,
+we, you know, went through the whole process
+the screening, his medical stuff. Just normal
+procedures that we follow and (Indiscernible
+of
+*00:04:04).
+MR.
+: Okay. Now when you say
+"he was dropped off over the weekend", when
+somebody arrives at the facility, what's the
+normal --
+MR.
+: I mean typically if
+somebody's that high profile --
+MR.
+: Um-hum.
+MR.
+-- we should've been
+notified and said hey, he's coming in.
+EFTA00125472
+
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+1
+weren't.
+2
+MR.
+Okay.
+3
+MR.
+I: You know, I mean, we saw it
+4
+on the news, but it didn't say. They just said
+5
+they had him in custody, but we didn't get any
+6
+formal, I didn't get any formal notice that he
+7
+had been brought into the institution.
+8
+So, he was dropped off, and you know, the
+Lieutenant on shift processed him in and
+10
+brought him into the institution. We didn't
+11
+find out or realize it until Monday.
+12
+13
+MR.
+: So, it was Monday that you
+first were officially made aware of it?
+14
+MR.
+: That I was made aware. You
+15
+16
+17
+know, we found out, and I don't remember if it
+was from looking at the news reports, we put it
+together that he had been brought into the
+18
+19
+20
+institution. We went through our Monday
+morning meeting that we went through. So,
+that's when --
+21
+22
+23
+MR.
+When he first arrived, was
+he placed in general population? Do you know
+where he was placed?
+24
+MR.
+: I don't recall where he was
+25
+placed when he came in.
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+MR.
+At some point, he was
+placed in Special Housing Unit?
+MR.
+Yes.
+MR.
+: Known as the SHU.
+MR.
+Right.
+MR.
+how did he end up there?
+MR.
+Well, he was a new
+commitment. He was high profile. So, we
+placed him in the Special Housing Unit so we
+can further evaluate, you know, his status. Is
+he ready for general population? And we do
+that with all inmates, but -
+MR.
+: Okay.
+MR.
+- and then to see, okay,
+any separation issues. Any threats to him,
+before we put him out there in general
+population.
+MR.
+population?
+Was he ever in general
+MR.
+: I don't recall. I don't,
+I'm not sure if it might've been the first day
+when he came in.
+MR.
+: okay.
+MR.
+But I'm not sure, so I mean,
+I would have to look at the 37 to confirm.
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+MR.
+But as far as you know,
+that Monday, the first business day after the
+weekend he was initially dropped off.
+MR.
+Right.
+MR.
+From that point forward,
+was he ever in general population?
+MR.
+No.
+MR.
+Okay. What are the
+policies in terms of, or is there policy that
+dictates when somebody goes into general
+population from the SHU after the first
+arrival?
+MR.
+Well, what we do is we
+evaluate the individual to see if they're ready
+for general population, if they can hang, you
+know --
+MR.
+Um-hum.
+MR.
+-- if they can populate.
+MR.
+MR.
+okay.
+: And it's a number of
+factors.
+It depends. I mean, if I have a gang
+member coming in, I'm taking into consideration
+separation issues on it. If it's, you know,
+somebody that might've been fraud or bank
+fraud, then we determine if it's any issues of
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+them going into the general population. So,
+it's a case-by-case basis on how we determine
+it.
+MR.
+Okay. What are the
+policies in terms of when you're notified if
+someone enters Special Housing Unit or is
+discharged from Special Housing Unit?
+MR.
+: Well what it is is, it's
+routed the individual, it's called a Release
+Form. So, several people sign it. They review
+it. I believe psychology, CMC, the Captain,
+and it goes to the Associate Warden and then
+they sign what we call is
+a Kick-Out. Meaning
+everybody's reviewed it and said, okay, this
+person is appropriate for general population.
+MR.
+: Okay. For Mr. Epstein,
+after that, he was never put in general
+population; correct?
+MR.
+No.
+MR.
+Was the determination to
+keep him in Special Housing? What was the
+communication that goes on there?
+MR.
+: Well we, now initially when
+he came in, it's the goal to determine, okay,
+can they go to general population.
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+MR.
+Okay.
+MR.
+So, between evaluating him,
+at the same time, we're looking at saying,
+okay, can he go to general population.
+MR.
+Um-hum.
+MR.
+So, it's a dual role that
+we're going to -
+MR.
+Sure.
+MR.
+: But I had gotten word, and I
+don't recall the date, where from my Regional
+Director which stated he's not to go to general
+population until further notice.
+MR.
+The Regional Director,
+where is that in the chain of command for BOP?
+MR.
+: We have five regional
+offices.
+MR.
+okay.
+MR.
+Each region has a Regional
+Director.
+MR.
+okay.
+MR.
+This is the Northeast
+Region.
+MR.
+MR.
+institutions.
+okay.
+Where we have 21
+So, he supervises and is in
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+charge of the 21 institutions.
+MR.
+Okay. So, is he --
+MR.
+(Indiscernible *00:08:37).
+MR.
+-- your direct supervisor?
+MR.
+He's my director supervisor.
+MR.
+MR.
+Okay. Who is that?
+(phonetic sp.).
+MR.
+MR.
+Yeah.
+MR.
+: And Mr.
+told you,
+do you recall if it was verbally or an email?
+Phone call?
+MR.
+:
+We had talked about it, too,
+but I would have to check if there was an email
+to go with it. But we did talk and said, hey,
+we're going to hold off on putting him out in
+general population.
+MR.
+Okay. Do you recall when
+you officially were, you and Mr.
+|, spoke
+about this?
+MR.
+: I don't want to give you the
+wrong date.
+But it was within that, you know,
+maybe a couple weeks after he arrived.
+MR.
+weeks after he arrived --
+Okay. So, it was a few
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+MR.
+Right.
+MR.
+okay. After Mr.
+told you to keep him, or it was agreed upon --
+MR.
+Um-hum.
+MR.
+-- to keep him in Special
+Housing Unit.
+MR.
+Right.
+MR.
+Who did you notify that he
+was to stay in the Special Housing Unit? How
+does that communication
+--
+MR.
+: So, what it does is I get my
+exec staff together --
+MR.
+MR.
+Um-hum.
+: - which is my Associate
+Wardens, the Captain, my exec, and we have our
+meetings, and I tell them he's not, you know, I
+lay out the specific instructions. He's not to
+go out to general population. And -
+MR.
+Were there, sorry.
+Go ahead.
+MR.
+MR.
+MR.
+NO.
+And that's basically how we
+start.
+MR.
+MR.
+Okay.
+Yeah.
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+MR.
+Were there any other
+specific directions or instructions given to
+the staff regarding him?
+MR.
+: Well, so at the time of him
+staying in there, we had to find him initially
+a roommate.
+MR.
+okay.
+MR.
+: So, and it's hard especially
+in Special Housing Unit when you've got gang
+members in there that are not appropriate to be
+housed with. So, we came up with, I came up
+with
+, who was in there. White
+male, probably be able to cope with him. And
+that's typically how we, you know, that's part
+of the evaluation process.
+MR.
+: Is it standard for inmates
+in Special Housing Unit to have cellmates?
+MR.
+them to have it.
+: We typically would like for
+MR.
+Sure.
+MR.
+: But certain situations
+dictate that they can. If an inmate's a total
+separation from a group, and we get word from
+US Attorney's office or the arresting agents
+that, hey, he's to be totally separated, then
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+they would be housed by themselves. They could
+have an incident in the institution, you know,
+for example our gang members, somebody has an
+issue, and for example, the Bloods, then we
+have to say hey, let's separate him from there.
+You know?
+MR.
+was there any directions
+specifically that Mr. Epstein was to have a
+cellmate at all times?
+MR.
+From psychology when -
+MR.
+okay.
+MR.
+- said hey, that he's
+required, he needs to have a cellmate at all
+times.
+MR.
+Okay. And that occurred
+later on? When he first arrived, there was no
+specific directions regarding that; correct?
+MR.
+No, it wasn't.
+MR.
+okay.
+MR.
+Wait, let me.
+MR.
+Sure.
+MR.
+You mean when he first came
+in were we talking about him having a cellmate?
+MR.
+MR.
+Initially.
+I don't recall any talks
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+about him.
+MR.
+Okay.
+MR.
+Initially, and trying to
+figure out when he first came in, how he was
+housed. I don't recall how he was housed when
+he first came in, but -
+MR.
+stranger to high profile —
+MR.
+_: Right.
+MR.
+: Okay. The MCC is no
+-- inmates.
+Generally
+speaking, how do you normally, or generally
+handle these type of high profile inmates? Any
+other special considerations or concerns. How
+does this work?
+MR.
+: Again, you come in. We
+evaluate him to determine, okay, if they can go
+out to general population or not. We've had,
+you know, we've had a bunch that come in that
+were able to go out. We had
+(phonetic
+sp.), you know, the phone that, I don't know if
+you recall, the one that
+MR.
+MR.
+MR.
+:
+(Indiscernible *00:12:41).
+okay.
+Him.
+So, when he first came
+EFTA00125482
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+in, you know, he was high profile. So, we
+brought him in to determine --
+FEMALE VOICE: Excuse me.
+MR.
+•: Yeah.
+FEMALE VOICE: Can you guys step out here
+for just a moment?
+MR.
+We, pausing the interview
+at 10:55 a.m. (tape paused).
+We're resuming the interview with Warden
+18
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+MR.
+MR.
+MR.
+MR.
+Yeah.
+(Indiscernible *00:00:14).
+The time is now 10:56. Joining the interview
+room is Assisting United States Attorney from
+the Southern District of New York,
+MS.
+MR.
+I apologize.
+Can you spell your name for transcription
+purposes?
+MS.
+Sure.
+MR.
+Thank you.
+Thanks.
+Before we were
+EFTA00125483
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+just going over some of the overall high-
+profile inmates and the general --
+MR.
+Um-hum.
+MR.
+-- evaluation of them.
+5
+6
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+Going back to, you said earlier that a few
+weeks had occurred. You and the Regional
+Director discussed keeping Epstein in the
+Special Housing Unit.
+MR.
+Um-hum.
+MR.
+How often was the Regional
+Director being briefed on Epstein?
+MR.
+: I guess the situation
+dictated it. If something happened, then we'd
+notify him, or he needed some questions for
+him, he would call me. But I don't want to, I
+don't recall the specific amount of times. But
+we were in contact.
+MS.
+MR.
+MR.
+Um-hum.
+Frequent contact.
+Okay. How often were you,
+are you notified differently of high-profile
+inmates or how often were you being aware or
+notified of Epstein's housing situation?
+MR.
+well, I mean, he was in the
+Special Housing Unit. So, I knew where he was.
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+MR.
+Okay.
+MR.
+: So, it wasn't like I had to
+be updated as to where he was. I knew where he
+was.
+10
+11
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+MR.
+okay.
+MR.
+: I mean, I knew that he went
+on his attorney visits, spent the whole day
+there. Would be the first one in, last one
+out. So, I mean, that's what I knew. And then
+I kind of (Indiscernible *00:02:06) with the
+attorneys. I had some outside attorneys
+complain about, you know, they were taking up
+the attorney room.
+So, I knew that was, you
+know, those issues were coming up with the
+attorney room.
+MR.
+Okay. Going back to
+general policies at the --
+MR.
+Um-hum.
+MR.
+- within the BOP,
+actually when Epstein arrive -
+MR.
+Um-hum.
+MR.
+- I think we already
+covered this, but just to, were any special
+arrangements or considerations given to him?
+MR.
+: As far as --
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+MR.
+obviously you said earlier
+he was put in the SHU on Monday.
+MR.
+: Right.
+MR.
+: After, was it, at that
+point, was there any issues that you're aware
+of regarding him? Anything that you needed to
+be aware of other than just who he was?
+MR.
+: No. Just who he was and the
+basic screening. The intake screening.
+MR.
+Okay. At the time he
+first arrived, did you have any, was there any
+notification of any mental health concerns?
+MR.
+MR.
+MR.
+weekend he came in, or --
+MR.
+Yeah.
+MR.
+MR.
+No, not that I know of.
+Okay. How --
+Are you talking about the
+(Indiscernible *00:03:19).
+: First arrival.
+MR.
+: That weekend, I don't know.
+But I know afterwards, he was medically
+assessed and they were, you know, our health
+service department assessed him and he, I think
+he might have told him that he had certain
+medications.
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+MR.
+MR.
+MR.
+Okay. When --
+- that he was taking.
+When inmates come into the
+MCC, are they all screened for mental health
+issues or medical issues?
+MR.
+: Well, yes. They come in,
+you're screened for your medical. The unit
+team screens you and psychology screens you.
+But --
+MR.
+What timeframe does that
+occur?
+MR.
+: Typically like with him, he
+came in on the weekend. So, it depends if
+there was a psychologist. Maybe the next day
+someone would go screen him, the on-call
+psychologist. But, you know, or Monday if
+someone came in. But typically the on-call
+psychologist is there through the weekend and
+will screen them.
+MR.
+: Who is notified of the
+results of those screenings?
+MR.
+: of?
+MR.
+: Of the medical screen and
+psychological screenings, who gets notified of
+that?
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+MR.
+find something in there?
+MR.
+MR.
+example? I mean --
+: As far as what? If they
+Yes.
+:
+Like what would be an
+MR.
+: Any medical concerns that
+people need to be aware of. Any psychological
+issues. How does that information get
+disseminated?
+MR.
+Because when we talk about
+medical issues, some of that falls under
+privacy issues.
+MR.
+MR.
+Um-hum.
+So, you know, it's not going
+to be divulged as to --
+MR.
+MR.
+okay.
+-- just like that.
+MR.
+Sure.
+MR.
+But as far as psychological,
+if it was something that psychologists did an
+interview and said, hey, there's a mental
+health issue or something, then she would, you
+know, she would let her Associate Warden know.
+She would let me know that, hey, there's some
+issues.
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+MR.
+Okay. And when he first
+arrived, were you made aware of any medical or
+mental issues regarding him?
+MR.
+Mental health, I don't
+recall any mental health. But I was told that
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+he was on certain medications or whatever. But
+it was general. It wasn't -
+MR.
+MR.
+okay.
+- anything major.
+MR.
+okay. And just, and
+that's a general policy for all inmates that
+arrive?
+MR.
+MR.
+The screening, yeah.
+Just the medical
+screening. They all get that?
+MR.
+Right.
+MR.
+Is there any, as a result
+of those screenings, is there any, does it have
+any bearing on where they're placed, whether
+it's special housing or general population?
+MR.
+: I mean typically if you do,
+like I said, if you do an intake screening and
+the individual comes in and they have no
+issues, no separation issues, and, you know,
+then they can populate like anyone else. But
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+if there are issues with them going out in
+general population; i.e., safety issues, then
+you would be placed in the Special Housing.
+MR.
+: Okay.
+MR.
+Until we could further
+evaluate if you could go to general population.
+MR.
+If someone during the
+mental health screening, the mental health, the
+psychologist deemed them to be suicidal -
+MR.
+okay.
+MR.
+-- what are the suicidal
+watch policies as it relates to that?
+MR.
+: So, if the psychologist was
+to say, hey, they're suicidal, then they would
+be placed on suicide watch.
+MR.
+MR.
+: Okay.
+: Now if the psychologist is
+not there and someone exhibits suicidal
+ideations or statements or thoughts, then
+they're placed on suicide watch.
+MR.
+Can you explain to me what
+suicide watch is, where it is in the MCC --
+MR.
+: It's on the second floor of
+the institution, on the same floor of the
+hospital.
+EFTA00125490
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+MR.
+Okay.
+MR.
+And it's a cell, and if you
+go on suicide watch, you're placed in a smock.
+MR.
+Okay.
+MR.
+That covers you and then
+you're watched for 24 hours.
+MR.
+Now the smock, is that
+made of paper, or --
+MR.
+:
+MR.
+MR.
+vests?
+It's cloth.
+Cloth?
+It's like, you ever see
+those movies where they have those heavy bomb
+MR.
+Uh --
+MR.
+:
+It's something, I mean, I
+don't want to you know, say, but it's something
+like that.
+MR.
+MR.
+MR.
+Okay.
+And it just hangs.
+Sure.
+MR.
+Hangs on them just like
+that. So --
+MR.
+And you said they' re
+monitored for 24 hours. How are they, is it -
+MR.
+There's a companion sitting
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+there. An inmate.
+MR.
+MR.
+MR.
+In the cell?
+No. Outside the cell.
+MR.
+Okay.
+It's a cell where you sit
+and observe.
+MR.
+another inmate or a staff?
+Okay. Is the companion
+MR.
+: No, it's a trained inmate
+companion. Now, we have four cells.
+If those
+cells get full, then we have to move them up to
+the Special Housing Unit and then put a staff
+watch on them.
+MR.
+: Okay. What policies are
+in place for suicide watch as it relates to
+staff response, notification, how people get
+notified, if they're moving from suicide watch
+to off suicide watch. How does that work?
+MR.
+psychology.
+•: That works through
+MR.
+MR.
+okay.
+Psychology evaluates and
+they' 11 say, okay, we've evaluated him and, you
+know, wherever we're going, typically you
+always usually go from the Special Housing Unit
+EFTA00125492
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+1
+to suicide. So, they'd say, okay you know
+2
+what, they're ready to go back up.
+3
+MR.
+: Okay. What role, how does
+4
+the program, is the psychologist the program
+5
+coordinator?
+6
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+25
+MR.
+: The chief psychologist runs
+the department.
+MR.
+Okay.
+MR.
+•: And then she has various
+psychologists that work under her.
+MR.
+okay.
+MR.
+: And then evaluate because we
+have a different mission as far as we have a
+forensic mission. So, we get a lot of forensic
+studies in the institution.
+MR.
+MR.
+: Okay.
+: And then we have a regular
+psychologist also that handles the inmate
+population but they work together and they
+handle everything.
+MR.
+okay. Who's ultimately
+responsible for placing somebody on suicide
+watch or off suicide watch?
+MR.
+:
+Well placing it, a staff
+member comes and says hey, this guy is
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+suicidal. You can place him on suicide watch.
+MR.
+Okay. Anybody in the
+institution can do that?
+MR.
+: Yeah. If I come upon an
+inmate that's saying, "Hey, I'm going to kill
+myself." Okay, we get him on suicide watch.
+Psychology comes and, you know, evaluates them
+and then comes up with a plan.
+MR.
+Within the psychology
+department --
+MR.
+Um-hum.
+MR.
+-- or the medical
+department there in mental health, who there
+ultimately makes that decision?
+MR.
+: I believe, and don't quote
+me on this. I believe the psychologists.
+MR.
+Okay.
+MR.
+: You know, they're trained
+professionals. So, they can make a decision
+and they consult with the Chief in, you know,
+determining okay what's the plan of action to
+move forward.
+MR.
+: And are you, when
+someone's placed in suicide watch, are you
+notified of that?
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+MR.
+: Yeah. They send out a form
+every day stating like who's on suicide watch,
+who's on psyche observation. So --
+MR.
+MR.
+okay.
+-- we're aware of who it is
+and then they' 11 send out a form if there's no
+one on there.
+MR.
+You said earlier that
+while on suicide watch, there was an observer.
+Right.
+MR.
+MR.
+How does an inmate become
+an observer?
+MR.
+MR.
+It's an inmate companion.
+A companion, I'm sorry.
+MR.
+: So, it's a trained program.
+So, they have to go through training. They
+have to take courses, and then they become
+eligible to become
+a companion.
+MR.
+an inmate companion?
+Who authorizes the use of
+MR.
+: The psychology department
+runs that.
+So --
+MR.
+: Do you have any input as
+the Warden in selecting or training or
+implementing the inmate companion program?
+30
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+MR.
+7:
+No.
+MR.
+Does every institution
+have an inmate companion program?
+MR.
+Yes.
+MS.
+Who's the Chief
+Psychologist?
+MR.
+(phonetic
+sp.).
+MR.
+And Ms.
+is the one
+who is ultimately responsible for determining
+if someone is on suicide watch and removing
+them; correct?
+MR.
+: well in conjunction with our
+staff.
+MR.
+: Okay.
+MR.
+Because you could be, a
+psychologist is assigned to the individual when
+they're working a plan with them. And if they
+come to the determination that hey, you know
+what, they no longer need to be on suicide
+watch.
+MR.
+Okay. But as the clinical
+director, she's ultimately responsible.
+MR.
+She's not the clinical.
+She's the Chief Psychologist.
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+MR.
+MR.
+Okay.
+Clinical Director is a
+separate position.
+MR.
+Okay. I apologize for
+that.
+MR.
+MR.
+MR.
+That's fine.
+: Thank you for clarifying.
+Okay.
+MR.
+Who in the medical staff,
+just for my clarification, who in the medical
+staff is ultimately responsible for removing
+somebody from suicide watch?
+MR.
+:
+The psychology department
+determines to remove somebody from -
+MR.
+So, who in the psychology
+department?
+MR.
+: Again, it depends on who's
+evaluating the inmate.
+MR.
+: Okay.
+So --
+MR.
+•: And so we have one, two,
+three, really we have, (Indiscernible
+*00:12:26)
+, uh, four. we have four
+psychologists on staff.
+MR.
+: You have four
+psychologists on staff.
+And any one of those
+32
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+four can remove somebody?
+MR.
+MR.
+Can remove somebody.
+Do those four have, who's
+those four supervisors?
+MR.
+MR.
+MR.
+DI-
+DI.
+Yeah.
+MR.
+What authority does she
+have to overrule them?
+MR.
+And I'm not a psychologist -
+-
+MR.
+Sure.
+MR.
+- to know what procedures
+they use -
+MR.
+Um-hum.
+MR.
+- or what conversation they
+have to determine if she's going to overrule
+them. I mean, she's the supervisor, and it's
+just like with any, you know, profession you
+have.
+MR.
+MR.
+reasoning --
+Right.
+If I come up with some
+MR.
+MR.
+Um-hum.
+In saying hey, I don't agree
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+with your decision, then we debate it and then
+we ultimately come to a decision.
+MR.
+: Okay.
+MR.
+As to yay or nay.
+MR.
+MR.
+Okay.
+So, it's kind of the same
+thing.
+MR.
+While on suicide watch,
+you said there's a 24-hour companion. What
+does staff do for the inmates while they're on
+suicide watch?
+MR.
+: Well we have a camera, well
+they're trained to, there's a phone there.
+SOr
+let's say something happened where an inmate's
+trying to do harm to himself. They pick up the
+phone and they call for assistance, because it
+goes directly to control center, and we respond
+accordingly to it.
+But we also in our control center, while
+the individual is on suicide watch, there's a
+camera there.
+MR.
+MR.
+MR.
+Okay.
+To view --
+What specific training
+does staff get as it relates to the suicide
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+watch?
+MR.
+Once a year during our
+annual training, we have suicide prevention
+training.
+MR.
+MR.
+MR.
+okay.
+During our annual training.
+And that's required for
+all --
+MR.
+MR.
+: All employees.
+What does that training
+cover?
+MR.
+•: Suicide signs, prevention,
+coping, just anything pertaining to suicide,
+sir. Signs to look for.
+MR.
+Um-hum.
+MR.
+Um --
+MR.
+Is there any specific
+staff that are more trained, or specifically
+trained for this area of the prison?
+MR.
+: Our Special Housing Unit
+staff get quarterly suicide prevention
+training.
+MR.
+: Okay. Is that part of
+something the MCC does independent, or is that
+policy dictated? How does that --
+35
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+MR.
+That's our policy dictates
+that they get quarterly training.
+MR.
+Okay. That's BOP policy;
+correct?
+MR.
+Yes.
+MR.
+Okay. When someone, you
+said that any staff member at the BOP can place
+somebody on suicide watch?
+MR.
+•: Yes.
+MR.
+Is there any paperwork or
+documentation for that that they have to fill
+out?
+MR.
+: No. Basically they'11 tell
+that, you know, that hey we need to place him
+on watch, and we'll place him on watch, and
+then we'll contact psychology.
+MR.
+: Okay.
+MR.
+To come in and talk to them.
+MR.
+• Okay. There's no referral
+that says, "I placed inmate" -
+MR.
+: No. Psychology will handle
+it --
+MR.
+okay.
+MR.
+- here and there, in their
+notes and their documentation that they were
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+placed on it, when they were placed on it.
+MR.
+So, the psychology
+department is responsible for documenting when
+people come in in treatment.
+MR.
+: We, you know, we have what
+we call a daily log in the --
+MR.
+Um-hum.
+MR.
+-- institution. So, the 1og
+would annotate somebody was placed on suicide
+watch also.
+MR.
+: Okay. Is there any
+specific forms or reports that get filled out
+when somebody is removed from suicide watch?
+MR.
+: I believe psychology would
+do those forms and saying in their reports why
+they were removed and if they're ready to be
+released.
+MR.
+MR.
+: Do you get those forms?
+: I don't get the special
+medical ones. I just, with the notification
+that, you know, with the one that email that
+goes out --
+MR.
+Um-hum.
+MR.
+- that the individual was
+released from suicide watch.
+EFTA00125502
+
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+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR.
+Do you get notified, you
+just said you get notified in the email that
+somebody's removed or --
+MR.
+: It's an email that the
+psychology department puts out stating who's on
+suicide watch, who's been removed.
+MR.
+: Is that a daily list?
+Like they send it once a day, or when someone
+new comes on and off? How does that --
+MR.
+It's a daily one. And --
+MR.
+Okay.
+MR.
+: And it states who's on
+watch, who's, you know, who's got released, and
+--
+MR.
+disseminated to?
+Who does that get
+MR.
+: It's a group. It's a group
+email that gets sent to all department heads,
+Captain, Lieutenants, everybody in the need to
+know.
+MR.
+This is the supervisors
+within the institution? The Lieutenants, the
+Captain.
+MR.
+MR.
+(Indiscernible *00:17:07).
+okay.
+EFTA00125503
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+MR.
+: And, don't quote me on that,
+but I need to look at the chain --
+MR.
+MR.
+: okay.
+- to see who's actually on
+it. But -
+MR.
+But it's not an
+institution-wide email?
+MR.
+: It is kind of sent out
+institution wide because you have the different
+departments on it. So, you can say it's
+institution wide.
+MR.
+Not every person in the
+institution gets that email, though?
+MR.
+: No. I don't -
+MR.
+Okay. Just not an MCC all
+type of --
+MR.
+MR.
+MR.
+: No, it's not an all staff.
+okay.
+Yeah.
+MR.
+What is the expectation of
+the department heads and the supervisors and
+the Lieutenants and Captains once they get this
+email?
+What are they supposed to do with that?
+MR.
+: I mean, it's just a
+notification that the individual's being
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+removed from suicide watch. So, it depends on
+where they're going. So, if they're going back
+to Special Housing Unit, so it's notification
+that hey, this person's been taken off. We
+have nobody on watch right now.
+MR.
+Okay. Are they supposed
+to disseminate that? What are they supposed to
+do with that information? Are they supposed to
+tell anybody where they -
+MR.
+Well, I mean when that
+individual is released --
+MR.
+Um-hum.
+MR.
+Wherever they're going for,
+they're going to be notified by psychology that
+they're coming directly -
+MR.
+okay.
+MR.
+- to you.
+MR.
+MR.
+okay.
+So, it was just an
+accountability -
+MR.
+okay.
+MR.
+-- thing just to know that
+hey, this person is getting off of watch.
+MR.
+So, psychology will notify
+whatever unit they're going back to?
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+18
+19
+20
+21
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+25
+MR.
+Well, it depends where
+you're going back to. Typically I always go to
+Special Housing Unit down.
+MR.
+: Okay.
+MR.
+And typically when you do,
+let's say an individual has tried to commit
+suicide. It's an infraction. So, they usually
+have an incident report that goes beyond that.
+So, you have to come up to the Special Housing
+Unit anyway before so that that infraction can
+be resolved.
+MR.
+: Okay.
+MR.
+So, there are a number of
+aspects of, you know, how. Did you go straight
+back or if you don't go back there.
+MR.
+: And this email that
+psychology sends out with the list of who's in
+and who's out of suicide watch --
+MR.
+: Who's on watch, yeah?
+MR.
+: -- is that once a day or
+Is that morning and evening
+twice a day?
+thing?
+MR.
+MR.
+MR.
+It depends.
+okay.
+When you come in in the
+EFTA00125506
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+morning, they could say, you know, this is
+2
+who's on watch, and then you get another one
+3
+stating who's been released off of watch.
+4
+MR.
+Okay. Is there any policy
+5
+or standard operation procedure on how
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+(Indiscernible *00:19:21) that email gets sent
+out?
+MR.
+MR.
+MR.
+MR.
+: How what?
+How frequent that email -
+No.
+Okay. But it should be at
+least once a day?
+MR.
+: That's when they send it
+out. I don't --
+MR.
+Okay. When somebody is
+removed from Special Housing --
+MR.
+Um-hum.
+MR.
+- and placed in suicide
+watch on the second floor --
+MR.
+Um-hum.
+MR.
+-- is anything done to
+their cell in Special Housing? Is there any
+precautions or anything that go into that?
+MR.
+: So, typically let's say you
+do leave, and it depends on how much space we
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+have. We really don't have that much space.
+MR.
+Okay.
+MR.
+: So, usually that cell,
+depending on if when they were removed from the
+cell, if they had a cellmate.
+So, what happens
+is that individual's property is removed, and
+we could possibly put somebody else in that
+cell.
+MR.
+Okay.
+MR.
+Um --
+MR.
+And again, the suicide
+watch versus psychological, the psyche eval
+that, you said that happened right away when
+someone first comes in the prison; correct?
+MR.
+Well I --
+MR.
+MR.
+A psyche eval?
+- I didn't say what you
+said before that. You said --
+MR.
+: A psychological eval.
+MR.
+Okay.
+MR.
+I want to clarify, earlier
+you said that people, inmates get that when
+they first come into the prison; correct?
+MR.
+: Yeah. Psychologically when
+they initially have to come and actually
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+perform -
+MR.
+MR.
+screening.
+MR.
+okay.
+-- an initial intake
+Is there a level below
+suicide watch?
+MR.
+: Well we also have what we
+call a psyche observation.
+MR.
+1: Okay.
+MR.
+: And I think the best way to
+describe that would be it's a step-down from
+suicide watch. For example, we might have a
+mental health inmate that is just mentally, you
+know, out there. So, we'll put them on psyche
+observation. They haven't said they're going
+to hurt themselves, but they have the potential
+to do it.
+Somebody might be on narcotics and acting
+erratic and you don't know what they're on.
+So, they might end up doing it. But it's a
+different type of observation because it's not
+as stringent as suicide watch.
+MR.
+: okay.
+MS.
+Can you explain what that
+means? What are the requirements when an
+EFTA00125509
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+2
+observation?
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+MR.
+]: If they're on psyche
+observation, we are not necessarily putting
+them in a smock. You know? You can still have
+your regular clothing. We're just observing
+your behavior and that. So, that's the
+difference.
+MS.
+: And does the psychologist
+stop by every day?
+MR.
+: They're treated the same way
+as somebody that's on suicide watch. They're
+evaluated, come up with a plan. They're ready
+to be released. Keep them on, more along those
+lines.
+MS.
+Well is someone on psyche
+evaluation, do they have an inmate companion
+watching them?
+MR.
+•: Psyche obs also has an
+inmate companion. So, anybody in that area has
+an inmate watching them.
+MR.
+: As the Warden, do you have
+any input on the determinate if someone's in
+psychological observation, in suicide watch or
+observation status? Do you have any input on
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+that?
+MR.
+: I don't overrule medical
+decisions. I'm not a doctor.
+MR.
+Um-hum.
+MR.
+If they come to me and say
+this is warranted whether it's medical care or
+not, I don't --
+MR.
+MS.
+Okay.
+But you're briefed on it?
+MR.
+I'm briefed on it. Yes.
+MS.
+Is that orally?
+MR.
+: Orally they' 11 come and say,
+well we'll discuss an inmate saying, hey, he
+has mental issues. I feel that they need to be
+placed here or there. And I'm going with your
+evaluation. I'm not going to, and I have good
+psychologists. So, I trust their judgment.
+MS.
+: Can an inmate be taken off
+of suicide watch by Dr.
+or her staff
+without consulting you?
+MR.
+: They can. The doctor
+decides who's coming off of watch. So, they
+can make the determination and, you know, they
+send up to the Associate Warden, the Captain,
+and it will come to release and if they're
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+going off it. So, it doesn't -
+MS.
+But do they-
+3
+4
+5
+MR.
+: — have to necessarily, it's
+not my approval.
+MS.
+: Do they typically consult
+6
+MR.
+7
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+11
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+13
+14
+15
+16
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+19
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+21
+22
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+25
+you when that happens?
+: Depending on, you know, if
+it's the case, you know? Who it is, you might
+be, like I said, a high profile individual they
+would say, "Hey, we're taking him off of watch.
+We're doing this." So, we'll be following the
+plan closely, so -
+MR.
+When it comes to Epstein,
+Jeffrey Epstein --
+MR.
+Um-hum.
+MR.
+-- he was in the mental
+health program. Can you just tell us your
+understanding of his involvement with the
+psychologist at MCC?
+MR.
+Um, let me back-track.
+MR.
+Sure.
+MR.
+It's not a mental health
+program.
+MR.
+MR.
+Okay.
+Um --
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+MR.
+MR.
+psychology -
+MR.
+MR.
+Sorry.
+Being, I guess, reviewed by
+Sure.
+- they're following him.
+He was on their case.
+MR.
+MR.
+knew about it?
+MR.
+MR.
+: Okay.
+And you want to know what I
+Yes.
+: Again, he was under their
+care. They were evaluating him, and, you know,
+going through their protocol to determine why
+he was on watch. If he was on suicide watch,
+can he come off of suicide watch? Was he
+suicidal? Things like that.
+MR.
+: At any time, were you
+aware or notified of him being suicidal or
+having any suicidal ideations or attempts?
+MR.
+: Well we had an incident
+where he was in the cell with
+MR.
+: Okay.
+MR.
+: - that it might've been a
+suicide attempt and it might not have been a
+suicide attempt. So, we followed the protocols
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+and put him on watch. There was also an
+internal investigation where he was interviewed
+and his cellmate was interviewed, and he
+basically denied (Indiscernible *00:25:35).
+MR.
+when you say "he denied",
+MR.
+MR.
+MR.
+He said --
+-- or Epstein?
+: No, Epstein stated that,
+"Hey, I didn't try to kill myself." And then
+said that he was sitting in the
+cell. He thought he was having a heart attack.
+So, I forget the words psychology used to
+determine what their conclusion was as far as
+the actual act.
+MR.
+okay.
+MS.
+: Did you review the
+incident report for the suicide attempt?
+MR.
+: I reviewed the investigative
+report that the Lieutenant interviewed both of
+them, took their statements, and all that
+because the review process goes from, the
+Lieutenant initiates it. It goes to the
+Captain, Associate Warden, and myself. And
+then I, uh, sign off on it.
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+MS.
+Did you speak with Dr.
+after she had consulted with Mr. Epstein
+when he was placed on suicide watch?
+MR.
+:
+Um, yes. We have SHU
+meetings, and we have it once a week, and
+Epstein was brought up, and she talked about
+Mr. Epstein.
+MS.
+After the suicide attempt?
+MR.
+1: Yes.
+MS.
+What day of the week is
+the SHU thing typically?
+MR.
+MS.
+It's Thursdays.
+: All right and --
+MR.
+Right.
+MS.
+-- what happens at the SHU
+meetings?
+MR.
+: It's a list where we go
+around and we talk about every inmate. We have
+inmates that are in there for infractions,
+criminal issues, from your office, a high-
+profile guy might come in. So, we just talk
+about, okay, what's the status. If we call in
+a disciplinary citation, that means they've
+been sanctioned and they're doing time, and
+then we look at the release date. We have some
+EFTA00125515
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+in there pending investigations.
+Cellphone
+2
+introduction. Drug introduction. So, that
+3
+goes through the investigative process, and
+4
+then we have, you know, we also have our SAMs
+5
+(phonetic sp.) inmates that are housed in
+51
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+25
+there.
+7
+8
+So, we basically discuss and talk about
+every inmate.
+MS.
+: And who attends these
+meetings?
+MR.
+•: Myself, all the Associate
+Wardens, the Unit Managers, psychology, the
+Captain, the SHU Lieutenant, the Investigative
+Lieutenant. So, we just have everyone there
+that's involved in the --
+MS.
+And what's your
+understanding of whether the SHU Lieutenant or
+the Captain brief out the duty Officers in the
+SHU about the outcome of that SHU meeting every
+week.
+MR.
+: I don't understand what you
+mean.
+MS.
+: So, do you have an
+understanding of whether, because the duty
+Officers are not present in the SHU meeting;
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+correct?
+2
+MR.
+: No.
+3
+MS.
+: Do you have an
+4
+understanding of how, for instance, if you tell
+5
+the Lieutenant, I want this done in the SHU,
+6
+will the Lieutenant then tell his duty Officers
+7
+after the meeting?
+8
+MR.
+: Well, the duty officer is
+supposed to make rounds throughout the
+10
+institution when they're on duty to observe and
+11
+report if anything is not right. And then if
+12
+13
+14
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+18
+19
+20
+21
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+25
+we have incidents, they make notifications, you
+know, to the region.
+MS.
+: To the region?
+MR.
+: To, like let's say we have a
+fight.
+MS.
+Um-hum.
+MR.
+: Or maybe like you said, a
+suicide attempt. So, they have to contact the
+Regional Duty Officer. That's their
+notification. They make the Regional Duty
+Officer, and then it moves up the chain that
+way, and then I have to make my notifications,
+which I make my notifications to the Regional
+Director.
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+MS.
+Okay. And my question is,
+does any information, do you have an
+understanding of whether any information that's
+conveyed in these SHU meetings gets briefed
+down to the line Officers who are responsible
+for patrolling the SHU?
+MR.
+MS.
+Right.
+It does?
+MR.
+: Yeah. The SHU Lieutenant is
+there, and he's in the meeting, he or she is in
+the meeting, and they're talking to their staff
+on what needs to be done or the status, you
+know. We're going in and we determine if
+somebody can be released, then that will be
+conveyed back that hey, an individual can be
+released.
+MS.
+: So, you were saying that
+after the July 23d suicide attempt, there was a
+Thursday SHU meeting?
+MR.
+: Right.
+MS.
+In which Dr.
+discussed at least her initial observations of
+Mr. Epstein?
+MR.
+: Well, she would initially
+discuss it there, but she would also initially,
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+2
+initiate it to the Aw. So, that would be
+3
+something immediate that she would say, hey,
+4
+he's on watch and this happened.
+5
+MS.
+And what happened at that
+6
+first SHU meeting after the suicide attempt?
+7
+MR.
+: The week of July 22nd to the
+8
+26th, I was on leave.
+9
+MS.
+: Okay.
+10
+MR.
+So, I was, you know, I was
+11
+getting called. So, I don't know the
+12
+13
+14
+15
+16
+17
+18
+19
+20
+specifics, but I was aware of, you know, I got
+called that hey, there was an attempt and the
+protocols were followed.
+MS.
+okay.
+MR.
+Notifications were made.
+MS.
+Okay. So, the following
+week which I think is the week of the 29th.
+MR.
+: The 29th or the 30%h, yeah.
+MS.
+You were back in the
+21
+22
+23
+24
+25
+office?
+MR.
+: That Monday. So, if you
+have a calendar, I can look at it.
+MS.
+MR.
+I think it's the 29th --
+So, yeah. So, the 29th is a
+54
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+Monday. I have to check, did I take a extra
+day or not? I'm not sure, but the 29th, I
+should've, I would've been back.
+MS.
+So, that Thursday meeting
+which looks like would've been August 15t, you
+were present at?
+MR.
+:
+Yes.
+MS.
+And what was discussed
+during the SHU meeting?
+MR.
+The SHU meeting, we'll
+discuss every inmate. Every inmate on the
+list, what's their status? Updates and all
+that stuff.
+MS.
+Okay. And specifically
+with respect to Epstein, what was discussed?
+MR.
+: I don't recall specifically.
+I know we would've talked about him. We
+would've probably talked about, you know, his
+psychological status and I got to remember on
+the first, he was probably back in the Special
+Housing Unit. So, we were probably, you know,
+talking about his housing conditions, what's he
+doing, and usually the conversation was during
+the day he was down at the attorney visits, you
+know?
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+And then there were certain exams that we
+had to do that we wanted to get done on him.
+And then we discussed that.
+MS.
+Uh, what kind of exams?
+MR.
+Physicals and then, you
+know, and I don't know if that was before or
+after his sleep apnea machine that he was, you
+know, requesting.
+MS.
+Um-hum.
+MR.
+Because typically, you know,
+you have to go through the fitting and the
+process, but, you know, we allowed that one to
+come in. We checked it, security wise, and
+said it was fine to come in, and we got it.
+So, I think we might have been discussing that,
+more along those lines.
+But we discuss every inmate in there.
+I
+don't specifically remember it. I know we
+would've talked about what the issues were
+pertaining to him.
+MS.
+MR.
+MS.
+MR.
+MS.
+Um, let's go back to --
+Um-hum.
+- the suicide attempt.
+okay.
+You said that you were on
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+leave that week, but you were notified by your
+Associate Warden?
+MR.
+MS.
+daily updates?
+•: Associate Warden, yes.
+Okay. Were you receiving
+MR.
+•: Not, I mean, they called me
+during the day the first time that it happened.
+Hey, this is what happened. He's on watch.
+And then the next day, you know, he was still
+on watch. So, there was really no, I didn't
+need that much updates because we knew he was
+on watch.
+MS.
+MR.
+MS.
+Regional Director?
+Okay.
+:
+Um --
+: And you notified your
+MR.
+: I notified my Regional
+Director. And then while I was on leave, my
+Regional Director was also in contact with my
+acting AW.
+MS.
+Did the --
+MR.
+MS.
+Acting Warden, I'm sorry.
+: Did the Regional Director
+convey any directions to your AW during that
+time?
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+MR.
+: I believe just the basics,
+you know. Keep him updated what's going on
+because at the time he was under psychology's
+care.
+MS.
+Um-hum.
+MR.
+•: So, once they're in that,
+there's really not that much input to go on
+because they're on watch.
+MS.
+And then Epstein was
+downgraded from suicide watch to psyche
+observation.
+MR.
+MS.
+Psyche observation.
+While he was still on the
+second floor?
+MR.
+Yes.
+MS.
+Were you notified of that
+change?
+MR.
+: Yes, that he was on psyche
+obs.
+MS.
+that with Dr.
+Okay. And did you discuss
+at all?
+MR.
+: Yeah. We talked about it.
+Again, it was, you know, him going back up to
+the Special Housing Unit. Although he wasn't
+suicidal, it was just a matter of, okay, who
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+are we going to house him with?
+MS.
+Um-hum.
+MR.
+: You know, coming to that
+decision and then that would give her more time
+to work with him if she needed.
+MS.
+discussion with Dr.
+Okay. Did you have a
+• about whether she
+felt he was still suicidal?
+MR.
+: Again, if the psychologist
+tells me that he's ready and he goes, I don't
+question medical judgment. I trust her
+judgement. If she says he's not suicidal and
+he's ready to go back, then we trust her
+judgment.
+MS.
+And she did --
+MR.
+Because she --
+MS.
+- tell you that?
+MR.
+: She said he was ready to go
+back. He wasn't suicidal and that he was ready
+to go back.
+MS.
+Did you review any of her
+reports or the psychologist's reports --
+MR.
+: I don't --
+MS.
+on the second floor?
+-- during the time he was
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+MR.
+medical files.
+No.
+I don't review any
+MS.
+And he came back to the
+SHU on the 30%h, is that right?
+MR.
+Uh, yes.
+MS.
+okay.
+MR.
+MS.
+Um-hum.
+And what discussions did
+you have, let's start with Dr.
+, about
+the conditions of his confinement in the SHU?
+MR.
+: She just said to get him in,
+you know, we're going to put him, get him a
+cellmate because typically every inmate that,
+you know, is on suicide or whatever, we say,
+okay, we're going to give him a cellmate. So,
+that was when we went through the process of
+figuring out, okay, who could we possibly put
+him in with? Um, the pickings were slim.
+So, I came up with
+and no
+wait, no.
+he had been put down
+there originally because of
+MS.
+: Um-hum.
+MR.
+: So, what happened was, we
+had to come up with some more inmates.
+so, I
+came up with three. It was, I believe,
+EFTA00125525
+
+LIMITED OFFICIAL USE
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+, and who was the other one? We had
+another sex offender in there that we were
+going to put him in there, and he said, "If he
+comes in here, it's going to be a problem."
+So, we didn't put him in there.
+So, we ended up putting
+MS.
+Um-hum.
+in there.
+MR.
+, an older gentleman.
+He couldn't be in the institution because it
+was cooperating, so we figured that was a good
+fit, and then I sent an email of the three to
+the Director's Chief of Staff I sent an email
+to.
+61
+10
+11
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+13
+14
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+19
+20
+21
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+MS.
+And what is his name?
+MR.
+(phonetic
+sp.).
+MS.
+: Okay. And so you emailed
+him, here are the three --
+MR.
+: Here are the three -
+MS.
+-- possible --
+MR.
+-- possible ones.
+MS.
+okay.
+MR.
+Right.
+MS.
+Did you tell
+-
+MR.
+EFTA00125526
+
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+MS.
+Did you tell Mr.
+that he needed to have a cellmate?
+MR.
+: Yes. That's what the
+discussion was, for a cellmate. So, I sent
+that up, spoke with my Regional Director. I
+believe he received it too, and came to the
+conclusion
+would probably be the best fit
+for him.
+So, we put him in the cell with
+10
+11
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+14
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+MS.
+Is there a policy about
+whether an inmate needs to have a cellmate
+after they've been taken off of suicide watch?
+MR.
+:
+There's no policy, but it's
+sound correctional judgment. I mean even if an
+individual is not on suicide watch, and you're
+in the Special Housing Unit, you typically want
+somebody in there with them.
+MS.
+Um-hum.
+MR.
+Because, I mean, you never
+know what could happen. So, just for somebody
+to talk to, you know, pass the time. So, you
+typically put somebody in there unless again
+we're in a situation where they're just totally
+separated from somebody -
+MS.
+Um-hum.
+EFTA00125527
+
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+MR.
+:
+-- and we can't put them in
+there because it becomes a life safety issue.
+MS.
+How long after someone is
+taken off suicide watch would you typically
+direct that they have a cellmate?
+MR.
+: It would depend on the
+situation, because you could be getting
+released to a unit where you would
+automatically have a cellmate going through, or
+you know, direction could put out that, hey,
+make sure the individual has a cellmate.
+So, there's no really timeframe on when
+you would decide that.
+MR.
+Just to clarify, as it
+relates to, I know you guys just discussed
+this, but just making sure I'm following you
+guys correctly. As it relates to the first
+suicide attempt back on July 23rd
+, Mr. Epstein.
+MR.
+: Right.
+MR.
+You were on leave.
+MR.
+MR.
+Yeah, the 22nd
+You were notified via
+telephone of this, and you notified the
+Regional Director. Is that correct?
+MR.
+:
+Yeah, of the, yeah, I did
+EFTA00125528
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+call him to tell him.
+MR.
+: You called the Regional
+Director?
+MR.
+:
+Yes.
+MR.
+-- while on leave to
+notify him? Did you notify anybody else of the
+23'd incident?
+MR.
+1: No, I called my boss, and --
+MR.
+Okay.
+MR.
+Yeah.
+MR.
+And that is, via the
+policy and your responsibilities, as a BOP
+policy and your responsibility as a Warden, is
+there anybody else that you were supposed to
+notify?
+MR.
+No.
+MR.
+okay.
+MR.
+NO.
+MR.
+: And your staff was
+notified because they were working in the
+institution; correct?
+MR.
+MR.
+Which staff?
+Your Assistant Warden, who
+-
+MR.
+Yeah. She was the Acting
+EFTA00125529
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+Warden, so she --
+MR.
+MR.
+MR.
+MR.
+Acting Warden.
+Yeah.
+Who was that?
+was
+At the time, I believe it
+(phonetic sp.).
+Yeah, she was Active Warden.
+MR.
+Okay. Do you happen to
+know if she notified anybody?
+MR.
+:
+She would've notified the
+Region also.
+MR.
+MR.
+Okay.
+And she would've notified
+the region, but she was just calling me --
+MR.
+okay.
+MR.
+- just to let me know like,
+hey, this is what's going on.
+MR.
+Okay. And back when, a
+few days later when Epstein was removed from
+suicide watch to psyche observation --
+MR.
+MR.
+that change?
+Um-hum.
+- were you notified of
+MR.
+MR.
+That he was being moved?
+Just downgraded from
+EFTA00125530
+
+LIMITED OFFICIAL USE
+1
+2
+suicide watch to psychological observation.
+MR.
+Yes.
+3
+MR.
+Did you notify anybody of
+4
+that?
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR.
+: Um, I might've called my
+boss to let him know that, hey, he's been
+downgraded off of suicide watch.
+MR.
+okay.
+MR.
+Yeah.
+MR.
+: You don't recall
+specifically calling?
+MR.
+No, I don't.
+MR.
+Okay.
+MR.
+But I probably would've
+notified him.
+MR.
+Okay. Did you recall
+notifying anybody specifically about that
+downgrade?
+MR.
+: What, as far as him?
+MR.
+Yep.
+MR.
+No, I don't recall, but it
+would've probably been my boss telling me --
+MR.
+: okay.
+MR.
+- hey, we moved him from
+suicide watch down to --
+66
+EFTA00125531
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+17
+18
+19
+20
+21
+22
+23
+24
+25
+MS.
+And that's the Regional
+Director?
+MR.
+: That's the Regional
+Director.
+MS.
+And what's his name?
+MR.
+MR.
+And then a few days later
+when he was removed from observation and placed
+back in Special Housing Unit, you were notified
+of that? Were you notified of that?
+MR.
+MR.
+:
+oh, yes.
+Did you notify anybody of
+that?
+MR.
+: When he was removed and
+placed back in the --
+MR.
+Yes.
+MR.
+-- Special Housing? Yeah, I
+let my supervisor know that that was the plan.
+MR.
+: okay.
+MR.
+He was moving him, because
+remember we had to get him --
+MR.
+Um-hum.
+MR.
+-- a roommate.
+MR.
+Right.
+MR.
+So, that was the whole
+EFTA00125532
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+process, notifying, hey, he's coming off watch.
+He's going to the Special Housing Unit.
+MR.
+MR.
+Um-hum.
+And he's going to get a
+roommate.
+MR.
+other than your Regional
+Director, did you notify anybody else?
+MR.
+That he was coming off -
+MR.
+Yes.
+MR.
+- or talk about it?
+MR.
+Yep.
+MR.
+Yeah. My exec staff.
+MR.
+MR.
+okay.
+And said that, you know,
+what the expectation was that, you know, he's
+going to have a cellmate.
+MR.
+So, you told, during that
+meeting, do you recall when that meeting was?
+MR.
+: I don't recall when the
+meeting was, but I just told them, hey, he
+needs to have a cellmate. This is his
+cellmate. Cellmate at all times. And, you
+know, put it out to your -
+MR.
+MS.
+: Okay. Um --
+Put it out to your people?
+EFTA00125533
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+MR.
+:
+To the departments and your
+areas of responsibility on that's how he was
+going to be housed.
+MS.
+: And who did you
+specifically tell that to?
+MR.
+•: My Associate Wardens were in
+there, whoever was acting, the Captain because
+that specifically falls under his area.
+MS.
+Um-hum.
+MR.
+The Special Housing Unit.
+I
+told him specifically he needs to be housed
+alone. I informed his Lieutenant, you know,
+and his offices and basically on each shift,
+just be mindful, you know, of making rounds and
+just not for him, just for everybody.
+MS.
+And what's the Captain's
+name?
+MR.
+MS.
+•. okay.
+MR.
+Um-hum.
+MS.
+Did you tell Captain
+this before Epstein was moved back to
+the SHU?
+MR.
+: Yeah. We had a meeting, and
+I got together and I said, hey, this was going
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+to be the plan that
+was going to be moved
+in with him. He was going to have a cellmate,
+and that was the protocol we were going to
+follow.
+MS.
+: Did
+confirm that he
+would tell his Lieutenants, or his -
+MR.
+: He confirmed. I followed up
+and asked him, did you put it out to the
+Lieutenants and staff working, and he told me
+yes.
+10
+11
+12
+13
+14
+15
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+17
+18
+19
+20
+21
+22
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+24
+25
+MS.
+And was that before
+Epstein, his confirmation, did that come before
+Epstein was moved back to the SHU, or around
+the first day he was in the SHU?
+MR.
+: No before. I had the
+conversation with him, and then I followed up
+afterwards and said, "Hey, did you disseminate
+the information?" And he said, "Everything was
+disseminated."
+But it wasn't just a one-day thing. It
+was a constant, I told him, a constant follow
+up, you know? Make sure that, you know, these
+protocols are being followed.
+MS.
+How many times do you
+recall telling Captain
+that, between
+EFTA00125535
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+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+when Epstein went back to the SHU -
+MR.
+Um-hum.
+MS.
+-- and then his suicide?
+MR.
+: I don't recall the number of
+times, but it was just a conversation
+constantly reminding that let's be vigilant on
+just not him, but everybody in the Special
+Housing Unit.
+MS.
+Once? Iwice?
+Could you estimate daily?
+MR.
+: I wouldn't say daily. I
+would say, I don't have an actual number. I
+don't want to say an actual number, but you
+know, if I did encounter, or I made rounds in
+the unit, I would, you know, tell staff up
+there, you know, be vigilant with your
+protocol.
+So, I don't know the specific amount of
+time.
+I make my rounds once a week at a
+minimum, but, you know, sometimes it's more.
+Sometimes it's less.
+MR.
+When it comes to the
+ability, so you specifically go back to, what
+you said earlier about
+MR.
+:
+Right.
+EFTA00125536
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+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR.
+You came up with three
+possible --
+MR.
+Right.
+MR.
+- roommates for him, and
+with that list, did you brief that up the chain
+for approval, or where did that go that list?
+MR. I
+: I sent it to, I made my boss
+aware of it.
+MR.
+Okay.
+MR.
+And then I sent it to the
+Chief of Staff in the Director's office. So, I
+don't know what conversations --
+MR.
+Sure.
+MR.
+- took place above that.
+Um --
+MR.
+MR.
+MR.
+chain.
+okay.
+I just know about --
+You briefed it up the
+chain. You briefed your suggestions up the
+MR.
+MR.
+any objections to that list?
+I went up the chain.
+And there was, were there
+MR.
+: I gave the three possibles -
+-
+EFTA00125537
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+22
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+25
+MR.
+Um-hum.
+MR.
+- but you know, one I had
+was a 26-year-old drug dealer I know he, and he
+was still in there, and I was like although he
+was separated, I just didn't -
+MR.
+Um-hum.
+MR.
+- feel that he could, you
+know, he might, somebody could convince him to
+do something. So, he didn't, I didn't feel
+comfortable with him, and I forget the other
+one. And I think the other one might've been
+somebody that was going to be releasing soon.
+MR.
+MR.
+: Okay.
+So, I took in the factors
+" age --
+MR.
+MR.
+Um-hum.
+-- and second when he
+checked himself in and feeling that he was
+going to be long-term.
+MR.
+: Okay. That, so you made
+special care and consideration in picking
+Epstein's roommate, cellmate?
+MR.
+Based on the --
+MR.
+MR.
+Yep.
+-- options I had --
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+19
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+21
+22
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+24
+25
+MR.
+Yep.
+MR.
+- which wasn't too many. I
+mean, he had to have a cellmate, and the
+options weren't good.
+MR.
+Are staff in the Special
+Housing Unit allowed to assign cellmates
+arbitrarily or on their own without consulting
+a Captain, Lieutenant, or yourself
+(Indiscernible *00:46:26).
+MR.
+: Yeah, the offices on their
+own can, you know, if they have to move
+somebody around can move somebody around based
+on they know who can be housed with who. If
+somebody's separation, they know who's
+separated from an individual. So, they can do
+that.
+MR.
+MR.
+doing that.
+MR.
+Okay.
+: I mean, they're capable of
+Okay. As it relates, talk
+about
+a little bit.
+MR.
+MR.
+correct?
+MR.
+Right.
+He's no longer in MCC;
+Right.
+EFTA00125539
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+25
+MR.
+the facility?
+When was he released from
+MR.
+: He was released, I believe,
+on Friday.
+MR.
+: Okay. Was he transferred
+out? Was he released from custody? Under what
+conditions, do you know?
+MR.
+: From what I understand, it
+was with all belongings. So, I don't --
+MR.
+okay.
+MR.
+- who took him. You can't,
+I mean, even if you look on Sentry, you don't
+know where he was --
+MR.
+Um-hum.
+MR.
+-- but when we looked at him
+originally, it still showed that he was going
+to court.
+MR.
+okay.
+MR.
+•: So, that he was going to be
+long-term.
+Now it's just showing there's no
+DST. So, I don't know where
+is.
+MR.
+Okay. But he's not in
+MCC?
+MR.
+MR.
+No, he's not in MCC.
+okay.
+EFTA00125540
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+17
+18
+19
+20
+21
+22
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+24
+25
+MR.
+Uh --
+MR.
+Prior to, you had, you
+were very active in making sure that Epstein
+had an appropriate cellmate?
+MR.
+Right.
+MR.
+What were you, leading up
+to the last week Friday, what were you aware of
+any court proceedings or any issues or
+concerns about him leaving the MCC?
+MR.
+I was off on Friday.
+MR.
+Okay.
+MR.
+: So, I didn't know anything
+about his court proceedings -
+MR.
+Okay.
+MR.
+- or whatever. I just know
+this from after the fact.
+MR.
+: Okay. When it comes to
+• the staff in the Special Housing Unit,
+how do they get notified of court dates, of the
+probability of someone being released from the
+facility? How does that process work?
+MR.
+: They get a call from
+receiving, it's called receiving and discharge.
+MR.
+MR.
+okay.
+where the inmates are
+EFTA00125541
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+19
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+22
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+25
+processed in and processed out. So, they get
+notification that hey, such and such is
+leaving, and send him down.
+MR.
+Okay. Does the MCC
+usually, or sometimes, what's the, how often or
+frequently does the MCC get advanced notice of
+an inmate leaving?
+MR.
+: It depends. If the
+inmate's designated --
+MR.
+MR.
+Um-hum.
+- then we know in advance
+he's designated. But usually the Marshalls
+will come and say, whoever is picking him up,
+"Hey, we're taking such and such." We might
+get a list ahead of time if somebody's going to
+maybe one of the county facilities or some they
+just come and say, "Hey, we need this guy."
+MR.
+the gin,
+okay. Ultimately Friday,
+is discharged.
+MR.
+Um-hum.
+MR.
+Leaving Epstein, actually
+let's talk about without a cellmate. Was there
+a plan in place if that were to happen?
+MR.
+: We'd review it and say,
+okay, who can he be with? But he wouldn't have
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+been alone.
+MR.
+was there anybody in the
+Special Housing Unit that was already vetted to
+room with, or cell with Epstein?
+MR.
+: No. Because again, didn't
+leaving -
+anticipate
+MR.
+: Okay.
+MR.
+- like that. But we
+would've gotten somebody in there temporarily.
+MR.
+When did you first become
+aware of
+leaving the MCC?
+MR.
+: After the death of Mr.
+Epstein.
+MR.
+Okay.
+MR.
+Um, when I came, you know,
+that was like my first question was like, where
+is his cellmate?
+MR.
+MR.
+MR.
+Okay.
+I was told he was gone.
+When were you first
+notified of the death of Epstein?
+MR.
+: I got a call about 6:50 and
+told me that, hey -
+MR.
+MR.
+okay.
+- that he attempted suicide
+EFTA00125543
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+8
+and they were going through life-saving
+measures.
+MR.
+: And who contacted you?
+MR.
+My Associate Warden,
+79
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR.
+MR.
+MR.
+MS.
+MR.
+Yes.
+Uh --
+Was she at the scene?
+No, she wasn't. The
+Lieutenant had called the Captain. The Captain
+called her, and then she called me.
+MS.
+And is it Lieutenant
+is that it?
+MR.
+: Lieutenant
+Operations Lieutenant.
+MR.
+was the
+Would you mind, in that
+conversation, would you mind just telling us
+about that conversation?
+MR.
+: She told me Epstein, they
+found him in his cell. They had a
+defibrillator on him and that they were working
+on him.
+MR.
+MR.
+okay.
+And when she told me that, I
+EFTA00125544
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+was like, okay. Where are they at? Is EMS
+coming in? She said she didn't have that much
+information because the Lieutenant was down
+with Epstein performing life-saving measures.
+So, that's when I came in.
+MR.
+When did you start asking
+questions about •
+? On the phone of when
+you arrived at the facility?
+MR.
+: So, when I got there, I was
+like, where is the cellmate.
+MR.
+: Um-hum.
+MR.
+: I asked the Lieutenant, like
+where is his cellmate, and Lieutenant said, "I
+asked the same question when I went down and,
+you know, started." He asked the officer,
+"Where's his cellmate?"
+And, you know, just couldn't, you know, he
+was disoriented and told me he had said that.
+So, that's when we started, you know, started
+the process of where's
+MR.
+Just for timeline
+purposes, about what time did you arrive?
+MR.
+I got there about 7:30.
+MR.
+Okay. Who within the
+Special Housing Unit would've had the ability
+EFTA00125545
+
+LIMITED OFFICIAL USE
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+1
+or who within the Special Housing Unit would've
+2
+had the ability or the authority to back-fill
+3
+I' spot as Epstein's cellmate?
+4
+MR.
+:
+Well what would've happened,
+5
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+which was instructed to them, was -
+MR.
+MR.
+: Okay.
+-- they would've told the
+Lieutenant or Captain, hey,
+I mean
+Epstein needs a cellmate. And then we would've
+started the process of getting him a cellmate.
+Because when, and this was Epstein's routine.
+He got up early in the morning at 8, and he
+didn't come back to his cell until about 7:30
+at night from his attorney visits.
+left in the morning. So, he doesn't
+come back to his cell until in the evening,
+which on that particular day, he got back
+about, from what I understand, around 6:45.
+MR.
+: Okay.
+MR.
+: Yeah.
+MR.
+You said that they were
+instructed to notify that Epstein needed a
+cellmate?
+MR.
+So, the Captain, as I told
+you before --
+EFTA00125546
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+MR.
+MR.
+Um-hum.
+-- when I told them about
+the expectations.
+MR.
+Yep.
+MR.
+All that was Epstein needs a
+cellmate.
+MR.
+Yep.
+MR.
+And he's to be having a
+cellmate at all times. If he doesn't, then
+they need to notify you and then you can push
+it up.
+MR.
+: So, you told the Captain -
+-
+MR.
+: I told the Captain
+specifically that.
+MR.
+MR.
+it out.
+: Okay. And the Captain was
+to tell his, below him.
+: He conveyed it to the
+Lieutenant, to the Officers, and disseminated
+MR.
+Okay. So, he should've
+been notified. How should the notification
+have worked?
+MR.
+MR.
+:
+when he --
+-- when
+realized
+EFTA00125547
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+that
+was dismissed?
+MR.
+The Officers should' ve
+called the Lieutenant --
+MR.
+Which Officers?
+MR.
+MR.
+MR.
+The ones working the unit?
+The Special Housing Unit?
+The Special Housing Unit
+Officers.
+MR.
+okay.
+MR.
+Because they know that he
+packed up. They -
+MR.
+MR.
+: Okay.
+So, once he gets packed up,
+they go --
+MR.
+okay.
+MR.
+They should've known, hey,
+let me notify and move it up the chain, Epstein
+doesn't have a cellmate.
+MR.
+How does
+' belongings
+get packed up? Who does that?
+MR.
+: When the staff in SHU pack
+up his stuff.
+MR.
+Okay. So, the staff in
+SHU would --
+MR.
+: They'll come to the door --
+EFTA00125548
+
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+MR.
+MR.
+Um-hum.
+-- and if they say WAB, it's
+with all belongings.
+MR.
+Okay.
+MR.
+So, they more than likely
+just took his stuff -
+MR.
+Um-hum.
+MR.
+-- and then whatever he had
+in his cell, and if he had something in the
+property room, they might've gone to get it.
+Or if they didn't, then we would somewhere down
+the line ship it to wherever his destination
+is.
+10
+11
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+MR.
+Is the staff that's
+packing up
+Correctional Officers?
+belongings different than the
+MR.
+' property would've
+been stored up in our Special Housing Unit.
+MR.
+: Right.
+MR.
+: And then it would've been
+taken by our Special Housing Unit staff to our
+receiving and discharge center.
+MR.
+Is that staff, when you
+say "staff", is that a different responsibility
+than being a Correctional Officer?
+EFTA00125549
+
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+MR.
+Well we're all, we're all
+correctional workers --
+3
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+MR.
+okay.
+MR.
+- but their department is,
+you know, the receiving and discharge --
+MR.
+Um-hum.
+MR.
+-- of inmates.
+MR.
+MR.
+okay.
+: So, that's where you process
+in -
+MR.
+Got you.
+MR.
+:
+- or process out. So, they
+would take the stuff down to them. They'd
+process in and process out.
+MR.
+: Okay. So, these are
+people that are different, have different
+responsibilities than, okay.
+MR.
+Right.
+MR.
+I got it.
+MR.
+The Special House -
+MR.
+Thank you for -
+MS.
+But the Officers in the
+SHU would have been responsible for packing up
+|' belongings?
+MR.
+:
+Right. They would've taken
+EFTA00125550
+
+LIMITED OFFICIAL USE
+86
+1
+all of his belongings. Now I don't know if he
+2
+has some property still in the property room.
+3
+But whatever was in his cell, they would've
+4
+gathered and taken down.
+5
+MR.
+So, the Officers that are
+6
+in the Special Housing Unit either would have
+7
+actively participated or observed
+8
+belongings being packed up and leaving?
+9
+10
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+25
+MR.
+: Right, and taken. And
+again, I don't know where
+went.
+MR.
+sure.
+MR.
+I don't know if he went to
+court.
+MR.
+Um-hum.
+MR.
+I don't know --
+MR.
+MR.
+Right.
+- but the terminology with
+all belongings.
+MR.
+MR.
+Sure.
+: So, he was being --
+MR.
+Is there any documentation
+or reports about when
+' belongings would
+have been collected from Special Housing Unit?
+MR.
+: I wouldn't say belongings,
+but there would be something showing that he
+EFTA00125551
+
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+was departed the institution.
+MR.
+: Okay. And that would be
+in the system somewhere?
+MR.
+: Uh, yeah. They would be
+receipts, but our receiving and discharge would
+have that.
+MR.
+Okay.
+MR.
+: And it will also show in
+Sentry, which we use to track on when he was
+keyed out.
+MR.
+Okay. So, just to recap.
+MR.
+Um-hum.
+MR.
+The Officers that were
+working in the Special Housing Unit would've
+observed
+' belongings leaving. They were
+instructed via the Captain through your orders
+that if Epstein was to have a cellmate at all
+times.
+MR.
+MR.
+: At all times.
+And that if that wasn't,
+you know, supposed to be briefed up to the
+Captain and then ultimately to you. Is that
+correct?
+MR.
+: Right. The Lieutenant, if
+the SHU Lieutenant was working, the SHU
+EFTA00125552
+
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+Lieutenant happened to be off that day.
+MR.
+: Um-hum.
+MR.
+: And then it goes up the
+chain to notify somebody that he doesn't have a
+cellmate.
+MR.
+MS.
+off that day, you said?
+MR.
+: Okay.
+So, the SHU Lieutenant was
+: He was off that day of --
+MS.
+: And which SHU was that?
+MR.
+Huh? It was the Lieutenant
+at the time was
+MS.
+MR.
+MS.
+Supervisor?
+Uh, Lieutenant
+So, who was the Acting
+MR.
+: We didn't, well the
+Operations, if we don't have a SHU Lieutenant
+on duty, the Operations Lieutenant is the
+Lieutenant that would come up, make rounds, and
+(Indiscernible *00:57:40).
+MS.
+Okay. And who was that on
+Friday?
+MR.
+: I don't recall. I have to
+look at the roster.
+EFTA00125553
+
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+MR.
+Okay.
+Let's talk a little
+bit about staffing that day.
+MR.
+okay.
+MR.
+Um --
+MR.
+Well, can I --
+MR.
+Yes.
+MR.
+- say one thing?
+MR.
+Of course.
+MR.
+: I sent a memorandum to, did
+he give it to you?
+MR.
+On?
+MR.
+: Well, I got a memorandum
+this morning --
+MS.
+This morning, yes.
+MR.
+: About the offices saying
+that they knew that he left and when he left he
+told the evening watch guy that Epstein needed
+a cellmate.
+MS.
+dated today?
+• Do you know why that's
+MR.
+: Because when I came in this
+morning, one of my Lieutenants came in and I
+asked him, I said, "Hey, have you heard
+anything about what went on on Friday?" And
+that's when he told me he had talked to the
+EFTA00125554
+
+LIMITED OFFICIAL USE
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+Officer, and the Officer told him he had
+notified them as to that, you know, Epstein
+3
+needed a Bunkie.
+4
+5
+MS.
+Okay. And who --
+MR.
+Um --
+6
+MS.
+-- asked the Officer to
+7
+8
+9
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+18
+19
+20
+21
+22
+23
+put that in writing?
+MR.
+: Uh, Lieutenant
+He
+had told him to put it in writing.
+MR.
+Just for, uh,
+(Indiscernible *00:58:59) if I may just --
+MS.
+Yeah.
+MR.
+-- read it so we're on the
+same page, here.
+MR.
+Um-hum.
+MR.
+So, we have a memo dated
+August 12, 2019 to the Warden from -
+MR.
+(phonetic sp.) I-
+MR.
+MR.
+Yeah.
+MR.
+MR.
+MR.
+Um-hum.
+And the subject is, Past
+24
+25
+Information from Special Housing Units.
+MR.
+:
+Um-hum.
+EFTA00125555
+
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+25
+MR.
+MR.
+MR.
+Lieutenant
+MR.
+MR.
+-
+91
+And
+was suggested, was told by
+to write this memo?
+Yes.
+Okay. And the memo, just
+MS.
+I don't think you need to
+(Indiscernible *00:59:26).
+MR.
+Okay, yep. Just --
+MS.
+Yeah.
+MR.
+- thanks. Just making
+sure we're on --
+MS.
+I appreciate that, yeah.
+MR.
+Overall staffing at MCC,
+if we can just go down that road for right now.
+Where, are you guys at full staff? Where are
+you in terms of staffing levels?
+MR.
+we're understaffed.
+MR.
+: Okay.
+MR.
+: So, we're starting the
+hiring process right now, but we do have to,
+you know, there's some posts that we can't
+fill. But --
+MR.
+Where are you in terms of
+EFTA00125556
+
+LIMITED OFFICIAL USE
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+2
+you say?
+92
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+staffing? Like what percentage are you, would
+MR.
+: I believe we're in our low
+80s, high 70s. I'd have to look at the
+staffing or whatever.
+MR.
+MR.
+But somewhere around 80%.
+Right, but it doesn't only,
+that's not the only issue. The only issue --
+MR.
+: Sure.
+MR.
+- is like we, let's say
+we're staffed to 80%, we've got about 30 people
+that we can't use.
+Either they're on Workman's
+Comp. They're on AWOL status. You name it, we
+have it. But the problem is, it takes a while
+to go through that process to remove an
+employee.
+So, we can't just hire when you have a
+bunch of people like that on you. So, that's
+where we're at.
+MR.
+: Okay. So, how do you as a
+Warden and as an institution compensate for
+being 20% understaffed?
+MR.
+: Well, I mean everyone has to
+chip in. I mean, we're not like the state
+where you have your Correctional workers and
+EFTA00125557
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+25
+you have the contractor workers.
+Everyone,
+despite the fact that you might have a
+different job title, you know how to perform
+the functions of a Correctional Officer. You
+have to qualify with weapons every year. You
+take training on working the housing units, and
+the majority of them weren't hired off the
+street as into their positions. There might be
+a few. But the majority were Correctional
+Officers and then promoted into the different
+positions.
+So, we have annual refresher training
+every year where we train and move on like
+that. But that's just not, it's not their
+primary discipline, being a Correctional
+Officer.
+MR.
+: You said all staff are
+trained as Corrections Officers?
+MR.
+: The terminology is you're
+Correctional workers.
+MR.
+Okay.
+MR.
+So, you know how to perform
+the functions of a Correctional Officer.
+MR.
+MR.
+okay.
+Carry firearms.
+You can do
+EFTA00125558
+
+LIMITED OFFICIAL USE
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+1
+escorted trips. You could work the housing
+2
+unit. The only ones who probably are exempt
+3
+from that are doctors and attorneys and
+4
+psychologists, the professionals. But everyone
+5
+else,
+6
+7
+8
+10
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+13
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+25
+MR.
+MR.
+Glencoe.
+MR.
+MR.
+training.
+MR.
+MR.
+And where do the
+Correctional workers receive this training?
+:
+Well initially you go to
+okay.
+Everyone goes to Glencoe for
+Um-hum.
+: And then specialized
+training, we have annual refresher training
+every year where we re-qualify and go over
+certain correctional topics.
+MR.
+about some specific people.
+Okay. Let me ask you
+MR.
+Okay.
+MR.
+If you happen to know if
+they, what their primary duties are.
+MR.
+Okay.
+MR.
+MR.
+He's a material handler
+EFTA00125559
+
+LIMITED OFFICIAL USE
+95
+1
+foreman.
+2
+MR.
+What is a material
+3
+handler?
+4
+MR.
+:
+They work in the warehouse.
+5
+So, in the warehouse, it has several functions.
+6
+You either work in the commissary which the
+7
+inmates shop for food. He can work in the
+8
+laundry where you do that, or you work in the
+warehouse where you're processing --
+10
+MR.
+Um-hum.
+11
+MR.
+-- in stuff. What's the
+12
+other one? We also have an outside warehouse
+13
+where we take deliveries.
+So, that's our, and
+14
+it's under our trust fund department.
+15
+16
+MR.
+August gth, August 10th -_
+: Okay. And the night of
+17
+18
+19
+20
+21
+MR.
+Right.
+MR.
+-- do you happen to know
+if Mr. Thompson was working as a Correctional
+Officer in that primary responsibility?
+MR.
+: He was one of the Officers
+22
+in the Special Housing Unit.
+23
+MR.
+: Okay. Do you know how
+24
+25
+often he works as a Correction, his
+responsibility as an Officer?
+EFTA00125560
+
+LIMITED OFFICIAL USE
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+MR.
+:
+What they do is since he
+works in that department, we might, if we need
+him during the daytime, assign him over to the
+department. But he does overtime. He was
+working overtime then. So, we have a lot of
+overtime. So, individuals in other departments
+work the overtime.
+MR.
+Is that something they can
+do voluntarily, or are they told to do that?
+How does that work?
+MR.
+: We have a volunteer list for
+the individuals that don't work in the
+department.
+MR.
+: Okay.
+MR.
+: If you're a Correctional
+Officer, we have what's called a mandation
+list. So, if we call around and I say, "Hey,
+we need somebody to work this", and everyone
+turns it down and says, "No, I don't want to
+work it", then we go to the mandation list.
+MR.
+okay.
+MR.
+Which is you're next up to
+be mandated to work a post.
+MR.
+MS.
+Okay. Um --
+Was he mandated that
+EFTA00125561
+
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+night?
+MR.
+•: I believe he wasn't. He
+wouldn't be mandated because he works as a
+material handler foreman.
+MS.
+Got it.
+MR.
+MS.
+MR.
+Yeah.
+MR.
+So, he signed up for it.
+okay.
+So, just to clarify, the
+Correctional Officers or only the Officers are
+on the mandated list?
+MR.
+: Right.
+MR.
+: The rest of Correctional
+workers have the opportunity to volunteer for
+overtime?
+MR.
+: Right. You volunteer for
+overtime.
+MR.
+MR.
+okay.
+Or during the daytime, I can
+say, "Look I need to fill these posts. I need
+you to come from your department to work over
+in Correctional services."
+MR.
+: Okay. Toba Noel (phonetic
+sp.).
+MR.
+Uh, is a Correctional
+EFTA00125562
+
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+25
+Officer.
+MR.
+She's a Corrections
+Officer?
+MR.
+Corrections Officer.
+MR.
+okay. Do you happen to
+know if she was working overtime or her regular
+shift that day?
+MR.
+: I'm not sure. I think it
+might've been (Indiscernible *01:04:52). I'm
+not sure. I think her regular, I'm not sure.
+MR.
+Okay.
+MR.
+Her regular shift was
+evening watch, and then she did it. So --
+Okay.
+MR.
+MS.
+Does she typically work in
+the SHU?
+MR.
+Uh, yes.
+She's been
+(Indiscernible *01:05:01).
+MS.
+Okay.
+MR.
+: And I don't know if that was
+her assigned quarterly post, but I do believe
+it is.
+MR.
+MR.
+MR.
+Captain L
+He's the Captain.
+EFTA00125563
+
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+MR.
+He's an
+Officer.
+MR.
+He's an Officer?
+MR.
+Yeah.
+MR.
+MR.
+He's an Officer.
+MR.
+MR.
+He's an Officer.
+MR.
+(phonetic
+sp.)?
+MR.
+She is the psychologist.
+MR.
+Okay. So, the only one,
+the only one, Michael Thomas, is the only one
+who's primary responsibility is not an Officer?
+MR.
+And Dr.
+MR.
+MS.
+Doctor, yep. Okay, great.
+Are you notified when a
+Corrections Officer is mandated to work
+overtime? Who makes that decision?
+MR.
+: The Lieutenant on shift
+handles that.
+MR.
+What are the rules, or any
+policies in terms of overtime? Is there a
+limit? Is there, how does the overtime work?
+Is there a cap in terms of hours a week?
+EFTA00125564
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+MR.
+MR.
+It's voluntary.
+Okay.
+MR.
+: And then it's, like you
+said, the prison business is 24 hours.
+MR.
+Um-hum.
+MR.
+We don't have the luxury to
+turn around and say we can't fill a post. Now
+I might have a post that might require, you
+know, X amount of people, but I have to staff
+it at a minimum where we're safe coming and
+going.
+MR.
+Um-hum.
+MR.
+So, there's really no set
+amount. I mean, depending, you know, I've been
+here, when I first got here where our staffing
+was really bad where people were doing four a
+week.
+MR.
+MR.
+MR.
+when you say -
+You know?
+-- "four a week", what is
+-
+MR.
+Four overtimes a week.
+MR.
+: Now is, when you say, what
+is an overtime? Is that like another 8-hour
+shift?
+EFTA00125565
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+MR.
+Another 8-hour shift.
+MR.
+okay. So, you -
+MR.
+: So, it depends on, you know,
+the number of people we have, those
+volunteering. So, right now we're in the
+hiring process where we are getting, you know,
+bodies to fill in these positions.
+MR.
+So, an overtime shift is
+eight additional hours?
+MR.
+MR.
+Eight additional hours.
+Okay. Is there any -
+MS.
+MR.
+Go ahead.
+- is there any limit on
+how many 16-hour days a week an employee can
+work?
+MR.
+: You just can't exceed the
+amount of 16 hours in a day.
+MR.
+Could you explain that for
+me?
+MR.
+MR.
+MR.
+Okay. You work eight hours.
+Right.
+You can only work 16 hours
+that day.
+MR.
+MR.
+okay.
+You can't work 24 hours.
+EFTA00125566
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+You can't, you're not like a fireman where, you
+know, you're on duty 24 hours in.
+MR.
+okay.
+MR.
+SO, there's a limit on the
+daily.
+MR.
+MR.
+MR.
+Okay.
+That you can do.
+But there's no limit on
+how many days in a row you can work those 16
+hours?
+MR.
+: No. If somebody wants to,
+they could.
+MR.
+: Do you have any unofficial
+or any guidance on that front?
+MR.
+: No, not really, because I
+mean you have some people that sign up for
+overtime.
+MR.
+MR.
+Got you.
+: You know? They say --
+MR.
+Um-hum.
+MR.
+- hey, they might, I don't
+know people's financial situations.
+MR.
+Right.
+MR.
+But they might say, hey, you
+know, I need to get some extra money --
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+MR.
+Yeah.
+MR.
+- for X, Y and Z. So, I
+don't know the specifics --
+MR.
+Okay.
+MR.
+- on why somebody would.
+MR.
+You know I had a previous
+job where my supervisor wouldn't let us work 21
+days in a row. We had to take that 22nd day
+off.
+MR.
+MR.
+Right.
+Do you guys have anything
+unofficial like that that --
+MR.
+days off.
+MR.
+MR.
+Well they have their two
+okay.
+So, you get two days off.
+So --
+MR.
+MR.
+MR.
+Is that --
+-- and that --
+: Is it required that they
+take those two days?
+MR.
+: Yeah. You take your two
+days. What you choose to do with those two
+days is your business. But we don't, like if
+someone, it has to be an emergency. Let's say
+EFTA00125568
+
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+it's your Friday. You won't get mandated on a
+2
+Friday because Federal Law states you have to
+3
+have X amount of hours off during the week.
+4
+MR.
+5
+MR.
+: Okay.
+In conjunction to days off.
+6
+So, (Indiscernible *01:08:57).
+7
+MR.
+So, the most 16-hour days
+8
+an employee can work is five, so they have two
+days off?
+9
+10
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+MR.
+days off.
+: Well not necessarily,
+because you could say hey I want to work on my
+MR.
+Okay. So, you can come in
+on your days off then?
+MR.
+voluntary.
+MR.
+MR.
+MR.
+: On your days off. That's
+• Okay.
+I can't just turn around --
+Sure.
+MR.
+- and say you have to stay
+but if you want --
+MR.
+MR.
+MR.
+overtime?
+okay.
+Um --
+Okay. Anything on the
+EFTA00125569
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+MS.
+No.
+MR.
+: Okay. Talk a little bit
+about the cameras in the facility.
+MR.
+okay.
+MR.
+What is your understanding
+on the general reliability of them?
+MR.
+: They're not good. We were
+just funded to get new cameras installed but,
+you know, when you're installing the cameras,
+there's a lot you have
+to do. The building is
+built in 1975. It's not like a new building,
+and we've got to go through cinderblock.
+There's a lot of things that, you know, are in
+that block. Asbestos. So, we have to do the
+wiring. SO, the system
+is outdated. Um --
+MR.
+when you say they're not,
+are they not reliable? Is it poor quality in
+recording? What's the --
+MR.
+: It's the recording, but what
+do they call that, the DVRs?
+MR.
+okay.
+MR.
+The ones that hold the
+recordings, they're breaking down. So,
+sometimes we have where they're not recording.
+We have to get it fixed, you know, more along
+EFTA00125570
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+those lines.
+MR.
+: How were you aware, how
+are you as the Warden made aware of cameras not
+working appropriately or any issues with the
+recording devices?
+MR.
+: The department head would
+bring it up to me, or the Associate Warden
+would tell me, you know, we were informed that
+the cameras aren't working.
+MR.
+What is the normal
+procedure when the cameras go down?
+MR.
+•: So, if the cameras go down,
+then the contact has to look and determine
+what's the problem with the cameras.
+MR.
+Okay. How long would you
+say that the cameras have been unreliable?
+MR.
+: What do you mean by
+"unreliable?"
+MR.
+I'm sorry, how long would
+you say the cameras have been not working?
+MR.
+They work, but periodically
+they go down.
+MR.
+MR.
+okay.
+That's what I meant by it,
+but they do record. You can, you know, it's
+EFTA00125571
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+the quality. Like you go to some places and
+some agencies where you have that bird vision
+type camera. That's not what we have.
+MR.
+: Okay.
+MR.
+: I mean, it's, you can see
+things, we can do some identifying, but they're
+not, you know, and they're only in certain
+locations.
+MS.
+And again, the chain of
+notification is the staff, the Corrections
+Officers or Corrections worker notifies the
+Shift Lieutenant?
+MR.
+As far as with the cameras?
+MS.
+Yes. If they're --
+MR.
+It depends on --
+MS.
+- not operating.
+MR.
+- who's using the cameras
+and reviewing the cameras.
+MS.
+: Okay.
+MR.
+•: You know, usually our
+investigative department's doing it, and they
+do the check, and if they come in and check and
+check the cameras and say, stuff's not
+recording, then they notify the Comp Shop or
+the facilities manager and say, hey, we have
+a
+EFTA00125572
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+problem. The cameras are not recording.
+MS.
+So, does SIS have a room
+where they can see the cameras in the facility?
+MR.
+:
+We have a, the camera room
+is in our communications room behind that area.
+MS.
+okay. So, if a camera, if
+the camera in the SHU was not working -
+MR.
+Um-hum.
+MS.
+-- someone in that camera
+room would be able to see that there's no feed
+from that particular camera?
+MR.
+: It's not the feed, it's the
+recording. You can have, you always have the
+life feed that you can see what's going on.
+it's the recording of it.
+MS.
+MR.
+Um-hum.
+: And the recordings
+typically, and don't quote me on it, are on a
+two-week or less timeline. So, what it is is,
+if it gets to that two-week period, the memory
+gets full, then it starts re-recording over
+again. So, that's how most camera systems
+work.
+MS.
+camera in the SHU was down --
+But if for instance a
+EFTA00125573
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+MR.
+Right.
+MS.
+-- someone in that camera
+room would see that the camera was down.
+MR.
+•: Or the SIS would check and
+say, determine hey the recordings are not down
+or yeah, you're right, or even the screen.
+MS.
+Um-hum.
+MR.
+: If we didn't have a visual
+screen to say, hey, there's problems with the
+camera.
+MS.
+And did that happen with
+the SHU camera? Was anyone notified that it
+wasn't working?
+MR.
+: Well, and this is what I was
+told after the fact, the SIS Lieutenant I
+believe conveyed that to the Communication
+Officer that there was a problem with the
+cameras.
+MS.
+(phonetic sp.)?
+MR.
+MS.
+MR.
+MS.
+Is that Lieutenant
+Lieutenant
+: And it's a she?
+Yes, she.
+When did she know about
+it?
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+MR.
+: I believe she told me she
+told him on Thursday that she made a
+notification for it.
+MS.
+Okay.
+MR.
+Um --
+MS.
+And that would be an oral
+notification?
+MR.
+I'm not sure.
+MS.
+okay.
+MR.
+But she did say she notified
+him. So --
+MS.
+: Okay.
+MR.
+Are you made aware of
+those notifications as well that the cameras
+are down and not working?
+MR.
+It would depend.
+MR.
+Okay.
+MR.
+You know, on how bad it was.
+If it was something that you can run out and
+fix immediately, you know, it would say, hey,
+you know, we can fix it. But if it was
+something that was going to be for a while, I
+would have to be notified.
+MR.
+And were you notified of
+this?
+EFTA00125575
+
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+2
+yeah.
+3
+MR.
+4
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+111
+I was told on Saturday.
+Okay. You were told after
+MR.
+After --
+MR.
+MR.
+MR.
+MR.
+- the fact.
+- the fact I was told.
+okay.
+: That the cameras weren't
+working.
+MR.
+I'm sorry, just who
+notified you of this?
+MR.
+Lieutenant
+told me.
+MR.
+Lieutenant, okay. Talking
+about, let's talk about phone calls in the SHU.
+MR.
+Um-hum.
+MR.
+What are the regulations
+or policies about giving inmates unreported
+phone calls?
+MR.
+During the intake screening,
+you can come in and in certain SHU situations,
+an inmate will get an unmonitored call if they
+don't have their telephone account set up.
+MR.
+okay.
+MR.
+So, they're afforded that
+EFTA00125576
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+opportunity.
+MR.
+: How does the inmate get a
+telephone account set up?
+MR.
+: Typically he has to go out
+of SHU into a housing unit and go through the
+voice recognition process in order to get set
+up for it. You can't do it in the Special
+Housing Unit.
+MR.
+: And we said earlier that
+Mr. Epstein was never left, was always in
+Special Housing Unit.
+: Was always in the Special
+MR.
+Housing Unit.
+MR.
+Did he have an opportunity
+to get a telephone account set up?
+MR.
+: The problem with Mr. Epstein
+was he was in the attorney room all day.
+MR.
+Okay.
+MR.
+•: From beginning to end, and
+that's something that you do during the daytime
+because our communications people are there.
+So, we did, and then again, he had to be in an
+assigned unit to get that. It's just to have
+it set up.
+MR.
+Okay. Was Mr. Epstein
+EFTA00125577
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+allowed phone calls?
+MR.
+MR.
+phone calls?
+Was he what?
+was Mr. Epstein allowed
+MR.
+: Yeah. His initial one, he
+didn't get his initial one, so we had to give
+him a call, his initial call when he came in.
+MR.
+Okay.
+MR.
+: Then while you're in the
+Special Housing Unit, you're entitled to one
+call every 30 days.
+MR.
+: Okay.
+MR.
+So, he was entitled to a 30-
+day phone call.
+MR.
+And are those normally
+monitored, recorded? How do those?
+MR.
+: Typically in his case, that
+he didn't have his monitor set up, the unit
+manager stood there and listened to the call.
+MR.
+MS.
+Lieutenant?
+: okay. Um --
+And would that be the
+MR.
+No. It was the Unit
+Manager.
+MS.
+And who would that be?
+EFTA00125578
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+MR.
+That was Mr.
+(phonetic sp.), L
+MS.
+okay.
+MR.
+So --
+MR.
+So, Mr.
+should
+have been listening to that phone call?
+MR.
+: Right, and from what I
+understand, he was listening.
+MR.
+: Okay. Are those phone
+calls recorded anywhere to ensure just to --
+MR.
+: No, they're not recorded,
+but we can trace the phone line to get the
+phone number.
+MR.
+okay.
+MR.
+To determine where the call
+was made.
+MR.
+: Okay. And in tracing of
+that to get the phone number, is the length of
+the call --
+MR.
+Yes.
+MR.
+-- noted as well?
+MR.
+Yes.
+MR.
+okay. But in terms of
+putting that into a system or a monitoring,
+there's not a database for that?
+114
+EFTA00125579
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+MR.
+We didn't, because again, he
+wasn't set up.
+MR.
+Okay. Are you aware of
+how many phone calls Mr. Epstein's made while
+in the Special Housing Unit?
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR.
+: I'm not sure. I'm not aware
+how many made. But I don't, I know he made
+that one -
+MR.
+Um-hum.
+MR.
+- that day and I'm aware of
+the initial one, but I don't believe he made
+that many, because I do believe I saw a
+correspondence that his attorney made to our
+attorney about him getting a phone call.
+MR.
+MR.
+okay.
+That he hadn't gotten a
+phone call. So, there's some correspondence on
+that.
+MR.
+okay. You got any else on
+the --
+MS.
+MR.
+MR.
+No.
+Okay.
+: Let's go over real quick
+(Indiscernible *01:18:13).
+MR.
+We covered this a little
+EFTA00125580
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+25
+earlier. I just wanted to go over it again.
+When were you first notified of Mr. Epstein's
+suicide, or medical, or situation?
+MR.
+About 6:45 --
+MR.
+Okay.
+MR.
+-- 6:50.
+MR.
+MR.
+Who did you notify?
+I immediately called my boss
+-
+MR.
+MR.
+okay.
+- to let him know and then
+tell him that I was on my way to the
+institution.
+MR.
+Did you notify anybody
+else?
+MR.
+Who, me?
+MR.
+Yes.
+MR.
+No. I just, I let him know,
+get dressed, get to the institution.
+MR.
+: Okay. When you arrived at
+the institution, did you speak to any staff
+there?
+MR.
+: When I got there, I saw
+obviously the Lieutenant. Um --
+MR.
+Which --
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+MS.
+Lieutenant
+MR.
+Uh, Lieutenant
+when he
+came in and my first, you know, any time you
+have a suicide attempt, you want to make sure
+your staff are all right and how they're doing.
+So, I went to, you know, to check on him to
+kind of get a debrief on what was going on. He
+kind of debriefed me on the situation. Um --
+MR.
+What did Lieutenant
+tell you?
+MR.
+: So, I asked him, so I
+basically told him what happened, and he said,
+he talked to Officer Noel and she said we
+didn't do the 3 o'clock count or the 5 o'clock
+count.
+And then he said he talked to Noel,
+Officer Noel, and she said, no he talked to
+Officer Thomas and that Officer Thomas said, "I
+messed up. We messed up." Something about it's
+not her fault. But he said he was just talking
+way off the line.
+Let me back-track a little. I did make
+one more call, because I couldn't get in
+contact with Lieutenant
+• I called up to
+the Special Housing Unit.
+EFTA00125582
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+MR.
+Okay.
+MR.
+: And I believe Ms. Noel
+picked up the phone, and I asked her, you know,
+what was going. And she told me what was going
+on. But she really couldn't talk. So, then I
+came, when I got to the institution, I saw her
+and I said, "Hey, are you all right? Is
+everything fine." And she was like okay.
+So, I had somebody from our crisis support
+team that was there talk to her to make sure
+that she was all right, and then I went to try
+to find Thomas. She said Thomas had left.
+So, I said, okay, "Left where? Where did
+he go?"
+They said, you know, "He went home. He
+was distraught."
+So, then I get another call saying Thomas
+was outside, and that he told me, "I'm not
+answering any questions from you. I want my
+union", I said Thomas, "I'm not concerned about
+what happened. I'm concerned about your well-
+being. Make sure you're all right. You've
+been through a traumatic experience", and he
+just kept talking.
+So, there was a staff member out there.
+I
+EFTA00125583
+
+LIMITED OFFICIAL USE
+1
+said, try to find him if he's outside. So,
+2
+they went outside and they said, you know, he
+119
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+was gone.
+I didn't see Ms. Noel, but I told them to
+get a memorandum from her on what happened.
+They told me said she wasn't feeling well and
+she had to talk to her Union rep.
+So, and I said, "You know what, let them
+go. We'll get back with them or somebody will
+get back with them." And they left. And we
+just started the process of collecting and
+preserving.
+MS.
+in to work since then?
+Have Noel or Thomas been
+MR.
+: No. Noel, I sent some
+support staff on Sunday to go talk to them.
+Today, the mother of Thomas' child, she works
+at the institution but they're not together,
+said, "Hey, he was with her all weekend but she
+can't get in contact with him." I sent her and
+a Lieutenant to go over to his house to find
+out if he's okay. He called me a little irate
+saying, "You know, you're sending people to my
+house. You know, I was sleeping."
+I said, "I'm checking on your well-being",
+EFTA00125584
+
+LIMITED OFFICIAL USE
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+1
+you know. And then I didn't know, and I asked
+2
+him, I said, "Did you call in for work today?"
+3
+And he said, "Yes, I did." And he said,
+4
+"He was sleeping and he was tired."
+5
+And I said, "well I'm just checking on
+6
+your well-being and just seeing how you are",
+7
+and I left it at that.
+8
+MS.
+That was this morning?
+MR.
+That was this morning.
+10
+MS.
+So, he basically called in
+11
+sick today?
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+MR.
+: He called in sick today.
+She's on days off Monday and Tuesday.
+MS.
+Okay.
+MR.
+: I'm going to assign both of
+them with no inmate contact, so they're going
+to be away from inmates and assigned on the
+outside (Indiscernible *01:23:09).
+MS.
+: And then Lieutenant
+MR.
+: And then that's basically
+what Lieutenant
+told me, and I told him,
+"Write a memorandum on what was said", and he
+wrote the memorandum and he submitted it.
+MS.
+Has he been in to work
+25
+since Saturday?
+EFTA00125585
+
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+MR.
+: Yes, he did. Actually he
+stayed there late on Saturday. He basically
+worked a double, and then he came back and
+worked during the day on it.
+So, he hasn't
+taken any time off.
+MS.
+Is he there now?
+MR.
+He's there. He's there
+today, so he's working here.
+MS.
+: And --
+MR.
+Oh, and I do have an
+addition. And I did ask him, you know, when he
+got there what happened, and he says, he
+doesn't know what the condition was because
+when Thomas called for the emergency medical,
+he opened the door and took him down himself
+and started life-saving measures.
+MS.
+So, Epstein was hanging
+from the door?
+MR.
+:
+We don't know what he was
+doing because Ihomas was the first one there,
+and when responding staff came, he was already
+there doing compressions and life-saving
+measures.
+So, I definitively can't say where,
+was he hanging? What position he was or not
+because nobody knows when they responded, so.
+EFTA00125586
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+MR.
+What is the policy
+regarding if an Officer or staff member sees an
+inmate in that situation?
+MR.
+: Okay. And I won't want to
+quote this is a policy thing, but you call for
+assistance and you wait for assistance to come
+because you don't know if that's a ploy. so,
+if you go in there as one person, and you know,
+when somebody's hanging, that's dead. That is
+dead weight.
+So, you go in there, you don't know if
+it's a ploy. So, you go in there and get
+overpowered, guess
+what? Now that individual
+has the cell door keys for every key on that
+range, and that could be a recipe for disaster.
+So, it might sound inhumane that, you
+know, we have to wait because the individual on
+the grill can't come down range either because
+if they get overpowered, guess what, we've lost
+a whole unit. And that's the most secure unit
+in the institution.
+So, she has to stay outside with the keys
+on the grill because there are two different
+keys. They don't mix. And we wait for
+responding staff to come in and perform, you
+EFTA00125587
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+know, the life-saving measures without
+endangering your safety.
+So, he went in and, you know, so again,
+there's no idea of what the cell looked like,
+what his position was, or anything.
+MS.
+Captain
+and Captain
+MR.
+I are they at work now?
+Captain
+MS.
+I think.
+MR.
+MS.
+His secretary is
+okay.
+MR.
+Yeah.
+MS.
+That may be a mistake.
+MR.
+Yeah.
+MS.
+So, Captain
+was the
+Captain on Friday; right?
+MR.
+Yes.
+MS.
+MR.
+okay.
+And I need to, and I'm not
+sure if he was at work either. I think he
+might've been off. But |
+is his
+secretary.
+MS.
+okay. And
+Lieutenant is it |
+MR.
+was the
+EFTA00125588
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+midnight Lieutenant.
+MS.
+MR.
+Okay. And he, she?
+She worked, apparently she
+relieved her early.
+worked at night and
+MS.
+Okay.
+MR.
+: At 5:33, but then I heard
+she came back and then left again. So, I don't
+know, I believe she went up to the unit.
+MS.
+Has she been at work since
+then?
+MR.
+I believe she's on days off.
+MS.
+MR.
+MS.
+Okay.
+So, she'll be back tonight.
+Okay. Do you want to step
+out for a minute?
+MR.
+Actually before -
+MS.
+Unless you have anything
+(Indiscernible *01:27:13).
+MR.
+Just a few --
+MR.
+okay.
+MR.
+little bit.
+-- if I can jump back a
+MR.
+okay.
+MR.
+Specifically go back to,
+did you have any one-on-one interactions with
+EFTA00125589
+
+LIMITED OFFICIAL USE
+125
+1
+Epstein?
+2
+MR.
+: Let's see, I had one, I saw
+3
+him by the attorney visit, small conversation.
+4
+Another one I saw him when I was making rounds
+5
+on the unit when he had first gotten into the
+6
+cell with
+1. He was going into the shower.
+7
+I asked him, "How was everything going." He
+8
+said, "I'm good. I'm fine."
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
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+24
+25
+And then
+I said, "How's he doing?"
+was like, "I want to go back to a unit."
+So, you know, was just that type of
+conversation while making rounds.
+MR.
+okay. Thank you.
+MR.
+Okay.
+MR.
+And did you want just step
+outside?
+MR.
+_: Huh?
+MR.
+• Do you mind if we just take a
+step out?
+MR.
+No, I have no problem.
+It is 12:23. We're
+MR.
+pausing the interview.
+We're resuming the interview at this time.
+It is 12:29 in the afternoon.
+MS.
+okay.
+So, the first
+EFTA00125590
+
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+25
+question is, I just want to make sure we have
+the name right.
+MR.
+MS.
+•: okay.
+: The Lieutenant or the
+Captain that you told that Epstein should have
+a cellmate?
+MR.
+: Well, it was Captain
+MS.
+okay.
+MR.
+Yeah.
+MS.
+Okay. And I know you're
+probably already doing this, but we just wanted
+to make sure you're preserving all of the
+emails that you referenced, any text messages
+that you've sent about this, any communications
+that you've had at all.
+MR.
+: Well when I had gave the
+direction, it was given verbally in a meeting.
+MS.
+MR.
+: Um-hum.
+: I didn't send emails out.
+I
+had a direct conversation.
+MS.
+: Okay.
+MR.
+So, it was everyone in the
+room. So --
+MS.
+Okay. But for instance,
+EFTA00125591
+
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+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+the email that you sent listing here are the
+three possibilities for --
+MR.
+MS.
+oh, yes.
+-- who's --
+MR.
+All of that --
+MS.
+-- the best. All of that.
+MR.
+MS.
+MR.
+Yeah. If you want that --
+-- you're preserving.
+-- that's there. It's
+preserved.
+MS.
+okay.
+MR.
+I'm sure this will
+inevitably happen, and it's a report for this.
+Has that already been drafted? Is that a
+process?
+MR.
+For?
+MR.
+Will there be an incident
+report regarding the discovery of Jeffrey
+Epstein's body?
+MR.
+: It's called a report of
+incident, a 583. So, we did that today.
+MR.
+Okay.
+MR.
+You know --
+MR.
+Um-hum.
+MR.
+-- just a brief statement on
+EFTA00125592
+
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+16
+17
+18
+19
+20
+21
+22
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+24
+25
+what happened, the times -
+MR.
+okay.
+MR.
+- and moving forward with
+that.
+MR.
+Do you know who drafted
+that?
+MR.
+•: The SIS Lieutenant does it.
+MR.
+Okay.
+MR.
+: And then I review it because
+it's ultimately sent from me. It's a report of
+incident --
+MR.
+MR.
+Um-hum.
+-- to our central office.
+So, I look at it, the synopsis.
+MR.
+okay.
+MR.
+Just for terminology to make
+sure it's accurate. And it's just a brief
+statement saying that, you know, he made
+rounds.
+MR.
+Um-hum.
+MR.
+He was unresponsive. Life-
+saving measures were initiated. Taken to the
+outside hospital and then he was pronounced
+deceased at that time. And then we just move
+on from there.
+EFTA00125593
+
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+19
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+21
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+MR.
+Just a couple of more -
+MR.
+Um-hum.
+MR.
+-- housekeeping stuff just
+to say, have you had any contact with the press
+regarding this?
+MR.
+MR.
+: No, I have not.
+Has any press contacted
+you directly?
+MR.
+: No, they have not.
+MR.
+Have you directed any
+staff to destroy anything?
+MR.
+MR.
+No, I have not.
+What directions have you
+given the staff in terms of preserving things?
+MR.
+: So, initially when we came,
+when I got in, I told the Captain, get all the
+1og books up there, the rounds, anything
+pertaining to get it and anything we can think
+of that might be needed. And it's given to the
+SIS. It's in the SIS office with the SIS
+Lieutenant.
+So, told them to preserve it, and whoever
+needed it, I know the IG has come by. They've
+taken some stuff. But basically preserve
+everything that might be needed to be
+EFTA00125594
+
+LIMITED OFFICIAL USE
+130
+1
+preserved. And then if any requests come, you
+2
+know, we'll go and get it and preserve it.
+3
+MR.
+: Are you --
+4
+MS.
+Can I just ask one quick
+5
+question about the 1og books?
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR.
+Yeah.
+MR.
+Actually while she's
+looking at it --
+MS.
+Yeah.
+MR.
+MS.
+-- do you mind?
+This is --
+MR.
+Are you aware of any
+objects missing from his cell? Are you aware
+of anything peculiar occurring since his
+suicide? Since his body was discovered?
+MR.
+: You mean missing from his
+cell?
+MR.
+YeS -
+MR.
+: I didn't observe the cell,
+so I don't know what's in --
+MR.
+Were you ever notified of
+any, after his body was discovered, have you
+been notified of any peculiarities or anything
+that stuck out in your mind as odd?
+MR.
+: As far as what would've been
+EFTA00125595
+
+LIMITED OFFICIAL USE
+1
+in his cell, or?
+2
+MR.
+3
+relates to him?
+131
+4
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+10
+11
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+13
+14
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+17
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+19
+20
+21
+22
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+25
+Anything in general as it
+MR.
+: Not that I can think of.
+I
+mean, it's just documents that we're still
+trying to gather -
+MR.
+Sure.
+MR.
+- and locate, but -
+MR.
+It's nothing odd because I
+don't know what happened in that cell.
+MR.
+Um-hum.
+MR.
+So, I don't know what
+would be --
+MR.
+MR.
+cell?
+okay.
+-- considered odd. Were
+you aware of him having any contraband in his
+MR.
+MR.
+MR.
+Contraband?
+Anything -
+Well --
+MR.
+-- he wasn't supposed to
+have? Any unapproved things in his cell?
+MR.
+No.
+MR.
+MR.
+okay.
+I mean, he would've received
+EFTA00125596
+
+LIMITED OFFICIAL USE
+1
+an incident report.
+2
+MR.
+132
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+: Okay.
+MR.
+: And the only incident report
+he had was, I guess it was the cloth that was
+found on the initial one, but then our
+Disciplinary Hearing Officer concluded that we
+couldn't' sustain any charges on him because it
+was inconclusive --
+MR.
+Okay.
+MR.
+- with it, but that's --
+MR.
+Okay. And were you aware
+of him having any enemies or anything, or being
+a specific target by anybody?
+MR.
+Where?
+MR.
+In the institution?
+MR.
+No. I mean no one's came to
+me specifically saying, you know, "He's my
+enemy", or all that, so I don't, you know.
+MR.
+Was he not to be, not to
+be celled with anybody because of any problems
+that he would have, or --
+MR.
+I mean.
+MR.
+: Let me rephrase that a
+little. Were you aware of any other inmates
+who had targeted him specifically?
+EFTA00125597
+
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+19
+20
+21
+22
+23
+24
+25
+MR.
+No.
+MR.
+okay.
+MR.
+Um-hum.
+MS.
+The log books -
+MR.
+Um-hum.
+MS.
+- just for the record,
+I'm showing a log book Tier G dated 08/10/2019.
+MR.
+Right.
+MS.
+So, this is filled out by
+a Corrections Officer --
+MR.
+Right.
+MS.
+-- who's doing the checks
+MR.
+Right.
+MS.
+- every 30 minutes.
+MR.
+Um-hum.
+MS.
+Correct?
+MR.
+les.
+MS.
+And they're supposed to
+write the time they start and end and then
+initial it?
+MR.
+Who did it.
+MS.
+And then the Operations
+Lieutenant signs it at the end of the shift.
+MR.
+: The shift that they reviewed
+EFTA00125598
+
+LIMITED OFFICIAL USE
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+it.
+2
+3
+4
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+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
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+24
+25
+134
+MS.
+okay. Okay.
+MR.
+This is not complete for the
+simple fact that, you know, with the emergency
+coming, I had them take it and preserve it.
+So, it was part of the preservation. So,
+that's probably why it doesn't go all the way
+up to 8 o'clock.
+MS.
+Got it.
+MR.
+Because as soon as I came
+in, I told the Lieutenant grab the 30-minute
+checks.
+MS.
+a circle for a signature?
+MR.
+MS.
+MR.
+: And is this a signature or
+That's a signature.
+okay.
+Whoever was in, and I
+believe, and I'm not sure, but if it was the
+morning watch Lieutenant, it would be
+Lieutenant
+MS.
+MR.
+MS.
+Yeah.
+I think that's all the
+questions that we have.
+MR.
+Great.
+That's it.
+The
+EFTA00125599
+
+LIMITED OFFICIAL USE
+135
+1
+2
+3
+4
+5
+6
+7
+8
+time is now 12:35. Warden, we really
+appreciate your time.
+MR.
+MR.
+okay.
+: And the interview is
+completed, oh actually before we do that. Is
+there anything that you would like to tell us?
+Any statements that you would like to make?
+Anything you think we should know about the
+incident in general? Just wanted to give you
+an opportunity if there's anything that you
+think we should know that we haven't discussed.
+MR.
+: I can't think of anything
+else. But I mean, as it comes along, I'll pass
+it on to the IG.
+Anything I get or any
+information.
+MR.
+MR.
+Thank you.
+Okay.
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+EFTA00125600
+
+LIMITED OFFICIAL USE
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+7
+8
+136
+CERTIFICATE
+I hereby certify that the foregoing pages
+represent an accurate transcript of the
+electronic sound recording of the proceedings
+before the Department of Justice, Office of the
+Inspector General in the matter of:
+Interview of
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Transcriber
+EFTA00125601
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bd8c0f26630efe88f0a78818be95247dd8eab79941154d0d46f00c309685d514.md b/vision-joined/ds9-parsed-01/bd8c0f26630efe88f0a78818be95247dd8eab79941154d0d46f00c309685d514.md
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@@ -0,0 +1,15 @@
+EPSTEIN CASE
+2 instrumental recruiters of children for Epstein:
+EFTA00068037
+
+WEST PALM BCH FL 334
+08 ]LIL 2019 PM 1 L
+U.S. Attorneys for the Southern District of New York
+Geoffrey Berman
+1 Saint Andrews Plaza,
+New York, NY 10007
+FOREVER / USA
+10007-170101
+EFTA00068038
+
+EFTA00068039
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bdad6e57a1bf2ece3f527ce8a520f1b8d0e7ef5ae02e5ec60f9ada32eeb21df2.md b/vision-joined/ds9-parsed-01/bdad6e57a1bf2ece3f527ce8a520f1b8d0e7ef5ae02e5ec60f9ada32eeb21df2.md
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@@ -0,0 +1,2 @@
+No Images Produced
+EFTA00128582
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bdb0cc733a30e8d815c6974f6e5d7d86bea33aaac36575b02260015b6432c54e.md b/vision-joined/ds9-parsed-01/bdb0cc733a30e8d815c6974f6e5d7d86bea33aaac36575b02260015b6432c54e.md
new file mode 100644
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@@ -0,0 +1,54 @@
+From: Chuck Cooper 4
+To:
+Ce: Sigrid McCawley <
+Nicole Moss <
+Kirk" «
+Subject: Re: Introduction
+Date: Thu, 13 Feb 2020 19:17:31 +0000
+P, Haley Proctor <
+"Michael W.
+Thank you Sigrid for this kind introduction.
+we would like very much to come to NYC to meet with you confidentially and oper
+surenge about our mutual interests in the Epstein matter. May we get back with some dates that would work at
+Best,
+Chuck
+Charles J. Cooper
+Cooper & Kirk, PLLC
+On Feb 13, 2020, at 1:28 PM
+> wrote:
+Sigrid, thanks, and received - we appreciate it.
+From: Sigrid McCawley <
+Sent: Thursday, February 13, 2020 10:41
+To:
+Cc: Nicole Moss|
+1; Chuck Cooper
+Haley Proctor
+Subject: Introduction
+Hello
+I wanted to take a moment to introduce you to Nicole Moss, Chuck Cooper and Haley Proctor - copied above. They are
+presently representingl
+lin her action against Dershowitz in the Southern District of New York.
+Feel free to reach out to them if you need anything.
+Best,
+EFTA00092500
+
+Sigrid
+Sigrid McCawley
+Partner
+BOIES SCHILLER FLEXNER LLP
+www.bsfllp.com
+The information contained in this electronic message is confidential information intended only for the use of the named recipients) and may contain information
+that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this
+electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any
+dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in
+error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1
+08201831BSF]
+NOTICE: This e-mail is from the law firm of Cooper & Kirk, PLLC ("C&K"), and is intended solely for the use
+of the individual(s) to whom it is addressed. If you believe you received this e-mail in error, please notify the
+sender immediately, delete the e-mail from your computer and do not copy or disclose it to anyone else. If you
+are not an existing client of C&K, do not construe anything in this e-mail to make you a client unless it contains
+a specific statement to that effect and do not disclose anything to C&K in reply that you expect to be held in
+confidence. If you properly received this e-mail as a client, co-counsel or retained expert of C&K, you should
+maintain its contents in confidence in order to preserve any attorney-client or work product privilege that may be
+available to protect confidentiality.
+EFTA00092501
\ No newline at end of file
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@@ -0,0 +1,88 @@
+From:
+Cc: "
+Subject:
+draft facts
+Date: Tue, 06 Oct 2020 23:59:21 +0000
+Chiefs,
+Below for review is a draft factual statement as a potential proposal to l
+s lawyers. We are undecided as
+to how to phrase the first paragraph and would welcome your thoughts on that and any other part of this draft. Happy to
+discuss.
+Thanks,
+3333332
+The parties agree that the following facts will be included, without objection, in the Presentence Report for the Court to
+consider at sentencing:
+First Paragraph Option #1: Between approximately 2001 and 2013,
+was employed by Jeffrey Epstein
+as a personal assistant.
+has been evaluated by an expert psychologist who specializes in victims of sex trafficking,
+who completed a report dated April 20, 2020 regarding |
+experiences before, during, and after her employment
+with Epstein. The parties agree that the contents of the expert's report may be considered at sentencing, and the parties
+do not dispute the contents or conclusions of the report.
+First Paragraph Option #2: Between approximately 2001 and 2013,
+was employed by Jeffrey Epstein
+as a personal assistant. At the time she was hired, |
+I was financially destitute, had a history of being sexually abused
+by an older male, and had been completely cut off from her family. Shortly after hiring L
+1. Epstein began sexually
+abusing her. That sexual abuse continued for years, and included at least one instance in which Epstein forcibly raped
+• Epstein also controlled various aspects of
+life, including her diet, her clothing, her hair, and her sleep.
+I job responsibilities included numerous tasks involving Epstein's daily schedule, travel, and residences. One of
+those responsibilities involved scheduling massage appointments for Epstein. When L
+was first hired, she used a
+directory provided to her by Ghislaine Maxwell to contact women and girls to massage Epstein. Over the ensuing years,
+would add new names to the directory when directed to do so by Epstein.
+During the period of her employment between approximately 2002 and 2005,
+_scheduled hundreds of
+appointments for women and girls, including dozens of minors, to massage Epstein. At those massage appointments,
+Epstein sexually abused dozens of minor victims. The majority of the massage appointments that I scheduled took
+place at Epstein's residence in Palm Beach, Florida, though some took place at Epstein's residence in New York, New York.
+During that same period, Epstein received approximately two to three massages per day. I
+was primarily
+responsible for scheduling those appointments in Palm Beach, but she occasionally scheduled them by phone while she
+was in New York City. When minor victims arrived for the appointments at Palm Beach,
+sometimes met them,
+walked them up to the massage room, and set up the massage table for the appointment. After at least some of the
+appointments,
+paid minor victims in cash. Epstein encouraged minor victims to bring other girls to massage him,
+which led to an increasing number of victims coming to massage Epstein at his residences.
+EFTA00089268
+
+Through the process of arranging and facilitating massage appointments for Epstein, |
+I met dozens of underage
+victims, who ranged in age from 14 to 17 years old. None of those victims explicitly told I
+that they were underage.
+Some of those victims did not have licenses, and |
+arranged for a driver to pick them up and take them to their
+appointments with Epstein. Some of those victims told |
+they could not attend certain appointment times because
+they were attending school. Epstein told
+that at least one of those victims was studying for the SATs.
+During the massage appointments with minor girls that |
+scheduled, Epstein sexually abused the minor girls by,
+among other things, masturbating while the victims touched Epstein, touching the victim's genitals, using a sex toy on a
+victim's genitals, engaging in oral sex, and/or engaging in sexual intercourse. Although |
+was not present for the
+vast majority of this abuse, she witnessed some of these massages. In particular, I
+I was present for and participated
+in one massage during which Epstein touched a minor victim's genitals.
+walked in on one instance in which a
+different minor victim was performing oral sex on Epstein.
+walked in on at least one additional massage during
+which a different minor victim was nude while massaging Epstein. At Epstein's direction, I
+I took nude or partially
+nude photographs of more than one minor victim.
+In or about 2005,
+learned that law enforcement was investigating Epstein for sex crimes involving minors, arising
+from the massage appointments that
+had facilitated. After learning about the investigation into Epstein,
+called multiple minor victims and encouraged them not to talk to law enforcement. At Epstein's direction, L
+financial incentives to victims for not speaking with law enforcement. Beginning in approximately 2006, multiple minor
+victims were interviewed by federal law enforcement officers who were conducting a criminal investigation of Epstein and
+his associates for sex trafficking of minors, among other federal offenses. During those interviews, minor victims reported
+to federal agents that Epstein paid them for sexualized massages while they were underage girls, including during
+massages that
+I scheduled.
+EFTA00089269
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bdd05f9efa2ecfb078fbe72eb5c40390c8ca979e055f7336c2a1ab1710425d18.md b/vision-joined/ds9-parsed-01/bdd05f9efa2ecfb078fbe72eb5c40390c8ca979e055f7336c2a1ab1710425d18.md
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@@ -0,0 +1,40 @@
+From:
+To: Paul Cassell <
+Subject: RE: t visa - victim
+Date: Sat, 19 Oct 2019 03:13:48 +0000
+Quickly following up, I did speak to our coordinator and she mentioned that a T visa is to be able to stay in the
+.S., rather than to enter the country -- she said it doesn't enable someone to come into the U.S. If she'
+ooperating with U.S. law enforcement there may be options to for her entry, but if there are other persona
+reasons for coming into the U.S., then it may be prohibitively difficult. Happy to discuss further if that's useful.
+-----Original Message-----
+From:
+Sent: Friday, October 18, 2019 23:03
+To: 'Paul Cassell' <
+Subject: RE: t visa - victim
+Paul,
+Apologies for the belated reply, I was traveling today and am just now catching up on emails and voicemails
+from this afternoon. Unfortunately I don't know of any immediate answers for you, but I can check with a human
+trafficking coordinator in our office and see if she has any guidance. Do you know if the individual's case was
+reported to law enforcement in the U.S.? I think that may be a requirement for a T-visa, so not sure if she or her
+attorneys are already in touch with authorities in some capacity. But please feel free to have them contact me
+directly if that would be useful, and feel free to give me a call over the weekend (or to have her counsel do so) if
+that would be useful. Sorry not to be of more immediate help, but I'm happy to keep in touch and hopefully she
+doesn't remain in limbo.
+thanks,
+-----Original Message----
+From: Paul Cassell <
+Sent: Friday, October 18, 2019 14:40
+To:
+Subject: Re: t visa - vietim
+Hi
+some attorneys that I respect very much are trying to get a woman from|
+linto the US on a T-visa. The
+Woman and her therapist
+Lone of the worlds leading experts are stuck in Toronto. It is possible the
+woman is an Epstein victim, allthough that has not been definitively established one way or the other. The case
+seems to be stuck in limbo with referral to law-enforcement agencies. The woman needs help immediately and I
+thought of you.
+Paul Cassell - sent from my iPhone - please excuse brevity and errors.
+> On Aug 7, 2019, at 3:16 PM,
+> wrote:
+EFTA00040519
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bdebddf42ac4ea402c80dd45f26e42d283936c1efc03a26cf15ea78ee24fc109.md b/vision-joined/ds9-parsed-01/bdebddf42ac4ea402c80dd45f26e42d283936c1efc03a26cf15ea78ee24fc109.md
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@@ -0,0 +1,30 @@
+From: "
+To: "
+(USANYS)" <
+(USANYS)" ≤
+Subject: Draft
+Date: Mon, 12 Aug 2019 15:21:29 +0000
+All, for your information:
+spoke to
+at 10:30 this morning, shortly after our meeting in
+•office. asked him
+whether in light of his IG investigation, should our Office be recused from the criminal investigation of the MCC and its
+guards relating to Epstein's suicide that |
+had referred to us.
+I said he saw no basis for our recusal and
+that we were authorized to convey his views on this issue to the DAG's office.
+then called
+who patched in
+Associate Deputy Counsel, ODAG. L
+•put the same
+question to them.
+I said that he saw no basis for our recusal because any possible conflict was too speculative.
+asked if he should also run the question by OAG and
+said that was unnecessary because the question would
+ultimately be brought back to him.
+Therefore we can and should proceed with the criminal investigation.
+Deputy United States Attorney
+United States Attorney's Office
+Southern District of New York
+Tel.:
+EFTA00078028
\ No newline at end of file
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@@ -0,0 +1,33 @@
+UNITED STATES DEPARTMENT OF JUSTICE
+Office of the Inspector General
+WARNINGS AND ASSURANCES TO EMPLOYEE REQUESTED
+TO PROVIDE INFORMATION ON A VOLUNTARY BASIS
+You are being asked to provide information as part of an investigation being conducted by the Office
+of the Inspector General. This investigation is being conducted pursuant to the inspector General
+Act of 1978, as amended
+This investigation pertains to: -
+jab performance failure and
+security failure
+This is a voluntary interview. Accordingly, you do not have to answer questions. No disciplinary
+action will be taken against you if you choose not to answer questions.
+Any statement you furnish may be used as evidence in any future criminal proceedings or agency
+disciplinary proceeding, or both.
+WAIVER
+I understand the warnings and assurances stated above and 1 am willing to make a statement and
+answer questions. No promises or threats have been made to me and no pressure or coercion of any
+Te.
+Signature of the Office of the Inspector
+General Special Agent
+Employeels Signature
+Name'of the Office of the Inspector
+General Special Agent
+Signature of Witness
+Name of Witness
+Employee's Name
+3/16/2022
+9.59am
+Date and Time
+MDC Brooklyn, Ny
+Place
+OIG Form III: 226/2 (05/03/21) Non-CustodiaVEmployee
+EFTA00117347
\ No newline at end of file
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@@ -0,0 +1,21 @@
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diff --git a/vision-joined/ds9-parsed-01/be449dda0fd2a9e5a2339d7ca698c1e146d31717c96f657f48c9173646066c12.md b/vision-joined/ds9-parsed-01/be449dda0fd2a9e5a2339d7ca698c1e146d31717c96f657f48c9173646066c12.md
new file mode 100644
index 0000000000000000000000000000000000000000..b40151cdb27a6e8588b2f71130aa86b2509f382e
--- /dev/null
+++ b/vision-joined/ds9-parsed-01/be449dda0fd2a9e5a2339d7ca698c1e146d31717c96f657f48c9173646066c12.md
@@ -0,0 +1,19 @@
+10/6/21, 12:30 PM
+NCIC Delayed Response
+Additional Inquiry Response
+ORI: NYFBINYO0
+Federal Bureau of Investigation - New York
+New York State Division of Criminal Justice Services
+Alfred E. Smith Building, 80 South Swan St.
+Albany, New York 12210. Tel: 1-800-262-DCJS
+Michael C.Green, Executive Deputy Commissioner of the NYS Division of Criminal Justice Services
+• Federal NCIC
+WARNING: Release of any NCIC information to unauthorized individuals or agencies, including the subject of the
+data, is prohibited. Please refer to section 4.2 of the CJIS security policy and Title 28, Part 20 of the code of'
+Federal Regulations for the proper acess, usc, and dissemination of the information contained in the NCIC
+restricted and non-restricted files.
+The following information is provided in response to your request for a search of the NCIC - Protection Order File based on:
+NYFBINY00
+SEC CONFER SALS AND TEN OF RETEN CORT CONFACT RECORDG DO NOT
+1/1
+EFTA00068973
\ No newline at end of file
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+}
diff --git a/vision-joined/ds9-parsed-01/be7300788e039529a6fe7a5bdc39d34f2a5e245ffbbef5820e4d85b85276ed31.md b/vision-joined/ds9-parsed-01/be7300788e039529a6fe7a5bdc39d34f2a5e245ffbbef5820e4d85b85276ed31.md
new file mode 100644
index 0000000000000000000000000000000000000000..a4e19ba2cca3cef16f22743b475d6208d2add52d
--- /dev/null
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@@ -0,0 +1,69 @@
+FD-302 (Rev. 5-8-10)
+- 1 of 2-
+FEDERAL BUREAU OF INVESTIGATION
+OFFICIAL RECORD
+Date of entry
+12/19/2019
+On August 19, 2019 at approximately 1300 hours the undersigned, along
+with Special Agent
+of the Office of the Inspector General,
+Special Agent
+of the Federal Bureau of Investigation
+and
+Assistant United States Attorneys for the Southern District of New York
+did interview Federal Bureau of Prisons
+EMPLOYEE 13
+at the Southern District
+Guard
+of NY. \
+EMPLOILE 131
+informed that he has been employed by the BOP for approximately
+five (5) years and is currently assigned as the Senior Officer of Special
+Housing (SOS) and 2nd officer of the SHU. EMPLOYEE T9 advised as to the proper
+way to do a "round" and "count" which was consistent with BOP memos and
+information. EMPLOYEE 13
+also advised as to several other
+practices, policies and procedures of being a guard at the SHU and MCC.
+EMPLOYEE I3
+did state that in terms of conducting and documenting the "rounds"
+during the day shift, to which he is assigned, that its fairly easy due to
+the fact that the guards are always "on the range" interacting with inmates
+and that generally the times are recorded and approximated at the end of the
+shift.
+EMPLOYEE T
+also stated that he knew EPSTEIN was a high profile prisoner but
+that at the end of the day EPSTEIN was still just a prisoner and
+ENPLOYED 13
+treated him the same. aron 13 stated that he never heard of guards not
+doing rounds and that due to his military career he feels he has a higher
+standard of integrity and would always do what's expected and required of
+EMPLOYEE 13
+also informed that he was aware of EPSTEIN's past suicide
+attempt and that he was flagged or on the "hot list". DIPLOY 13
+stated that
+on the date prior to EPSTEIN's death he was aware that EPSTEIN was without a
+cell mate and needed one and notified other guards relieving him from his
+shift. The interview concluded at 1404 hours.
+Investigation on
+08/20/2019
+New York, New York, United States (In Person)
+File #
+Date drafted 12/18/2019
+by
+This document contains neither recommendations nor conclusions of the FBI. It is the property of the FL and is loand to your agency; it and is contents ang moe
+to be distributed outside your agency-
+EFTA_00000851
+EFTA00135251
+
+FD-302a (Rev. 5-8-10)
+Continuation of FD-302 of (U) Interview of EMPLOYED IB
+_, On
+08/20/2019
+, Page
+2 of 2
+Further details of the interview and statements made by EMPIOYEE T3
+recorded on the interview notes which are attached to this report.
+PROTECTED MATI
+SDNY_00007728
+EFTA_00000852
+EFTA00135252
\ No newline at end of file
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@@ -0,0 +1,6 @@
+From: "
+To: "
+Subject: List
+Date: Mon, 28 Jun 2021 19:25:14 +0000
+Attachments: PAE_Data_Copy_of_Data_Hosted_On_20210622_095654.xIsx
+EFTA00069869
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/beac7bcc16b8d527e7e3dccbdda40bdd343133a432cd2c10084b856365917fe9.md b/vision-joined/ds9-parsed-01/beac7bcc16b8d527e7e3dccbdda40bdd343133a432cd2c10084b856365917fe9.md
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@@ -0,0 +1,37 @@
+LLC STATEMENT IN SUPPORT
+OF REGISTRATION
+HYPERION AIR, LLC is a limited liability company of a United States Citizen and is eligible to
+register aircraft in its name. In this regard, we make the following representations
+NAME
+TYPE OF ENTITY
+Jeffrey E. Epstein
+Individual
+5. The LLC is managed by a Manager.
+U.S. CITIZENSHIP
+VERIFICATION
+VES _X NO_
+NAME
+Lawrence Visoski
+TYPE OF ENTITY
+Individual
+U.S. CITIZENSHIP
+VERIFICATION
+YES X NO
+The undersigned certifies that he understands that an LLC is eligible to register aircraft in its name provided tha
+1) at least 2/3rds of the managers or managing members are "U.S. Citizens" within the meaning of 49 U.S.C
+(2) at one 5 is posesions, and species is that A COT REGISTER 4 A NOTIZEN
+CORPORATION.
+If any member of this LLC is not a United States Citizen as defined in 40102(a)(15)(C) an explanation appears below t
+support the certification that this LLC is a "U.S. Citizen" as required by 49 U.S.C. Section 40102(a)(15)(C)
+The undersigned hereby also certifies that the information given herein is true and correct and meets all citizenship
+specifications as required by the Federal Aviation Administration.
+- 24)
+Manager
+/
+EFTA00040823
+
+FILED WITH FAA
+AIRCRAFT REGISTRATION-DR.
+2013 AUG 13 AM 7 39
+OKLAHOMA CITY
+OKLAHOMA
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/beb762a78687c27ee31711dd0e4573e1ee26d5fc4dca902c2f764fc32869793c.md b/vision-joined/ds9-parsed-01/beb762a78687c27ee31711dd0e4573e1ee26d5fc4dca902c2f764fc32869793c.md
new file mode 100644
index 0000000000000000000000000000000000000000..32ae965eac4801e056f4e9bf33b24e1f8d56f188
--- /dev/null
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@@ -0,0 +1,132 @@
+CG
+COHEN & GRESSER LLP
+300 Third Avenue
+New York, NY 10022
+12129577600 phor
+ww.cohengresser.co
+Mark S. Cohen
+Christian R. Everdell
+November 25, 2020
+TO BE FILED UNDER SEAL
+VIA EMAIL (SUBMITTED PURSUANT TO SECTION 2(B)
+OF JUDGE NATHAN'S INDIVIDUAL PRACTICES IN CRIMINAL CASES)
+The Honorable Alison J. Nathan
+United States District Court
+Southern District of New York
+40 Foley Square
+New York, New York 10007
+Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+Dear Judge Nathan:
+On behalf of our client, Ghislaine Maxwell, we plan to file a Renewed Motion for
+elease on Bail (the "Motion) and respectfully request an in camera conterence, with a
+ounsel present, to address the appropriate procedures for the filing and consideration of th
+Motion. For the reasons explained below, we intend to request, pursuant to Fed. R. Crim. P.
+49.1(d), that the Court permit the filing of portions of the Motion and certain supporting
+overnment, Pretrial Services, and the Court when the Motion is filed. We are merely requesting
+hat sensitive contents of the submission be accorded confidentiality protections similar to thos
+that the government routinely requires in protective orders, including the one in this case.
+In the four months since this Court denied Ms. Maxwell's request for bail and granted the
+government's motion for detention, Ms. Maxwell and her counsel have assembled substantial
+information that was not available to present at the initial hearing, as well as a comprehensive
+bail package co-signed by sureties who were unable to come forward at that time. Accordingly,
+Ms. Maxwell now seeks to renew her request for bail pursuant to 18 U.S.C. § 3142(f).
+Ms. Maxwell's renewed application will rely on sensitive and private information that, if
+made public, would be highly damaging to both Ms. Maxwell and third parties, including:
+• Letters from Ms. Maxwell's family members and close friends, who have agreed to
+serve as sureties to support Ms. Maxwell's renewed bail application. The letters
+contain personal details that, if made public, would invite identification and
+EFTA00079612
+
+The Honorable Alison J. Nathan
+November 25, 2020
+Page 2
+harassment of the sureties and other third parties, including minor children. They are
+legitimately afraid that if their identities become public, they will be subjected to the
+same relentless media scrutiny and threats that Ms. Maxwell has experienced for
+more than a year, like the following sample of social media posts:
+"they need to get this bitch n string her up by her neck ... f*cking monster...
+#GhislaineMaxwell."
+"I hope someone finds her and kills her.
+That would be justice. Obviously her
+lawyers know's where she is, someone should stick them up to batteries untill we
+find out where she is."
+"SHE'S HERE in #Massachusetts ?! The bitch #GhislaineMaxwell who
+#Sex Trafficked young girls for #Epstein ?!?! Why the hell isn't she being brought in
+for questioning @ManchesterMAPD ?! WE DO NOT WANT HER HERE!
+#SleezyLeach She is CLOSE ENOUGH to me, I could grab her myself!
+• A financial report, prepared by the accounting firm Macalvins Limited, that provides
+a summary of Ms. Maxwell's financial condition from 2015-2020 and discloses all of
+her assets, all assets held in trust, and assets held by other family members.
+• A discussion and analysis of certain materials produced by the government in
+discovery marked "Confidential" and their impact on the government's case against
+Ms. Maxwell, which must be filed under seal pursuant to the terms of the Protective
+Order in this case (Dkt. 36).
+Fed. R. Crim. P. 49.1(d) provides that "a court may order that a filing be made under seal
+without redaction. The court may later unseal the filing or order the person who made the filing
+to file a redacted version for the public record." While the Second Circuit has recognized a
+presumption of access under both common law and the First Amendment, it is appropriate to
+permit the filing of documents under seal if "countervailing factors" in the common law
+framework or "higher values" in the First Amendment framework so demand. Lugosch v.
+Pyramid Co. of Onandaga, 435 F.3d 110, 124 (2d Cir. 2006); see also Unites States v. Wey, 256
+F. Supp. 3d 355, 411 (S.D.N.Y. 2017) (Nathan, J.) (granting motion to seal evidentiary exhibits
+and finding that privacy interests "outweigh any public interest in disclosure, whether derived
+from the First Amendment or the common-law right of access").
+Moreover, a lower presumption of public access applies to documents submitted in
+connection with powers that are "ancillary to the court's core role in adjudicating a case" than to
+"material introduced at trial, or in connection with dispositive motions." Brown v. Maxwell, 929
+F.3d 41, 49-50 (2d Cir. 2019) (applying lower presumption to documents submitted in
+connection with discovery and evidentiary motions than to summary judgment filings). Thus, a
+lower presumption of public access attaches the parties' pretrial bail submissions than to exhibits
+introduced at trial or in connection with a motion to dismiss.
+EFTA00079613
+
+The Honorable Alison J. Nathan
+November 25, 2020
+Page 3
+Here, that lower presumption is far outweighed by the significant privacy interests
+implicated by the materials at issue. See United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir.
+1995) ("the privacy interests of innocent third parties ... should weigh heavily in a court's
+alancing equation"). If Ms. Maxwell's sureties are publicly identified, they will be harasse
+imply for their association with and support of her. Indeed, some of Ms. Maxwell's closes
+friends and family have already suffered significant consequences. For example,
+The sureties are legitimately scared that they and their children will suffer the same
+consequences, and may not be able to come forward at all, if the Court does not allow their
+letters and their identities to be sealed. See id. at 1051 ("[C]ourts have the power to insure that
+their records are not used to gratify private spite or promote public scandal[.]"). These
+individuals are entitled to the same privacy as Ms. Maxwell's accusers, no longer minors, who
+have been permitted to remain anonymous even though many have revealed their identities.
+The presumption of public access is also outweighed by Ms. Maxwell's privacy interest
+in details regarding her financial condition, as well as the privacy interests of third parties that
+would be implicated if Ms. Maxwell's assets were publicly disclosed. See id. (personal financial
+records traditionally considered private, not public).
+Similar privacy interests led the court to permit the redaction of bail submission materials
+in United States v. Nejad ("Sadr"), Case 1:18-cr-00224-AJN (S.D.N.Y.). Like this case, Sadr
+involved a defendant with meaningful assets and a bail package with numerous co-signers. At
+the initial bail hearing, Judge Carter ordered both defense counsel and the government to redact
+attachments to their submissions because they contained "sensitive private information with
+respect to a whole series of individuals." (Id., Dkt. 21 at 25.) The privacy interests at stake here
+are significantly higher, given the documented threats against Ms. Maxwell and harassment of
+her family and friends.
+For the reasons set forth above, we believe that portions of the Motion, and certain
+materials submitted in support thereof and in opposition thereto, should be filed under seal. We
+respectfully request an in camera conference to address these issues and other confidentiality
+concerns related to the Motion. We have consulted with the government, which consents to the
+redaction and sealed filing of (1) the names and identifying information of any proposed
+cosigners, (2) any discovery materials designated confidential under the Protective Order in this
+case, and (3) any information derived from confidential discovery materials in this case. The
+government does not consent to the in camera conference.
+EFTA00079614
+
+The Honorable Alison J. Nathan
+November 25, 2020
+Page 4
+cc: All counsel of record (via email)
+Respectfully submitted,
+Christian R. Everdell
+Mark S. Cohen
+Christian R. Everdell
+COHEN & GRESSER LLP
+800 Third Avenue, 21st Floor
+New York. New York 10022
+CEND
+EFTA00079615
\ No newline at end of file
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@@ -0,0 +1,156 @@
+U.S. Department of Justice
+Office of the Inspector General
+EVIDENCE CUSTODY DOCUMENT
+OFFICE
+CASE #
+LOG#
+DATE AND TIME OF SEIZURE
+NUFO
+2019-010614
+19
+5/3/22 12:45
+PROPERTY SEIZED FROM
+LOCATION OF SEIZURE
+Amanda
+Moore
+24 Federal P/z
+DESCRIPTION OF THE PROPERTY SEIZED
+1
+Tel Property receipt. pg 30f4 (attached)
+18 red nape foldens #s 1-18 in l box
+See attachment 50-597
+NAME AND SIGNATURE OF WITNESS
+NAME AND SIGNATURE OF SEIZING
+SPECIAL AGENT
+ITEM
+1
+DATE/TIME
+5/3/2214:35
+12/1/22
+10:50 Arh
+12-19-24
+11: 15am
+12-19-24
+RELEASED BY
+CHAIN OF CUSTODY
+RECEIVED BY
+PURPOSE
+into evidence
+New Ev. exce
+Retem to
+с на сам
+с у сам.
+Find opaleto
+OIG FORM III - 234/1 (04/23/07)
+EFTA00123429
+
+FD-597 (Rev. 4-13-2015)
+rase 3 or 4
+Case ID:
+UNITED STATES DEPARTMENT OF JUSTICE
+FEDERAL BUREAU OF INVESTIGATION
+Receipt for Property
+907-111-3151222
+On (dares May 3 2022
+item (s) listed below were:
+Collected/Seized
+Received From
+Returned To
+Released To
+(Name)
+(Street Address) 10J/Ottice c
+(City) _
+Rew Lark Field dEceasector General
+Description of lem 6): a tae-Cue lungate Pancada icE 40 11) 23TECIA (19)
+dailye - One icogate loconda SonER MD 9008E05 (1RC)
+Vadire - De 'enneto Corderation Cre Ho in zior (12i)
+Received By:
+Printed Name/Title:
+Received From:
+Printed Name/Title:
+EFTA00123430
+
+U.S. Department of Justice
+Office of the Inspector General
+OFFICE
+CASE #
+MYFO
+2019-010€14
+PROPERTY SEIZED FROM
+EVIDENCE CUSTODY DOCUMENT
+LOG#
+DATE AND TIME OF SEIZURE
+22
+5/3/22 12:45
+LOCATION OF SEIZURE
+2e Federal PIz.
+ITEM
+DESCRIPTION OF THE PROPERTY SEIZED
+TEl property Receipt pe. tof 4 (attached)
+le candboand boxes (5 line items) 2 05 4h
+boxes (1B-19) are i line item
+see attichment FD-597
+• 1357 • 1321
+• 1B59
+• 1B20 = 1B19 (2 Boxes)
+NAME AND SIGNATURE OF WITNESS
+NAME AND SIGNATURE OF SEIZING
+SPECIAL AGENT
+ITEM
+/
+1
+1359
+I B59
+DATE/TIME
+5/3/22 14:02
+12/1/22
+10:30 AM
+10-17-24
+225pm
+10-17.24
+12-14-24
+1:5am
+12-19-24
+RELEASED BY
+CHAIN OF CUSTODY
+RECEIVED BY
+1
+PURPOSE
+into evidence
+New Filence
+etern to cas
+Final Retern
+to FBI
+Return to case
+agent
+Final tonster
+to 30P
+OIG FORM III - 234/1 (04/23/07)
+EFTA00123431
+
+FD-597 (Rev: 4-13-2015)
+Page 4 or 4
+Case ID:
+UNITED STATES DEPARTMENT OF JUSTICE
+FEDERAL BUREAU OF INVESTIGATION
+Receipt for Property
+907-11-351202
+on (dato) a1 3 2021
+item (s) listed below were:
+Collected/Seized
+Received From
+Returned To
+Released To
+(Name)
+(Street Address) 10 / Offic
+Dew Lack feld of locke Gaseral.
+Description of ltem (1): Che Lage la Pox - DRape 1 510211901(050)
+Dall Pueridge Vi WA Cooler Procate 50Pa212 (1BJ2)
+he box containing White Has (Vikay doofit cra
+he kne bacating Whale 41 Corkery doris
+containi all land doves (Bal)
+Received By:
+Printed Name/Title:
+Received From:
+Printed Name/Title:
+EFTA00123432
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bec145f02452934905a03f09f023b3b94a25fbff874860bad71b8259b34197f4.md b/vision-joined/ds9-parsed-01/bec145f02452934905a03f09f023b3b94a25fbff874860bad71b8259b34197f4.md
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@@ -0,0 +1,9 @@
+From: "
+To:
+Subject: SIS Report
+Date: Fri, 02 Aug 2019 16:35:56 + 0000
+Importance: Normal
+Attachments: TEXT.htm; 2019_08_02_12.
+_34_59.pdf
+attached is the Epstein SIS report.
+EFTA00140524
\ No newline at end of file
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@@ -0,0 +1,116 @@
+From:
+Sent:
+To:
+Subject:
+Stackman, Scott
+Tuesday, August 11, 2020 5:52 PM
+Brown, Paul S.; Fleming, Andrew-J (G-INV); Keith, Regina
+FW: MAXWELL: Transfer Recap
+From: Garcia, Camille
+Sent: Thursday, February 27, 2014 3:35 PM
+To: Stackman, Scott; Casriel, Lyle
+Cc: Klein, Matthew; Ramdeen, Vijai; Shkreli, Juliana; Waldron, Chelsey Devon
+Subject: MAXWELL: Transfer Recap
+Scott/Lyle,
+Here is a recap of the transfer:
+BANKING ACCOUNTS
+Account Title
+UBS A/C
+Ghislaine Maxwell
+Ghislaine Maxwell
+Max Foundation
+Max Foundation
+116 East 65th Street LLC
+Pot and Kettle LLC
+Ellmax LLC
+TerraMar Project, Inc.
+TerraMar Project, Inc.
+Max Hotel Services Corp.
+Total Banking Assets
+JPM Mkt
+Value
+a/o 12/31/13
+16,872.07
+3,122,468.82
+3,517.72
+17,213.42
+10,731.50
+5,838.70
+87,974.09
+50,989.28
+0.00
+2,399.64
+3,318,005.24
+Value
+at UBS
+27,047.74
+3,517.75
+30,265.73
+5,838.70
+87,974.09
+35,749.95
+0.00
+2,360.13
+192,754.09
+Notes
+Completed
+In process
+Completed
+In process
+Completed
+Completed
+Completed
+Completed
+Completed
+INVESTMENT ACCOUNTS
+Account Title
+UBS A/C
+Ghislaine Maxwell
+Ghislaine Maxwell
+Ghislaine Maxwell - OAP IHD
+Ghislaine Maxwell - TAP DYS
+JPM Mkt
+Value
+a/o 12/31/13
+$5,259,275.95
+430.00
+$1,967,979.33
+$1,036,516.92
+Value
+at UBS
+0.00
+1,793,384.45
+1,031,614.80
+1
+Notes
+Waiting to submit once international
+positions are transferred out of JPM A/C
+Zero Balance @ JPM
+ACAT Completed - Equity Positions
+ACAT Completed - Mutual Funds
+SDNY_GM_02742189
+EFTA00078335
+
+Ghislaine Maxwell - TAP ARFI
+Ghislaine Maxwell - HY
+Ghislaine Maxwell - DAP FDG
+Ghislaine Maxwell - IRA
+Total Investment Assets
+$1,003,477.16
+3.00
+$2,045,944.92
+1,966,430.85
+S 56,821.46
+56,278.66
+11,370,448.74
+5,839,491.96
+991,783.20 ACAT Completed - Mutual Funds
+0.00 Zero Balance @ JPM
+ACAT Completed - Equity Positions
+ACAT Completed - Mutual Fund
+TOTAL ASSETS
+14,688,453.98
+6,032,246.05
+2
+SDNY_GM_02742190
+EFTA00078336
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/beeaf4441f2494042847ba5992db507e478a97114064e91bdb843deab841ecda.md b/vision-joined/ds9-parsed-01/beeaf4441f2494042847ba5992db507e478a97114064e91bdb843deab841ecda.md
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@@ -0,0 +1,17 @@
+From:
+To:
+Subject: Epstein recent flight records
+Date: Wed, 07 Aug 2019 21:58:23 +0000
+UC Customs and Border Protection records show the following recent flight information for Epstein as it relates
+to St. Thomas.
+6/11/2019 flight from St Thomas to Teterboro.
+5/18/2019 flight from St Thomas to West Palm Beach.
+5/5/2019 flight from St Thomas to Teterboro.
+4/14/2019 flight from St. Thomas to West Palm Beach.
+Detective
+NYPD / FBI
+Child Exploitation Human Trafficking Task Force
+Office:
+Cell:
+Fax:
+EFTA00089023
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bf02852306560dd7fd98d85a6249c7d0414699552b17092a68ea786368104547.md b/vision-joined/ds9-parsed-01/bf02852306560dd7fd98d85a6249c7d0414699552b17092a68ea786368104547.md
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@@ -0,0 +1,70 @@
+From: '
+To: "l
+(USANYS) 3" <
+Ce: "l
+Subject: Re: RE: Re:
+Date: Wed, 14 Aug 2019 13:35:38 +0000
+D" ‹
+That's right. We have Florida victims who were called from NY, which would have given us venue, but those are
+victims identified during the previous investigation.
+Sent from my iPhone
+On Aug 14, 2019, at 9:31 AM,
+(USANYS) 3 <
+P wrote:
+So all conduct (of any kind) related to those victims was confined to Florida?
+Sent from my iPhone
+On Aug 14, 2019, at 9:27 AM,
+> wrote:
+Thanks
+- these are accurate, except for #1 you'd need to add the phrase "for which we have venue" to make
+it accurate. We have FL victims based on tip line calls, but no basis for venue for a substantive count.
+Sent from my iPhone
+On Aug 14, 2019, at 9:12 AM,
+(USANYS) 3 <
+> wrote:
+Yup, I hear all of that. Good to know re counsel.
+Does the following accurately state your view of our evidence, or would you want to tweak anything:
+(1). The only trafficking offenses that involved the Florida property for which we have evidence are those
+involving victims identified in the original Florida investigation.
+(2) We do not presently have evidence of trafficking offenses involving the VI property, recognizing that the
+search warrant results remain unknown.
+Sent from my iPhone
+On Aug 13, 2019, at 11:01 PM,
+wrote:
+Really really appreciate it, thanks. One thing I think would be useful to note - this isn't anything you don't already
+know, but just to say it - is if we were able to forfeit properties, precisely what (if any) process there is available to
+get the proceeds of an eventual presumable sale of the properties to the victims, and any limitations on
+distributions to particular victims either in terms of amounts or logistics.
+And just as a heads up from our end, we've talked to multiple attorneys yesterday and today who intend to file
+lawsuits on behalf of multiple clients, respectively, starting tomorrow (when the New York State look-back law re-
+EFTA00072128
+
+opens the SOL for sex crimes without limitation) and who have asked whether a Government forfeiture action
+would have any effect of staying, delaying, or subrogating their civil claims.
+From:
+(USANYS) 3 <
+Sent: Tuesday, August 13, 2019 22:48
+To:
+Subject: Fwd: Re:
+Nothing for you guys to do about the below yet, but 1 want you guys to be aware of it. I'm going to try to
+manage expectations tomorrow, but you may well get pulled into the discussion.
+Sent from my iPhone
+Begin forwarded message:
+From:
+(USANYS)" <
+Date: August I3, 2019 at 10:36:37 PM EDT
+To: "l
+I (USANYS) 3" 4
+Subject: Re:
+I want a cognizable theory to pursue residences in NY, FL and VI. If you need evidence beyond what the
+team has let's talk about it tomorrow.
+On Aug 13, 2019, at 10:11 PM,
+(USANYS) 3 <
+Either is doable by Thursday am. Just making sure I know what you need.
+Sent from my iPhone
+On Aug 13, 2019, at 8:52 PM,
+(USANYS) <
+I will need a summary of our forfeiture options re Epstein Thursday morning, ok? |
+P wrote:
+• wrote:
+EFTA00072129
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bf0839d0aa50d9f3553c8f3b19b3958f9c237d4ea0ef3fecc9d2b21b0c7a2cea.md b/vision-joined/ds9-parsed-01/bf0839d0aa50d9f3553c8f3b19b3958f9c237d4ea0ef3fecc9d2b21b0c7a2cea.md
new file mode 100644
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@@ -0,0 +1,80 @@
+From:
+(USANYS)"
+To: Christian Everdell
+Subject: RE: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion
+Date: Mon, 22 Nov 2021 20:29:58 +0000
+Hey Chris,
+I think all that's left is your response on Witness-3, and then the Court's order.
+We'll circulate our proposed redactions to the Dietz/Loftus briefing tomorrow after the conference.
+Thanks.
+From: Christian Everdell
+Sent: Monday, November 22, 2021 2:47 PM
+To: Rohrbach, Andrew (USANYS)
+Subject: [EXTERNAL] RE: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion
+Will do. Taking care of it now.
+From:
+Sent: Monday, November 22, 2021 2:42 PM
+To: Christian Everdell <
+Subject: RE: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion
+Hey Chris - yes, and you can also file your response on GX-52. (Our original letter is already on the docket at 457.)
+From: Christian Everdell <
+Sent: Monday, November 22, 2021 2:40 PM
+Subject: [EXTERNAL] FW: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion
+We now file our response to the birth certificate motion, right?
+From: NYSD_ECF_Pool@nysd.uscourts.gov
+Sent: Monday, November 22, 2021 2:03 PM
+To: CourtMail@nysd.uscourts.gov
+Subject: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Letter Motion
+This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-
+mail because the mail box is unattended.
+***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits attorneys of
+record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents
+filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other
+EFTA00078224
+
+users. To avoid later charges, download a copy of each document during this first viewing. However, if the
+referenced document is a transcript, the free copy and 30 page limit do not apply.
+U.S. District Court
+Southern District of New York
+Notice of Electronic Filing
+The following transaction was entered by
+Case Name:
+USA v. Maxwell
+Case Number:
+1:20-cr-00330-AJN
+Filer:
+USA
+Document Number: 488
+on 11/22/2021 at 2:03 PM EST and filed on 11/22/2021
+Docket Text:
+LETTER MOTION addressed to Judge Alison J. Nathan from AUSAs
+dated November 18, 2021 re: Authenticate birth
+certificates . Document filed by USA as to Ghislaine Maxwell,
+1:20-cr-00330-AJN-1 Notice has been electronically mailed to:
+CaseView.ECF@usdoj.gov, USANYS.ECF@USDOJ.GOV
+CaseView.ECF@usdoj.gov, USANYS.ECF@USDOJ.GOV
+caseview.ect@usdoj.gov, usanys.ecf@usdoj.gov
+Bobbi C Sternheim
+Christian R. Everdell
+David Boies,
+Jeffrey S. Pagliuca
+Katielynn Boyd Townsend
+autodocket@cohengresser.com
+NYC_Managing_Clerk@bsfllp.com
+CaseView.ECF@usdoj.gov, USANYS.ECF@ USDOJ.GOV
+Laura A. Menninger
+Mark Stewart Cohen
+CaseView.ECF@usdoj.gov. USANYS.ECF@USDOJ.GOV
+Patrick J. Smith
+Sigrid S. McCawley
+EFTA00078225
+
+1:20-cr-00330-AJN-1 Notice has been delivered by other means to:
+The following document(s) are associated with this transaction:
+Document description:Main Document
+Original filename:n/a
+Electronic document Stamp:
+ISTAMP dcecfStamp_|D=1008691343 [Date=11/22/2021] [FileNumber=26830188
+-0] [26e81b320da409ccaa60e71b81a05379e51c46a710a011ba99578fc0d3cOabeba
+0a1da8490aab1fc7e38aa207ba0ed993f8354ef9d3709c07cd9dfef69a38454]]
+EFTA00078226
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bf757b326f9d3d1ebe6062e951045fabf5ad93431ec82edf8ee2783fb8fda0b8.md b/vision-joined/ds9-parsed-01/bf757b326f9d3d1ebe6062e951045fabf5ad93431ec82edf8ee2783fb8fda0b8.md
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@@ -0,0 +1,195 @@
+From: "
+To: "
+(USANYS)" <
+(USANYS)"
+P.
+(USANYS)" <
+P.
+(USANYS)" <
+Cc: "
+(USANYS)" 4
+(USANYS)" <
+(USANYS)".
+(USANYS)"
+(USANYS)" <
+(USANYS)" <
+(USANYS) 1"
+Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
+Date: Wed, 30 Dec 2020 21:23:34 +0000
+I, who is the Associate Warden at the MCC. There's a possibility that there will be a very
+short declaration from someone at the MDC to discuss the specific accommodations for Maxwell. I am
+working through that with
+From:
+To:
+(USANYS) <
+Sent: Wednesday, December 30, 2020 2:45 PM
+(USANYS) •
+(USANYS) <
+(USANYS) <
+• (USANYS) <
+(USANYS)
+Cc:
+(USANYS) <
+P:
+(USANYS)
+(USANYS)
+(USANYS) <
+(USANYS) 1 <
+Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
+Thanks. Who is signing the declaration for BOP?
+From:
+(USANYS) <
+Sent: Wednesday, December 30, 2020 2:40 PM
+To:
+| (USANYS) <
+(USANYS) <
+• (USANYS) ‹
+(USANYS) <
+(USANYS)
+Cc:
+(USANYS) <
+P:
+(USANYS)
+(USANYS) <
+| (USANYS)
+(USANYS) 1 4
+Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
+We are in the process of finalizing our response to the Maxwell/Rivera issue. We intend to
+explain that the discovery and counsel access accommodations that have been provided to Maxwell
+and Rivera, respectively, result from the specific circumstances of their cases, the specific requests of
+their lawyers, and their individual housing circumstances. On all of these factors, there are several
+important differences, including:
+The Maxwell case has multiple times more discovery than the Rivera case. Hence, the need for
+such expanded discovery access is greater in the Maxwell case.
+EFTA00066951
+
+- At the MDC, Maxwell has a unique housing situation, as she is in protective custody outside the
+general population. She therefore has sole access to a room to use a computer and phone for
+approximately 13 hours a day. Rivera, by contrast, is housed in the general population.
+- There are approximately 8o other inmates at the MCC in Rivera's unit that use the same VTC
+room for court appearances, probation interviews, and attorney meetings. By contrast, Maxwell
+shares access to the MDC VTC room with substantially fewer inmates. The MDC can therefore
+provide 15 hours of VTC meetings with her attorneys without compromising access for other
+MDC inmates. The same is not true for Rivera at the MCC.
+Going forward, even though Rivera's counsel have asked (and the Court has ordered) that Rivera
+receive three hours of laptop access each day, the MCC is now leaving the laptop with him all day long,
+and only takes it back at night to charge it. Therefore, the MCC is now providing the same amount of
+electronic discovery access to Rivera that Maxwell receives at the MDC.
+As for providing Rivera with up to 15 hours of VTC access, we will explain that doing so will
+compromise access for other inmates. If defense counsel expresses a need for additional time, the
+MCC will continue to find ways to accommodate those requests as best as they can.
+Please let me know if you have any questions or would like to discuss this further.
+Best,
+From:
+(USANYS) <
+Sent: Monday, December 21, 2020 4:42 PM
+To:
+(USANYS) <
+(USANYS) <
+I (USANYS) <
+| (USANYS) 4
+P:
+P;
+(USANYS)
+Cc:
+(USANYS) <
+(USANYS)
+| (USANYS)
+(USANYS) <
+(USANYS) 1 <
+Subject: RE: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
+Thanks,
+Can you keep me posted on what we think will be the substance of the draft declaration when you know
+(that is, before we are submitting anything on 12/31)? And how much of this is attributable to differences between MCC
+and MDC, as well as specific differences in their housing situations?
+From:
+To:
+(USANYS) <
+Sent: Monday, December 21, 2020 4:35 PM
+| (USANYS) <
+(USANYS) <
+• (USANYS) 4
+| (USANYS) <
+(USANYS)
+(USANYS)
+| (USANYS)
+Cc:
+(USANYS) <
+(USANYS) <
+P;
+(USANYS) 1 <
+Subject: Disparities in Counsel and Discovery Access for Ghislaine Maxwell and Justin Rivera
+All:
+EFTA00066952
+
+I wanted to bring to your attention a recent issue that's surfaced in United States v. Rivera et al., a sex
+trafficking case pending before Judge Engelmayer. As I'll describe in more detail below, Judge
+Engelmayer has asked us to submit a declaration from the BOP explaining why the discovery and
+counsel access accommodations provided to Ghislaine Maxwell (detained at the MDC outside the
+general population) cannot be extended to Justin Rivera (detained at the MCC in the general
+population).
+Justin Rivera was charged in February 2019 with sex trafficking conspiracy. He's been detained at the
+MCC since April 2019 on consent (he's also serving a state sentence). His trial, which was originally
+scheduled for April 2019, is expected to start on February 16, 2020. In July 2020, he had new counsel
+appointed, citing an irreconcilable breakdown with his former counsel.
+Since this fall, Judge Engelmayer has become increasingly frustrated with the MCC's treatment of
+Rivera. In particular, he's cited their failure to provide Rivera with adequate accommodations to
+review discovery and meet with his lawyers, who refuse to visit Rivera at the MCC for personal health
+the MCC to provide Rivera access to a laptop for three hours per day; and (2) a videoconference order,
+which requires the MCC to make available four hours of videoconferencing each week, in addition to
+any telephone or videoconference calls obtained through the Federal Defenders.
+At the moment, there's not a concern, at least from Judge Engelmayer, that the amount of time Rivera
+has for videoconferences and electronic discovery review is insufficient for trial preparation, although
+defense counsel has stated that they may request more time in the future. However, in a letter last
+night and during a court conference this morning (transcript attached), defense counsel cited the
+accommodations that the MDC has provided to Maxwell, describing them as "strikingly different and
+far superior" to those afforded to Rivera. Defense counsel further suggested that Rivera was being
+treated differently on account of his race, gender and class. Judge Engelmayer stated that the
+disparity in access "jumped off the page" and that the optics were "terrible," and asked us to explain
+the rationale for the differing treatment. After conferring with
+and
+before
+our conference, we explained our understanding that the disparity comes down to the fact that
+Maxwell and Rivera have very different housing situations, with Maxwell's situation being more
+amenable to greater access to electronic discovery review and legal visits.
+Judge Engelmayer asked us to submit a declaration, from an appropriate person at the BOP,
+explaining in more detail why the accommodations provided to Maxwell cannot be extended to Rivera.
+Based on the recent bail opposition in the Maxwell case, I believe the differences in counsel/discovery
+access are as follows:
+Accommodation
+Review of electronic
+discovery (NB: each
+defendant has laptop access)
+Counsel visits (by video)
+Maxwell
+13 hours per day/7 days per
+week (91 hours total)
+3 hours per day/5 days per
+week (15 hours total)
+Rivera
+3 hours per day/7 days per
+week (21 hours total)
+Weekend legal calls
+As needed
+Four hours per week (plus an
+additional two hours
+scheduled through the
+Federal Defenders) (6 hours
+total)
+Not available
+EFTA00066953
+
+The declaration is due by December 31. Because Judge Engelmayer's request implicates at least two
+criminal cases, and potentially the ongoing civil litigation with the MCC, we wanted to make sure that
+you were all aware of this issue. We are also happy to set up a call to discuss this further. In the
+meantime, we are working with
+to identify the appropriate declarant and draft ar
+explanation for the Court.
+Best,
+Bhaskaran
+Assistant United States Attorney
+United States Attorney's Office for the Southern District of New York
+One Saint Andrew's Plaza
+New York, NY 10007
+Tel:
+EFTA00066954
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bf7b6fd16f222023ce2d9f7280d7a53f13cf8b59457966d4a132225b45214477.md b/vision-joined/ds9-parsed-01/bf7b6fd16f222023ce2d9f7280d7a53f13cf8b59457966d4a132225b45214477.md
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@@ -0,0 +1,297 @@
+Case 9:08-cv-80736-KAM Document 361-15 Entered on FLSD Docket 02/10/2016 Page 1 of
+11
+EXHIBIT
+15
+EFTA00081262
+
+Case 9:08-cv-80736-KAM Document 361-15
+Entered on FLSD Docket 02/10/2016 Page 2 of
+11
+To lefkowitz@kirkland.com, jlefkowitz@kirkland.com
+bcc
+09/15/2007 03:16
+PM
+Subject JE negotiatons
+History.
+The message has been replied o
+and forwarded.
+Hi Jay -- Sorry to trouble you over the weekend. Here are the
+revised documents with the 403 charge. I have gotten some
+negative reaction to the assault charge with
+L as the
+victim, since she is considered one of the main perpetrators of the
+offenses that we planned to charge in the indictment. Can you talk
+to Mr. Epstein about a young woman named
+7 We have
+hearsay evidence that she traveled on Mr. Epstein's airplane when
+she was under 18, in around the 2000 or 2001 time frame. That
+falls outside the statute of limitations, but perhaps we could
+construct a 371 conspiracy around that?
+Let me know what you think.
+Thank you,
+«< Attachment Information charging 4uo and 113.pdr has been
+archived by user 'CommonStore/IT/Kirkland-Ellis' on '11/26/2007
+01:07:57. 222
+ses Attachment 'OLY Plea Agreement v5403 and 113 violations.pdf
+has been archived by user 'CommonStore/IT/Kirkland-Ellis' on
+*11/26/2007 01:07:57.>>
+08-80736-CV-MARRA
+RFP WPB 000235
+EFTA00081263
+
+Case 9:08-cv-80736-KAM Document 361-15 Entered on FLSD Docket 02/10/2016 Page 3 of
+D
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.
+18 U.S.C. § 403
+18 U.S.C. § 113(a)(5)
+UNITED STATES OF AERICA
+JEFFREY EPSTEIN,
+Defendant.
+A
+INFORMATION
+The United States Attorney charges that:
+COUNT 1
+In or around August 2006, in Palim Boach Coyot, in the Southen District of Florida, and
+elsewhere, the defendant,
+JEFFREY EPSTEIN,
+did knowingly and intentionally violate the privacy protection accordaby 18 U.S.C. § 3509 to a
+child victim, that is, Jane Doe #1; in violation of Title 18, United States-Code, Sections 403 and 2.
+COUNT 2
+In or around
+_ 2005, in the special territorial jurisdiction of the United States, that
+is, in an aircraft owned by a United States citizen while in flight over the high seas, and elsewhere,
+the defendant,
+JEFFREY EPSTEIN,
+08-80736-CV-MARRA
+- RFP WPB 000236
+EFTA00081264
+
+Case 9:08-cv-80736-KAM Document 361-15 Entered on FLSD Docket 02/10/2016 Page 4 of
+did knowingly commit a simple assault on a person who was over the age of 16 years, that is,
+in violation of Title 18, United States Code, Section 113(a)(5).
+D
+R. ALEXANDER ACOSTA
+UNTIED STATES TREY
+ASSISTANT UNITED STATES ATTORNEY
+A
+F
+T
+2
+08-80736-CV-MARRA
+RFP WPB 000237
+EFTA00081265
+
+Case 9:08-cv-80736-KAM Document 361-15 Entered on FLSD Docket 02/10/2016 Page 5 of
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+D
+Case No.
+UNITED STATES OF AMERICA
+VS.
+JEFFREY EPSTEIN.
+Defendi
+PLEA AGREEMENT
+The United States Attorney for he Southern District of Florida ("the United States"),
+and Jeffrey Epstein (hereinafter referred to as the "defendant") enter into the following
+agreement:
+The defendant agrees to plead guilty to the Information which charges the
+defendant as follows: Count 1 charges that the defendant knowingly and intentionally
+violated the privacy protection accorded to child victims by 18 U.S.C. § 3509; in violation
+of Title 18, United States Code, Sections 403 and 2; and Count 2 charges that the defendant,
+while in an airplane over the high seas, did knowingly commit a ample assault on a person
+who was over the age of 16 years, that is
+I, in violation of Title 18, United States Code,
+Section 113(a)(5).
+The defendant is aware that the sentence will be imposed by the Court after
+considering the Federal Sentencing Guidelines and Policy Statements (hereinafter
+Page 1 of 7
+08-80736-CV-MARRA
+RFP WPB 000238
+EFTA00081266
+
+Case 9:08-cv-80736-KAM Document 361-15 Entered on FLSD Docket 02/10/2016 Page 6 of
+11
+• %
+"Sentencing Guidelines"). The defendant acknowledges and understands that the Court will
+compute an advisory sentence under the Sentencing Guidelines and that the applicable
+guidelines
+prill be determined by the Court relying in part on the results of a Pre-Sentence
+Investigation by the Court's probation office, which investigation will commence after the
+guilty plea has been entered. The defendant is also aware that, under certain circumstances,
+the Court may depart from the advisory sentencing guideline range that it has computed, and
+may raise or lower that advisory sentence under the Sentencing Guidelines. The defendant
+is further aware and understands that the Court is required to consider the advisory guideline
+range determined under the Sentencing Guidelines, but is not bound to impose that sentence;
+the Court is permitted to tailor the ultimate sentence in light of other statutory concerns, and
+such sentence may be either more severe or less severe than the Sentencing Guidelines'
+advisory sentence. Knowing these facts, the defendant understands and acknowledges that
+the Court has the authority to impose any sentence within and up to the statutory maximum
+authorized by law for the offenses identified in paragraph 1 and that the defendant may not
+withdraw the plea solely as a result of the sentence imposed.
+The defendant further understands and acknowledges that, as to Count 1 of the
+Information, the Court may impose a statutory maximum term of imprisonment of up to one
+(1) year, to be followed by a term of supervised release of up to a maximum of one (1) year.
+In addition to terms of imprisonment and supervised release, the Court may impose a fine of
+up to $100,000. The defendant further understands and acknowledges that, as to Count 2 of
+the Information, the Court may impose a statutory maximum term of imprisonment of up to
+Page 2 of 7
+08-80736-CV-MARRA
+RFP WPB 000239
+EFTA00081267
+
+Case 9:08-cv-80736-KAM Document 361-15 Entered on FLSD Docket 02/10/2016 Page 7 of
+11
+six (6) months, to be followed by a term of supervised release of up to a maximum of one (1)
+year. In addition to terms of imprisonment and supervised release, the Court may impose a
+fine of u
+$100,000.
+The defendant further understands and acknowledges that, in addition to any
+sentence imposed under paragraph 3 of this Agreement, a special assessment in the amount
+of $50 will be imposed on the defendant, which must be paid at or before the time of
+sentencing.
+The defendant understands that the Court will order that he must pay full
+restitution to all victims of the offense to which he is pleading guilty. The defendant
+understands that the amount of resti
+ation owed to each victim will be determined at or
+before sentencing.
+6. The parties agree to jointly recommend that the defendant receive a sentence
+of eighteen (18) months' imprisonment, to be followed by two (2) years of supervised
+release; and a fine of $200,000.
+7.
+The defendant agrees that, if any of the victims identified in the federal
+investigation file suit pursuant to 18 U.S.C. § 2255, the defendant will not contest the
+jurisdiction of the U.S. District Court for the Southern District of Florida over his person
+and/or the subject matter, and the defendant will not contest that the identified victims are
+persons who, while minors, were victims of violations of Title 18, United States Code,
+Sections(s) 2422 and/or 2423. The United States agrees to provide the defendant's attorneys
+with a list of the identified victims, which will not exceed forty, after the defendant has
+Page 3 of 7
+08-80736-CV-MARRA
+RFP WPB 000240
+EFTA00081268
+
+Case 9:08-cv-80736-KAM Document 361-15 Entered on FLSD Docket 02/10/2016 Page 8 of
+• 1.
+signed this agreement and has been sentenced. The United States further agrees to make a
+motion with the United States District Court for the Southern District of Florida for the
+appointinen, of a guardian adlitem for the identified victims and the defendant's counsel may
+contact the identified victims through that guardian.
+The defendant agrees to plead guilty (not nolo contendere) to an Information
+filed by the Palm Beach County State Attorney's Office charging an offense for whích the
+defendant must regisler as a sex offender, that is, solicitation of minors to engage in
+prostitution, in violation of Fl. Stat. 796.03. The defendant agrees that he and the Palm
+Beach County State Attorney's Office will make a joint, binding recommendation that the
+Court impose a sentence of at least
+ty (30) months, to be divided as follows:
+(a)
+the defendant shall begin by serving at least twenty (20) months in
+prison, without any opportunity for withholding adjudication or
+sentencing, and without
+probation or community control in lieu of
+imprisonment; and
+(b)
+following the term of imprisonment, the defendant shall serve ten (10)
+months of community control/home confinement with electronic
+monitoring.
+T
+9.
+The defendant agrees to waive all challenges to the Information filed by the
+State Attorney's Office and to waive the right to appeal his conviction and sentence in the
+state court.
+10. The defendant agrees that he will provide to the U.S. Attorney's Office copies
+Page 4 of 7
+08-80736-CV-MARRA
+RFP WPB 000241
+EFTA00081269
+
+Case 9:08-cv-80736-KAM Document 361-15 Entered on FLSD Docket 02/10/2016 Page 9 of
+11
+of all proposed agreements with the Palm Beach County State Attorney's Office prior to
+entering into those agreements.
+D
+The United States reserves the right to inform the Court and the probation
+office of all facts pertinent to the sentencing process, including all relevant information
+concerning the offenses committed, whether charged or not, as well as concerning the
+defendant and the defendant's background, and to respond to any questions from the Court
+and the Probation Office and to any misstatements of fact or law. Subject only to the express
+terms of any agreed-upon sentencing recommendations contained in this Agreement, this
+Office further reserves the right to make any recommendation as to the quality and quantity
+of punishment.
+A
+12. The defendant is aware that the sentence has not yet been determined by the
+Court. The defendant also is aware that any estimate of the probable sentencing range or
+sentence that the defendant may receive, whether that estimate comes from the defendant's
+attorney, the government, or the probation office, is a prediction, not a promise, and is not
+binding on the government, the probation office or the Court. The defendant understands
+further that any recommendation that the government makes to the Court as to sentencing,
+whether pursuant to this agreement or otherwise, is not binding on the Court and the Court
+may disregard the recommendation in its entirety. The defendant understands and
+acknowledges, as previously acknowledged in paragraph 2 above, that the defendant may not
+withdraw his plea based upon the Court's decision not to accept a sentencing
+recommendation made by the defendant, the government, or a recommendation made jointly
+Page 5 of 7
+08-80736-CV-MARRA
+RFP WPB 000242
+EFTA00081270
+
+Case 9:08-cv-80736-KAM Document 361-15 Entered on FLSD Docket 02/10/2016 Page 10 of
+by both the defendant and the government.
+13. WAIVER OF RIGHT TO APPEAL AND COLLATERALLY ATTACK
+THE STENCE. The defendant is aware that Title 18, United States Codo, Section 3742
+affords the defendant the right to appeal the sentence imposed in this case. Acknowledging
+this, in exchange for the undertakings made by the United States in this plea agreement, the
+defendant hereby waives all rights conferred by Section 3742 to appeal any sentence
+imposed, including any restitution order, or to appeal the manner in which the sentence was
+imposed, unless the sentence exceeds the maximum permitted by statute or is the result of
+an upward departure or upward variance from the guideline range that the Court establishes
+at sentencing. The defendant furthe
+#yoluntarily and expressly waives, to the maximum
+extent permitted by federal law, the right to collaterally attack his sentence in any post-
+conviction proceeding, including a motion on any ground brought under 28 U.S.C. § 2254,
+28 U.S.C. 82255, 18 U.S.C. § 3572, or 18 U.S.C. 55771. The defendant further understands
+that nothing in this agreement shall affect the government's right and/or duty to appeal as set
+forth in Title 18, United States Code, Section 3742(b). However, if the United States appeals
+the defendant's sentence pursuant to Section 3742(b), the defendant shall be released from
+the above waiver of appellate rights. By signing this agreement, the defendant acknowledges
+that he has discussed the appeal waiver set forth in this agreement with his attorney:
+14.
+If the defendant fails in any way to fulfill each one of his obligations under this
+Plea Agreement, the United States, and only the United States, may elect to be released from
+its commitments under this Plea Agreement. If the United States elects to void the Plea
+Page 6 of 7
+1.
+08-80736-CV-MARRA
+RFP WPB 000243
+EFTA00081271
+
+Case 9:08-cv-80736-KAM Document 361-15 Entered on FLSD Docket 02/10/2016 Page 11 of
+11
+Agreement because of a breach by the defendant, then the United States agrees not to use the
+defendant's guilty plea against him. However, the United States may prosecute the defendant
+for any andrall Federal crimes that he has committed related to this case and may seek any
+sentence for such crimes up to and including the statutory maximums. The defendant
+expressly waives any statute of limitations defense and any constitutional or statutory speedy
+trial defense to such a prosecution, except to the extent that such a defense exists as of the
+date he signs this Pleal Agreement. Finally, the defendant understands that his violation of
+the terms of this Plea Agreement would not entitle him to withdraw his guilty plea.
+15. This is the entire agreement and understanding between the United States and
+the defendant. There are no other agr
+ments, promises, representations, or understandings.
+Date:
+By:
+R. ALEXANDER ACOSTA
+UNITE STATES ATTORNEY
+Date:
+Date:
+By: _
+JEFFREY EPSTEIN, DEFENDANT
+1
+By:
+JAY LEFKOWITZ, ESQ.
+ATTORNEY FOR DEFENDANT
+Page 7 of 7
+08-80736-CV-MARRA
+RFP WPB 000244
+EFTA00081272
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bfd485a52fcfa9a695d3eea0e3c96b2a60bc72557a2a01bb152e12ad9a1001dd.md b/vision-joined/ds9-parsed-01/bfd485a52fcfa9a695d3eea0e3c96b2a60bc72557a2a01bb152e12ad9a1001dd.md
new file mode 100644
index 0000000000000000000000000000000000000000..e5b31183f7bdc75ae2fc3ec024dc1608e1813bf8
--- /dev/null
+++ b/vision-joined/ds9-parsed-01/bfd485a52fcfa9a695d3eea0e3c96b2a60bc72557a2a01bb152e12ad9a1001dd.md
@@ -0,0 +1,125 @@
+From: "
+To:
+Cc: "
+Subject: RE: DOJ Visit and Discovery
+Date: Thu, 10 Sep 2020 15:55:22 +0000
+| (USANYS)"
+Got it, will do. Thanks very much.
+From
+To:
+Cc:/
+Sent: Thursday, September 10, 2020 11:42 AM
+(USANYS) <
+Subject: RE: DOJ Visit and Discovery
+She should have it. If he tells you anything differently today or tomorrow, let me know.
+>>>
+> 9/10/2020 10:36 AM > > >
+Thanks very much,
+From
+Sent: Thursday, September 10, 2020 7:17 AM
+To: |
+Cc:|
+(USANYS) <
+Subject: Re: DOJ Visit and Discovery
+It was delivered around 3 pm, which I believe was after her call with counsel. I will double check with my paralegal though.
+Thanks,
+>>
+Hi
+> 9/10/2020 12:01 AM > > >
+Maxwell's attorney just emailed me saying that his client still has not received this drive. Would you please confirm for us
+tomorrow that she has this drive?
+Thanks very much,
+On Sep 9, 2020, at 8:17 PM,
+ wrote:
+Really appreciate you looking into that.
+Assistant United States Attorney
+Southern District of New York
+EFTA00087964
+
+1 St. Andrew's Plaza
+New York, NY 10007
+From: Holly Pratesi <
+Sent: Wednesday, September 9, 2020 4:45 PM
+To:
+Cc:
+Subject: RE: FW: DOJ Visit and Discovery
+Drive was delivered today.
+Best
+(USANYS) <
+>>>
+> 9/8/2020 7:01 PM >> >
+Thanks very much,
+Really appreciate the quick response. Please let us know if you learn of any planned visit from
+DOJ. Our office is not aware of any planned visit either.
+And apologies for the oversight, we must have forgotten to email you about the drive. Our paralegal sent a new drive
+out for Maxwell on Thursday, September 3'd.
+'. Attached are the two accompanying letters. Would you please look into
+its status for us?
+Thanks again,
+Assistant United States Attorney
+Southern District of New York
+1 St. Andrew's Plaza
+New York, NY 10007
+From: Holly Pratesi <
+Sent: Tuesday, September 8, 2020 6:44 PM
+To:
+Cc:
+(USANYS) <
+Subject: Re: FW: DOJ Visit and Discovery
+Good evening
+I am unaware of any visit tomorrow by DOJ representatives. I will raise this early tomorrow with staff and see if 1 can get
+any further details about this.
+When was the drive sent last week? We have received two drives to date - are you saying another was sent? I do not recall
+seeing any emails about a third set (if I missed it while out of the office, I apologize).
+Thanks,
+> 9/8/2020 6:41 PM >>>
+We just received the below email from Ghislaine Maxwell's attorney. Do you know what DOJ representatives they are
+referring to? Regardless, per counsel's instruction below, please ensure that no DOJ representatives speak with Maxwell
+without her counsel present.
+Also, would you please check on the status of the drive our office sent out last week?
+I can be reached on my cellphone at
+and am happy to have a call if that would be useful.
+Thank you,
+Assistant United States Attorney
+Southern District of New York
+1 St. Andrew's Plaza
+EFTA00087965
+
+New York, NY 10007
+From: Christian Everdell <
+Sent: Tuesday, September 8, 2020 6:37 PM
+To:
+(USANYS) <
+Cc: Mark S. Cohen <
+P; Laura Menninger <
+P; Jeff Pagliuca
+Cubinct. DOLVirit aad Discour
+Thope you had a good Labor Day weekend. Our client has advised us that representatives from the DOJ will be meeting
+with her in the MDC tomorrow. We are not clear who these representatives are or what they intend to meet with our
+client about. But it goes without saying that she is a represented party and that no representatives from DOJ should be
+speaking with her without her counsel present. We request that you notify the appropriate people at MDC about this as
+soon as possible.
+Also, our client has still not received the replacement hard drive you sent out on Thursday, September 3, at our request.
+As a result, it is now over two weeks past the August 21 deadline for completion of the initial tranche of discovery and
+Ms. Maxwell is still unable to review a substantial portion of the discovery produced to date. Ms. Maxwell cannot
+participate in her defense if she cannot review the discovery. Accordingly, we request that you expedite the delivery of
+the hard drive.
+Regards,
+Chris
+Christian Everdell
+
+800 Third Avenue
+New York, NY 10022
+view big
+www.conengresser.com
+New York | Seoul | Paris | Washington DC | London
+
+CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only
+the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient, you are hereby notified that any
+review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify
+the sender by telephone and permanently delete this e-mail. Thank you.
+PRIVACY: A complete copy of our privacy policy can be viewed at: https://www.cohengresser.com/privacy-policy
+EFTA00087966
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bfe07e3a374b14639274633d1576a5bbaf9728fd4288fdd350f209b19cb3b6ed.md b/vision-joined/ds9-parsed-01/bfe07e3a374b14639274633d1576a5bbaf9728fd4288fdd350f209b19cb3b6ed.md
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@@ -0,0 +1,17 @@
+From: "
+To:
+Cc: "
+Subject: FW: [EXTERNAL] Elizabeth Loftus
+Date: Mon, 22 Nov 2021 19:45:50 +0000
+(USANYS)"
+Forwarding per our usual practice.
+Team, I don't think we need to categorize this as NTW for the defense, but let me know if you disagree.
+Thanks,
+From: Angela Foster
+Sent: Monday, November 22, 2021 2:20 PM
+To:
+Subject: [EXTERNAL] Elizabeth Loftus
+Why would this woman have a seat at "the table" when she clearly knew Epstein and his ilk? She was on the board of
+EDGE. She knew Epstein https://www.edge.org/memberbio/elizabeth_loftus
+Sent from my iPhone
+EFTA00078484
\ No newline at end of file
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+}
diff --git a/vision-joined/ds9-parsed-01/bfecfc77642eb8786a652a6652c33b94c476728960424ae4c61a1da41ec36589.md b/vision-joined/ds9-parsed-01/bfecfc77642eb8786a652a6652c33b94c476728960424ae4c61a1da41ec36589.md
new file mode 100644
index 0000000000000000000000000000000000000000..547c2c4f44d18bcf330528053a16248426278a42
--- /dev/null
+++ b/vision-joined/ds9-parsed-01/bfecfc77642eb8786a652a6652c33b94c476728960424ae4c61a1da41ec36589.md
@@ -0,0 +1,76 @@
+31b1
+Sign-ln Sheet
+SH SUICIDE
+6/6/19
+Dr. millek
+Fignature
+I. NoeL
+BOp 11232
+10-260-2019
+TN 4. 22.21
+EFTA00117579
+
+2/28/19
+• SHU Suicide PreentioN Training (le)
+EFTA00117580
+
+MCC NEW YORK
+TRAINING PARTICIPANT SIGN-IN LOG
+COURSE TITLE:_
+Suicide Prevention/SHU Training.
+_COURSE CODE: _
+TRAINING DATE(S): From: December 7-2018 To:_December 7, 2018
+_ TOTAL TRNG HRS. 114
+TRAINING TIMES: Emmi
+_To: _ 12:00pm
+INSTRUCTOR(S):
+_ NOTE: INSTRUCTORS) MUST ATTACH AGENDA
+OR SUMMARY OF TRAUNING
+LAST NAME (PRINTED)
+FIRST NAME (PRINTED)
+BOP ID
+SIGNATURE
+OFFICE
+USE
+1.
+2.
+3
+4.
+5.
+6.
+7.
+9.
+10
+11
+12
+13.
+14.
+15.
+16.
+17.
+18.
+19.
+20.
+By signing above you attest to not only attending the above named training course,
+but also to understanding the course material, policies and procedures pertaining to
+the training.
+SENSITIVE - LIMITED OFFICIAL USE
+EFTA00117581
+
+10/10/2018
+Specla
+Housing
+Unit Management Sucide Prevention
+Objectives
+• Understand suicide risk associated with
+locked units and single cells
+• Identify high risk groups
+- mentally Ill inmales
+- behavior disordered inmales
+- sex offender and protective cusiody inmates
+Objectives
+• Discuss management strategies for
+specific at risk inmates in this SHU
+• Review emergency response procedures
+1
+EFTA00117582
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/bff959c7b45149357c2ef5db021dd6cc5f5481f42ac45c6092bef523aa163540.md b/vision-joined/ds9-parsed-01/bff959c7b45149357c2ef5db021dd6cc5f5481f42ac45c6092bef523aa163540.md
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@@ -0,0 +1,75 @@
+U.S. Department of Justice
+Memorandum
+Federal Bureau of Prisons
+MCC New York
+Metropolitan Correctional Center
+150 Park Row
+New York, New York 10007
+August 12, 2019
+MEMORANDUM FOR TOVA NOEL, CORRECTIONAL OFFICER
+FROM:
+SUBJECT:
+Captain
+Reassignment of Duties & Limited Institution Access - Noel, Tova
+This memorandum is written to notify you effective with issuance
+and/or receipt of this memorandum, and until further notice, you
+are required to complete duties as assigned by the Operations
+Lieutenant. You will be assigned to work either Stati
+Screening, or Front Lobby.
+If there is no vacancy in either of
+these two positions, the Operations Lieutenant will assign you
+to Phone Monitor.
+You will continue to work your normal schedule of Wednesday
+through Thursday 2:00 pm - 10:00 pm and Friday through Sunday
+4:00 pm - 12:00 am, with Monday and Tuesday being off days.
+will continue to follow normal protocol as it relates to leave
+requests and procedures. As a reminder, you are not to leave
+your assigned area without checking with the Supervisor first.
+Your access within the confines of the institution will be
+limited. You will be restricted to the first floor.
+Should you have any questions or concerns regarding this
+correspondence, please feel free to contact me.
+I have received the original and one copy on the date indicated.
+Signature
+Date
+EFTA00122406
+
+U.S. Department of Justice
+Memorandum
+Federal Bureau of Prisons
+MCC New York
+Metropolitan Correctional Center
+150 Park Row
+New York, New York 10007
+August 12,
+2019
+MEMORANDUM FOR CONTROL CENTER
+FROM:
+Captain
+SUBJECT:
+Limited Institution Access - NOEL, Tova
+Please be advised the above employee is not authorized access beyond the first floor. This
+restriction will remain in effect until further notice.
+Questions or concerns should be directed to me or
+AW (P).
+EFTA00122407
+
+U.S. Department of Justice
+Memorandum
+Federal Bureau of Prisons
+MCC New York
+Metropolitan Correctional Center
+150 Park Row
+New York, New York 10007
+August 12,
+2019
+MEMORANDUM FOR CONTROL CENTER
+FROM:
+Captain
+SUBJECT:
+Limited Institution Access - THOMAS, Michael
+Please be advised the above employee is not authorized access beyond the first floor. This
+restriction will remain in effect until further notice.
+Questions or concerns should be directed to me or
+1, AW (P).
+EFTA00122408
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/c0121ed74d6a8b14ebd0ec1762461a1d09092bfae32e68574721c0ca1bb28ca5.md b/vision-joined/ds9-parsed-01/c0121ed74d6a8b14ebd0ec1762461a1d09092bfae32e68574721c0ca1bb28ca5.md
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@@ -0,0 +1,12 @@
+From:
+Mon 8/12/2019 7:30:31 PM
+Subject: SW Chronological Log 7/23-24/19 re: Epstein, Jeffrey Edward, Reg. No. 73618-054
+IEXT_2.htm
+2019 08 12 15 10 43.pdf
+I/M companion assumed duties from staff on 7/23/19 @ 7 am until 7/24/19 @ 8: 45 am (S/W)
+Epstein was transferred to psych observation on 7/24/19 @ 8:45 am until 7/30/19 at 8:15 am (I/M
+companion was utilized).
+Associate Warden
+MCC New York
+CONFIDENTIAL
+SDNY_00009684
\ No newline at end of file
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diff --git a/vision-joined/ds9-parsed-01/c032bb869dc707595e0b6155122c8bf4808011a56825a7c1029f16355184abbd.md b/vision-joined/ds9-parsed-01/c032bb869dc707595e0b6155122c8bf4808011a56825a7c1029f16355184abbd.md
new file mode 100644
index 0000000000000000000000000000000000000000..97fd97bcc4cb61d4e581e771b1e62b0b5de645fd
--- /dev/null
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@@ -0,0 +1,427 @@
+You are acting as a proxy for another user (TOVA
+NOEL).
+Completed Work
+Direct links are not supported in
+Proxy Mode
+Return to Home of TOVA NOEL Close Session
+1 Ethics taught in annual raining
+vICTPhase# FLetC 8128118-9/14/281
+Show Completions:
+All
+Completion Date *
+Title
+3/8/2019 04:00 PM
+8 Correctional Training, Annual-BOP
+3/8/2019 07:30 AM
+8 Female Offenders, Annual
+Refresher -BOP
+3/8/2019 07:30 AM
+8 Trauma Informed Correctional
+Care, Annual Refresher -BOP
+3/7/2019 10:41 AM
+Information Security Awareness -
+BOP
+3/7/2019 10:41 AM
+• Oleoresin Capsicum (OC) Aerosol
+Spray, User Re-familiarization -BOP
+3/6/2019 11:00 AM
+8 Firearms, All Weapons, Annual
+Certification -BOP
+3/5/2019 12:00 PM
+8 Self-Contained Breathing
+Apparatus (SCBA) & Fit-Test
+Refresher - BOP
+3/4/2019 10:21 AM
+[ Weapons of Mass Destruction
+(WMD) -GOV
+3/4/2019 10:20 AM
+9 Continuity of Operations (COOP) -
+GOV
+3/4/2019 10:20 AM
+8 Prison Rape Elimination Act
+(PREA)
+9/13/2018 12:48 PM
+8 Firearms. All Weapons, Annual
+Certification -BOP
+9/13/2018 12:36 PM
+8 Correctional Training Program
+Phase II, Introduction -BOP
+9/13/2018 12:36 PM 8 Correctional Training. Annual -BOP
+7/13/2018 04:00 PM 8 Correctional Training Program
+Phase I, Introduction -BOP
+7/13/2018 04:00 PM 8 Employee Familiarization Non-
+Institution -BOP
+7/13/2018 12:44 PM
+8 Female Offenders - BOP
+7/13/2018 12:44 PM 8 Female Offenders, Annual
+Refresher -BOP
+7/5/2018 12:46 PM
+8 Oleoresin Capsicum (OC) Aerosol
+Spray. User Initial -BOP
+7/3/2018 12:51 PM
+[W Electronic Search Devices -BOP
+7/3/2018 12:51 PM
+Inmate Pat Search -BOP
+7/3/2018 12:51 PM
+[• Staff Pat Search -BOP
+7/3/2018 12:49 PM
+8 Cardio Pulmonary
+Resuscitation/Automatic External
+Defibrillator (CPR/AED)
+Certification -BOP
+6/28/2018 12:54 PM
+9 Key Control -BOP
+Status
+All
+Complete
+Complete
+Complete
+Complete
+Complete
+Complete
+Complete
+Complete
+Complete
+Complete
+Complete
+Complete
+Requirement Met
+Complete
+Requirement Met
+Complete
+Requirement Met
+Complete
+Complete
+Complete
+Complete
+Complete
+Action
+Complete
+EFTA00122319
+
+Completion Date • Title
+6/28/2018 12:53 PM 9 Globally Harmonized System
+(GHS) -BOP
+6/28/2018 12:53 PM @ National Protective Vest
+Procedures- BOP
+6/27/2018 04:00 PM 8 Trauma Informed Correctional
+Care, Annual Refresher -BOP
+6/27/2018 04:00 PM 8 Trauma- Informed Correctional
+Care- BOP
+6/27/2018 12:56 PM
+9 BOP Records Management
+Training
+6/27/2018 12:55 PM 8 Affirmative Employment -GOV
+6/27/2018 12:53 PM
+• Correctional Practices: Managi
+derly Inmates -BC
+6/27/2018 12:53 PM
+8 Managing Inmates with Disabilities
+6/27/2018 12:50 PM (9 Continuity of Operations (COOP) -
+GOV
+6/27/2018 12:50 PM
+19 Weapons of Mass Destruction
+(WMD) - GOV
+6/27/2018 12:45 PM 4 Information Security Awareness -
+6/26/2018 12:54 PM
+8 Diversity -BOP
+6/26/2018 12:54 PM
+9 Special Housing Unit (SHU).
+Quarterly -BOP
+6/26/2018 12:52 PM
+6/25/2018 12:54 PM
+(W Reporting Wrongdoing:
+Whistleblowers and their Rights and
+Protections -GOV
+4 Domestic Violence, Sexual Assault.
+and Stalking in the Workplace
+(Skillsoft)
+6/25/2018 12:52 PM
+8 Prison Rape Elimination Act
+(PREA)
+Complete
+Complete
+Items: 39
+Status
+complete
+All
+Complete
+Requirement Met
+Complete
+Complete
+Complete
+Complete
+Complete
+Complete
+Complete
+Complete
+Complete
+Complete
+Complete
+Action
+* All dates are for America/New York time zone.
+EFTA00122320
+
+Amend 4: Add
+I. GENERAL INFORMATION
+Participant's Names: NOEL, TOVA
+Mateo, Miguel
+TRAINING AUTHORIZATION (SF-182)
+Location of Training:
+Bureau of Prisons - Staff Training Academy
+Federal Law Enforcement Training Center (FLETC)
+Course Title:
+Introduction to Correctional Techniques
+Phase II (BOPB-1864 & BOPB 1865)
+Course Codes: HRM-0100-BXX (76 hrs)
+CSV-0430-BXX (28 hrs)
+STA will key this training
+Training Period (Date/Time):
+Starts:
+Ends:
+Tuesday, August 28, 2018, 7:30 a.m.
+Friday, September 14, 2018, 4:30 p.m.
+# of Course Hours
+Duty Hours:
+104
+Non-Duty Hours:
+Total Hours:
+104
+Training Codes:
+Purpose:
+Type:
+Source:
+8
+8
+1
+Special Interest
+Travel Dates:
+Travel to the Staff Training Academy:
+Monday, August 27, 2018
+Return travel will be scheduled:
+Saturday, September 15, 2018
+More information regarding travel can be found in Section II.
+Accounting Code/Cost Center:
+Indirect Costs:
+Travel
+FP RR II 21 N1 171
+Per Diem
+Other..
+FMS - Yes
+$
+$5.00
+$
+STDS - Yes
+AUTHORIZING OFFICIAL
+Name:
+Signature:
+Direct Costs:
+N/A
+//s//
+Date:
+7/10/18 Amend 7/19/18
+Name:
+HUMAN RESOURCE MANAGER
+Signature:
+Date:
+7/20/18
+Name:
+Signature:
+Date:
+7/20/15
+EFTA00122321
+
+II. TRAVEL
+Airline Arrival Times: For participants who are flying, all arriving and departing flights should be scheduled through
+the Jacksonville International Airport (JAX), Jacksonville, Florida. Schedule your arrival time to coincide with the
+FLETC shuttle pick up times of 3:30 p.m. or 7:30 p.m. A midnight shuttle can be arranged on the travel day in the event
+a flight has been delayed or cancelled; this shuttle is only used under extenuating circumstances.
+The FLETC shuttle will be located at the ground transportation area, located outside of the baggage claim area to the far
+left. Again, the scheduled pick up times are 3:30 p.m. and 7:30 p.m. The scheduled shuttle bus will be white. Email your
+flight arrival time to GLN/ReeistrarOffice@bop.goy to ensure you have a seat on the shuttle.
+If a participant is unable to use the transportation provided by the FLETC, it will be their responsibility to arrange
+transportation to the Training Center. The cost of any alternative transportation must be reimbursed by the Institution.
+Rental cars are not authorized by the Staff Training Academy.
+If you experience flight delays/problems resulting in arriving at JAX later than 7:30 p.m., notify the STA at
+by 4:30 p.m., after 4:30 p.m. notify FLETC at
+Airline Departure Time: Return flights are to be scheduled after 8:30 a.m. The FLETC transportation scheduled time
+of pick-up to JAX is approximately 5:00 a.m. Transportation will not be furnished other than the time indicated.
+Luggage: Consult with the airline and/or the BOP authorized travel agent regarding the number of luggage pieces
+allowed, size, and weight limitations. In the event an airline charges to check a first and/or second bag, notify your
+business office. You will be authorized reimbursement for up to two checked bags that comply with the airline's
+standards; however, you will be responsible for any charges due to being oversized or overweight.
+NOTE: Please allow space in your luggage for your training materials (approximate 4 inch manual).
+II. TRAINING ATTIRE
+Dress Code for the First Day: Participants must wear professional attire (business casual) on their first training day.
+You may not wear jeans of any color, shorts, t-shirts, hats or any clothing considered inappropriate.
+Uniforms: The FLETC will issue uniforms to be wor during training hours. Participants are responsible for bringing
+solid black shoes or boots to wear with the uniform. Athletic shoes are required for the Physical Ability Test. The
+clothing assigned to you for training is your responsibility; anything that is lost must be paid for before you leave.
+PHS Staff: PHS staff may bring and wear their Service Dress Blue uniform the first day of training and for the
+graduation ceremony.
+IV. LODGING AND MEALS
+articipants will be informed of their lodging assignment upon arrival at the FLETC Registration Office. The FLETC wi
+rovide transportation to and from the participants' lodging facilit
+All meals are provided for by FLETC. Participants housed off-center will be provided transportation to and from FLETC
+on both training and non-training days.
+EFTA00122322
+
+V. NOTES FOR PARTICIPANTS
+BOP - ID: It is imperative that you know your BOP-ID number prior to your arrival; you will need to have it.
+Weapons: Personal firearms are not permitted on the FLETC and storage for them is not available.
+GroupWise: Email access is not available; computer access is only available at the FLETC library.
+Graduation Ceremony: Family and friends are welcome to attend the graduation ceremony. All visitors to the FLET
+nust have a basic background check completed prior to the graduation date. The FLETC visitor procedures and forms an
+on the GLYNCO Sallyport page, http://sallyport.bop.gov/train/gln/fletc.jsp. The visitor must complete the FLETC visitor
+form. You must turn the form in on the 1ª day of class.
+NOTE: If the visitor is a Foreiga Nationa/LPR, U.S Citizen born outside the U.S, or Naturalized Citizen, visitor
+forms and documentation must be received by the FLETC 30 days prior to the graduation date to ensure the form
+is processed.
+Failure to follow the FLETC visiting procedures will result in the requested visitor being denied access to the FLETC.
+Staff Training Academy Website: Visit the Staff Training Academy homepage on Sallyport, listed under Glynco. You
+will find the STA Participant Handbook, the FLETC Student Participant Handbook, and some Frequently Asked
+Questions regarding the STA. You can read FLETC's Standards of Conduct as you will be required to sign an
+acknowledgement of having read it during the registration process.
+Cross Development Course Requirement: All Chaplains, PHS staff, and Medical/Dental Officers that elect to waive
+firearms; must know their computer password and ensure that it will not expire while at the STA; we do not have the
+ability to reset it.
+Mailing Address: If you plan to receive mail while you are at the STA, use the following address:
+Your Name, Bureau of Prisons, BOPB-1864 or BOPB-1865, I
+Glynco, GA 31524
+VI. HUMAN RESOURCES
+Responsibility: You are responsible for ensuring each participant has received a copy of this training authorization and
+all instructions have been thoroughly discussed with them. Participants are to bring a copy of both the training and travel
+authorizations with them.
+Medical Form: A current (dated within 30-days of scheduled training) Pre-Training Medical Assessment Form must be
+received for each participant by August 14, 2018. Failure to comply may result in the participant being removed from the
+class. Please scan the medical form to:
+• If you do not have the capability to email the form;
+it may be faxed to
+Cancellation: Written notification will be made to the STA immediately for all participant cancellations, to ensure the
+vacancy can be filled. A waiver will be required for the participant being cancelled, follow the procedure for
+cancellations per Program Statement 3906.22, Chapter 6, Page, 34 Para (b).
+VII. CONTACT INFORMATION
+GLN Repistrar:
+Normal Duty Hours: 7:30 a.m. - 4:30 p.m. (Eastern Standard Time)
+Staff Training Academy Main Line-
+After Normal Duty Hours: FLETC Security -
+If this number is used to contact a participant after normal duty hours/weekends, a message will be given
+to the participant, providing the class number is provided.
+EFTA00122323
+
+PARTICIPANTS
+BOPB - 1864
+MCC NEW YORK
+NOEL, TOVA (Add 7/19)
+EFTA00122324
+
+ACKNOWLEDGMENT OF RECEIPTS
+I certify I've received the below listed items and will conduct a thorough review of all Program Statements as noted below.
+Standards of Employee Conduct, P.S. 3420.11, dated 12/16/2013
+Drug Free Workplace, P.S. 3735.04, dated 06/30/1997
+Acknowledgment of Receipt of Notice to Employee Whose Position Has Been Determined
+Subject to Random Drug Testing (Attachment A)
+Acknowledgment of Receipt of Notice to Employee Whose Position Is Not Subject to
+Random Drug Testing (Attachment B)
+Use of Force and Application of Restraints on Inmates,
+P.S. 5566.06, dated 11/30/2005
+Personal Computers, P.S. 1237.14, dated 05/07/2007
+Affirmative Action and Diversity Management Program,
+P.S. 3713.21, dated 05/16/2001
+Discrimination and Retaliation Complaints Processing,
+P.S. 3713.24, dated 06/16/2014
+Searching, Detaining, or Arresting Visitors to Bureau Grounds and Facilities
+P.S. 5510.15, dated 07/17/2013
+Computer Security Training
+Computer Security Awareness Certification
+Master Agreement, Federal Bureau of Prisons and Council of Prison Locals
+Misdemeanor Crimes of Domestic Violence
+Guidance Regarding Law Enforcement Officers Safety Act (LEOSA)
+Employee Handbook
+Manual and Procedures for Providing Reasonable Accomodations
+0.27.2018
+EFTA00122325
+
+DEC1365 ACKORTEDGEMENI OF RBCEIPT OF "STANDARDS OF EMPLOYEE CONDUCE COERM
+U.S. DEPARTMENT OF JUSTICE
+FEDERAL BUREAU OF PRISONS
+I,
+Tova
+NOeL
+(Employee's Name)
+, hereby acknowledge
+receipt of Program Statement #3420.11. I further acknowledge that my
+conduct is governed by this policy and it is my responsibility to familiarize
+myself with the provisions of this document.
+Date:
+X
+(Signature)
+1.25. 2018
+Inatitution: MCC New york
+:
+PDF
+Prescribed
+by P3420
+EFTA00122326
+
+PS 3735.04
+June 30, 1997
+Attachment A, Page 1
+AcknowLedgement of Receipt of Notice to Employee
+Whose Position Has Been Determined Subject to Random Drug Testing
+ffer a helping hand to those who need it
+nessage that any illegal drug use is, quite simply, incompatible
+vith the mission of the Bureau of Prisons.
+The position you hold has been determined to be a Test Designated
+Position.
+s such, you may be selected for urinalysis dru
+esting for the presence of controlled substances
+You may be required to submit to testing in the following drug
+test categories:
+1. Random Selection
+2. Reasonable Suspicion of drug use on-, or off-duty
+Post Accident
+4. Post Completion of Substance Abuse Treatment Program
+11 initial positive test results will be confirmed with a ga
+hromatography/mass spectrometry analysis. This is the mos
+accurate testing available.
+illegal drug.
+related to positive topica are prote by de fine a
+A test result which the physician has found to be positive, or a
+refusal to submit to drug testing may result in disciplinary
+action up to, and including dismissal.
+confident at assistance by onto ang stel all may seek.
+Assistance Program Coordinator.
+An employee who makes his or her
+trug problem known to his or her Chief Executive Officer prior to
+suspicion or investigation may qualify for protection from
+disciplinary action.
+I have read the above
+identified as subject to random drug testing.
+Statement on Employee Drug Testing.
+see Tora Not
+Date 10.25.18
+Printed Name
+EFTA00122327
+
+Acknowledgment of Receipt of Guidance Materials
+Regarding the Law Enforcement Officers Safety Act of 2004
+I have received a copy of the Law Enforcement Officers Safety Act
+(P.I. 108-277); the Bureau of Prisons February 27, 2006,
+• memorandum titled "Guidance Regarding the Law Enforcement
+Officers Safety Act (LEOSA);" the Department of Justice's January
+31, 2005, memorandum titled "Guidance on the Application of the .
+Law Enforcement Officers Safety Act of 2004 to Current and
+Retired Department of Justice Law Enforcement Officets, " title 18
+V.S.C. $ 3050; 28 C.F.R. S5 511.10-511.16, and the Department of
+Justice. Policy Statement on the Use of Deadly Force.
+Tova Nock
+Staff Member Printed Name
+Bare Membr signature
+4.25.18
+Date Signed
+'Place this form on the left side
+Personnel Folder
+of
+the employee's Official
+EFTA00122328
\ No newline at end of file
diff --git a/vision-joined/ds9-parsed-01/c04893c646ee507ddf1283a8d025aa6cacff1e9f020f8f307d38c79a6388a604.json b/vision-joined/ds9-parsed-01/c04893c646ee507ddf1283a8d025aa6cacff1e9f020f8f307d38c79a6388a604.json
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new file mode 100644
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@@ -0,0 +1,363 @@
+NYMEC 530.03 *
+PAGE 001
+BUREAU OF PRISONS COUNT SHEET
+NEW YORK MCC
+OTRG EQ****
+OCTG EQ
+**
+08-10-2019
+01:20:48
+V
+COUNT
+AREA
+CENSUS
+B-A
+C-A
+E-N
+E-S
+G-N
+G-S
+H-A
+I-N
+K-N
+K-S
+R-A
+Z-A
+2-B
+26
+10
+83
+79
+78
+88
+4
+86
+89
+137
+1
+72
+5
+TOTAL
+758
+COUNT
+VERIFY
+V
+TU
+T
+2
+2
+2
+VERIFY
+COUNT
+COUNT COUNT AREA
+ARIANINE
+26
+B-A
+10
+C-A
+81
+E-N
+79
+B-S
+78
+G-N
+88 G-S
+4
+H-A
+86
+I-N
+89
+K-N
+135
+K-S
+1
+R-A
+72
+Z-A
+5
+Z-B
+754
+-4--
+OFFICIAL PREPARING COUNT:
+OFFICIAL TAKING COUNT:
+COUNT CLEARED TIME:
+Hit
+EFTA00119492
+
+METROPOLITAN CORRECTIONAL CENTER
+NEW YORK, NY
+OFFICIAL OUT COUNT
+DATE:
+08/10/2019
+FROM:
+i Count)
+APPROVED:
+(Operations Lieutenant)
+REG #
+NAME
+UNIT
+1. 85369-054 Woolasten KS
+248816-066 SANTANA
+3. 86900-054 WALKER 5N
+4. 86409-054 BuLLock 5A
+5.
+6.
+7.
+8.
+9.
+10.
+11.
+12.
+COUNT TIME:
+LOCATION:
+0300Am
+Hoop
+REG #
+NAME
+UNIT
+13.
+14.
+B-A
+I-N
+C-A
+K-N
+E-N
+K-S
+2 OUT-COUNT BY UNIT
+E-S
+G-N
+7 R-A
+Z-A
+G-S
+Z-B
+H-A .
+Total Out-Counted:
+This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count
+repare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as at
+Out-Count. No other form will be accepted in lieu of the Out-Count Form.
+EFTA00119493
+
+NYMEC 530*05 *
+INMATE ROSTER
+PAGE 001 OF 001
+CATEGORY: OCT
+ASSIGNMENT: HOSP
+OPER CATG
+ASSIGNMENT
+OPER CATG ASSIGNMENT
+NUM ASSIGNMENT REG NO
+0001 HOSP
+NAME
+86409-054 BULLOCK
+0002
+48816-066 SANTANA
+0003
+86900-054 WALKER
+0004
+85369-054 WOOLASTON
+*
+08-10-2019
+01:21:34
+GROUP CODE:
+FACILITY: NYM
+OPER CATG ASSIGNMENT
+OCT DATE
+OTR
+08-10-2019 E05-535L
+18-10-2019 K09-0281
+18-10-2019 E06-546:
+08-10-2019 K11-053L
+WRK
+SUICIDE OR
+UNASSG
+SUICIDE OR
+SUICIDE OR
+UNASSO
+FS WAREHOU
+SUICIDE OR
+GO000
+TRANSACTION SUCCESSFULLY COMPLETED
+EFTA00119494
+
+Unit: BA
+Count:
+26
+Print Name:
+Metropolitan Correctional Center
+Official Count Slip
+Date: 8. 10-19
+Time: 3:00nm
+Signature:
+Print Name:
+Signature:
+Unit:
+Count:
+Print Name:
+Signature:
+Print Name:
+Signature
+Metropolitan Correctional Center
+Official Count Slip
+CA
+10
+Date.
+8/10/19.
+Time:
+3em
+EFTA00119495
+
+Unit: EN
+Count:
+Print Name
+Signature:
+Print Name
+Signature
+Metropolitan Correctional Center
+Official Count Slip
+_ Date 08-10-2019
+81
+Time: 3:00 A.M
+Unit: ES
+Count:
+Print Nam
+Signature:
+Print Nam
+Signature_
+Metropolitan Correctional Center
+Official Count Slip
+_Date S110119
+79•
+Time: 3°°%AM
+EFTA00119496
+
+Unit:
+Count:
+Print Name:
+Signature:
+Print Name:
+Signature:
+Metropolitan Correctional Center
+Official Count Slip
+GN
+78
+Time: 3:00 Am
+Unit:
+Count:
+Print Name:
+Signature:
+Print Name:
+Signature:
+Metropolitan Correctional Center
+Official Count Slip
+G.5
+Date: 08/10/19
+88
+Time:
+0300
+EFTA00119497
+
+Unit:
+Count:
+Print Name: 9
+Signature:
+Print Name:
+Signature
+Metropolitan Correctional Center
+Official Count Slip
+KN
+_ Dare 8/10/191
+89
+Time: 30GiAm
+Unit:
+Count:
+Print Name:
+Signature:
+Print Name.
+Signature _
+Metropolitan Correctional Center
+Official Count Slip
+KS
+135
+Date
+8/10/2017
+Time: 03,00Am
+-
+EFTA00119498
+
+Metropolitan Correctional Center
+Official Count Slip
+Date: 8-10-19
+Time: 3:00Am
+Unit:
+HOSP
+Count:
+Print Name:
+Signature:
+Print Name:
+Signature:
+Unit:
+HA
+Count:
+4
+Print Name:
+Signature:
+Print Name: _
+Signature:
+Metropolitan Correctional Center
+Official Count Slip
+Date: 8-10-19
+Time: 3:00am
+EFTA00119499
+
+Metropolitan Correctional Center
+New York, New York
+Official Count Slip
+Unit:
+RA:
+Date: 8/10/19
+Count:
+1
+"Time:
+3:00
+1. Print Name:
+1. Signature:
+2. Print Name:
+2.
+Signature:
+Metropolitan Correctional Center
+IN Orchat Count Ste
+8/10/19
+86
+Bam
+Times,
+Unit:
+Count:
+Print Name:
+Signature:
+Print Name:
+Signature:
+EFTA00119500
+
+Unit:
+Count:
+Print Name:
+Signature:
+Print Name:
+Signature:
+metropoman correctional Center
+Official Count Slip
+ZA
+Date:
+Time: 3Am
+e sael
+Metropolitan Correctional Center
+Official Count Slip
+Unit:
+2-B
+Date: S-10-2019
+1 Coune: 5
+Print Name:
+Signature:
+Print Name:
+Signature:
+EFTA00119501
\ No newline at end of file
diff --git a/vision-joined/ds9-parsed-01/c05d966ac1e0981cb19c48f7b4892f1af803af931eb12e755bd7678f77a3570c.json b/vision-joined/ds9-parsed-01/c05d966ac1e0981cb19c48f7b4892f1af803af931eb12e755bd7678f77a3570c.json
new file mode 100644
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diff --git a/vision-joined/ds9-parsed-01/c05d966ac1e0981cb19c48f7b4892f1af803af931eb12e755bd7678f77a3570c.md b/vision-joined/ds9-parsed-01/c05d966ac1e0981cb19c48f7b4892f1af803af931eb12e755bd7678f77a3570c.md
new file mode 100644
index 0000000000000000000000000000000000000000..7b62a475d59b5e55fa1148788d93c36eb3ebe102
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+++ b/vision-joined/ds9-parsed-01/c05d966ac1e0981cb19c48f7b4892f1af803af931eb12e755bd7678f77a3570c.md
@@ -0,0 +1,362 @@
+NYMEC 530.03 *
+PAGE 001
+BUREAU OF PRISONS COUNT SHEET
+NEW YORK MCC
+OTRG EQ****
+OCTG EQ
+**
+08-10-2019
+01:20:48
+V
+COUNT
+AREA
+CENSUS
+B-A
+C-A
+E-N
+E-S
+G-N
+G-S
+H-A
+I-N
+K-N
+K-S
+R-A
+Z-A
+2-B
+26
+10
+83
+79
+78
+88
+4
+86
+89
+137
+1
+72
+5
+TOTAL
+758
+COUNT
+VERIFY
+V
+TU
+T
+2
+2
+2
+VERIFY
+COUNT
+COUNT COUNT AREA
+ARIANINE
+26
+B-A
+10
+C-A
+81
+E-N
+79
+B-S
+78
+G-N
+88 G-S
+4
+H-A
+86
+I-N
+89
+K-N
+135
+K-S
+1
+R-A
+72
+Z-A
+5
+Z-B
+754
+-4--
+OFFICIAL PREPARING COUNT:
+OFFICIAL TAKING COUNT:
+COUNT CLEARED TIME:
+3%4
+EFTA00119904
+
+METROPOLITAN CORRECTIONAL CENTER
+NEW YORK, NY
+OFFICIAL OUT COUNT
+DATE:
+08/10/2019
+FROM:
+(Staff Member Preparing Out Count)
+APPROVED:
+Operations Lieutenant)
+REG #
+NAME
+UNIT
+1. 85369-054 Woolesten KS
+248816-066 SANTANA
+3. 86900-054 WALKER 5N
+4. 86409-054 BuLLock 5A
+5.
+6.
+7.
+8.
+9.
+10.
+11.
+12.
+COUNT TIME:
+LOCATION:
+0300Am
+Hoop
+REG #
+NAME
+UNIT
+13.
+14.
+B-A
+I-N
+C-A
+K-N
+E-N
+K-S
+2 OUT-COUNT BY UNIT
+E-S
+G-N
+7 R-A
+Z-A
+G-S
+Z-B
+H-A .
+Total Out-Counted:
+This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIOR to the affected count
+repare this form in ink. Group the inmates according to their respective housing units. This form is to be used only as at
+Out-Count. No other form will be accepted in lieu of the Out-Count Form.
+EFTA00119905
+
+NYMEC 530*05 *
+INMATE ROSTER
+PAGE 001 OF 001
+CATEGORY: OCT
+ASSIGNMENT: HOSP
+OPER CATG
+ASSIGNMENT
+COPER CATG ASSIGNMENT
+NUM ASSIGNMENT REG NO
+0001 HOSP
+NAME
+86409-054 BULLOCK
+0002
+48816-066 SANTANA
+0003
+86900-054 WALKER
+0004
+85369-054 WOOLASTON
+*
+08-10-2019
+01:21:34
+GROUP CODE:
+FACILITY: NYM
+OPER CATG ASSIGNMENT
+OCT DATE
+OTR
+08-10-2019 E05-535L
+18-10-2019 K09-0281
+18-10-2019 E06-5461
+08-10-2019 K11-053L
+WRK
+SUICIDE OR
+UNASSG
+SUICIDE OR
+SUICIDE OR
+UNASSO
+FS WAREHOU
+SUICIDE OR
+GO000
+TRANSACTION SUCCESSFULLY COMPLETED
+EFTA00119906
+
+Metropolitan Correctional Center
+Official Count Slip
+Unit: BA
+Date: 8. 10-19
+count: 26
+Time: 3:00nm
+Print Name:
+Signature:
+Print Name:
+Signature:
+Unit:
+Count:
+Print Name:
+Signature:
+Print Name:
+Signature
+Metropolitan Correctional Center
+Official Count Slip
+CA
+10
+Date.
+8/10/19
+- Time: 34m
+EFTA00119907
+
+Unit: EN
+Count:
+Print Namo:
+Signature:
+Print Name:
+Signature
+Metropolitan Correctional Center
+Official Count Slip
+_Date 08-10-2019
+81
+Time: 3:00 A.M
+Unit: _
+ES
+Count:
+Print Name
+Signature:
+Print Name
+Signature
+Metropolitan Correctional Center
+Official Count Slip
+_Date 8/10/19
+79
+June: 3°/Aм
+EFTA00119908
+
+Unit:
+Count:
+Print Name:
+Signature:
+Print Name:
+Signature:
+Metropolitan Correctional Center
+Official Count Slip
+GN
+78
+Time: 3:00 Am
+Unit:
+Count:
+Print Name:
+Signature:
+Print Name:
+Signature:
+Metropolitan Correctional Center
+Official Count Slip
+G.5
+88
+Date: 08/46/19
+Time:
+BROd
+EFTA00119909
+
+Unit:
+Count:
+Print Name: S
+Signature:
+Print Name: -
+Signature
+Metropolitan Correctional Center
+Official Count Slip
+KN
+89
+- Date 8/10/19
+Time: 3CGiAm
+Unit:
+Count:
+Print Name:
+Signature:
+Print Names.
+Signature,
+Metropolitan Correctional Center
+Official Count Slip
+KS
+_ Date
+8/10/2017
+135
+Time: 03,00A.
+-
+EFTA00119910
+
+Metropolitan Correctional Center
+Official Count Slip
+Date: 8-10-19
+Time: 3:00Am
+Unit:
+HOSP
+Count:
+Print Name:
+Signature:
+Print Name:
+Signature:
+Unit:
+Count:
+HA
+4
+Print Name:
+Signature:
+Print Name: -
+Signature:
+Metropolitan Correctional Center
+Official Count Slip
+Date: 8-10-19
+Time: 3:00am
+EFTA00119911
+
+Metropolitan Correctional Center
+New York, New York
+Official Count Slip
+Unit:
+RA:
+Date: 8/10/19
+Count:
+1
+"Time:
+3:00
+1. Print Name:
+1. Signature:
+2. Print Name:
+2.
+Signature:
+Unit:
+Metropolitan Correctional Center
+IN Orchat Count Ste
+8110/19
+86
+Ban
+Count:
+Print Name:
+Signature:
+Print Name:
+Signature:
+EFTA00119912
+
+Unit:
+Count:
+Print Name:
+Signature:
+Print Name:
+Signature:
+metropoman correctional Center
+Official Count Slip
+ZA
+Date:
+Time: 3Am
+saelo
+Metropolitan Correctional Center
+Official Count Slip
+Unit:
+2-B
+Date: S-10-2019
+¡ Count: 5
+Print Name:
+Signature:
+Print Name:
+Signature:
+Nel e
+EFTA00119913
\ No newline at end of file
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+From: "
+To: "l
+(USANYS)" <
+(USANYS)" -
+Ce: "
+(USANYS) [Contractor]" <
+Subject: Epstein Coconspirators
+Date: Wed, 06 May 2020 19:43:57 +0000
+(USANYS)"
+ABC News got a tip that something is imminent. We obviously declined, but just for press office edification, is
+anything happening?
+Sent from my iPhone
+EFTA00104596
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@@ -0,0 +1,520 @@
+1al01/21
+UNITED STATES GOVERNMENT
+MEMORANDOM
+METROPOLITAN CORRECTIONAL CENTER
+New York, NY 10007
+August 10, 2019
+REPLY TO
+ATTN OF:
+M/W Operations Lieutenant
+SUBJECT: Daily Activity Report
+TO:
+• Warden
+Associate Warden (0)
+Associate Warden (P)
+Executive Assistant
+Captain
+Lieutenants
+Departments Heads
+Daily Activity as communicated or documented by the Operations
+Lieutenant for August 09, 2019, was received and/or reviewed. The
+following information was
+noted.
+Morning Watch Shift:
+reported I/M I
+on HA-Unit w/inmate
+companion pending bed space (SHU). Treaty Transfer return Jones
+#06178-104 (Flight Can-x, due to, mechanical problems) .
+Correctional assignment Sanitation vacated, due to, a shortage of
+staff.
+Control Center Fire Panel remains inoperative.
+Day Watch Shift:
+reported I/M Garcia #79043-054 (Code $111) placement on
+the Special Housing Unit. Correctional assignments Phone Monitor,
+2 Sally
+Officer, 10 South #2,
+Rec
+: Officer |
+#1, Rec Officer #2
+vacated, due to, a shortage of staff.
+Evenina Watch Shift:
+reported I/M Fernandez 86824-054 placement on Dry
+Cell in
+RaD holding cell. Correctional assignments SHU #4 vacated,
+due to, a shortage of staff.
+CONFIDENTIAL
+SDNY_00010148
+EFTA00062211
+
+INMATES IN OUTSIDE HOSPITAL/SUICIDE WATCH/FURLOUGH/DRY CELL:
+I/M
+on Suicide Watch w/inmate companion
+I/M
+on Suicide Watch w/inmate companion
+I/M
+pending bed space (SHU)
+NEW ADMISSIONS TO MCC New York:
+Carreon #82858-198
+Lora #79951-054
+Matthews #91753-054
+Mutimura #76329-054
+RELEASED FROM MCC NEW YORK:
+Booth 50501-054
+Bussey #55210-053
+Cuyler #89936-053
+Jones #06178-104
+Ramirez #81219-054
+Reyes #85993-054
+ADMISSIONS TO THE SPECIAL HOUSING UNIT:
+Garcia #79043-054 (Code #111)
+TOTAL NUMBER OF CELLS IN SHU THAT ARE PRESENTLY TRIPLE BUNKED:
+None
+MISSING FIRE AND SECURITY REPORT:
+Unit 2/3/7/9/11 Mgmt.
+Safety
+Central Tool Room
+Education/Recreation
+Facilities Offices
+MISSING EQUIPMENT INVENTORY FORM:
+Attorney Conference
+3 Sallyport
+Roof Recreation
+CONFIDENTIAL
+EFTA00062212
+
+THE FOLLOWING LEAVE WAS UTILIZED:
+FURLOUGH: 00
+ANNUAL LEAVE: 08
+SICK LEAVE: 09
+OFFICIAL TIME: 01
+SUSPENSION: 01
+FFLA: 00
+EMLA: 00
+COP: 04
+ANOL: 11
+ADVANCE LEAVE: 00
+IWOP: 00
+ADMIN LEAVE: 00
+COMP TIME: 00
+TRAINING: 04
+GLYNCO: 00
+INOP (M) : 02
+TOA: 00
+EPO: 00
+TRAVEL: 00
+THE FOLLOWING OVERTIMES WERE HIRED:
+E-1 OVERTIME:
+Number of staff = 24
+E-1 COMPTIME:
+Number of staff = 00
+60-2 OVERTIME (USM MEDICAL) :
+CONFIDENTIAL
+Hours = 188.00
+Hours = 00.00
+SDNY_00010150
+EFTA00062213
+
+Number of Staff = 00
+B-2 OVERTIME:
+Number of Staff = 00
+09D OVERTIME (SPECIAL) :
+Number of Staff = 00
+XXX OVERTIME (AIRLIFT) :
+Number of Staff = 00
+87S OVERTIME (TREATY TRANS) :
+Number of Staff = 03
+Hours = 00.00
+Hours = 00.00
+Hours = 00.00
+Hours = 00.00
+Hours = 29.00
+INSTITUTION TOTALS AT THE BEGINNING OF THE MORNING WATCH SHIFT:
+08-09-2019 / 12:00 AM
+UNIT B-A:
+26
+UNIT E-N: 87
+UNIT E-S:
+81
+UNIT G-N: 79
+UNIT G-S: 80
+UNIT H-A: 03
+UNIT I-N: 85
+UNIT K-N: 88
+UNIT K-S: 138
+UNIT Z-A: 77
+UNIT Z-B: 05
+TOTAL:
+759
+CONFIDENTIAL
+SDNY_00010151
+
+UNITED STATES DEPARTMENT OF JUSTICE
+METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
+DAILY LIEUTENANT'S LOG
+Shift-Day-Date: M/W Friday,
+August 09, 2019
+Beginning Count: 759
+Daily Sensitive Information:
+M/W
+I/M
+on Suicide Watch w/inmate companion
+I/M
+on Suicide Watch w/inmate companion
+I/M
+pending bed space (SHU)
+TIME
+CHRONOLOGICAL EVENTS
+12:00
+AM
+Lieutenant
+assumes duties as the Morning Watch
+Operations Lieutenant.
+The fire alarm and sprinkler system are
+operational w/exception of Control Center Fire Panel.
+PREA
+announcement conducted via the Institution Public Address System
+and/or Radio, Restraint Equipment Cage inventory conducted. All
+equipment accounted for. Metal Detector checks conducted. All
+operative w/the
+exception of
+Rear
+Gate/Facilities/RED.
+Roof
+Check completed. All secure.
+Temporary Chit Inventory: #1:2;
+#2:5; #3:5; #4:6: #5:5; #6:0; Hosp: 0
+12:00
+Institution Count in progress
+AM
+12:00
+NYPD Phone Check $1142
+AM
+12:09
+Body Alarm testing in progress
+AM
+12:16
+Body alarm testing completed
+AM
+12:30
+Watch Calls cont.
+AM
+12:35
+Good Verbal count announced
+AM
+12:55
+Clear Institution count announced
+AM
+3:00
+AM
+Institution Count in progress
+3:03
+AM
++1 TRTY TRANS (return): Jones #06178-104 to IN
+3:27
+AM
+Good Verbal count announced
+3:29
+AM
+Clear Institution count announced
+5:00 AM
+Institution Count in progress
+5:40 AM Good Verbal count announced
+5:43 AM Clear Institution count announced
+8:00 AM
+Relieved of duties by It.
+as D/W Operations Lieutenant
+STG International Terrorist phone calls monitored:
+WITSEC inquiry(s) was/were received during my tour of duty:
+The following Inmate (s) were placed in Administrative Detention:
+Name
+Reg: Number
+Reason
+Unit
+SHU: 77/5
+BC
+759
+SHU
+77/5
+759
+7775
+760
+760
+760
+760
+77/5
+77/5
+77/5
+Ops It.
+Time
+Ending Count: 760 SHU: 77; 10-south: 05; SHU OBS: 00;
+Local Hosp: 00; H/A OBS: 02; B/A OBS: 00; Dry Cell: 00;
+H/A (PBS) ; 01; H/A (PCLAS): 00
+AD Order
+CONFIDENTIAL
+SDNY_00010152
+EFTA00062215
+
+UNITED
+STATES DEPARTMENT OF JUSTICE
+METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
+DAILY LIEUTENANT'S LOG
+SHIFT-DAY-DATE:
+D/W - Friday,
+August 09, 2019
+Beginning Count: 760
+D/W
+Daily
+Sensitive Information:
+I/M
+on Suicide Watch w/inmate companion
+I/M
+on Psych obs. w/inmate companion.
+I/M
+on DRY Cell w/staff watch in R&D.
+8:00
+AM
+Lieutenant
+assumes duties as the Day Watch Operations
+Lieutenant. The fire alarm and pump system is inoperable at this
+time. Fire Watch is in Progress. Unable to conduct PREA
+announcement over the Institution Public Address System, due to,
+system malfunction. Restraint Equipment Cage inventory conducted.
+All equipment accounted for. Metal Detector checks conducted.
+All operative w/the exception of Rear Gate.
+Roof Check
+completed. All secure. Temporary Chit Inventory: #1:0; #2:5;
+#3:5; #4:6; #5:6; #6:5; Hosp: 0
+Daily Hand Stamp : DJBE/LEFT HAND
+8:00
+8:10
+8:30
+AM
+AM
+AM
+NYPD Phone Check #2286
+Body Alarm Test Initiated.
+AM Census Conducted
+50501-054 BOOTH E01-506L to PRE REMOVE, 55210-053 BUSSEY E02-513U
+to PRE REMOVE. 85993-054 REYES 206-220UAD to PRE REMOVE -3
+8:50
+AM
+Body Alarm Testing Complete.
+8:58 AM
+86627-054 JONES K12-069U to L HOSP USM -1
+10:00 AM
+81219-054 RAMIREZ E08-562L FT REL
+-1
+10:24 AM
+-1 I/M Cuyler #89936-053 from ES to GCT REL
+11:24 AM
+79951-054 LORA
+new commit +1
+12:30
+PM
+- PM Census Conducted
+12:35 PM
+86627-054 JONES return from L-Hosp +1
+1:10
+PM
+I/M
+off suicide watch
+2:41
+PM
+-1 I/M Jones #06178-104 from IN to TREATY TRANS
+3:15 PM
+I/M
+placed on dry cell from ZA
+3:45
+PM
+Institutional lockdown
+for count.
+4:00
+PM
+Relieved of duties by
+E/W Operations Lieutenant.
+Inmates
+Visitation: ZA
+Adults
+Children
+17
+ION SCANNING TESTED HITS: 0
+STG/High Alert phone calls monitored:
+20
+9
+CONFIDENTIAL
+SHU: 77/5
+760
+77/5
+757
+76/5
+756
+76/5
+755
+776/5
+754
+755 76/5
+756| 76/5
+755
+75/5
+Total
+46
+SDNY_00010153
+EFTA00062216
+
+UNITED STATES DEPARTMENT OF JUSTICE
+METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
+DAILY LIEUTENANT'S LOG
+WITSEC inquiry (s) was/were received during my tour of duty: O
+The following Inmate(s) were placed in Administrative Detention: 0
+[Reg Numbex
+A/D Order
+Ops
+Act It
+Ending Count: 755 ; SHU:75 ; 10-South: 05; SHU OBS: 00.
+ocal Hosp: 00; H/A OBS: 02; B/A OBS: 00; Dry Cell: 0:
+CONFIDENTIAL
+SDNY_00010154
+EFTA00062217
+
+UNITED STATES DEPARTMENT OF JUSTICE
+METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
+DAILY LIEUTENANT'S LOG
+SHIFT-DAY-DATE: E/W - Friday, August 9, 2019
+Beginning Count: 755
+Daily Sensitive Information.
+I/M
+on Psych Obs w/inmate companion.
+E/W
+I/M
+on PSYCH OBS. W/inmate companion.
+I/M
+on Suicide watch w/inmate companion.
+I/M
+on suicide watch w/ inmate companion.
+I/M
+on Dry cell w/staff watch in R&D
+TIME
+CHRONOLOGICAL EVENTS
+Lieutenant
+assumes duties as the Evening Watch
+Operations Lieutenant. Unable to conduct PREA announcement over
+Institution Public Address System, due to, system malfunction.
+Restraint Equipment Cage inventory conducted. All equipment
+accounted for. Metal Detector checks conducted. All operative
+w/the exception of Rear Gate.
+Roof Check completed. All secure.
+Temporary Chit Inventory: #1:4; #2:4; #3:5; #4:5; #5:5; #6:3;
+4:00
+PM
+4:01
+PM
+4:08
+PM
+4:37
+PM
+5:00 PM
+5:03
+PM
+6:00
+PM
+6:34
+PM
+6:39
+PM
+6:47
+PM
+7:45
+PM
+8:12
+PM
+8:21
+PM
+Institution count in progress.
+NYPD Phone Check #2624
+Body alarm testing in progress.
+Body alarm testing completed
+Good verbal count
+Clear institutional count.
+Watch call in progress
+I/M Hemmingway #14728-053 from ZA to ES
++1 I/M Matthews 91753-054 from BAIBOND to RA
+I/M Reid #85609-054 from ZA to GS
+Trash Iun in progress
++1 I/M Carreon #82858-198 from BAILBOND to RA
+I/M
+and I/M
+from ZA to
+Suicide watch
+8:28
+PM
+8:36 PM
+8: 42 PM
+10:00
+PM
+I/M
+#79043-054 from KN to ZA Introduction of tobacco
++1 I/M Mutimura #76329-054 from REL to RA
+Trash run complete
+Institutional count in progress.
+10:41
+PM
+10:43
+PM
+12:00
+AM
+Good verbal count announced.
+Clear institutional count announced.
+Relieved of duties by
+as the M/W Lieutenant.
+INMATES
+VISITING: KN
+ADULTS
+CHILDREN
+STG/High Alert phone calls monitored:
+WITSEC inquiry (s) was/were received during my
+tour of duty: 0
+The following Inmate(s) were placed in Administrative Detention: 0
+CONFIDENTIAL
+SHU: 75/
+5
+B/C
+755
+SHU
+75/5
+755
+755
+756
+757
+758
+75/5
+74/5
+73/5
+71/5
+72/5
+758 72/5
+TOTAL
+71
+SDNY_00010155
+EFTA00062218
+
+NAME
+ops. It.
+Act. It.
+UNITED STATES DEPARTMENT OF JUSTICE
+METROPOLITAN CORRECTIONAL CENTER, NEW YORK, NY
+DAILY LIEUTENANT'S LOG
+REG NUMBER
+79043-054
+REASON
+331
+UNIT
+KN
+TIME
+8:28 PM
+A/D ORDER
+YES
+Ending Count: 758 ; SHU: 72; 10-South: 05; SHU OBS: 00;
+Local Hosp: 00; H/A OBS: 04; B/A OBS: 00; Dry Cell: 01;
+CONFIDENTIAL
+SDNY_00010156
+EFTA00062219
\ No newline at end of file
diff --git a/vision-joined/ds9-parsed-01/c092896bc3aedfe051b10f75218d8da746e2c9b7a3d39846187ed0bc130a10af.json b/vision-joined/ds9-parsed-01/c092896bc3aedfe051b10f75218d8da746e2c9b7a3d39846187ed0bc130a10af.json
new file mode 100644
index 0000000000000000000000000000000000000000..55f1a9e27ffab9eaa5a99e44b6586480b15f6d44
--- /dev/null
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diff --git a/vision-joined/ds9-parsed-01/c092896bc3aedfe051b10f75218d8da746e2c9b7a3d39846187ed0bc130a10af.md b/vision-joined/ds9-parsed-01/c092896bc3aedfe051b10f75218d8da746e2c9b7a3d39846187ed0bc130a10af.md
new file mode 100644
index 0000000000000000000000000000000000000000..9deac60aac35d86774cb0af623c456f441a2c5b5
--- /dev/null
+++ b/vision-joined/ds9-parsed-01/c092896bc3aedfe051b10f75218d8da746e2c9b7a3d39846187ed0bc130a10af.md
@@ -0,0 +1,266 @@
+Child Exploitation/Porn Update Report III (080, 087)
+(events within last 45 days highlighted)
+C: \Program Files (x86)\SAP BusinessObjects\SAP BusinessObjects Enterprise XI
+4.0 Data\procSched\ USAHUBSWVCRY161.AdaptiveJobServer\~tmp3a84b1763136de3-rpt
+Total Cases
+3
+Data as of 02/25/2021 11:02 am
+3
+15
+3
+Total
+EFTA00096870
+
+EFTA00096871
+
+EFTA00096872
+
+EFTA00096873
+
+EFTA00096874
+
+EFTA00096875
+
+EFTA00096876
+
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+
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+
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+
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+
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+
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+
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+
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+
+This report shows child exploitation cases that have been coded o8o or 087 where you are noted as Lead AUSA. If you have a child
+exploitation/porn case that does not appear on this list, or if a case is incorrectly assigned to you, you must bring it to the
+attention of the clerks. Please close each case or fruitless investigation as soon as possible to avoid distraction from the cases that
+| (St. Andrew's) ori
+(White Plains).
+2018R01618
+11/30/2018
+US v. Jeffrey Epstein
+Public Corruption
+Vie_Wit Flag:
+Y
+11/30/2018
+08/22/2019
+BDCS
+NOTE
+02/27/2020 CSST
+Epstein, Jeffrey
+19-CR-00490
+1 18:00371
+1 18:00371
+1 18:00371
+2 18:01591
+2 18:01591
+≥ 18:01591
+Investigation re: alleged trafficking and enticement of minors
+Docket Text: MANDATE of USCA (Certified Copy) as to Jeffrey Epstein re: [34] Notice of Appeal.
+USCA Case Number 19-2221. The parties in the above-referenced case have filed a stipulation
+withdrawing this appeal pursuant to FRAP 42. The stipulation is hereby "So Ordered"..
+Clerk USCA for the Second Circuit. Issued As Mandate: 08/21/2019.
+Nolle, suicide 8/29/19.
+Arrested: 2019/07/06 00:00:00
+Indictment 07/02/2019
+Dismissed without Prejudice 08/29/2019 By Government from District Court w/ DOJ Authoriz
+Dismissed without Prejudice 08/29/2019 By Government from District Court w/ DOJ Authoriz:
+(scS) or case Satus (cs30) notesin LiN as e/dicat (write clearly), Clerks will input into Brief Description of Case
+2020R00719
+07/07/2020
+US v Ghislaine Maxwell
+Public Corruption
+Vie_Wit Flag:
+Maxwell, Ghislaine
+20-CR-00330
+Indictment 06/29/2020
+1 18:00371
+2 18:02422
+3 18:00371
+4 18:02423a
+5 18:01623
+6 18:01623
+For the defendant(s) above, please indicate/update (write clearly). Clerks will input into Brief Description of Case
+(BDCS) or Case Status (CSST) notes in LIONS as indicated).
+EFTA00096931
+
+Investigative steps taken (including status of forensics) (CSST):
+Investigative steps remaining (CSST):
+Anticipated arrest date (if not already arrested) (CSST):
+Bail/custody status (CSST):
+Anticipated charges (or anticipated additional charges) (CSST):
+Any evidence of contact with children not already indicated above (BDCS):
+Any other notable information not already indicated above (BDCS):
+EFTA00096932
+
+EFTA00096933
+
+EFTA00096934
+
+EFTA00096935
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+
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+
+EFTA00096968
\ No newline at end of file
diff --git a/vision-joined/ds9-parsed-01/c099ba65c0cc82fdfada3fe3ed0e25ea3401e25d8864b26ef97f7e3ae435a0de.json b/vision-joined/ds9-parsed-01/c099ba65c0cc82fdfada3fe3ed0e25ea3401e25d8864b26ef97f7e3ae435a0de.json
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diff --git a/vision-joined/ds9-parsed-01/c099ba65c0cc82fdfada3fe3ed0e25ea3401e25d8864b26ef97f7e3ae435a0de.md b/vision-joined/ds9-parsed-01/c099ba65c0cc82fdfada3fe3ed0e25ea3401e25d8864b26ef97f7e3ae435a0de.md
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+Suicide Watch
+Chronological
+Log
+Inmate Companions Log
+Name of inmate on watch:
+Epstein
+Register #:
+16318-054
+Institution:
+MCC
+Date Watch Began / Ended
+Suicide Smock/Slippers
+Suicide Blanket
+Suicide Mattress
+July 232019-1421,29
+To be completed by Chief Psychologist at conclusion of watch:
+Booklet .
+1
+of L
+Paper Cup/Soap
+SW Paper Spoon
+Finger Toothbrush
+Tampons or Foam Belt/Napkin
+SWCL - INMATE
+EFTA00122765
+
+STAPLE LOCAL PROCEDURES HERE
+Check one of the following:
+D
+This is the initial log book for this suicide watch.
+Enter date and time watch began:
+& This is a continuation log book for this watch.
+•Enter date and time this watch book was initiated:
+7-23-09 7:00am
+Instructions to Observer:
+Document your observations every
+minutes.
+Legibly print and sign your name at the beginning of your shift.
+EFTA00122766
+
+PP37
+NYMBJ 531.01#
+PAGE 001 OF 001 *
+INMATE HISTORY
+MED DY ST
+REG NO..: |76318-054 NAME...: EPSTEIN, JEFFREY EDWARD
+CATEGORY: MDS
+FUNCTION: DIS
+FORMAT: Г
+FCL ASSIGNMENT DESCRIPTION
+NYM NOT MED CL NOT MEDICALLY CLEARED
+NYM
+SUIC WATCH SUICIDE WATCH
+Page 1 of 1
+07-24-2019
+12:32:30
+START DATE/TIME STOP DATE/TIME
+07-06-2019 2124 CURRENT .
+07-23-2019 0140 07-24-2019 0845
+G0005
+TRANSACTION
+SUCCESSFULLY COMPLETED - CONTINUE PROCESSING IF DESIRED
+•
+https://bop.tcp.doj.gov:9049/SENTRY/J1PP160.do
+7/24/2019
+EFTA00122767
+
+Suicide Watch Observation Log
+a pstein
+on watch:
+Reg 4: 76318-03% Date: 7/23/19
+Time
+Observations: Briefly note your observations, Initial all entries.
+Initials.
+7isban:
+chrmato Companion Eleb i..
+#7627505x assume reponsibly?
+formal Epitein 1776315-057
+IX1Sam
+Inmates Epstein scotting.
+1:30am
+Immate Epstein si sitting
+I the edge of ho bed, persuee.
+7:4dam
+Inmate. Epstein askedspot. vi
+30
+toilet poper
+1:45am Inmate Eputine soldrovi
+on the edy of tin bed, pensiva
+1:Stam
+inmate: @patein laid domes n
+8:00am
+'lamese laying on bussybithin
+8:1 2am
+30
+8:15am
+asked for toilet paper etheles
+Inmate Epstein is sittingat
+the edge of his bed, -
+8:23am
+Inmate Epstein asked to
+speak rudbhisaltaney-
+8:30am
+Inmate Epstein is setbay on
+the edgy of for bed —
+21 N
+404:1
+N53AD
+Or 01
+Note to all observers: Legibly print and sign your name at the beginning of your shift.
+EFTA00122768
+
+Suicide Watch Observation Log
+Name of inmate
+on watch:
+Epstein
+Reg#: 76318-054 Date: 07.23-19
+Time
+Observations: Briefly note your observations. Initial all entries.
+Initials
+8:3lam
+Inmate Epstain is paujarame o
+8:45am
+Inmate Epsten i sittr
+at thredgof hirle he mention
+to me that heishungry —
+* 8: 54am
+inmato Epstens says he feele fir
+it smolles te chant water - DE
+9:00am
+Inmat Epsteen = paringonound,
+9:10AM
+looking out thi cumdo
+catsar satin s
+115am
+9:30am
+DI.
+is still specking with
+Inmate Epstein
+Inmate Epstein js sittingon the edge.
+ofhis.-bed.
+Inmate testan askedter the time ..
+9.45am
+10:00
+matt tipstan is sitting on theedeskhisked
+508:
+Inmate Epsteinesked to spare ith
+hisattorney Inmate Epstein is usive;
+thie restroom
+1l1Sam
+Inmate Epstein is spaking within
+10-bam
+Inmate Epstein mentioned tome"..
+that Do
+Tsaid: hisattorney
+isnt here yet.:
+10:20am
+nmate Epstanis drinking water -
+Note to all observers: Legibly print and sign your name at the beginning of your shift.
+2
+EFTA00122769
+
+Suicide Watch Observation Log
+a marmal Eps tein
+on watch:
+Reg#: 76318-054 Date: 72319
+Time
+Observations: Briefly note your observations. Initial all entries.
+Initials
+10300Mh
+Inmate Epstein is pacing around -
+103lam
+Inmate Epstein shungry,—
+1045am
+Inmate Epstein is pacing aroun
+Heis nor with bishead a gainst the
+wall
+oh It 2z 7-23-15
+* ip: Sam Inmate Epstein is eating Bren-
+-OE:
+11:0am
+Inmate Epstein is sitting on the
+edge of his bed.
+1l-)Dam
+Inmate Epstein washed his neck-
+Inmate Epstein is pacing around —
+Inmate Epstein is paring as ound-
+11:45am
+Inmate Epstein is sitting of the
+edge of his bad
+1200pm
+Inmate Epstein is sittinget the
+eage of bis bed, withhis legs cased.-
+n-08pk
+12:10 p
+12:15 pm
+1230pm
+Inmate Estein laid down —
+Dety Rounds C. Melender
+cau
+Inmate Epstein is drinking water"
+Inmate Epsten issiHingontle
+edgeother bad/ mailing for shoo
+1240pm
+Inmate Epstein is being taken
+to sochis attaine,
+17:45pm
+Inmate Epsten is stir Mattrira
+f:00pm
+Inmate Ekin is still w/attaree
+cE
+OE
+OE
+Note to all observers: Legibly print and sign your name at the beginning of your shift.
+3
+EFTA00122770
+
+on watch:
+Time
+1:15pm
+130pm
+79:15
+$0:30.-
+700:45
+20.00
+20:5
+20:30
+2045222586
+21:00
+21:15.
+2:30
+* 21:45
+12:00
+22:15
+22:30
+22:45
+Suicide Watch Observation Log
+Reg#: 76318-057 Date: 7-23.19
+Observations: Briefly note your observations. Initial all entries.
+Inmate Epstein is w/attaneystill
+Initials
+00
+Inmate Eatinis mossary.
+START SHET SIC TIDIE SSUMES I
+I/M. EPSTEIN IN CeLl # IN 7-23-19
+I'm EpsteN is tacky acut tute -
+I/M EPSTEN iS FALKWO ABUT FINANCE
+IlM EPsteiN is taLiNG ABut SCieNt -
+I EPSteiN Is talKING ABUT MATh
+JIM EPSTEIN IS tALIEING ABUT: fINANCE
+JIm EPStEIN IS tALKING ABNUT THE PrISON
+ENVIRUNMENT
+Ilm EPSteN IS DiSCUSSNG PriSON -
+ENVIRONMENT
+Eim Aslenhis taLK INU ABOut iAis
+erasiata Medal, handmans sig
+IIM EPStEIN IS EATING PELNUt BUttir + i
+DriNKiNG WAteR
+EIm GPStEiN DECDEs To LM doreN -
+I IM EPSteIN APPEARS tO BE SCOOPING -
+IIm EPSteIN PAPEARS tU BE SLOODIVE-
+uT
+шт,.
+XO END S4. IT IIC T.SOAG #>8355-053 /CA
+Note to all observers: Legibly print and sign your name at the beginning of your shift.
+4
+EFTA00122771
+
+on watch: "
+Time
+1045M
+Suicide Watch Observation Log
+::.Reg#:76318-054
+Date: 7/23/19
+Observations: Briefly note your observations. Initial all entries.
+Initials
+1; Brandon DeCAIUA#16520 055 aSSUMeS.. 140
+responsibility tor the suicide watchut...
+Fatein #76318-054 inCell#4 on 7/23/19-1
+11°°PM
+1130pm
+1142pM
+1155pм
+1209M
+1230Am
+125AM
+1246AM
+10°AM
+1'5AM
+122AM
+13°Aм
+1PAM
+2°AM
+25AM
+23°AM
+242AM
+02450м
+JUNe
+*
+mate SEIN sisteeping
+Staffrovinds"
+е 20
+note FASTEN seeing .
+lunate FROTEINisseeDing
+Li 17
+320
+SEND
+Epstein in cellt4 at this time onese
+UB
+Note to all observers: Legibly print and sign your name at the beginning of your shift.
+5
+EFTA00122772
+
+Suicide Watch Observation Log
+Name of Inmate
+on watch:
+Time
+0300am
+Epstein
+Reg #: 76318-054 Date: 7/24/19
+Observations: Briefly note your observations. Initial all entries.
+Initials
+Ilm Epstein appears to be sleeping
+at this
+time om
+0315 am Elm Epstein appeors to be sleepingammi
+UB
+0330 am
+In Epstein affears in be sleeph mm
+0345 am
+Yin Epstein has shifted to his right side,
+appears to be sleeping at this time, an
+0400 am
+0415 aM
+0430 am
+I\m Elstem allears to be sleeping-
+Am Elsten alearo to be sleeping
+UB
+UB
+UB
+I/m Eestein woke of 0425 in to ost the
+time, new he appears to be disting back to
+Sleel-
+CB
+0445 ам
+In Eestein woke to use the battitoon(urine)
+and drank water before asking the time, not ne
+is sting on the bed.
+0500 am
+Im Epstein is laving on his back in the bed
+he appears to have tallen aslees
+0515 am
+In Bestern appears to be Sleeling-
+CB
+0530aM Im Festein appears to be steeping, the cle
+en shift just wecked en him
+0545am
+0545 am I/m Elstein affears to be sleeping —
+CB.
+CB
+0600 am
+Ilm Epsein appears te be steeling.
+* 6l5an
+In Epstein has waken up te use the
+bathroom (urine) and has diank some water,
+he asked whot tame was breakfast and
+%
+nedial.,
+UB
+Note to all observers: Legibly print and sign your name at the beginning of your shift.
+6
+EFTA00122773
+
+Suicide Watch Observation Log
+on watch:
+Name orumat Epstein
+Reg#: 76318-054 Date: 7/24/19
+Time
+Observations: Briefly note your observations. Initial all entries.
+Initials
+0630am
+Ilm Epstein appears to be sleeping at this
+time, breakfast has arrived but has not been
+aiven to him as ot yet -
+0645 am
+07000m
+7:00AM
+Im Epstein appears to be sleefingm
+CB
+UB
+Ill Billack end of tour—
+Sfart the wrw shipt Reshare Marting 27758050
+Du Pda Ops LT der
+7:15 AM
+IM Epsteun recibe his breakgast and —
+ust bad to Shep and ark the
+- Ter his Madication
+7:30 AM
+7:35 AM
+IM Epstein appears toke Sleepino
+ImEnstein gotup ant he es have
+sreatfast
+2:400M IM Epstein ast vor a Shower and -
+I Call ete 44
+Yu Epstern Steel eatens his brotrost
+is setting down on his
+8:00 AM
+8:15AM
+8:20 Am
+interviened IM. Estein tor psychol
+8:30 Am Dr.
+8:45 Am Dr.
+fron suicide watch to Bychdogical
+OBservAtion-
+Note to all observers: Legibly print and sign your name at the beginning of your shift.
+7
+EFTA00122774
\ No newline at end of file
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+}
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+n-Flemer
+Gaksa | Aşcimp
+Sunsa Arçine
+Gapa
+Againie
+J. Crawford
+K. AKOPstA
+(.Tyer
+M. Gruders
+y. Jardolu,
+Schmet
+Schmdh
+M. Gonzaler
+Donaldson
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+Asumuld
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+Tlavesen
+Onz
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+8 /7
+817
+Arik
+Ce
+2
+InMate
+Kcg#
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+Tine
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+Chenny
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+Bt00 | D
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+#lAhandh
+26005S
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+86239-0843:00
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+16307-054 57g
+5-78
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+8/8,
+818
+NAME
+Angela
+SGILLEPIA
+• taffmaun
+aall
+3 faj:
+Manaf.
+Dawarzai?
+V. EUEVAOS
+V. Grelra
+S.Richmas
+Billzi
+DAu
+N. LIMAN!
+WIEDER
+GASAMASSIMA
+G.Tali
+Colon-
+Meade +
+304. ht
+Banaa,
+D. Holler
+1. wew ster
+•Alin sulme Sur
+SIgNATUre
+INMaTe
+TiMe TiME
+iN
+OUT
+Arcecyo
+JONAS
+Jove
+Fi stin
+87565654
+Manaf
+SCtL
+KIGiNE
+Vesa
+Reg#t
+91126653
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+5701694
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+76sl8-or
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+J: Epskin
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+Mendra - Suken 51916-054 10: 154 41:80
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+1579 K0S7
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+11.50
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++9562-054-10-25/1i30
+Armenth
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+1451240
+EFTA00106307
+
+NAME
+= 81
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+N
+E 851
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+INMate
+Reg#
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+Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+THE NEW YORK TIMES COMPANY,
+Plaintiff,
+X
+:
+:
+:
+COMPLAINT
+- against -
+FEDERAL BUREAU OF PRISONS,
+:
+Defendant.
+:
+Plaintiff THE NEW YORK TIMES COMPANY ("The Times"), by its undersigned
+attorneys, alleges as follows:
+This is an action under the Freedom of Information Act, 5 U.S.C. § 552
+("FOIA"), to obtain an order for the production of agency records from Defendant Federal
+Bureau of Prisons ("BOP") in response to requests properly made by Plaintiff.
+The records concern Jeffrey Epstein, the wealthy financier charged with sex
+trafficking of minors who died at the Metropolitan Correctional Center ("MCC") on August 10,
+2019. Epstein's relationships with prominent figures in politics, business, and Hollywood
+entertainment contribute to the public interest in Epstein and the circumstances surrounding his
+death.
+PARTIES
+Plaintiff The New York Times Company publishes The New York Times
+newspaper and www.nytimes.com. The New York Times Company is headquartered in this
+judicial district at 620 Eighth Avenue, New York, New York, 10018.
+1
+EFTA00074140
+
+Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 2 of 7
+4.
+Defendant BOP is an agency of the federal government that has possession and
+control of the records that Plaintiff seeks.
+JURISDICTION AND VENUE
+This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §
+1331 and 5 U.S.C. § 552(a)(4)(B).
+6.
+Venue is premised on Plaintiff's place of business and is proper in this district
+under 5 U.S.C. § 552(a)(4)(B).
+FOIA requires that agencies respond to requests within 20 business days. See 5
+U.S.C. § 552(a)(6)(A).
+8.
+Defendant BOP has failed to meet the statutory deadlines set by FOIA. See 5
+U.S.C. § 552(a)(6)(A)-(B). Plaintiff is therefore deemed to have exhausted all administrative
+remedies, pursuant to 5 U.S.C. § 552(a)(6)(C).
+FACTS
+The August 12, 2019 Requests
+On August 12, 2019, The Times submitted two FOIA requests to BOP.
+10. The first request sought information about the procedures followed in housing
+Epstein at the MCC, as well as background information about Epstein as an inmate.
+11.
+One subset of that request centered on records relating to the designation of
+Epstein as a suicide risk: "Documents showing when MCC staff held meetings regarding Jeffrey
+Epstein, and who attended"; "All records generated from the meeting at MCC during which it
+was decided that Jeffrey Epstein would be taken off suicide watch"; "The Post-Watch report
+compiled in order to take Jeffrey Epstein off suicide watch"; and "All medical reports related to
+Jeffrey Epstein at MCC."
+2
+EFTA00074141
+
+Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 3 of 7
+12. A second subset focused on the operations of the MCC during the time of
+Epstein's attempted suicide and, later, his death: "The signed log in the Special Housing Unit at
+MCC that shows when prison staff did rounds on July 22 and 23, and Aug. 9 and 10"; "The
+overtime sign-up sheets for the Special Housing Unit (9 South) at MCC for Aug. 9 and 10, and
+on July 22 and 23"; and "Documents showing which staff were augmented at MCC and what
+positions they worked in on Aug. 9 and 10, and on July 22 and 23."
+13.
+A third subset focused on Epstein's experience as an inmate: the intake screening
+form, inmate profile, and chronological disciplinary records for Epstein at MCC; all quarter
+entries showing which cells Epstein was housed in at MCC; incident reports related to Epstein at
+MCC; the Central Inmate Monitoring (CIM) Clearance and Separatee data sheet for Epstein at
+MCC; security designation records and chronological disciplinary records for Epstein at MCC;
+and the signed visitor log for Epstein at MCC.
+14.
+The second request filed on August 12, 2019 sought video camera footage and
+BOP documents pertaining to Epstein's suicide and to his first suicide attempt, as well as BOP
+documents (including email correspondence and meeting minutes) pertaining to the decision to
+remove Epstein from suicide watch, BOP special investigation reports mentioning Epstein, and
+BOP correspondence with the U.S. Attorney's Office regarding Epstein.
+15.
+On September 23, 2019, BOP responded, providing tracking number 2019-05665
+(apparently consolidating the two August 2019 requests) and stating that all responsive records
+"are categorically exempt from disclosure" under Exemptions 5, 6, 7(A), 7(C), 7(E), and 7(F),
+and that, as a result, the agency was "not required to conduct a search for the requested records."
+16.
+On October 3, 2019, The Times sent via FedEx an administrative appeal of the
+categorical denial of the two August 2019 requests. That appeal noted that agencies have a
+3
+EFTA00074142
+
+Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 4 of 7
+statutory duty to "make reasonable efforts to search" for responsive records, 5 U.S.C. §
+552(a)(3)(C), that BOP ought to have made a good faith effort to search for responsive records to
+determine whether there are any non-exempt responsive records, and that it was implausible,
+given the breadth of the requests, that all responsive records were properly withheld. On October
+9, 2019, The Times received an e-mail indicating that the appeal was received and was assigned
+appeal tracking number DOJ-AP-2020-000123.
+17.
+On November 27, 2019, The Times spoke by phone to the assigned FOIA officer,
+who indicated that the agency was processing the appeal and hoped to provide a response within
+2-3 weeks.
+18. To date, The Times has not received any response to its administrative appeal, nor
+any documents responsive to either of the August 2019 requests.
+The December 12, 2019 Request
+19. On December 12, 2019, The Times submitted a FOIA request by e-mail to BOP.
+The request sought: "(1) The full log of Mr. Epstein's phone calls to and from the MCC; "(2)
+All email correspondence to and from Mr. Epstein while he was at the MCC (including any
+correspondence through the Corrlinks system or any other email system he had access to)"; "(3)
+The full log of people who visited Mr. Epstein while he was at the MCC and when they visited";
+"(4) The full list of people that Mr. Epstein had requested to be on his approved visitor list"; "(5)
+The full list of people that Mr. Epstein had requested to be on his approved email
+correspondence list"; and "(6) The full list of people that Mr. Epstein had requested to be on his
+approved call list." The December 12, 2019 request sought expedited processing and indicated
+that records generated by BOP employees based in New York, Texas, and Washington, D.C.
+should be searched.
+4
+EFTA00074143
+
+Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 5 of 7
+20.
+On December 16, 2019, BOP acknowledged receipt of The Times's December 12,
+2019 request, and indicated that it was assigned FOIA/PA request number 2020-01336 and was
+forwarded to processing office CO. The letter also stated that BOP had denied The Times's
+request for expedited processing and assigned the request to the complex processing queue.
+21.
+BOP has failed to respond to the December 12, 2019 request within the statutory
+time frame required under FOIA.
+22.
+The January 2, 2020 Request
+On January 2, 2020, The Times submitted a FOIA request by e-mail to BOP.'
+That request sought: "The full recordings of the last three phone conversations that Mr. Epstein
+had." The Times's January 2, 2020 request again sought expedited processing and indicated that
+records generated by BOP employees based in New York, Texas, and Washington, D.C. should
+be searched.
+23.
+On January 9, 2020, The Times received a letter from BOP, explaining that the
+agency determined the December 12, 2019 and the January 2, 2020 requests "should be
+aggregated into one request, which is request number 2020-01336." That letter also denied The
+Times's request for expedited processing of the January 2, 2020 request.
+24.
+BOP has failed to respond to The Times's January 2, 2020 request within the
+statutory time frame required under FOIA.
+25.
+COUNT ONE
+Plaintiff repeats, realleges, and reincorporates the allegations in the foregoing
+paragraphs as though fully set forth herein.
+' The Times also submitted a second FOIA request to BOP on January 2, 2020, which was
+assigned tracking number 2020-01578. That request does not seek records specific to Epstein and
+is not at issue in this suit.
+5
+EFTA00074144
+
+Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 6 of 7
+26.
+Defendant BOP is subject to FOIA and must therefore release in response to a
+FOIA request any disclosable records in its possession at the time of the request and provide a
+lawful reason for withholding any materials as to which it is claiming an exemption.
+27.
+BOP has failed to meet the statutory deadlines set by FOIA. See 5 U.S.C. §
+552(a)(б)(A)-(B). Accordingly, Plaintiff is deemed to have exhausted its administrative remedies
+under FOIA.
+28.
+BOP has no lawful basis for declining to release the records requested by Plaintiff
+under FOIA.
+29. Accordingly, Plaintiff is entitled to an order compelling BOP to produce records
+responsive to its FOIA request.
+REQUEST FOR RELIEF
+WHEREFORE, Plaintiff respectfully requests that this Court:
+30. Declare that the documents sought by its FOIA request, as described in the
+foregoing paragraphs, are public under 5 U.S.C. § 552 and must be disclosed;
+31.
+Order BOP to provide the requested documents to Plaintiff within 20 business
+days of the Court's order;
+32. Award Plaintiff the costs of this proceeding, including reasonable attorney's fees,
+as expressly permitted by FOIA; and
+33.
+Grant Plaintiff such other and further relief as this Court deems just and proper.
+Dated: New York, New York
+January 30, 2020
+Is/ David E. McCraw
+David E. McCraw
+Alexandra Perloff-Giles
+6
+EFTA00074145
+
+Case 1:20-cv-00833-PAE Document 1 Filed 01/30/20 Page 7 of 7
+Legal Department
+The New York Times Company
+620 8th Avenue
+New York, NY 10018
+Phone:
+Fax:
+E-mail:
+Counsel for Plaintiff
+7
+EFTA00074146
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+From:
+To:
+NY) (FBI)"
+|(USANYS)"
+Cc: "
+NYPD)"
+Subject: Intakes
+Date: Tue, 12 Jan 2021 17:42:25 +0000
+Attachments: (U)_Date_ Submitted_ 07_12_2020_07_06_53_PM_ET_Transaction_Number_07A23145-
+DOC9-43BC-.pdf;
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+email_address
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+_Called_the_FBI.pdf;
+_LNU,_Cell_Telephone
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@@ -0,0 +1,516 @@
+.:
+LAST WILL AND TESTAMENT
+OF
+JEFFREY E. EPSTEIN
+1, JEFFREY E. EPSTEIN, of Little St. James Island, St. Thomas, United States Virgin Islands,
+do make, publish and declare this to be my Will hereby revoking all prior Wills and Codicils
+made by me.
+I direct my Executor to pay from my estate all expenses of
+my last illness, my funeral and burial expenses, the administration expenses of my estate and all
+of my debts duly proven and allowed against my estate.
+B.
+I direct my Executor to pay from my estate, as
+compensation to each Executor for serving as Executor hereunder, the sum of Two Hundred
+Fifty Thousand Dollars ($250,000) to each Executor upon the completion of probate of my
+estate. No Executor shall receive any other compensation for serving as Executor hereunder;
+provided, however, that my Executor shall be reimbursed from my estate for all reasonable
+costs, expenses, charges, and liabilities incurred or paid in respect thereto, including fees and
+expenses of counsel or any other agents hired by my Executor, and my Executor shall not be
+liable therefor individually.
+C.
+I direct my Executor to pay from my estate the
+federal and state transfer taxes described in Paragraph B(1) of Article SEVENTH.
+direct my Executor to pay from my estate al
+xpenses of storing, insuring, packing, shipping and delivering my tangible personal property i
+accordance with Article SECOND.
+SECOND:
+I give all of my property, real and personal, wherever situated,
+after the payments and distributions provided in Article FIRST, to the then acting Trustees of
+The Jeffrey E. Epstein 2012 Trust (the "Trust") created under that certain Trust Agreement (the
+"Trust Agreement) dated October 24, 2012, as the same may be amended from time to time, to
+be held in accordance with the provisions comprising the Trust Agreement at the time of my
+death.
+THIRD:
+A.
+I appoint DARREN K. INDYKE, JOSEPH PAGANO and
+2657367.1
+GJ_000138
+EFTA00074246
+
+JAMES E. STALEY to be the Executors of this Will. If any one or more of my Executors fails
+to qualify or ceases to act, I appoint ANDREW FARKAS as successor Executor. I authorize the
+last acting Executor to designate his successor as Executor.
+B.
+If my estate must be administered in whole or in
+part in any jurisdiction other than the state or territory of my domicile at the date of my death
+and if my Executor is unable or unwilling to serve in such jurisdiction, then I appoint the
+successor Executor of my estate designated in Paragraph A of Article THIRD provided that he is
+able and willing to serve in such jurisdiction. If no Executor or successor Executor is able and
+willing to serve in such jurisdiction, my Executor shall designate a successor Executor to serve
+in such jurisdiction. Such designation shall be made by written instrument delivered to such
+successor Executor.
+C.
+No bond or other security shall be required of any
+Executor in any jurisdiction.
+Any Executor may resign in the manner provided
+for by the governing statutes of the state or territory having jurisdiction of the administration of
+my estate or, in the absence of such statutory guidance, by filing a written notice of resignation
+with the Court having jurisdiction of the administration of my estate. Any Executor who resigns
+shall not be entitled to any compensation hereunder for any services rendered as Executor prior
+to his resignation.
+B.
+My Executor shall not be accountable or
+responsible to any person interested in my estate for the manner in which my Executor in good
+faith exercises or declines to exercise any discretionary authority or power of my Executor. My
+Executor shall not be liable for any loss or depreciation in value occasioned by reason of any
+negligence, error or mistake of judgment in entering into any transaction, in making any sale or
+investment, in continuing to hold any property or by reason of any action or omission, whether
+by my Executor or any other fiduciary, unless my Executor has acted in bad faith. In the absence
+of proof by affirmative evidence to the contrary, each Executor shall be deemed to have acted
+within the scope of my Executor's authority, to have exercised reasonable care, diligence and
+prudence and to have acted impartially as to all interested persons. An Executor shall not be
+liable for the acts or defaults of another Executor.
+FOURTH: The following provisions shall apply to my estate and to my
+Executor, except as is otherwise specifically provided in this Will:
+A.
+My Executor has the entire care and custody of all
+this power it would not be authorized or appropriate for fiduciaries under any statutory or other
+rule of law. My Executor shall exercise my Executor's best judgment and discretion for what
+my Executor believes to be in the best interests of the beneficiaries hereunder. If more than two
+Executors are empowered to participate in the decision to exercise or not exercise any fiduciary
+power granted by this Will or by law, a majority of such Executors shall be empowered to make
+such decision.
+2
+GJ_000139
+EFTA00074247
+
+Except as otherwise provided herein, my Executor
+shall have the power:
+(1) to enter upon and take possession of the
+assets of my estate and collect the income and profits from such assets, and to invest and
+reinvest such assets in real, personal or mixed assets (including the common trust funds of a
+corporate fiduciary) or in undivided interests therein without being limited by any present or
+future investment laws;
+(2) to retain all or any part of the assets of my
+estate (without regard to the proportion that any one asset or class of assets may bear to the
+whole) in the form in which such assets were received or acquired by my Executor;
+(3)
+to sell or dispose of, exchange, transfer,
+invest or loan all or any part of the assets of my estate which may, at any time, be held by my
+Executor for such sums or upon such terms as to payment, security or otherwise as my Executor
+determines, either by public or private transactions;
+to buy and sell options, warrants, puts, calls
+or other rights to purchase or sell (collectively "options") relating to any security or securities,
+regardless of whether such security or securities are then held by my Executor, and whether
+such options are purchased or sold on a national securities exchange, and to exercise with
+respect to such options all powers which an individual owner thereof could exercise, including,
+without limitation, the right to allow the same to expire;
+(5) with respect to oil, natural gas, minerals,
+and all other natural resources and rights to and interests therein (together with all equipment
+pertaining thereto) including, without limiting the generality of the foregoing, oil and gas
+royalties, leases, or other oil and gas interests of any character, whether owned in fee, as lessee,
+lessor, licensee, concessionaire or otherwise, or alone or jointly with others as partner, joint
+tenant, or joint venture in any other noncorporate manner, (a) to make oil, gas and mineral
+leases or subleases; (b) to pay delay rentals, lease bonuses, royalties, overriding royalties,
+taxes, assessments, and all other charges; (c) to sell, lease, exchange, mortgage, pledge or
+otherwise hypothecate any or all of such rights and interests; (d) to surrender or abandon, with
+or without consideration, any or all of such rights and interests; (e) to make farm-out, pooling,
+and unitization agreements; (f) to make reservations or impose conditions on the transfer of
+any such rights or interests; (g) to employ the most advantageous business form in which
+properly to exploit such rights and interests, whether as corporations, partnerships, limited
+partnerships, mining partnerships, joint ventures, co-tenancies, or otherwise exploit any and all
+such rights and interests; (h) to produce, process, sell or exchange all products recovered
+through the exploitation of such rights and interests, and to enter into contracts and agreements
+for or in respect of the installation or operation of absorption, reprocessing or other processing
+plants; (i) to carry any or all such interests in the name or names of a nominee or nominees; (i)
+to delegate, to the extent permitted by law, any or all of the powers set forth herein to the
+operator of such property; and (k) to employ personnel, rent office space, buy or lease office
+equipment, contract and pay for geological surveys and studies, procure appraisals, and
+generally to conduct and engage in any and all activities incident to the foregoing powers, with
+3
+GJ_000140
+EFTA00074248
+
+full power to borrow and pledge in order to finance such activities; together with the power to
+allocate between principal and income any net proceeds received as consideration, whether as
+royalties or otherwise, for the permanent severance from lands of oil, natural gas, minerals, and
+all other natural resources;
+(6) to hold all or any part of the assets of my
+estate in cash or in bank accounts without the necessity of investing the same;
+(7)
+to improve, repair, partition, plat or
+subdivide all or any part of the assets of my estate;
+to litigate, defend, compromise, settle
+bandon or submit to arbitration on such terms and conditions as my Executor determines an
+claims in favor of or against my estate or the assets of my estate;
+(9) to loan or borrow money in such amounts
+and upon such terms and conditions as my Executor determines, assume such obligations or give
+such guarantees as my Executor determines, for the purpose of the acquisition, improvement,
+protection, retention or preservation of the assets of my estate, or for the welfare of the
+beneficiaries of my estate;
+(10) to carry on for as long and in such manner
+as my Executor determines any business enterprise in which I owned any interest at my death,
+either individually, or as a partner, joint venture, stockholder or trust beneficiary; to sell such
+business enterprise as an ongoing business; to consolidate, merge, encumber, dissolve, liquidate
+or undertake any other extraordinary corporate transaction relating to such business enterprise;
+(11) to vote in person or by proxy any and all
+stock or securities and to become a party to any voting trusts, reorganization, consolidation or
+other capital or debt readjustment of any corporation, association, partnership, limited liability
+partnership, limited liability company or individual with respect to stocks, securities or debts
+held by my estate;
+(12) except as provided in paragraphs B(19) and
+B(20) of this Article FOURTH, to enter into any good faith transactions with my Executor
+individually or with any corporation, partnership or other entity in which my Executor has an
+ownership interest;
+(13) to lease, mortgage, pledge, grant a security
+interest in or otherwise encumber all or any part of the assets of my estate for any term of years
+whether or not beyond the duration of my estate (including, without limitation, any such action
+for the benefit of any of the beneficiaries of my estate);
+(14) to abandon any property of my estate, real
+or personal, which my Executor may deem worthless or not of sufficient value to warrant
+keeping or protecting; to abstain from the payment of taxes, water rents or assessments and to
+forego making repairs, maintaining or keeping up any such property; and to permit such
+property to be lost by tax sale or other proceedings or to convey any such property for a nominal
+4
+GJ_000141
+EFTA00074249
+
+consideration or without consideration so as to prevent the imposition of any liability by reason
+of the continued ownership thereof;
+(15) to elect the mode of distribution of the
+proceeds payable to my estate from any profit-sharing plan, pension plan, employee benefit
+plan, individual retirement plan, insurance contract or annuity contract pursuant to the terms of
+such plan;
+(16) to allocate, in my Executors discretion, any
+adjustment to basis provided to my estate under the provisions of Federal and State law with
+respect to property comprising my estate, without any obligation to make a compensatory
+adjustment among the beneficiaries hereunder on account of such allocation;
+(17) to conduct any audit, assessment or
+investigation with respect to any asset of my estate regarding compliance with any law or
+regulation having as its object protection of public health, natural resources or the environment
+("Environmental Laws"); to pay from the assets of my estate to remedy any failure to comply
+with any Environmental Law (even to the exhaustion of all of the assets of my estate); and, as
+may be required in my Executor's judgment by any Environmental Law, to notify any
+governmental authority of any past, present or future non-compliance with any Environmental
+Law; and
+(18) to sell to the Trustee under the Trust
+Agreement any stocks, bonds, securities, real or personal property or other assets or borrow
+from the Trustee under the Trust Agreement even though the same person or persons occupy the
+office of the Executor of my estate and the Trustee under the Trust Agreement.
+(19) No executor shall directly or indirectly buy
+or sell any property for the estate from or to himself, or from or to his relative, employer,
+employee, partner, or other business associate.
+(20) No executor shall lend estate funds to
+himself, or to his relative, employer, employee, partner, or other business associate.
+C.
+Except as otherwise provided herein, my Executor
+shall have the power:
+to employ agents,
+attorneys-at-law,
+consultants, investment advisers (to whom my Executor has discretion to delegate my
+Executor's investment authority and responsibility), other executors and other fiduciaries in the
+administration of my Executor's duties; to delegate to such persons, or to one or more of my
+Executors, the custody, control or management of any part of my estate as my Executor
+determines and to pay for such services from the assets of my estate, without obtaining judicial
+authorization or approval;
+(2) to delegate, in whole or in part, to any
+person or persons the authority and power to (a) sign checks, drafts or orders for the payment or
+withdrawal of funds, securities and other assets from any bank, brokerage, custody or other
+5
+GJ_000142
+EFTA00074250
+
+account in which funds, securities or other assets of my estate shall be deposited, (b) endorse for
+sale, transfer or delivery, or sell, transfer or deliver, or purchase or otherwise acquire, any and
+all property, stocks, stock warrants, stock rights, options, bonds or other securities whatsoever,
+(c) gain access to any safe deposit box or boxes in which my assets or assets of my estate may
+be located or which may be in the name of my Executor and remove part or all of the contents of
+any such safe deposit box or boxes and release and surrender the same, and (d) take any other
+action that my Executor may have the power to take with respect to my estate and the property
+thereof; no person or corporation acting in reliance on any such delegation shall be charged with
+notice of any revocation or change of such delegation unless such person or corporation receives
+actual notice thereof;
+(3) to pay any property distributable to a
+beneficiary under a legal disability, without liability to my Executor, by paying such property
+(a) to such beneficiary, (b) for the use of such beneficiary, (C) to a legal representative of such
+beneficiary appointed by a court or if none, to a relative for the use of such beneficiary, or (d) to
+a custodian for such beneficiary designated by my Executor;
+(4)
+to distribute to any of the beneficiaries of
+my estate in kind or in cash, or partly in kind and partly in cash, and to allocate different kinds
+or disproportionate shares of assets or undivided interests in assets among all of such
+beneficiaries;
+(5) to have evidence of ownership of any
+security maintained in the records of a Federal Reserve Bank under the Federal Reserve Book
+Entry System; to deposit funds in any bank or trust company; to carry in the name of my
+Executor or the nominee or nominees of my Executor and with or without designation of
+fiduciary capacity, or to hold in bearer form, securities or other property requiring or permitting
+of registration; and to cause any securities to be held by a depository corporation of which an
+Executor is a member or by an agent under a safekeeping contract; provided, however, that the
+books and records of my Executor shall at all times show that such investments are part of my
+estate;
+(6) to renounce and disclaim, in whole or in
+part, and in accordance with applicable law, any assets, interests, rights or powers (including
+ny power of appointment) which are payable to (or exercisable by) me or my estate, which are
+ncludible in my estate or Gross Estate or over which I have any right, title, interest or power
+and
+on the life of an Executor which is included in my netie, such axe infor she pol py or ipate ly
+the decision to exercise or not exercise any fiduciary power in connection with any incidents of
+6
+GJ_000143
+EFTA00074251
+
+ownership for such policy or annuity, including, without limitation, any decision to continue,
+assign, terminate or convert such policy or annuity or to name the beneficiary of such policy or
+annuity.
+E.
+An Executor hereunder may by a written notice
+delivered to the other Executor (or Executors) decline to participate in the decision to exercise or
+not exercise any fiduciary power granted by this Will or by law.
+F.
+If an Executor is not empowered (because of a
+conflict of interest, declination to act or otherwise) to participate in the decision to exercise or
+not exercise any fiduciary power granted by this Will or by law, then the remaining Executor or
+Executors shall be empowered to make such decision. If no Executor is empowered to
+participate in such decision, then the successor Executor of my estate designated in Paragraph A
+of Article THIRD and able and willing to act shall be empowered to make such decision. If no
+Executor or successor Executor is empowered to participate in such decision, my Executor may
+designate a successor Executor to serve as Executor of my estate who shall be empowered to
+make such decision but shall have no other power or authority of my Executor. Such designation
+shall be by written notice delivered to such successor Executor.
+(1) Except as otherwise specifically provided
+herein and except as provided in Paragraph G(2) of this Article, my Executor shall allocate
+receipts and disbursements in accordance with sound trust accounting principles and shall have
+discretion to allocate receipts and disbursements when the treatment is uncertain under
+applicable laws or generally accepted accounting principles in the judgment of my Executor.
+(2)
+Except as otherwise specifically provided in
+this Will, my Executor shall not treat any part of the principal amount of the proceeds of sale of
+any asset of my estate as income distributable to or for the benefit of any beneficiary entitled to
+distributions of income; provided, however, that my Executor shall treat a portion of any
+proceeds of sale of any financial instrument originally issued or acquired at a discount equal to
+the amount which (a) has previously been characterized as ordinary income for income tax
+purposes or (b) will be characterized as ordinary income for income tax purposes in the year of
+such sale, as income for trust accounting purposes.
+FIFTH:
+Where a party to any proceeding with respect to my estate has the
+same interest as a person under a disability, it shall not be necessary to serve legal process on the
+person under a disability.
+SIXTH:
+If any beneficiary under the Trust shall in any way directly or
+indirectly (a) contest or object to the probate of my Will or to the validity of any disposition or
+provision of my Will or of the Trust or (b) institute or prosecute, or be in any way directly or
+indirectly instrumental in the institution or prosecution of, any action, proceeding, contest,
+objection or claim for the purpose of setting aside or invalidating my Will or the Trust or any
+disposition therein or provision thereof, then I direct that (a) any and all provisions in the Trust
+for such beneficiary and his issue in any degree shall be null and void and (b) my estate, whether
+passing under my Will or the Trust or pursuant to the laws of intestacy, shall be disposed of as if
+such beneficiary and his issue in any degree had all failed to survive me.
+7
+GJ_000144
+EFTA00074252
+
+SEVENTH: A. As used herein:
+(1) The term "Executor" of a person's estate
+means all persons or entities who occupy the office of executor, administrator, personal
+representative, or ancillary administrator while such persons or entities occupy such office,
+whether one or more persons or entities occupy such office at the same time or times, and
+includes any successor or successors to that office. The term "Trustee" means all persons or
+entities who occupy the office of Trustee under the Trust Agreement while such persons or
+entities occupy such office, whether one or more persons or entities occupy the office of Trustee
+at the same time or times, and includes any successor Trustee or Trustees. A reference to a
+person's estate or probate estate means that person's estate which is subject to probate
+administration. A reference to a person's Will means such person's Last Will and Testament and
+any Codicil or Codicils thereto.
+(2) The term "IRC section" means a section of
+the Internal Revenue Code of 1986, as amended, or the corresponding provision of any
+successor Internal Revenue law, as in effect as of the date of my death.
+A reference to any tax also includes any
+interest or penalties thereon. A reference to a person's "Gross Estate" means such person's gross
+estate as finally determined for purposes of computing such person's federal estate tax.
+(4)
+Whenever the singular number is used, the
+same shall include the plural, and the masculine gender shall include the feminine and neuter
+genders.
+B.
+(1) The federal and state transfer taxes which
+my Executor shall be obligated to pay pursuant to Paragraph B of Article FIRST shall consist of
+all federal and state estate, inheritance, succession, and similar taxes (including any federal or
+state generation-skipping transfer tax) imposed upon my probate estate or by reason of my death
+in respect to all assets which pass under this Will or the Trust Agreement. Subject to Paragraph
+B(2) of this Article, all federal estate taxes with respect to assets not passing under this Will or
+the Trust Agreement (such assets are referred to as the "Apportionment Assets") and any
+applicable state estate taxes with respect to the Apportionment Assets shall be apportioned
+among all persons interested in the Apportionment Assets. My Executor shall make reasonable
+efforts to collect all federal estate taxes and state estate, inheritance, succession and similar taxes
+allocable to the Apportionment Assets from the recipients of the Apportionment Assets. Without
+changing the apportionment of taxes in this Paragraph B(1), my Executor has discretion, but is
+not required, to pay all or part of such taxes allocable to the Apportionment Assets. To the
+extent my Executor pays such taxes allocable to the Apportionment Assets, my Executor shall
+seek reimbursement for such taxes from the recipients of the Apportionment Assets. My
+Executor shall not be personally liable for any of such taxes if my Executor is unable, with
+reasonable efforts, to collect payment (or reimbursement) from any recipient of any
+Apportionment Assets for any or all of such taxes allocable to such assets.
+(2) My Executor has discretion to direct the
+Trustee of the Trust Agreement to pay all or any portion of the taxes which my Executor is
+8
+GJ_000145
+EFTA00074253
+
+directed or obligated to pay pursuant to Paragraph B of Article FIRST and this Paragraph B
+pursuant to a written direction delivered to the Trustee under the Trust Agreement. Any taxes
+which my Executor directs the Trustee under the Trust Agreement to pay shall be allocated and
+paid from the trusts under the Trust Agreement as provided under the Trust Agreement.
+Except as otherwise specifically provided in this
+Will, a bequest or devise to an individual who does not survive me shall lapse notwithstanding
+any law to the contrary.
+D.
+To the extent that the distribution to the Trustee
+under the Trust Agreement pursuant to Article SECOND shall not be effective, I give all the rest
+of my property, real and personal, wherever situated, after the payments and distributions
+Trust Agreement, be to held in trust under this Will in accordance with the provisions
+comprising the Trust Agreement at the time of my death, which provisions are incorporated in
+this Will by reference.
+IN WITNESS WHEREOF, I have duly executed this Will the 24" day of
+October, 2012.
+JEFFREY E EPSTEIN
+The foregoing written instrument was on the date thereof, signed, published and
+declared by the Testator therein named as the Testator's Will in the presence of us and of each
+of us, who, at the Testator's request, in the Testator's presence and in the presence of each
+other, have subscribed our names as witnesses thereto.
+fian anett
+residing at
+Portunishing tow wy 11050
+residing at
+New YoRK, NY 10021
+9
+GJ_000146
+EFTA00074254
+
+We,
+JEFFREY E. EPSTEIN, RichardBanet and,
+the Testator
+and the witnesses, respectively, whose names are signed to the foregoing instrument, having
+been sworn, declared to the undersigned officer that the Testator, in the presence of the
+witnesses, signed the instrument as his Will, that he signed, and that each of the witnesses, in the
+presence of the Testator and in the presence of each other, signed the Will as a witness.
+JEFFREY E. EPSTEIN,
+chand Saut
+STATE OF
+)ss:
+COUNTY OF )
+Subscribed and sworn to before me by JEFFREY E. EPSTEIN, the Testator, who is personally
+known to me or who has produced
+as identification, and by
+Richard Barnett
+as identifies on an is nersonally known to me or who has
+witness who is personally known to me or who has produced
+as identification, on
+October 24, 2012.
+Sworn to before me this 24"* day of
+October, 2012.
+Votary Publi
+Hi Thee
+Notar:
+Cusi
+Commis
+ER
+New York
+Count
+1. 7. 20.14
+10
+GJ_000147
+EFTA00074255
+
+FIRST CODICIL TO LAST WILL AND TESTAMENT
+OF
+JEFFREY E. EPSTEIN
+1, JEFFREY E. EPSTEIN, of Little St. James Island, United States Virgin Islands,
+having made my last will and testament dated October 24, 2012, declare this to be a
+FIRST:
+I hereby delete paragraph A of Article THIRD of my will and
+substitute in its place the following new paragraph A of Article THIRD:
+"A.
+I appoint DARREN K. INDYKE, JOSEPH PAGANO and JAMES E. STALEY
+to be the executors of this Will. If any one or more of my Executors fails to qualify or
+ceases to act, I appoint DAVID J. MITCHELL as successor Executor. I authorize the
+last acting Executor to designate his successor Executor."
+SECOND:
+testament.
+In all other respects 1 ratify and republish my said last will and
+IN WITNESS WHEREOF, I have dully executed this First Codicil to Last Will
+and Testament of Jeffrey E. Epstein on the 6th day of June, 2013.
+JEFFREY E EPSTEIN
+We, the undersigned, do hereby certify that the foregoing instrument was
+names thereto as witnesses to the execution thereof, which we hereby do in the
+bf each other on the day and year last above written
+residing at
+New YoCll, NY 10021
+residing at
+NEN CANAAN, CT O6840
+GJ_000148
+EFTA00074256
+
+AFFIDAVIT
+STATE OF NEW YORK
+COUNTY OF NEW YORK
+)
+) SS:
+)
+Each of the undersigned, being at least 18 years of age, being duly sworn,
+deposes and says:
+The foregoing instrument was subscribed in our presence and sight at
+the end thereof by JEFFREY E. EPSTEIN, hereinafter referred to as the Testator, on
+the 6th day of June, 2013.
+2.
+The Testator at the time of making such subscription declared and
+published the foregoing instrument so subscribed to be a First Codicil to his Last
+Will and Testament.
+Each of the undersigned witnesses thereupon signed as a witness at
+the end of the foregoing First Codicil to the Testator's Last Will and Testament at the
+request of the Testator and in his presence and in sight of each other.
+4.
+The Testator, declares and each of the undersigned witnesses
+confirms, that the Testator can read, write and converse in the English language; is
+free from restraint and undue influence; is suffering no defect of sight, hearing or
+speech and is suffering from no other physical or mental impairment; and is over 18
+The foregoing First Codicil to Last Will and Testament of Jeffrey E.
+Epstein was executed as a single, original instrument and was not executed in
+counterparts.
+6.
+Each of the undersigned witnesses was acquainted with the Testator
+at such time and each of the undersigned witnesses makes this affidavit at Testator's
+request.
+2
+GJ_000149
+EFTA00074257
+
+Each of the undersigned has, contemporaneously with the execution
+of this affidavit, examined the signatures at the end of the foregoing First Codicil to
+Last Will and Testament of Jeffrey E. Epstein, and such signatures are the signatures
+affixed by the Testator and by each of the undersigned witnesses.
+STEIN
+Witness.
+STATE OF NEW YORK
+)
+)ss:
+COUNTY OF NEW YORK
+)
+Subscribed and sworn to before me by JEFFREY E. EPSTEIN, the Testator, who is
+personally known to me or who has produced
+as identification, and by
+as identification, and
+a witness who is per wiles won to emon ly knows rome of
+who has produced
+Sworn to before me this 6" day of June,
+2013.
+Notary Publi
+Hottie
+HARRY I. BELLER
+Notary Public, State of New York
+No. 01BE4853924
+ualified in Rockland C
+ommission Expires Feb. 17,20L
+3
+GJ_000150
+EFTA00074258
\ No newline at end of file
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+From:
+To:
+(USANYS)" 4
+Cc: "
+Subject: FW: Letter regarding discovery attached.
+Date: Mon, 10 Aug 2020 22:35:14 +0000
+Attachments: letter_to_USA
+_ re _protective_order_(002)_(002)final.pdf
+Inline-Images: image001 jpg
+FYI - we'll circle up on this when
+is back tomorrow.
+From: Jeff Pagliuca 4
+Sent: Sunday, August 09, 2020 18:56
+To:
+Cc: Laura Menninger ‹
+o; Nicole Simmons <
+Subject: Letter regarding discovery attached
+Dear Counsel,
+Please see attached conferral letter.
+Jeff
+; Mark S. Cohen
+Jeffrey S. Pagliuca
+Haddon, Morgan and Foreman, P.C.
+www.hmflaw.com
+mation that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to
+the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing.
+distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have
+received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its
+attachments without reading or saving it in any manner. Thank you
+EFTA00094738
\ No newline at end of file
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+Exhibit X
+EFTA00065796
+
+The Honourable Alison | Nathan
+United States District Court
+Southern District of New York
+United States Courthouse
+40 Foley Square
+New York, NY10007
+Dear Your Honour,
+2al November 2020
+R:E: Miss Ghislaine Maxwell - Bail Applisation
+I am sending this character reference in the knowledge that it will be presented to the court at
+Ghislaine's bail hearing. The content of this letter is the truth and within my knowledge.
+Both
+I first met Ghislaine
+Ghislaine and her immediate family have been family friends for decades
+Following our first encounter we became close
+friends and remained in constant touch ever since. We would always speak on her birthday which
+falls on Christmas Day.
+Ghislaine and I would regularly socialize together and
+amongst many other adoring friends and family members. was
+immediately drawn to Ghislaine when I first met her and both her honesty and integrity shone
+throush from the moment we first met and I was therefore delighted to be asked
+adores Ghislaine and it deeply disturbs me that a
+country as great as the United States would even think that Ghislaine poses a danger to children or
+minors and further to this 1 would have absolutely no hesitation in allowing Ghislaine to look after
+at any time.
+Ghislaine is a prominent individual and I believe she will fight these charges to the end. She will not
+evade justice and is not in any way a flight risk. She should be granted bail immediately so that she
+can form a proper defence to these horrendous charges. She has faced monstrous allegations in the
+press that forced her to have to worry about her safety.
+I am not being paid or retained to provide this letter. I would however respectfully be prepared to
+offer any nancial surety that I can afford in order to meet any bail pledge that the court may set. I
+await the courts decision and remain on standby should 1 be asked to fulfil any such commitment.
+Yours faithfully
+LIO L
+EFTA00065797
\ No newline at end of file
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+From:
+To:
+Subject: [EXTERNAL EMAIL] - FBI Public Affairs News Briefing Monday, October 26, 2020
+Importance: Normal
+Priority: Normal
+Sensitivity: None
+Mobile version and searchable archives available at
+https:/
+https:
+TO: THE DIRECTOR AND SENIOR STAFF
+DATE: MONDAY, OCTOBER 26, 2020 6:30 AM EDT
+TODAY'S TABLE OF CONTENTS
+Leading the News
+• Police Departments Preparing For Potential Election Day Unrest.
+Protests
+• Trump Supporters And Opponents Clash In New York's Times Square.
+• Most Black Lives Matter Demonstrations Have Been Peaceful.
+• Seattle Office Of Police Accountability: Seattle Officers Utilized Excessive Force Against Protestors.
+• Illinois Officer Fired After Shooting And Killing Black Man.
+• WPost A1 Discusses Mother's Struggle To Get Help For Black, Mentally III Son Amid Pandemic, Racial
+Unrest.
+• Black Journalists Who Worked With Vogue Editor In Chief Wintour Feel She Created Environment That
+Sidelined Black Women.
+• DOJ: Boogaloo Bois Member Fired On Minneapolis Police Precinct.
+• FBI Arrests White Supremacist Who Allegedly Targeted BLM Founder.
+• WPost Al: Experts Increasingly Cite Systemic Racism As Cause Of Some Racial Disparities In US.
+• Alabama Voters Have Chance To Eliminate Racist Language From State Constitution.
+Operation LeGend
+• Myrtle Beach, South Carolina To Receive Federal Grant To Fight Gun Crime.
+Counter-Terrorism
+• Michigan Judge Slashes Bond For Man Linked To Whitmer Kidnap Plot.
+• CSIS: White Supremacists Responsible For Majority Of US Terrorist Attacks This Year.
+• Man Receives 20-Year Prison Sentence For Purchasing Firearms Used In 2015 Terror Attack In California.
+• Ninth Circuit Dismisses Key Terrorism Charge For California Man.
+• UK Special Forces Storm Vessel In Suspected Hijacking.
+• Afghanistan Claims Top Al-Qaida Propagandist Wanted By FBI Was Killed.
+• Guantanamo Bay Not Closing Despite Lack Of Population Growth Under Trump.
+• Bloomberg Analysis: French Interior Minister Now "Public Face Of A Crackdown Whipping Up Sentiment
+Against The Broader Muslim Community."
+• Spokesman Says Houthis Targeted Airports, Base In Saudi Arabia.
+• At Least Six Children Die In Cameroon During Attack On School.
+• Trump Marks 37th Anniversary Of Terrorist Attack In Beirut.
+• US Embassy In Turkey Warns Of Potential Terrorist Attacks.
+Counter-Intelligence
+• Sen. Johnson: FBI Interviewed Hunter Biden's Former Partner.
+EFTA00136985
+
+• Russian Bankers Ask Judge To Depose Steele Dossier Source Danchenko.
+• Judge Orders DOJ To Verify Filings In Flynn Case.
+• CISA Contradicting Trump's Attempts To Question Election.
+• Cuccinelli Addresses Foreign Interference In US Election.
+• Ransomware Attack On Georgia County Government Disables Voter Signature Database.
+• O' Brien Says Hackers Can't Change Votes.
+• Voters Urged To Be Careful When Opening Election-Related Mail.
+• Editorial: Americans Must Brave Outside Attacks On Elections And Vote.
+• FBI Alerted After Online Video Implies Maryland Election Judge Improperly Marked Ballot.
+• Cybersecurity Experts Concerned Over Threat Of Disinformation From Within US.
+• Continuing Coverage: DOD, ODNI Release Intel Budget Requests For FY21.
+• Kremlin Laments US Election Campaigns' Focus On Dislike For Russia.
+• US Imposes Sanctions On Russian Government Research Center Involved In 2017 Cyberattack.
+• Report: Russian Scientists Were In Contact With Military Science Institute Developing Novichok Nerve Agent.
+Criminal Investigations
+• Maxwell's Attorneys: US Prosecutors Not Honoring Promise To Supply Evidence.
+• Teenager Sentenced To Time In Juvenile Facility, Probation For Plotting Attack On Black Church.
+• California Prosecutors To Again Seek Death Penalty For Peterson.
+• NXIVM Leader Speaks Ahead Of Sentencing.
+• Teen Plotted To Assassinate Joe Biden, Federal Authorities Say.
+• Former Ohio City Councilman Arrested On Human Trafficking Charges.
+• FBI Investigating Border Patrol Officer-Involved Shooting.
+• Illinois Police Department Fires Officer Who Killed Black Teen As FBI Joins Shooting Investigation.
+• FBI Investigating "Ambush Style" Killing On Crow Reservation In Montana.
+• FBI Set To Release New Information On 1981 New York Cold Case.
+• Nearly $100K In Narcotics Seized In Florida Operation.
+• FBI Releases Photo Of Florida Bank Robbery Suspect.
+• Six California Gang Members Indicted On Federal Charges.
+• California Man Faces Federal Child Pornography Charges.
+• Texas Woman Gets 17 Years In Federal Prison For Bank Robberies.
+• Alleged California Gang Members To Stand Trial On Multiple Attempted Homicide Charges.
+• Man In Custody After Allegedly Abducting Daughters, Two Boys Found Dead.
+• Former Ohio Priest Charged With Sex Trafficking Of A Minor.
+• Texas Man Charged With Sexual Assault Of Child.
+Financial Crime & Corporate Scandals
+• Judge Orders Securities Fraud Case Against Texas Attorney General To Move To Paxton's Home County.
+• Attorneys For LA Lawmaker To Challenge Federal Court's Grand Juror Selection Methods.
+• US Charges Costa Rican Man In $1M Lottery Tax Scam.
+Cyber Division
+• US Sanctions Russian Government Research Institution For Cyberattacks Against Key Infrastructure Of Allies.
+• Louisiana National Guard Called In To Prevent Cyberattacks Weeks Prior To Election.
+• Bipartisan Bill Would Help National Guard Support States' Cybersecurity Modernization.
+• French Court Asks Microsoft To Guarantee Safeguards Against Sharing Health Data With US.
+• Kushner's "Close Friend" Charged With Cyberstalking.
+Laboratory
+• Police Say Body Found In Missouri Creek Was Missing Social Worker.
+Law Enforcement Services
+• When Jury Trials In DC Superior Court Will Resume Still Uncertain.
+• Proponents Of Now-Passed Virginia Sentencing Measure Feel Bill Will Have Transformational Impact.
+• Springfield, Massachusetts Police Working To Repair Relationship With FBI.
+International Relations
+• After Arrest Of Former Defense Minister On Drug Charges, Mexico's President Shifts Some Blame To US
+Officials.
+Other FBI News
+EFTA00136986
+
+• Trump Plans To Fire Wray, Haspel, Esper If He Is Reelected
+Other Washington News
+• Senate Votes 51-48 On Cloture, Setting Barrett Up For Monday Confirmation.
+• Pence To Continue Campaigning Even After Top Staffers Test Positive.
+• Fauci Says Effectiveness Of Vaccines Will Be Evident By Early December.
+• Trump, Administration Officials Defend Response To Coronavirus.
+• Whitmer: Trump's Plans For Rally In Lansing Is "Recipe For Disaster"
+• Administration Cancels Plan To Offer Santa Impersonators Early Access To Vaccine.
+• US Records "Biggest Two-Day Surge" In Coronavirus Cases.
+• Native Americans "Disproportionately" Impacted By COVID Ahead Of Election Day.
+• False Positives Having "Serious Consequences" In Some Communities.
+• Protesters Burn Masks In Pushback Against Restrictions.
+• Green Bay "Noticeably Subdued" Despite Football's Return.
+• Fox's Baier, MacCallum, Perino Advised To Quarantine.
+• Biden Tweet From 2019 Warning Of Pandemic Trends On Anniversary Of Post.
+• Pelosi "Optimistic" About Coronavirus Relief Bill Before Election.
+• DOJ Lawsuit Against Google Targets Agreement With Apple.
+• Senators Request IG Investigation Of CBP's Warrantless Utilization Of Cellphone Location Data.
+Undocumented Farm orker Died Aiteration Rienues Must Weit Longer To Receive Visas
+Undocumented rarmworker Died Alter di
+• Tropical Storm Zeta Strengthens In Caribbean.
+• Kushner, Ivanka Trump Threaten To Sue Over Lincoln Project Billboards.
+• State Department Confirms It Has Suspended Diversity Programs.
+• Pelosi Says She Plans To Seek Another Term As Speaker.
+• High Winds Increase California Wildfire Risk.
+• State Department Suspends Diversity Training Following Trump Executive Order.
+• WPost Analysis: Trump Has "Presided Over A Norm-Shattering Expansion Of Private Interests In
+Government."
+• WPost A1: Trump Has Made Sustained "Assault" On Civil Service.
+• NYTimes A1: Trump's Financial Records "Cast Doubt" On Philanthropic Claims.
+• WPost Analysis: Trump Has To Pay Off $400M In Loans By 2024.
+International News
+• European Countries Impose New Restrictions Amid Second Wave Of COVID Cases.
+• Colombia Passes 1M Confirmed Coronavirus Cases.
+• Malaysia's King Rejects PM's Proposal To Declare COVID State Of Emergency.
+• Iraqis Protest A Year After Demonstrations That Toppled Government.
+• As Peace Talks Continue, Taliban Fighters Stage Attacks Across Afghanistan.
+• Trump Announces Sudan Will Recognize Israel.
+• Meadows Predicts More Middle East Peace Deals.
+• Pompeo, Esper To Reinforce Trump's Anti-China Message In India.
+• WPost Analysis: Putin has Benefitted From Trump's Time In Office.
+• Thousands Of Belarusians Protest, Demanding Lukashenko's Resignation.
+• Armenia, Azerbaijan Agree To Cease-Fire.
+• Polish Protesters Disrupt Church Services After Tightening Of Abortion Law.
+• France Withdraws Its Ambassador To Turkey.
+• Chileans Vote To Draft A New Constitution.
+• Venezuelan Opposition Leader Arrives In Madrid.
+• Fiftieth Country Ratifies Treaty On The Prohibition of Nuclear Weapons.
+• WPost Urges Openness About Invisible Attacks On US Diplomats, Intel Officers.
+The Big Picture
+• Headlines From Today's Front Pages.
+Washington's Schedule
+• Today's Events In Washington.
+EFTA00136987
+
+Leading the News
+Police Departments Preparing For Potential Election Day Unrest.
+The Washington Post
+(10/24, Berman, 14.2M) reports that "police departments across the country are bracing for Election Day,
+mobilizing officers as they prepare for the possibility of voter intimidation, unrest or violence." Though law
+enforcement agencies typically prepare "for elections, officials say this year's preparations are unusually
+extensive because of the sheer levels of anxiety and toxicity across the country - with fears that a modern
+American election could give way to potential violence." Las Vegas Metropolitan Police Department Deputy
+Chief Andrew Walsh said, "I don't think we've seen anything like this in modern times." Meanwhile, Chicago
+Police Superintendent David Brown said, "We are all in conversations with our counterparts across the country
+about what we might expect. But everything is uncertain. And so we're trying as best we can to anticipate any
+hazard that might happen."
+The Wall Street Journal (10/24, Subscription Publication, 7.57M) reports that according to law
+enforcement officials and business leaders, the New York Police Department has told Midtown Manhattan
+businesses to take extra security measures due to the possibility of protests surrounding the presidential election.
+Americans Purchasing "Tactical Apparel" Ahead Of Election. Bloomberg
+ (10/23, Robison, Adams-Heard, 4.73M) says, "Conflict is on America's streets in 2020, and 'tactical
+apparel' has become a lifestyle industry serving militarized law-enforcement agents and the freelance gunmen
+who emulate them. Less than two weeks before Election Day, orders are rolling in." Bloomberg adds that since
+last year, Internet orders have propelled "a 20-fold jump in sales of goods like the $220 CM-6M gas mask -
+resistant to bean-bag rounds - for Mira Safety of Austin, Texas." Regarding his new customers, Mira Safety
+founder Roman Zrazhevskiy said, "They think that no matter who wins, Biden or Trump, there are going to be
+people who are upset about the result."
+Minnesota AG Probing Firm Accused Of Recruiting Armed Guards For Election Day. NBC News
+ (10/23, Wong, 6.14M) reports,
+"Minnesota Attorney General Keith Ellison
+announced on Tuesday that his office launched an investigation into a private security company that has been
+accused of recruiting armed security guards for Election Day, saying that such an effort would intimidate voters."
+Atlas Aegis "is accused of posting since-deleted advertisements on Facebook for U.S. military Specials
+Operations personnel to guard polling sites in Minnesota on Election Day, according to a lawsuit filed by the
+Council on American-Islamic Relations of Minnesota (CAIR) and the League of Women Voters of Minnesota."
+Poll: More Than Two In Five Ready To Question Legitimacy Of Election Result. Reuters
+ (10/25, Kahn) reports that a Reuters/Ipsos poll of
+2,649 likely voters (10/13-10/20) shows that 43% of supporters of Joe Biden would not accept a victory by
+President Trump as legitimate, "while 41% of Americans who want to re-elect Trump would not accept a win by
+Biden. Smaller portions would take action to make their displeasure known: 22% of Biden supporters and 16%
+of Trump supporters said they would engage in street protests or even violence if their preferred candidate loses."
+Several outlets look at the possibility of conflict and even violence in the wake of the election. The Wall Street
+Journal
+(10/25, Horwitz, Seetharaman, Subscription Publication, 7.57M) reports Facebook has prepared internal tools
+designed for use in what it calls "at-risk" countries for use in the US. The Philadelphia Inquirer
+EFTA00136988
+
+ (10/25, Orso, 347K) reports progressive organizations in Philadelphia
+progressive "are planning "mass action" and preparing protests for the days after the Nov. 3 election in the event
+of coordinated voter intimidation, mail-in ballot invalidation, or other electoral discord." The Seattle Times
+ (10/25, 935K) reports officials across the US are preparing for the prospect that this
+year's long, hot summer of unrest won't end" with the election.
+Kansas City Mayor Quinton Lucas (D), on CBS' Face The Nation
+ (10/25, 14.2M) writes, "One week
+before Americans choose their path forward, the quadrennial crossroads reeks of despair. In almost every
+generation, politicians pose certain elections as the most important of their time. But the 2020 vote takes place
+with the country in a historically dark mood - low on hope, running on spiritual empty, convinced that the wrong
+outcome will bring disaster."
+At Least 58.6M Have Voted So Far. The AP (10/25, Ricardi, Kastanis) reports, "With nine days
+before Election Day, more people already have cast ballots in this year's presidential election than voted early or
+absentee in the 2016 race as the start of in-person early voting in big states led to a surge in turnout in recent
+days." At least 58.6 million ballots have been cast so far. Democrats "have continued to dominate the initial
+balloting, but Republicans are narrowing the gap. GOP voters have begun to show up as early in-person voting, a
+sign that many heeded [Trump's] unfounded warnings about mail-voting fraud."
+On ABC World News Tonight
+https://playvideo.bulletinintelligence.com/a3abbed98f2b49fb93599lae2b26f123?pubid=fbi> (10/25, story 2,
+3:20, Llamas, 4.45M), Stephanie Ramos reported that this weekend saw "early voting breaking voter turnout
+records across the country. More than 93,000 voters turned out to the polls on the first day of early voting" in
+New York City, where "massive lines stretched for blocks, with voters determined to make their ballot count."
+The CBS Weekend News (10/25, story 5, 2:55, Yuccas, 9.26M) reported on absentee votes being cast by Americans outside the
+US.
+Texas Supreme Court Stays Order Blocking Abbott's Limit On Ballot Dropoff Sites. The Dallas Morning News
+ (10/25, 946K) reports the Texas Supreme Court has stayed a lower court's order
+that had blocked an order by Gov. Greg Abbott (R) "limiting counties to one mail ballot drop-off site. The
+decision followed a ruling Friday by Texas' Austin-based Third Court of Appeals that had upheld a state judge's
+order blocking Abbott's order. The state had appealed the Third Court of Appeals order." The state Supreme
+Court "was still reviewing whether to take further action in the case and ordered both sides to file their responses
+by 5 p.m. Monday."
+Reuters (10/23, Brice) reports the Texas 3rd Court of Appeals on Friday
+"ruled the Republican governor cannot limit drop-off sites for mail ballots to one per county, a setback for U.S.
+President Donald Trump." The court concurred with a "lower court that limiting the number of drop boxes would
+increase the risk that voters could get infected with COVID-19, and would infringe on their right to vote." Texas
+Gov. Greg Abbott "has informed the voting rights groups who oppose his move to limit drop boxes that he
+EFTA00136989
+
+intends to quickly appeal Friday's ruling to the Texas Supreme Court, effectively delaying the re-opening of
+ballot drop-off locations."
+Boston Ballot Dropbox Set On Fire. The Boston Globe
+
+(10/25, 972K) reports, "A ballot drop box outside the Boston Public Library was set on fire early Sunday
+morning, according to state and city officials, who say it appears to be a deliberate, criminal attack and called it a
+'disgrace to democracy.'" The fire "was set around 4 a.m. in the Copley Square drop box."
+Pennsylvania Supreme Court: Mail-In Ballots Can't Be Rejected Over Signature Discrepancy. Reuters
+ (10/23, Pitas) reports Pennsylvania's
+Supreme Court "ruled on Friday that mail-in ballots cannot be refused because a voter's signature does not
+appear to match the one on file, a decision that could help Democratic presidential candidate Joe Biden." The
+court ruled, "(We) hold that county boards of elections are prohibited from rejecting absentee or mail-in ballots
+based on signature comparison conducted by county election officials or employees, or as the result of third-
+party challenges based on signature analysis and comparisons." According to Reuters, "Democrats hailed the
+move while Republicans were critical."
+Voter Advocates Drop Suit Against Ohio Rule Limiting Drop Boxes. The AP
+ (10/23, Smyth) reports that "a coalition of voter advocacy groups
+dropped a lawsuit Friday against Ohio's strict rule limiting ballot drop boxes to one location per county, a coup
+for President Donald Trump's reelection campaign in a key battleground state." The A. Philip Randolph Institute,
+the American Civil Liberties Union of Ohio, and the League of Women Voters of Ohio "made the decision after
+the federal appellate court in Cincinnati set a timetable last week that pushed further activity in the case past
+Election Day." Ohio ACLU Legal Director Freda Levenson "said that would 'obviously be too late.'"
+Protests
+Trump Supporters And Opponents Clash In New York's Times Square.
+The New York Times (10/25,
+Southall, 18.61M) reports, "Political tensions over the upcoming presidential election escalated on New York
+City's streets on Sunday, as supporters of President Trump clashed with counterprotesters during a day of
+demonstrations." As a "pro-Trump caravan" organized by "a group that identifies itself as Jews for Trump"
+passed through Times Square, it "converged with a group of anti-Trump protesters who had marched from
+Brooklyn. The cars in the convoy were then blocked by counterprotesters, and some drivers got out of their cars
+to confront the anti-Trump demonstrators." The clashes "came as the Police Department was preparing for more
+possible unrest." In Brooklyn, one police officer "used a police loudspeaker to voice support for the president
+while arguing with a man on the street." The officer "was suspended without pay on Sunday after videos of the
+incident went viral on social media."
+The New York Daily News (10/25, Annese, 2.52M) reports that during the Times
+Square clash, "protesters hollered curses at former mayor Rudy Giuliani," who said he "wasn't part of the 'Jews
+for Trump' caravan" but was on his way home from a radio appearance. The New York Post
+ (10/25,
+Celona, Moore, Fitz-Gibbon, 4.57M) also reports on the Giuliani incident.
+EFTA00136990
+
+Most Black Lives Matter Demonstrations Have Been Peaceful.
+In an approximately 4,500 word piece, USA Today (10/24,
+10.31M) reports that President Trump "and his supporters continue to warn voters that big cities run by
+Democrats are "going to hell' due to violence associated with Black Lives Matter protests that erupted
+nationwide this summer in the wake of a series of police killings of Black Americans." However, those who
+reside "and work in those cities say the president is either terribly misinformed or lying." Though cities
+throughout the nation have seen murders and shootings significantly increase, "the vast majority of
+demonstrations associated with the Black Lives Matter movement have been non-violent." USA Today goes on
+to feature comments from residents of Portland, Milwaukee, Chicago, Detroit, and Louisville regarding how
+their cities have been impacted by protests.
+Demonstrators Arrested Following Floyd's Death Were Charged Mostly With Nonviolent Offenses. In an
+approximately 3,000 word piece, the Washington Post
+< https://www.washingtonpost.com/graphics/2020/investigations/george-floyd-protesters-arrests/> (10/23,
+14.2M) reported that demonstrators arrested following George Floyd's death "were a diverse, young group of
+people who demonstrated close to home and were charged largely with nonviolent crimes, according to a...Post
+review of data on more than 2,600 people detained in 15 cities." The data belies suggestions by the President as
+well as "other officials that those who took to the streets were mostly agitators from out-of-town." According to
+the Post's review, the vast "majority arrested in those 15 cities - 2,059 of the 2,652 - were accused of nonviolent
+misdemeanors, most on charges of violating curfew or emergency orders."
+LAPD Reports Indicate Most Floyd Protests Were Nonviolent. Under the headline "LAPD Reports Show That
+The Vast Majority Of George Floyd Protests Were Peaceful," the Los Angeles Times
+ (10/23,
+4.64M) says, "Field reports from Los Angeles police commanders at protests across the city this summer indicate
+that between 6% and 7% resulted in violence, destruction or serious uses of force by police, according to the
+LAPD." Most events that occurred in the timeframe "reviewed - May 25 to July 31 - were peaceful."
+Seattle Office Of Police Accountability: Seattle Officers Utilized Excessive Force Against Protestors.
+The Hill (10/24, 2.98M) reports the Seattle Office Of Police Accountability "found that police
+officers in the city used excessive force during some encounters with protesters amid multiple Black Lives
+Matter demonstrations over the summer." The office made public five finished probes "into the conduct of the
+Seattle Police Department in its handling of protests in the city that began in late May following the death of
+George Floyd." The Hill adds that OPA "said in a press release that it has been contacted more than 19,000 times
+about officers' conduct at these demonstrations since May 30 and has opened 126 investigations."
+Illinois Officer Fired After Shooting And Killing Black Man.
+The New York Times (10/24,
+Cramer, 18.61M) reports, "An Illinois police officer who shot and killed a 19-year-old Black man who was
+sitting in a car that was reversing toward the officer has been fired, according to the police." The Times adds that
+"the officer, who has not been publicly identified, was fired on Friday night, three days after the shooting, said
+Wayne Walles, the chief of police in Waukegan, III." In a statement on Friday, Walles said, "The City of
+Waukegan terminated the officer that discharged his firearm during that incident, for multiple policy and
+procedure violations." Meanwhile, the Illinois State Police "said on Thursday that they were investigating the
+EFTA00136991
+
+killing of the man, Marcellis Stinnette." The CBS Weekend News
+ (10/24, story 5,
+0:21, Yuccas, 2.08M) reported that Stinnette's girlfriend, who was driving the car, was wounded.
+WPost A1 Discusses Mother's Struggle To Get Help For Black, Mentally III Son Amid Pandemic, Racial Unrest.
+In an approximately 4,500 word front-page piece, the Washington Post
+ (10/24, A1, 14.2M)
+highlights a Georgia mothers struggle to get help for her 11-year-old son, who's Black and mentally ill, amid
+both the pandemic and increasing racial unrest.
+Black Journalists Who Worked With Vogue Editor In Chief Wintour Feel She Created Environment That
+Sidelined Black Women.
+A roughly 3,800 word New York Times (10/24, Lee, 18.61M) piece says that "Black journalists who have worked with" Vogue editor
+in chief Anna Wintour, "speaking on the condition of anonymity out of fear of retribution, said they had not
+gotten over their experiences at a magazine whose workplace mirrored its exclusive pages." Many of the
+individuals the Times interviewed "said the racism they encountered was usually subtle, but sometimes blunt.
+Their main accusation was that Ms. Wintour created a work environment - and there is no facet of Vogue that
+she does not control - that sidelined and tokenized women of color, especially Black women."
+DOJ: Boogaloo Bois Member Fired On Minneapolis Police Precinct.
+The Minneapolis Star Tribune (10/23, 1.04M) reports that "in the wake of protests" after George
+Floyd's killing, "a member of the Boogaloo Bois opened fire on the Minneapolis Police Third Precinct with an
+AK-47-style gun and screamed 'Justice for Floyd' as he ran away, according to a federal complaint made public
+Friday." Ivan Harrison Hunter, "a 26-year-old from Boerne, Texas, is charged with one count of interstate travel
+to incite a riot for his alleged role in ramping up violence during the protests in Minneapolis on May 27 and 28."
+Charges indicate that Hunter "shot 13 rounds at the south Minneapolis police headquarters while people were
+inside. He also looted and helped set the building ablaze, according to the complaint, which was filed Monday
+under seal."
+The Washington Post (10/23, Bailey, 14.2M) reports, "According to a
+federal criminal complaint filed Monday but made public Friday," Hunter, of Bourne, Texas, "traveled to
+Minneapolis after Floyd's death and was captured on surveillance video May 28 firing 13 rounds from an AK-47
+into the precinct building as it was overtaken by protesters. According to the complaint, Hunter fired his gun and
+allegedly shouted, 'Justice for Floyd!"" Hunter "was charged with traveling across state lines to participate in a
+riot and made his first court appearance Friday in San Antonio, according to Erica MacDonald, the U.S. attorney
+for the District of Minnesota, whose office is handling the case."
+CNN < https://us.cnn.com/2020/10/23/us/boogaloo-bois-arrest/index.html> (10/23, Campbell, 83.16M) reports,
+"According to a federal criminal affidavit, Hunter was present between May 27-28 at the Minneapolis Police
+Department's Third Precinct when the building was set on fire during protests. The FBI said it obtained video
+that showed Hunter firing 13 rounds from an AK-47 style rifle into the Third Precinct while people were inside
+the building." Hunter "returned to Texas after the Third Precinct incident, and 'made various statements on social
+EFTA00136992
+
+media describing the violence in which he engaged in Minneapolis,' according to the affidavit." CNN adds, 'In
+the charging documents, the FBI alleged that Hunter was also associated with Steven Carrillo - another adherent
+of the Boogaloo Bois movement who is charged with killing two law enforcement officers in California in late
+May and early June."
+The Hill (10/23, Castronuovo, 2.98M) reports, "Federal officials wrote in the complaint that
+another individual charged in connection with the incident who is cooperating with authorities said that Hunter
+was the one who fired shots outside the precinct, which authorities later corroborated with several social media
+posts. Upon returning to Texas, Hunter made several posts about the event and on May 30, Hunter reportedly
+sent a message to another individual stating, 'I set fire to that precinct with the black community,' followed by
+'Minneapolis third precinct,' according to the legal documents. On May 31, Hunter sent a message to another
+individual, saying, 'My mom would call the fbi if she knew what I do and at the level I'm at w[ith] it.'''
+ABC News (10/23, 2.97M) reports, "Hunter is the third 'Boogaloo Bois' member to face
+federal charges for his role in the Minneapolis riots, along with Michael Solomon and Benjamin Teeter - who
+were previously indicted on charges of conspiracy to provide material support for a foreign terrorist organization.
+All three were communicating and coordinating their movements regularly through the night of the riots,
+according to the FBI affidavit."
+The San Francisco Chronicle (10/24, Williams, 2.67M) reports, "Carrillo, 32, is accused of spraying bullets
+across a guard shack in front of the Ronald V. Dellums Federal Building in Oakland on May 29, killing David
+Patrick Underwood, a federal security officer from Pinole, and wounding another person. One week after the
+Oakland shooting, the Air Force sergeant allegedly ambushed deputies in Santa Cruz County who were
+responding to reports of a van containing guns and bomb-making materials. Sgt. Damon Gutzwiller, 38, was
+killed and several other deputies were wounded." Authorities "said Hunter and Carrillo had been messaging each
+other on Facebook before, during and after the Oakland and Minneapolis shootings. About four hours after the
+shooting that killed Underwood, Hunter messaged Carrillo, 'go go go,' according to the court documents."
+BuzzFeed News (10/24, Hernandez) and the Daily Beast (10/23, Weil, 1.39M) also report.
+FBI Arrests White Supremacist Who Allegedly Targeted BLM Founder.
+Black Entertainment Television (10/23, 893K) reports, "Alicia Garza, co-founder of the Black Lives
+Matter movement, revealed on Twitter today (October 23) that she was told by the FBI of a possible white
+supremacist plot against her." BET adds, "Garza shared that agents from the bureau visited her to inform her that
+they had arrested a suspected white supremacist who was armed and has her name 'on a list.' "They arrested a
+man in Idaho on weapons charges who they believe was affiliated with white supremacist groups,' Garza
+tweeted. "They found my name on a list in his home, alongside others."*
+WPost Al: Experts Increasingly Cite Systemic Racism As Cause Of Some Racial Disparities In US.
+In a front-page article, the Washington Post (10/22, A1, Samuels, 14.2M) reports experts "are increasingly
+pointing tosystemic racism" as the cause of racial disparities in the US that relate to health and certain kinds of
+deaths. The article says Black men in the US "are twice as likely as White men to die of a cocaine overdose,
+EFTA00136993
+
+twice as likely to be killed by police and...10 times as likely to" be murdered.
+Study: Black Individuals Arrested For Misdemeanors At Higher Rates Than Other Racial Groups. The
+Washington Post (10/23, Mettler, 14.2M)
+"People of color are still disproportionately arrested on misdemeanors in Prince George's even though
+the rate of enforcement for such lower-level charges has decreased in the Maryland county and across six other
+large jurisdictions over the past 10 years, according to a new national study from the Data Collaborative for
+Justice at John Jay College." The study "draws on data collected from agencies between the early 2000s and the
+late 2010s in New York, Louisville, Los Angeles, Seattle, Durham, N.C., St. Louis and the D.C. suburb of Prince
+George's." According to the Post, "The key findings, including that Black people were arrested for
+misdemeanors at the highest rate of any racial group, come as government leaders and law enforcement officials
+nationwide face mounting pressure to reform criminal justice and policing."
+Alabama Voters Have Chance To Eliminate Racist Language From State Constitution.
+The AP (10/23, Reeves) reports Alabama voters once more have an opportunity
+to eliminate "the racist language of Jim Crow from the state's constitution, which was approved in 1901 to
+enshrine white supremacy as state law." Prior efforts to remove "the offensive phrases have failed," and though
+"organized opposition to the measure" hasn't materialized this time, there is concern "that conservative backlash
+to the Black Lives Matter movement could quash the proposal, which qualified for the ballot months before the
+nationwide demonstrations that" followed George Floyd's killing. The AP adds, "A measure on the Nov. 3 ballot
+would allow the state to recompile its 119-year-old constitution in a process supporters say would remove a
+lingering stain from the state's era of racial segregation and the legalized oppression of Black people."
+Operation LeGend
+Myrtle Beach, South Carolina To Receive Federal Grant To Fight Gun Crime.
+The Myrtle Beach (SC) Online
+(10/24, Albert, 47K) reports, "Myrtle Beach will now have help from the federal government in putting violent
+County. Shootings took the lives of a Myrtle Beach police officer, two beloved members of the Racepath
+community and armed suspects." According to MBO, "A review of FBI and U.S. Census Bureau data shows the
+violent crime rate in Myrtle Beach outpaces places like Virginia Beach, Va., and Daytona Beach, Fla. It even
+surpasses cities such as Chicago. The federal grant is part of Operation Legend, an initiative led by the
+Department of Justice to lower violent crime."
+Counter-Terrorism
+Michigan Judge Slashes Bond For Man Linked To Whitmer Kidnap Plot.
+The AP (10/23) reported from Jackson, Michigan, "A judge on Friday slashed
+bond from $10 million to $100,000 for a man accused of assisting in a scheme to kidnap Michigan Gov.
+Gretchen Whitmer and commit other violence against state government." The AP adds, "A defense attorney
+argued that Pete Musico was kicked out of the group in the early summer because he was too 'soff' and wouldn't
+commit to violence after participating in armed but legal spring rallies at the Capitol. 'He was telling them you
+cannot accomplish what we're trying to accomplish through violence,' Kareem Johnson said." Jackson County
+Judge Michael Klaeren "reduced Musico's bond, clearing the way for him to be released from jail. He must wear
+a GPS tether."
+The AP (10/24, Flesher) reports from Traverse City, Michigan, "When members of a Michigan paramilitary
+group were accused a decade ago of scheming to overthrow the U.S. government, their defense was based
+largely on one claim: We were all talk, no action. It worked so well that a federal judge took the rare step of
+dismissing most charges against the extremist group known as Hutaree, without giving the jury a say." The AP
+adds, "A defense lawyer in that case now represents Ty Garbin, one of six men accused of conspiring to kidnap
+Democratic Gov. Gretchen Whitmer because of anger over her stay-at-home policies to contain the coronavirus.
+Again, attorney Mark Satawa contends his client had no intention to carry out the alleged plan, whatever he
+might have said in recorded or online conversations. "Saying things like 'I hate the governor, the governor is
+tyrannical' ... is not illegal, even if you're holding a gun and running around the woods when you do it,' Satawa
+told The Associated Press."
+MLive (MI) (10/24, Burns, 925K) reports, "The idea that 14
+men accused of planning to kidnap Michigan Gov. Gretchen Whitmer were actually trying to enact a legal
+citizen's arrest is far-fetched, law experts who spoke with MLive say," but "it's a possible legal defense." Barry
+County Sheriff Dar Leaf, "who criticized Whitmer's coronavirus restrictions during a May 18 Michigan Patriot
+Rally in Grand Rapids, at which he shared the stage with one of the criminally charged suspects, first raised the
+prospect that this may not have been a kidnapping plot at all. 'It's just a charge, and they say a "plot to kidnap"
+and you got to remember that,' Dar told Fox 17 Grand Rapids' reporter Aaron Parseghian. 'Are they trying to
+kidnap? Because a lot of people are angry with the governor, and they want her arrested. So are they trying to
+arrest or was it a kidnap attempt? Because you can still in Michigan, if it's a felony, make a felony arrest.""
+Whitmer Says Several Officials Have Received Death Threats. Michigan Gov. Gretchen Whitmer (D), on Fox
+News Sunday
+(10/25, 1.27M), said, "We are just days since the plot to kidnap and try and kill me was revealed. Fourteen
+people have been arrested. First, I want to acknowledge the incredible work of the FBI and the Michigan state
+police. But I also want to acknowledge that rhetoric like this contributes to bringing up the heat. I have asked the
+White House since April to bring the heat down. That's when the death threats started. We now know that my
+good friend Mike DeWine, Republican governor of Ohio has been receiving threats. We know the people on both
+sides of the aisle who are just to do their jobs and save lives, like [NIAID Director] Fauci, have received threats.
+This kind of rhetoric is anti-American and it seeks to undermine the foundational principles of this country."
+Fox News (10/25, Blitzer,
+27.59M) reports that Whitmer "blamed the Trump administration for rhetoric that she claimed led to a
+kidnapping plot against her, after the Trump campaign accused her of encouraging attempts on the president's
+life. 'First I want to acknowledge the incredible work of the FBI and the Michigan State Police,' Whitmer told
+'Fox News Sunday' host Chris Wallace, 'but I also want to acknowledge that rhetoric like this contributes to
+bringing up the heat. I have asked the White House since April to bring the heat down. That's when the death
+threats started."
+Arkansas Gov. Asa Hutchinson (R), on CBS' Face The Nation
+ (10/25, 2.24M),
+discussed the degree of harsh rhetoric in the campaign, particularly the "lock her up" chants at the President's
+rallies. Hutchinson said, "That's not a chant I would ever participate in. You know, we need to have a more civil
+EFTA00136995
+
+discourse, even though it's a hotly contested presidential race. We need to lead by example."
+CSIS: White Supremacists Responsible For Majority Of US Terrorist Attacks This Year.
+The New York Times (10/24, Gross,
+18.61M) says, "White supremacists and other like-minded groups have committed a majority of the terrorist
+attacks in the United States this year, according to a report by a security think tank that echoed warnings made by
+the Department of Homeland Security this month." The Times adds that "the report, published Thursday by the
+Center for Strategic and International Studies, found that white supremacist groups were responsible for 41 of 61
+"terrorist plots and attacks" in the first eight months of this year."
+Man Receives 20-Year Prison Sentence For Purchasing Firearms Used In 2015 Terror Attack In California.
+The AP (10/23, Dazio, Taxin) reports that "the man who bought two rifles that
+husband-and-wife assailants used to kill 14 people in a Southern California terror attack" in 2015 received a 20-
+year prison sentence on Friday. Enrique Marquez Jr. "supplied the weapons that Syed Rizwan Farook and
+Farook's wife, Tashfeen Malik, used on Dec. 2, 2015, to open fire on a meeting and holiday gathering of San
+Bernardino County employees who worked with Farook. Minutes later, a post on a Facebook page associated
+with Malik pledged allegiance to the leader of the Islamic State terror group." Farook and Malik "died later that
+day in a gunbattle with authorities."
+The Orange County (CA) Register (10/23, Rokos, 546K) reports, "U.S. District Court Judge Jesus G.
+Bernal said he couldn't hold Marquez legally responsible for the 14 slayings. Authorities have said that Marquez
+did not know about the plot in advance." Marquez, of Riverside, California, "had been convicted of conspiracy
+to provide material support to terrorists and making a false statement on federal firearms-purchase forms:
+Marquez said the firearms he was buying in 2011 and 2012 were for his use. Instead, he sold them to neighbor
+Syed Rizwan Farook as part of an aborted plan to wage attacks on motorists on the 91 Freeway and at Riverside
+City College, prosecutors said. By then, Farook had radicalized his longtime friend to Islam."
+The New York Times
+(10/23, Levenson, 18.61M) reports, 'In pleading guilty, Mr. Marquez had acknowledged making false statements
+in connection with his role as a 'straw buyer' of the rifles, federal prosecutors said." Farook and Malik "were
+killed in a shootout with the authorities hours after the massacre, which was the worst terrorist attack on
+American soil since Sept. 11, 2001, federal prosecutors said." Federal prosecutors said Marquez "had admitted in
+a plea agreement and in open court that he had also plotted with Mr. Farook in 2011 and 2012 to attack Riverside
+City College and a California freeway. Those attacks were never carried out, but Mr. Marquez had discussed
+with Mr. Farook using radio-controlled improvised explosive devices for the attacks and bought Christmas tree
+light bulbs and a container of smokeless powder to use in the devices, federal prosecutors said."
+The Hill (10/23, 2.98M) reports that Marqez "pleaded guilty in 2017 to conspiracy to
+provide material support and resources to terrorists, and one count of making false statements in connection with
+the acquisition of firearms. "This defendant was an active member of a conspiracy that planned to inflict death
+and destruction on innocent people,' First Assistant United States Attorney Tracy Wilkison said in a statement.
+'By his own admissions, this defendant collaborated with and purchased weapons for a man he definitively knew
+held radical and anti-American beliefs - and who wanted to kill innocent people.'" The Wall Street Journal
+ (10/23, Levy, Subscription Publication, 7.57M) also reports.
+EFTA00136996
+
+Ninth Circuit Dismisses Key Terrorism Charge For California Man.
+The San Jose (CA) Mercury News
+(10/23, Gartrell, 456K) reports from San Francisco, "In a rebuke of a Bay Area federal judge's decision, the
+Ninth Circuit Court of Appeals has struck down a terrorism enhancement against a man who was sentenced to 15
+years in federal prison for opening six Twitter accounts for an undercover agent he believed was a member of
+ISIL." Amer Alhaggagi "was convicted of 'attempting to provide material support' to terrorists simply because
+he agreed to open social media accounts for the purported member of the Islamic State, known as ISIL and
+ISIS." Prosecutors asked US District Judge Charles Breyer "to apply a so-called "terrorism enhancement' that
+made him eligible for up to 20 years. Breyer applied the enhancement and sentenced Alhaggagi to 15 years." The
+appeals court ruled that the enhancement "did not apply to Alhaggagi's case."
+UK Special Forces Storm Vessel In Suspected Hijacking.
+Reuters (10/25, Nicholls) reports, "British special forces stormed a Greek-
+operated oil tanker in the English channel on Sunday" in a "suspected hijacking." Special forces troops from
+Special Boat Service "boarded the Nave Andromeda near the Isle of Wight off southern England." UK officials
+"authorised the armed forces to board the ship "to safeguard life and secure a ship that was subject to suspected
+hijacking', the defence ministry said." It isn't "clear where the stowaways were from or what their intentions
+were." British police said, "They had made verbal threats towards the crew. No one has been reported injured."
+Afghanistan Claims Top Al-Qaida Propagandist Wanted By FBI Was Killed.
+The AP (10/25) reports, "Afghanistan claimed Sunday it killed a top al-Qaida propagandist,"
+Husam Abd al-Rauf, also known as Abu Muhsin al-Masri, "on an FBI most-wanted list during an operation in
+the country's east." The move, as well as ongoing violence, "threaten the face-to-face peace talks and risk
+plunging this nation beset by decades of war into further instability." Afghanistan's National Directorate of
+Security "claimed on Twitter to have killed him in Ghazni province," then "released a photograph late Sunday
+afternoon it described as al-Rauf's corpse, which resembled FBI images of the militant leader." According to
+"Wahidullah Jumazada, a spokesman for the provincial governor in Ghazni...Afghan forces killed six suspected
+militants in the raid, without acknowledging al-Rauf had been killed."
+Reuters (10/24, Shalizi) reports that NCTC
+Director Chris Miller "confirmed al-Masri's death in a statement, saying his removal .. from the battlefield is a
+major setback to a terrorist organization that is consistently experiencing strategic losses facilitated by the United
+States and its partners."" Miller added the loss "highlights the diminishing effectiveness of the terrorist
+organization."
+Bloomberg (10/24, Najafizada, 4.73M) reports, "The U.S. issued a federal arrest warrant in 2018 after he
+was charged with conspiracy to kill American nationals and providing material support and resources to foreign
+terrorist organizations," according to the FBI website.
+EFTA00136997
+
+The Hill (10/25, Coleman, 2.98M) reports that an Afghan presidential palace statement said the death
+"proved that the threat of terrorism and the Taliban's links to terrorist networks are still in place." The statement
+added, "The Taliban should prove to the people, the government of Afghanistan and the international community
+that they are ending their links with terrorist groups, including al-Qaida." The palace is urging those groups to
+"stop the war and violence and facilitate a dignified and sustainable peace in the country."
+Guantanamo Bay Not Closing Despite Lack Of Population Growth Under Trump.
+The Hill (10/25, Kheel, 2.98M) reports that Guantanamo Bay's "population has not grown" under
+President Trump, whose Administration "recently celebrated bringing two of the most notorious alleged ISIS
+fighters to the United States for trial." The detention center "has all but disappeared from either party's talk on
+the campaign trail as the facility nears 20 years of operations," and remains open. The Administration has,
+however, brought "27 Americans captured by the SDF back to the United States for prosecution," the DOJ
+announced this month. Amnesty International's Daphne Eviatar said her group will "definitely try to push a new
+administration on this." She added the US is "coming on the 20th anniversary of the prison, and I think that
+people might remember, 'Oh my god, this prison is still open. People are still being held indefinitely without
+charge or trial. This is crazy.
+Bloomberg Analysis: French Interior Minister Now "Public Face Of A Crackdown Whipping Up Sentiment
+Against The Broader Muslim Community."
+A Bloomberg (10/24, Nussbaum, 4.73M) analysis says that French Interior Minister
+Gerald Darmanin "has vowed to root out extremists after a grisly murder in Paris. In saying he wants to preserve
+a distinctly French way of life, he risks the perception he's targeting not just Islamists, but all Muslims."
+Bloomberg adds that Darmanin's "vision for the country includes fewer halal butchers, ethnic clothing stores and
+even specialist supermarket aisles." While speaking with French television on Tuesday, he said, "It always
+shocked me to enter a supermarket and see a shelf devoted to the food of one community, and to another one
+next to it." He also said, "Some people need to understand that winning market share by appealing to basic
+instincts doesn't necessarily contribute to the common good." According to Bloomberg, Darmanin "has become
+the public face of a crackdown whipping up sentiment against the broader Muslim community."
+Spokesman Says Houthis Targeted Airports, Base In Saudi Arabia.
+Reuters (10/24, Khalek) reports, "The military
+spokesman for Yemen's Houthi movement said in a tweet on Saturday it had targeted the Jizan and Abha airports
+and the Khamis Mushait base in Saudi Arabia with drones." Previously on Saturday as well as in a pair of
+"statements on Friday, the Saudi-led coalition had said it had intercepted and destroyed three explosive-laden
+drones from the Houthis aimed towards the southern region of Saudi Arabia." Moreover, on Sunday, "the
+coalition said it had intercepted another drone aimed for the same region." According to Reuters, "The coalition's
+spokesman did not specify the targets of the drones in the statements on Saudi state news agency SPA." Houthi
+military spokesman Yahia Sarea tweeted, "The hit was accurate."
+At Least Six Children Die In Cameroon During Attack On School.
+EFTA00136998
+
+The New York Times
+(10/24, 18.61M) reports, "Gunmen killed at least six children and badly wounded about eight others when they
+opened fire in a school in the city of Kumba in Cameroon's Southwest region on Saturday, officials told
+Reuters." Officials indicated that secessionist insurgents were behind the attack, "though Reuters was unable to
+immediately confirm that."
+Trump Marks 37th Anniversary Of Terrorist Attack In Beirut.
+President Trump on Friday tweeted , "On
+the 37th anniversary of the horrendous attack on our United States Marines, Sailors, and Soldiers in Beirut, we
+honor the 241 heroes who lost their lives that day. We will NEVER forget them. Semper Fi!"
+US Embassy In Turkey Warns Of Potential Terrorist Attacks.
+The AP (10/23)
+reports that the US Embassy in Ankara, Turkey "issued a security alert on Friday, saying it had received reports
+of a possible coming attack on Americans and other foreigners, and temporarily suspended consular services."
+According to the AP, the embassy "urged American citizens to exercise caution, including while at large office
+buildings, shopping malls and other places foreigners gather. It said citizen and visa services would be suspended
+temporarily at all U.S. consulates in Turkey."
+The Washington Post (10/23, Fahim, 14.2M) reports
+that the State Department "issued [the] unusually sharp warning Friday about new threats to U.S. citizens in
+Istanbul, saying that the U.S. Mission in Turkey has received 'credible reports of potential terrorist attacks and
+kidnappings' targeting Americans and other foreign nationals." The Post adds, "A Turkish government
+spokesman said the country's Interior Ministry would release a statement about the security warning later
+Friday."
+Counter-Intelligence
+Sen. Johnson: FBI Interviewed Hunter Biden's Former Partner.
+The Washington Times (10/23, Scarborough, 492K) reports Senate Homeland Security and Government Affairs
+Chairman Ron Johnson on Friday announced the FBI "interview[ed] former Hunter Biden business partner Tony
+Bobulinski, who came forward on Wednesday to assert that he met with Joseph R. Biden about his son's
+profitable foreign business ventures." The Wall Street Journal < https://www.wsj.com/articles/hunter-bidens-ex-
+business-partner-alleges-father-knew-about-venture-11603421247> (10/23, Duehren, Areddy, Subscription
+Publication, 7.57M) reports Bobulinski has alleged that Joe Biden worked with his son to set up an investment
+firm in partnership with a Chinese state-controlled oil company, although the deal never came to fruition.
+Republicans Advocate For Investigations Into Hunter Biden Emails. White House Chief of Staff Meadows, on
+Fox News' Sunday Morning Futures (10/25),
+said, "It's very important because what we see is what most Americans hate about Washington DC: a politician
+EFTA00136999
+
+gets elected and they go out and enrich themselves and their family and there's no denying that that's happened
+here when we start to see the evidence, whether it comes out in the next nine days or the next nine months, Joe
+Biden will be at the very center of this. He will be a guilty player in all of this and when you start to look at the
+mounting evidence, whether it is with money laundering or whether it is with a number of witnesses that are now
+coming forward, Joe 's story just doesn't holdup."
+Sen. Ron Johnson (R-WI), on Fox News' Sunday Morning Futures
+ (10/25), said, "The Vice President is lying,
+again. Check out page 78 of our report where we show a company, a Chinese company, CEFC, transferred about
+$5 million to businesses controlled by Hunter Biden. $5 million, so no, he's lying. He's lying about the fact he
+said he never spoke to his son Hunter about his overseas business connections, flew over to China, had a
+handshake with Jonathan Li, who ended up being a business partner in BHR, which is that investment firm and
+we documented and talked to the Vice President and the conflict of interest in Ukraine, the Vice President then
+talked to Hunter to raise a meeting with Amos Hochstein, so the Vice President has been caught in repeated lies
+over Biden Ine about his family's businesses."
+RNC Chair Ronna McDaniel, on Fox News Sunday
+ (10/25, 1.27M),
+said, "I think that it's incumbent upon the press to start investigating. I think what's frightening is we should
+have a free and fair press that should be looking at a laptop that has not been disputed by the Biden campaign to
+be authentic. These emails are deeply troubling as it looks like Hunter Biden is negotiating with a Chinese
+energy company to profit not just for himself, but for his father, but it warrants an investigation. That's not my
+job. That's the press" job. That's for the FBI, those who have this laptop, to look into it."
+Trump 2020 Director of Press Communications Erin Perrine was asked on Fox News' MediaBuzz
+ (10/25, 536K)
+about conservatives who say making Hunter Biden a top campaign issue is a mistake. Perrine said, "talking
+about a wide variety of things here but, again, this is the 47 months versus 47 years argument the President's
+been making the entire time. The reason President Trump is President of the United States is a rejection of the
+Obama/Biden policies and a corrupt crooked Hillary Clinton Inc. That's why he is President.... So absolutely,
+this is going to be part of the conversation even if the media doesn't want to do their job and cover it."
+Michigan Gov. Gretchen Whitmer (D), on Fox News Sunday
+(10/25, 1.27M),
+said, "[Joe Biden] has answered these questions. The American people aren't going to be distracted from the fact
+that this election is about the dinner table issues. The dinnertable issue of 2020 is a Trump administration that has
+never been able to have a national strategy on COVID. The dinnertable issue is the tens of millions who are
+unemployed because of the lack of a national strategy around COVID. The dinnertable issue is the fact that so
+many people are in line at the food pantries across the country because of a lack of national strategy around
+COVID. That's what we need to be focusing on, because that is life and death for the people of this country and
+having a President who gets it, who has a plan, who will get us back to work and keep us safe, that's what Joe
+Biden offers."
+In her Washington Post (10/25, 14.2M) column, Monica Hesse
+says the Trump campaign's final strategy "has landed, convolutedly, on the narrative that Hunter Biden is an
+inconvenient son," but "as a starting place, we might note that Joe Biden's response to all of this has been to love
+his son." According to Hesse, 'Hunter Biden might not be the son America dreams of having. Joe Biden might
+be the dad."
+Giuliani Allies Advance His Claims On Hunter Biden. Under the headline "Giuliani's Crew Of Misfits And
+Hucksters Storms Into The Hunter Biden Wars," the Daily Beast (10/25, Markay, 1.39M) reports
+that according to "bombastic private investigator" Bo Dietl, former NYPD Commissioner Bernie Kerik, "white
+EFTA00137000
+
+shoe attorney" Bobby Costello, and "whistleblower" Bradley Birkenfeld are among "a makeshift team of
+investigators, cynical political operatives, and loyal Trump boosters who have latched on to the Hunter Biden
+saga as the miracle cure for the president's re-election woes.*
+Putin Rejects Trump's Criticism Of Hunter Biden's Business In Ukraine, Russia. Reuters
+ (10/25, Osborn) reports Russian
+President Vladimir Putin "said on Sunday that he saw nothing criminal in Hunter Biden's past business ties with
+Ukraine or Russia, marking out his disagreement with one of Donald Trump's attack lines in the U.S.
+presidential election." Reuters adds Putin, "who has praised Trump in the past for saying he wanted better ties
+with Moscow, has said Russia will work with any U.S. leader, while noting what he called Joe Biden's "sharp
+anti-Russian rhetoric.
+WSJournal Rejected Effort By White House Allies To Push Hunter Biden Email Story. In a nearly 2,300-word
+article, the New York Times (10/25, Smith, 18.61M) reports two sources say that in October, three allies of the President
+met with "straight-shooting" Wall Street Journal White House reporter Michael Bender, to pitch him on writing
+an article about "a cache of emails detailing Hunter Biden's business activities." According to the Times, "The
+Trump team left believing that The Journal would blow the thing open and their excitement was conveyed to the
+president." However, the Times adds that as they "waited with excited anticipation for a Journal exposé, the
+newspaper did its due diligence," and after the New York Post broke the story, ultimately "published a brief item,
+just the stub of [its] reporting. The core of it was that [Hunter Biden's former business partner Tony Bobulinski]
+had failed to prove the central claim."
+Meanwhile, a New York Times (10/25,
+Lipton, Vogel, Haberman, 18.61M) analysis says "there is no evidence that the former vice president was
+involved in or profited from a joint venture pursued by his son and brother."
+However, the Wall Street Journal (10/25,
+Subscription Publication, 7.57M) editorializes that the press has a progressive bias, as is evident from the
+response to its reporting on Hunter Biden. The Journal accuses other mainstream media outlets of wrongly using
+their influence to advance Democrats at the expense of the public.
+Parnas: Giuliani Was Offered Salacious Documents Belonging To Hunter Biden In Spring 2019. Politico
+ (10/24, Bertrand,
+4.29M) reports President Trump's personal lawyer Rudy Giuliani "was offered salacious photos and other
+documents belonging to Joe Biden's son Hunter in the spring of 2019, earlier than previously known, according
+to one of Giuliani's closest former associates." Moreover, the alleged offer was made by a Ukrainian oligarch
+seeking assistance "with a potential legal jam." According to Politico, "The claim made by Lev Parnas, a
+Ukrainian-born businessman who was indicted last year on campaign finance charges, raises new questions
+about the provenance of the materials Giuliani has said he obtained recently from a computer repair shop in
+Delaware - and that he is now touting to accuse the Democratic nominee of corruption." Parnas, "who
+collaborated with Giuliani on the former New York mayor's quest to find damaging information on the Bidens
+beginning in late 2018, now says that similar materials were being offered to Giuliani just weeks after Joe Biden
+launched his presidential run."
+Politico Analysis: MAGA World Attempting "To Conjure Up The Same Event That Helped Them" During 2016
+"Home Stretch." A Politico (10/24, Nguyen, 4.29M) analysis says that "MAGA world is trying to conjure up the same event that
+helped them in the home stretch of 2016 - an out-of-left-field FBI investigation into their opponent." Though
+"the ingredients are all the same," an FBI probe is not, in the current instance, "supplying the ingredients.
+Instead, MAGA adherents are sourcing the ingredients and hoping they summon an FBI investigation. And, of
+course, the new target is Joe Biden, not Hillary Clinton." According to Politico, Giuliani "has obtained a laptop
+he claims belongs to" Hunter Biden and has given the laptop "to the FBI, claiming it contains emails that show a
+variety of misdeeds and corruption - even if the emails aren't all verified, don't offer conclusive evidence of the
+EFTA00137001
+
+misdeeds and bear the hallmarks of a Russian disinformation effort."
+In his Washington Post (10/24, 14.2M) column, Max Boot says that while Trump "got himself
+impeached by trying to blackmail Ukrainian officials into accusing Biden and his son Hunter of wrongdoing," it
+has not "stopped the right-wing scandal merchants from employing the supposed Hunter Biden emails to malign
+his father." Boot concludes, "The scandal is not anything that Joe Biden did. It is that Trump is running what
+may be the sleaziest presidential campaign since the notorious election of 1800 - or possibly ever."
+Russian Bankers Ask Judge To Depose Steele Dossier Source Danchenko.
+The Daily Caller (10/25, 716K)
+reports lawyers for Alfa Bank "asked a federal judge on Friday to order Igor Danchenko, the primary source for
+the Steele dossier, to appear for a deposition regarding his work on the salacious document." The Daily Caller
+adds the lawyers "said in a court filing on Friday that Danchenko had rejected a subpoena to appear voluntarily
+for a deposition in a lawsuit against Fusion GPS, which commissioned the infamous dossier on behalf of the
+Clinton campaign and DNC." According to the Daily Caller, German Khan, Peter Aven, and Mikhail Fridman,
+the owners of Alfa Bank, "are suing Fusion GPS for defamation over one of the memos from Christopher
+Steele's 35-page dossier."
+Judge Orders DOJ To Verify Filings In Flynn Case.
+Politico (10/23, Cheney, 4.29M) reports US District Judge Emmet Sullivan, who is "presiding over
+the criminal case against former national security adviser Michael Flynn," on Friday "ordered the Justice
+Department to conduct an unusual review of its filings in the case and certify by Monday whether any have been
+manipulated." Politico describes the order as "a signal of intense distrust" between Sullivan and the DOJ,
+"whose filings are typically accepted at face value." According to Politico, the DOJ "acknowledged that two
+documents it previously filed - handwritten notes taken by former FBI counterintelligence agent Peter Strzok
+and former FBI deputy director Andrew MeCabe - were altered 'inadvertently' to include inaccurate dates."
+CISA Contradicting Trump's Attempts To Question Election.
+The AP (10/24, Fox) reports that a day after President Trump this month
+"predict[ed] on Twitter that this election would be 'the most corrupt' in American history," Christopher Krebs,
+the director of the Cybersecurity and Infrastructure Security Agency, "an obscure government agency he
+created," ended an online conference by saying, "I have confidence that your vote is secure, that state and local
+election officials across this country are working day in and day out, 24/7, that the 2020 election is as secure as
+possible." According to the AP, CISA "has been offering a counternarrative as it works behind the scenes to not
+only help safeguard the election but also to reassure the public despite messages to the contrary from the White
+House."
+In addition, the Washington Post (10/24, Gardner, Stanley-Becker,
+Viebeck, 14.2M) reports state and local officials "hastened to reassure Americans this week that the nation's
+election systems are secure after the country's top intelligence official accused Iran of sending threatening emails
+to voters in several states and the United States said Russia obtained voter information from at least one county."
+EFTA00137002
+
+The Post adds US officials "and cybersecurity experts said the activity did not appear to include penetration of
+voting systems or access to voter registration databases, or the hacking of equipment that could be tampered with
+to alter election results."
+However, Trump on Saturday tweeted ,
+"What a terrible thing for Biden to say! Rigged Election?" He added
+, "Law Enforcement is watching and
+involved. So dishonest!"*
+The Washington Post (10/24, Stanley-Becker, Romm, 14.2M) reports election offices nationwide have seen
+an uptick in questions about the integrity of the election, "including many where residents have routinely voted
+by mail, said" Weber County Clerk Ricky Hatch (R), "who also chairs the election committee for the National
+Association of Counties." The Post adds, "In many cases, the worries can be traced to baseless or alarmist
+statements by President Trump and posts on his Twitter feed. Others have been fed by headlines stripped of
+context and misleading reporting in the mainstream media, according to election administrators, voting rights
+advocates and experts in online communication." According to the Post, "The confusion and chaos follow a
+months-long campaign by Trump and his allies to sow doubt about voting by mail, a method of casting ballots
+that has been embraced in Democratic- and Republican-leaning states and has grown more popular this year
+because of the coronavirus pandemic."
+Meanwhile, the New York Times
+(10/23, Grady, 18.61M) highlighted a new Centers for Disease Control and Prevention report that "cites lessons
+learned from Delaware's primary and suggests that voters could use some instruction in the right way to wear a
+mask." The Times reported that while "many states and cities have imposed safety measures to protect voters and
+poll workers from exposure to the coronavirus," the CDC on Friday warned that polling places "still have the
+potential to become 'mass gathering events," and it announced "measures to prevent the spread of Covid-19
+could be improved." CNN (10/23, 83.16M) reports similarly.
+Bloomberg View: US Election Security Effort Robust Despite President's Public Comments. The editorial board
+of Bloomberg View (10/25, 4.73M) wrote that the US government "has gone to extraordinary lengths to
+protect this year's election from foreign interference." Last week, for instance, DNI Ratcliffe and FBI Director
+Christopher Wray "held a joint briefing to warn that Iran and Russia had obtained registration data and (in Iran's
+case) sent fraudulent emails intended to intimidate voters." On October 15, DOJ "announced the indictment of
+six Russian intelligence officers who had engaged in politically motivated computer attacks around the world,
+including one who had previously been charged for the 2016 incident." Behind the scenes, national security
+agencies "have frozen the assets of foreign hackers, imposed sanctions, revoked visas, knocked spies offline,
+prevented suspected adversaries from entering the U.S., and worked with social-media companies to take down
+suspect accounts, all in a preemptive effort to prevent further meddling." The moves are "in marked contrast to
+the president himself, who has said next to nothing about election interference publicly."
+Cuccinelli Addresses Foreign Interference In US Election.
+On the RJ Harris Show (10/23), Acting DHS Deputy Secretary Ken Cuccinelli addressed the department's recent
+report on foreign interference in the election. On the Mike Broomhead Show
+ (10/23),
+Cuccinelli explained "what information the Russians and Iranians got from us," and sought to reassure
+"Americans that their votes cannot be changed or negated."
+EFTA00137003
+
+Ransomware Attack On Georgia County Government Disables Voter Signature Database.
+The AP (10/23, Bajak) reports, "A ransomware attack that hobbled a Georgia
+county government in early October reportedly disabled a database used to verify voter signatures in the
+authentication of absentee ballots." The ransomware attack marks "the first reported case of" such an attack
+impacting "an election-related system in the 2020 cycle." The attack on Hall County, which took place on
+October 7, "hit critical systems and interrupted phone services, the county said in a statement posted on its
+website." The AP paraphrases a Gainesville Times report as having said that "the attack also disabled the
+county's voter signature database."
+Atlanta Journal-Constitution: Georgia Voting System Vulnerable To Cyberattacks. The Atlanta Journal-
+Constitution (10/23, 895K) reports, "Georgia's new electronic voting
+system is vulnerable to cyberattacks that could undermine public confidence, create chaos at the polls or even
+manipulate the results on Election Day." While state officials "have dismissed" concerns over "security
+deficiencies in Georgia's system and in electronic voting in general," a Journal-Constitution investigation
+"shows...Secretary of State Brad Raffensperger's office weakened the system's defenses, disabling password
+protections on a key component that controls who is allowed to vote." His office has also "pushed out new
+software to each of the state's 30,000 voting machines through hundreds of thumb drives that experts say are
+prone to infection with malware." The Journal-Constitution urges officials to "tell voters to verify their selections
+on a paper ballot before feeding it into an optical scanner."
+O'Brien Says Hackers Can't Change Votes.
+Politico (10/25,
+Hooper, 4.29M) reports National Security Adviser Robert O'Brien told CBS' Face The Nation
+ Sunday that
+Russian hackers who have carried out attacks on state and local governments "can't change votes" in the Nov. 3
+elections. Asked if hackers can change votes or make it more difficult to vote, O'Brien said, "No, they can't do
+either of those things. And we got ahold of them early on because we've got great cyber folks, and we put a stop
+to it, but there's nothing they can do to change your vote or to stop you from voting."
+Fox News (10/25, O'Reilly, 27.59M) reports that O'Brien's comments "come just days after U.S. officials
+said that Russian hackers have targeted the networks of dozens of state and local governments in the United
+States in recent days, stealing data from at least two servers." The NSA official "tried to assure Americans that
+the hackers can't change voters or make it harder to cast a ballot." However, he said, "the actor may be seeking
+access to obtain future disruption options, to influence U.S. policies and actions, or to delegitimize (state and
+local) government entities."
+Voters Urged To Be Careful When Opening Election-Related Mail.
+The Detroit Free Press < https://www.freep.com/story/news/politics/elections/2020/10/25/emails-russia-iran-
+disinformation-2020-election/6012932002/> (10/25, 1.52M) urges voters to "be extra cautious when election-
+related emails swoosh into their inboxes." For instance, voters in some states recently "received threatening
+emails claiming to be from the far-right, authoritarian group Proud Boys," though those were "part of a
+EFTA00137004
+
+disinformation campaign," according to DNI Ratcliffe. Last week, Ratcliffe "Iranian hackers were behind the
+attack." University of Michigan's director of the Center for Social Media Responsibility, Paul Resnick, said
+voters should stay alert. He said, "If you're thinking, "This might be a phishing attack'... You're already halfway
+to safety." The Free Press also advises voters to check the address and if they suspect something out of the
+ordinary, to "get an independent verification of the information."
+Editorial: Americans Must Brave Outside Attacks On Elections And Vote.
+The editorial board of the San Antonio Express-News
+ (10/23, 762K) writes that a "cyberwar against the U.S." is being waged on the election. Threats
+such as the recent emails received by voters in multiple states from actors claiming to be far-right extremists
+"should spark bipartisan concern." The email attack, which has been attributed to Iran, was a "deliberate act to
+damage America, either by scaring voters or exacerbating existing tensions, and we see a government that should
+be more transparent with voters about these threats." The editorial board urges voters to "be mindful of these
+outside attacks, resist their fearmongering and divisiveness, and vote."
+FBI Alerted After Online Video Implies Maryland Election Judge Improperly Marked Ballot.
+WUSA-TV Washington (10/23, 98K) reports that the FBI has been alerted to a suspected "intentional
+disinformation attack this week" in Montgomery County, Maryland, "according to James Shalleck, the President
+of the County's Board of Elections." A video "showing an election judge marking a mail-in ballot with a pen"
+was circulated online, though "county elections authorities say [they] are false claims of election fraud." The FBI
+said its "standard practice is to neither confirm nor deny any investigation, we take all election-related threats
+seriously, and, we're committed to supporting our election security partners and protecting the American people
+during the 2020 election season." A Montgomery County investigation "determined the worker seen in the video
+was filling in a lightly marked mail-in ballot so that it could be accurately read by counting machines, according
+to elections authorities."
+Cybersecurity Experts Concerned Over Threat Of Disinformation From Within US.
+The New York Times
+(10/25, Niu, Bracken, Eaton, 18.61M) reports that experts are more concerned with disinformation coming from
+our very own backyard" than that coming from Russia or other foreign countries. For instance, one man, "with a
+single tweet, disrupted a governor's race in Kentucky" in 2019. The incident "became one of the most viral
+pieces of disinformation in an already close election and cast doubt on the results." The Times says the "same
+pattern is already playing out this year, with the added layer of uncertainty caused by the coronavirus pandemic."
+Currently, "there is no unified policy from the major tech companies when it comes to combating election
+misinformation."
+Continuing Coverage: DOD, ODNI Release Intel Budget Requests For FY21.
+Bloomberg Government (10/23) reported that DOD and ODNI "released their intelligence budget requests for fiscal 2021
+EFTA00137005
+
+totaling $85 billion earlier this year." The agencies "released enacted 2020 figures Oct. 21, allowing for
+comparisons and revealing a slight decrease from $85.8 billion total in the fiscal 2021 request." The intelligence
+budget is "comprised of two primary categories, the Military Intelligence Program (MIP) and the National
+Intelligence Program (NIP)." MIP includes "spending for the intelligence components of the military services as
+well as some of the funding for intelligence agencies that fall under DOD" such as DIA and NGA. NIP includes
+funding for agencies such as CIA, "portions of the FBI," INR, "as well as some portion of the DOD-controlled
+agencies."
+Kremlin Laments US Election Campaigns' Focus On Dislike For Russia.
+Reuters (10/23, Antonov) reports, "The Kremlin
+said on Friday it regretted that US election campaigns seem like competitions for candidates to show how much
+they dislike Russia, but that it was only up to American voters to pick a new president on Nov. 3."
+US Imposes Sanctions On Russian Government Research Center Involved In 2017 Cyberattack.
+The New York Times (10/23, Perroth, 18.61M) reports that the US on Friday "imposed economic sanctions against a
+Russian government research organization that was responsible for a potentially deadly cyberattack on a Saudi
+petrochemical facility in 2017." Though the target was not named, "description of the attack matched with a
+hacking that year of Petro Rabigh, the Saudi oil giant, that shut off the safety systems that are used to prevent an
+explosion." The State Research Center of the Russian Institute of Chemistry and Mechanics "built the custom
+tools used in a spate of 2017 attacks on oil facilities in the Middle East as well as attempted hackings of at least
+20 electric facilities in the United States." Officials said the tools had the "capability to cause significant physical
+damage and loss of life." The 2017 episode "prompted an investigation" by the NSA, FBI, DHS, and "the
+Pentagon's Defense Advanced Research Projects Agency, as well as investigators at Schneider, the security firm
+FireEye's Mandiant security team and Dragos, a security firm that specializes in industrial control security'"
+The Washington Post (10/23, Nakashima, 14.2M) reports,
+"The Treasury Department's designation of an institute of the State Research Center of the Russian Federation
+marks the first time the United States has sanctioned hackers for targeting industrial control systems, analysts
+said." Treasury Secretary Steven Mnuchin said, The Russian Government continues to engage in dangerous
+cyber activities aimed at the United States and our allies. .. This Administration will continue to aggressively
+defend the critical infrastructure of the United States from anyone attempting to disrupt it." Assets held by the
+institute in the US are frozen, "and Americans are barred from engaging in transactions with the lab." Treasury
+"said in a news release that the use of the Triton malware 'against our partners is particularly troubling given the
+Russian government's involvement in malicious and dangerous cyber-enabled activities.**
+Also reporting are Reuters (10/24, Satter), Bloomberg
+ (10/23, Mehrotra, 4.73M), and The Hill https://thehill.com/policy/cybersecurity/522504-treasury-
+sanctions-russian-group-for-targeting-us-critical-facilities» (10/23, 2.98M).
+Report: Russian Scientists Were In Contact With Military Science Institute Developing Novichok Nerve Agent.
+EFTA00137006
+
+CNN (10/23,
+Lister, 83.16M) reports, "Bellingcat has uncovered new details about Russia's development of the Novichok
+nerve agent," which was used against Sergei Skripal in 2018 and Alexey Navalny this year. The investigative
+group "found frequent contacts between the director of a military science research institute in St. Petersburg and
+the agents accused of poisoning Skripal and his daughter Yulia with Novichok in the English city of Salisbury in
+March 2018." The Bellingcat report was published on Friday. It "finds that scientists previously working for the
+Russian Ministry of Defense 'were dispersed into several research entities which continued collaborating among
+one another in a clandestine, distributed R&D program."
+Bloomberg (10/23, Meyer, 4.73M) reports that Bellingcat "said it found close links between two
+research organizations that allegedly have masterminded the Novichok program since 2010 - the St. Petersburg
+State Institute for Experimental Military Medicine of the Ministry of Defense and the Scientific Center Signal -
+and a clandestine unit of Russia's GRU military intelligence." Watchdog group the Organization for the
+Prohibition of Chemical Weapons "earlier this month confirmed that Navalny was poisoned by a military-grade
+Novichok nerve-agent on Aug. 20, when he was campaigning for anti-Putin candidates in elections in Russia's
+Siberia."
+Putin Purges FSB As He Reiterates Lack Of Involvement In Navalny Poisoning. The Daily Beast
+
+(10/23, 1.39M) reports, "President Vladimir Putin vowed on Thursday he would not be swayed by Western
+pressure over the poisoning" of Alexei Navalny. Still, a "reported mysterious shakeup in a Russian intelligence
+agency, and other comments by Putin, suggest the Kremlin has been forced to at least try to demonstrate distance
+between the president and those who might be behind" the poisoning of Putin's "prominent domestic critic."
+Putin has "declared he had personally allowed Navalny to leave Siberia for Berlin for medical treatment, which
+saved the opposition leader's life." The Russian President also "fired the deputy director" of FSB, General Sergei
+Smirnov, "according to a report in a respected business newspaper, RBK."
+Criminal Investigations
+Maxwell's Attorneys: US Prosecutors Not Honoring Promise To Supply Evidence.
+Bloomberg (10/24, Hurtado, Burnson, 4.73M) reports, "Ghislaine Maxwell's lawyers
+say U.S. prosecutors are reneging on a promise to provide her with the evidence they've collected in her sex-
+trafficking case." According to Bloomberg, "The government's failure to provide the evidence makes it
+impossible for Maxwell to prepare her defense, the British socialite's lawyer Jeffrey Pagliuca said Friday in a
+letter to U.S. District Judge l
+" As an illustration, the indictment does not provide exact "dates for
+when Maxwell committed the alleged crimes, only saying they occurred between 1994 and 1997, Pagliuca said."
+He wrote, "Neither the indictment nor the discovery inform Ms. Maxwell about critical information necessary to
+prepare her defense."
+Teenager Sentenced To Time In Juvenile Facility, Probation For Plotting Attack On Black Church.
+The Hill https://thehill.com/blogs/blog-briefing-room/news/522608-teen-accused-of-plotting-to-attack-black-
+church-sentenced-to> (10/24, Pitofsky, 2.98M) reports, "A 17-year-old girl who was accused of plotting an
+attack against a predominantly Black church was sentenced to four years in a juvenile facility and probation on
+Thursday." According to The Hill, "The teenager, who is white, was arrested and charged last year after law
+enforcement officials discovered her alleged plan to attack parishioners of the Bethel African Methodist
+EFTA00137007
+
+Episcopal Church in Gainesville, Ga., with knives." CNN reported that in a statement, Sixth Episcopal District of
+the AME Church Presiding Prelate Bishop Reginald Jackson said, "While we are angered and frustrated by this
+incident, we do not hold hostility against this defendant. While she apparently hates or hated us, we do not hate
+her, and do not wish to nullify her future, and do not give up on her."
+California Prosecutors To Again Seek Death Penalty For Peterson.
+The AP «https://apnews.com/article/san-francisco-us-news-california-courts-
+9f6862c21cf96d5736f574787d5af446> (10/23, Thompson) reports prosecutors in California "said Friday they
+again will seek the death penalty for Scott Peterson even as a county judge considers throwing out his conviction
+for murdering his pregnant wife because of juror misconduct during a 2005 trial that riveted the nation."
+Stanislaus County Assistant District Attorney Dave Harris "announced that it is prosecutors' intention to retry the
+penalty phase of the case, spokesman John Goold said after a court hearing."
+NXIVM Leader Speaks Ahead Of Sentencing.
+NBC Nightly News (10/23, story 10, 2:54, Holt, 1.82M) reported on an interview with NXIVM leader Keith Raniere to
+"Dateline" from jail "for the first time since his arrest." Correspondent Stephanie Gosk referred to NXIVM as *a
+shadowy self help organization described by federal prosecutors as cult-like." Raniere "has not spoken publicly
+since his arrest for than two years ago," and Gosk indicated that his interview occurred days before his
+sentencing on federal charges. Raniere "spoke with, of all people, the man that helped bring him down, web
+journalist Frank Parlato, a former NXIVM spokesman." Parlato asked, "Do you intend to make a statement at
+your sentencing that you are innocent?" As part of his response, Raniere said, "Yes, I am innocent." He also said
+during the interview, "There is a horrible injustice here and whether you think I'm the devil or not, the justice
+process has to be examined."
+Teen Plotted To Assassinate Joe Biden, Federal Authorities Say.
+The Washington Post
+(10/23, Bella, 14.2M) reports 19-year-old Alexander Hillel Treisman appears to have planned and threatened to
+assassinate Joe Biden, federal authorities say. The teen "searched online for Biden's home address and for night-
+vision goggles, and purchased an AR-15 in New Hampshire, according to federal court documents first reported
+Thursday by WBTV." In the spring, "Treisman ended up at a Wendy's within four miles of Biden's home in
+Delaware." After "he was arrested later that month in North Carolina, police searching his van found four rifles,
+a 9mm handgun, explosive materials, books on bomb making, and $509,000 in cash that's believed to be his
+inheritance." These "revelations all come in an order that a federal magistrate judge filed earlier this month
+outlining why Treisman, who was indicted by a federal grand jury in September on child pornography charges,
+should remain in custody:" It remains "unclear whether Treisman will face additional charges related to the
+alleged plot."
+ABC World News Tonight (10/23, story 7,
+1:22, Holt, 1.82M) reported, "Police near Charlotte, North Carolina say when they checked out an abandoned
+van in this bank parking lot they found guns and cash inside."
+The AP < https://www.usatoday.com/story/news/nation/2020/10/23/man-van-full-guns-had-plans-execute-joe-
+biden/3740228001/> (10/23) reports from Kannapolis, North Carolina that Treisman "had searched earlier this
+year for Democratic presidential candidate Joe Biden's home online, traveled near the home and wrote a
+checklist that ended with the word 'execute,' according to federal court documents." The AP adds, "The
+information was contained in documents related to a detention hearing for Alexander Hillel Treisman, held in
+U.S. District Court in Durham. A magistrate, in an order signed Oct. 8, ordered Treisman to remain in custody."
+According to the AP, "An officer with the U.S. Marshal's Service and the Joint Terrorism Task Force testified
+that a search of Treisman's electronic devices and account showed a timeline of internet searches between March
+and May of this year seeking information about Biden's home address, state gun laws, rifle parts and night vision
+goggles."
+CNN
+(10/24, Campbell, 83.16M) reports, "Between March and May 2020," Treisman "conducted internet searches on
+Biden's home address and traveled within 4 miles of the Biden residence, according to a detention order signed
+by a federal magistrate judge." CNN adds, "After describing Treisman's alleged interest in Biden, the judge
+wrote that authorities also discovered a checklist believed to have been written by the defendant, which included
+the word 'execute." Also included in a list of evidence noted by the judge was an online meme posted by
+Treisman in April 2020 with the caption: 'should I kill joe biden?' The information about the former Vice
+President was included among a lengthy list of evidence that prosecutors included in his case. Although a grand
+jury indicted Treisman for possession of child pornography, he has not been charged in relation to the weapons in
+his possession, or his research or writings on Biden. Prosecutors declined to talk about any potential future
+charges."
+CBS News (10/23, O'Kane,
+3.68M) reports, "While Treisman faces pornography charges and has not been charged with any crimes related to
+his possession of guns or other evidence, a judge ruled that due to the evidence, he should remain in custody."
+Treisman, "who used the alias Alexander S. Theiss, is from Washington and was arrested in May after police in
+Kannapolis, North Carolina, received calls about a van left in a parking lot. Through the window of Treisman's
+green Honda, which was left outside of a bank, Kannapolis police officers saw 'an AR-15 style rifle,' explosive
+material, a box for a handgun and ammunition, FBI Special Agent Aaron Seres testified, according to the court
+documents."
+Former Ohio City Councilman Arrested On Human Trafficking Charges.
+The Cincinnati Enquirer < https://www.usatoday.com/story/news/nation/2020/10/24/michael-mearan-charged-
+sex-trafficking/6027744002/> (10/24, Hunt, Grasha, Dufour, Mitchell, 223K) reported former Portsmouth, Ohio
+city councilman and still-practicing attorney Michael "Mearan was arrested on human trafficking, racketeering
+and related charges." Victims allege that "Mearan, as a prominent attorney, would represent women facing drug
+charges," promise "them lenient sentences from judges he knew and parole officers willing to ignore probation
+requirements," so long as the women agreed "to have sex for money." Women said they "were paid anywhere
+between $200 and $2,000 per encounter, and in some of the instances, Mearan himself handled the payment."
+FBI Investigating Border Patrol Officer-Involved Shooting.
+EFTA00137009
+
+USA Today (10/25, Falcon, 10.31M) reports the FBI and local police in Texas are
+investigating after a "U.S. Border Patrol officer-involved shooting that killed one man and injured two in Laredo,
+Texas, on Friday night." US Border Patrol Laredo Sector's Chief Patrol Agent Matthew Hudak "said U.S. Border
+Patrol, U.S. Homeland Security, and Webb County Sheriff's Office intercepted a tractor trailer truck in Laredo
+that was used to smuggle a large number of undocumented immigrants." A vehicle arrived on the scene, "and as
+it got close enough to realize the smuggling load had already been intercepted, the driver aggressively put his
+vehicle in reverse and tried to flee the scene," Hudak said in a video.
+The New York Times (10/25,
+Levenson, 18.61M) reports Border Patrol agents shot and killed the driver of the vehicle after it "reversed into an
+agent and pinned him against another vehicle, according to U.S. Customs and Border Protection." The driver
+"died at the scene. The Border Patrol agent, who sustained leg injuries, was taken to a hospital and later
+released." Hudak said two other occupants of the car were also injured. An FBI San Antonio spokesperson
+"confirmed on Sunday that the bureau was participating in the investigation."
+The AP (10/24) reports the vehicle was "another semi," and after "officers identified themselves and were
+approaching the tractor-trailer when the driver began moving in reverse, pinning a Border Patrol agent against
+another vehicle. Other agents then opened fire, shooting the driver, who was pronounced dead at the scene."
+Illinois Police Department Fires Officer Who Killed Black Teen As FBI Joins Shooting Investigation.
+The Lake County (IL) News-Sun (10/24, Ward, 1.75M) reports Waukegan,
+Illinois, Police Chief Wayne Walles announced Friday that an "officer who shot and killed a 19-year-old Black
+man and wounded his girlfriend has been terminated from the department...hours after Lake County's chief
+prosecutor said the FBI would be joining the investigation into the incident." Walles "said the officer had been
+fired for "multiple policy and procedure violations' related to the death of Marcellis Stinnette and the wounding
+of Tafara Williams."
+The AP (10/23) reports Lake County State's Attorney Michael Nerheim said the bureau "will join Illinois State
+Police in investigating a police shooting in suburban Chicago that killed a Black man who was a passenger in a
+vehicle and wounded the Black female driver," saying "he asked the U.S. Justice Department to review the
+circumstances surrounding the fatal shooting."
+Reuters (10/23, Staff) reports the Waukegan Police Department "said a
+Hispanic male officer shot into the couple's car because it went into reverse when he approached it and he feared
+for his safety. No firearm was found in the vehicle, the police said."
+The Hill (10/23, Polus, 2.98M) reports state officials "had previously opened an investigation into
+wrongdoing by the cop in question, a five-year veteran of the suburban Chicago police force, who opened fire at
+the couple after they fled a traffic stop. Now, the FBI is joining the efforts after County State Attorney Michael
+Nerheim requested that the bureau review the circumstances surrounding the incident."
+FBI Investigating "Ambush Style" Killing On Crow Reservation In Montana.
+EFTA00137010
+
+The Billings (MT) Gazette (10/25, Kordenbrock, 180K) reports
+the FBI is leading the investigation into "an 'ambush style homicide' Saturday on the Crow Reservation Saturday
+left one person dead." A press release from the Crow Tribe Executive Branch "says that two members of a
+federally recognized tribe were involved.... The Crow Tribe Executive Branch, citing the Crow Tribal Police,
+identifies the suspect in the killing as 27-year-old Taylor Leigh Plainbull."
+FBI Set To Release New Information On 1981 New York Cold Case.
+WSYR-TV Syracuse, NY (10/23, 58K) reports next week the FBI is set to release new information on "one of Central
+New York's coldest cases. Tammy Mahoney was last seen in Oneida in 1981. The 20-year-old Morrisville State
+College student was hitchhiking south on Route 46" when she was "picked up and taken to a party on the Oneida
+Nation."
+Nearly $100K In Narcotics Seized In Florida Operation.
+The Fort Myers (FL) News-Press (10/23, Greenockle, 173K) reports, "The Lee County
+Sheriff's Office said it arrested a Cape Coral man Wednesday after finding about $100,000 worth of narcotics
+while serving him a warrant on an unrelated case." According to the News- Press, "The U.S. Marshalls Regional
+Fugitive Task Force served a warrant on Leonard Pitters, 26, in the 1100 block of NE 11th Street, Cape Coral, for
+aggravated assault with a deadly weapon for an active case from June 17, according to an LCSO news release. In
+that case, Pitters allegedly battered and threatened his victim at gunpoint." The News-Press adds, "The narcotics
+unit took over the investigation and got a search warrant for Pitters' home where they found cocaine, fentanyl,
+heroin, crack cocaine, oxycodone, hydrocodone pills, two firearms and $87,452 in U.S. currency, the release
+states."
+FBI Releases Photo Of Florida Bank Robbery Suspect.
+WFOR-TV
+Miami (10/23) reports, "The FBI is releasing a picture of a robber who robbed a Pompano Beach bank on Friday
+afternoon." The suspect "is wearing a light blue button-down shirt with collar, a black Under Armor baseball hat
+with a red, white and blue logo, sunglasses and a black neck gaiter mask."
+Six California Gang Members Indicted On Federal Charges.
+The San Jose (CA) Mercury News (10/23, 456K) reports US Attorney for the
+Northern District of California David L. Anderson and other law enforcement officials on Thursday "named
+members of a Salinas gang "murder squad' in an unsealed federal indictment on Thursday describing how six
+Norteño gang members allegedly conducted seven shootings, killing eight people and injuring several others."
+The piece quotes FBI SAC John Bennet saying, "Over the past three years, the FBI San Francisco Division has
+worked to link this murder squad with the Nuestra Familia and Norteño street gangs."
+EFTA00137011
+
+California Man Faces Federal Child Pornography Charges.
+The Sacramento (CA) Bee (10/23, 567K)
+reports a federal grand jury has indicted Jayson Fernandez Butay of Sacramento, California, for "producing and
+possessing child pornography in connection with an FBI investigation of alleged exchanges he had on Snapchat,
+according to filed court documents." Butay "is accused of producing child pornography with a minor on Sept.
+28, 2019, according to a news release from the U.S. Attorney's Office in Sacramento."
+Texas Woman Gets 17 Years In Federal Prison For Bank Robberies.
+The Killeen (TX) Daily Herald (10/23, 47K)
+reports Eboni Siamone McMurray was sentenced to "more 17 years in federal prison in connection with two
+armed bank robberies, announced U.S. Attorney Gregg N. Sofer, FBI San Antonio Division Special Agent in
+Charge Christopher Combs and Killeen Police Chief Charles F. Kimble."
+KWKI-TV Waco, TX (10/23) reports in June, McMurray "pleaded guilty to two counts of
+bank robbery and two counts of brandishing a firearm during a crime of violence. ... FBI agents and Killeen
+Police officers, with assistance from the U.S. Marshals Service, arrested McMurray at her residence without
+incident the following day. She has since remained in federal custody."
+Alleged California Gang Members To Stand Trial On Multiple Attempted Homicide Charges.
+The East Bay (CA) Times (10/25, 63K) reports court
+records show "four of seven people who are alleged to be part of a North Richmond gang that police have linked
+to at least eight nonfatal shootings and multiple targeted robberies have been ordered to stand trial." The four
+"are to stand trial on 23 felony counts that include eight attempted murder charges, a count of conspiracy to
+commit murder, and a half-dozen robberies or attempted robberies." All seven "were arrested and charged last
+May, following a Richmond police and FBI-led operation that targeted members of a North Richmond gang
+known as Jet Life."
+Man In Custody After Allegedly Abducting Daughters, Two Boys Found Dead
+The AP (10/24) reports, "Authorities found two girls who were abducted from a Kansas home where two
+boys were discovered dead Saturday, and a suspect is in custody." An Amber Alert "said the suspect in the
+abduction is the girls' father, 40-year-old Donny Jackson. Leavenworth County Emergency Management said in
+a Facebook post that Jackson also is a person of interest in the homicides... The FBI referred questions to the
+›atrol, which said the sheriff's office was answering questions in the case.'
+Former Ohio Priest Charged With Sex Trafficking Of A Minor.
+EFTA00137012
+
+WTOL-TV Toledo, OH (10/23, Strock, 76K) reports from
+Findlay, Ohio, "A former Findlay priest is the subject of a 10-count indictment, facing charges that include sex
+trafficking of minor, sex trafficking of an adult and minor by force, fraud and coercion." According to WTOL-
+TV, "The indictment was handed down by a federal grand jury in Cleveland on Friday against Michael J.
+Zacharias, 53. He was arrested on Aug. 18 and has since remained in federal custody. "This defendant is accused
+of using his status and position as a religious and community leader to seek out troubled minors and exploit their
+personal challenges for his own satisfaction, U.S. Attorney Justin Herdman said." WTOL-TV adds, "According
+to court documents, from approximately 1999 to July 2020, Zacharias is accused of sex trafficking of a minor
+victim and using force, fraud or coercion to sexually traffic other minors and adults."
+Texas Man Charged With Sexual Assault Of Child.
+KXXV-TV Waco, TX (10/24, 44K) reports that a Montgomery County, Texas man "is accused of sexual
+assault of a child and authorities are concerned there could be more victims." KXXV-TV adds, "On October 22,
+2020, the Montgomery County Sheriff's Office conducted a search and arrest warrant operation in the Magnolia,
+Texas area for Felipe de Jesus Ledezma-Arellano. The operation was conducted with the assistance of the US
+Marshals Service, the FBI, and the Montgomery County District Attorney's Office. During the execution of this
+operation, Felipe was located and taken into custody on a sexual assault warrant." According to KXXV-TV, "The
+initial report indicated that a two-year-old female child was possibly a victim of sexual abuse at a Magnolia
+residence, according to MCSO. As Detectives investigated further, they identified three additional female victims
+in this case that were subjected to prolonged periods of domestic violence and sexual abuse at the hands of the
+suspect."
+Financial Crime & Corporate Scandals
+Judge Orders Securities Fraud Case Against Texas Attorney General To Move To Paxton's Home County.
+The AP
+(10/23, Bleiberg) reports Harris County District Court Judge Jason Luong on Friday "ordered the long-running
+criminal case against Texas Attorney General Ken Paxton returned to his home county in a legal victory for the
+Republican." Luong "ruled that the securities fraud case should continue in Collin County, north of Dallas,
+siding with Paxton's defense attorneys." Paxton "pleaded not guilty in 2015 and the case has been stalled for
+years over legal challenges."
+Attorneys For LA Lawmaker To Challenge Federal Court's Grand Juror Selection Methods.
+The My News LA (CA) (10/23) reported, "Attorneys for Jose Huizar are preparing to challenge the methods
+used to choose the federal grand jurors that indicted the suspended Los Angeles city councilman on public
+corruption charges, according to court papers obtained Friday." Huizar's attorneys "indicate that they wish to
+question whether the grand jury in their client's case represented "a fair cross-section of the community.'
+Attorneys aren't seeking juror names, but want, among other things, attendance records and reasons for the
+possible absences of any grand jurors who indicted Huizar. Such information "may reveal the demographic
+effects that the current pandemic had on the operation and composition of the grand jury in this case,' the
+document states."
+EFTA00137013
+
+US Charges Costa Rican Man In SIM Lottery Tax Scam.
+The El Paso (TX) Times (10/24, 123K) reports,
+"A Costa Rican man has been indicted by a federal grand jury in El Paso in an alleged lottery scam." Allan
+Francisco Castrillo Bastos, 39, "who currently lives in El Paso, is accused of scheming to steal more than $1
+million from dozens of people who believed they had won the lottery and had to pay a tax in advance of
+receiving their winnings, according to a news release from the U.S. Attorney's Office Western District of Texas.
+On Wednesday, Castrillo Bastos waived arraignment and entered a plea of not guilty to the charges." The Times
+adds, "A 13-count federal grand jury indictment charges Castrillo Bastos with conspiracy to commit wire fraud,
+10 counts of wire fraud, making a false statement to obtain credit and conspiracy to commit money laundering.
+The indictment alleges Castrillo Bastos participated in, or caused, a series of fraudulent wire transfers between
+August 2018 and March 2019."
+Cyber Division
+US Sanctions Russian Government Research Institution For Cyberattacks Against Key Infrastructure Of Allies.
+The Wall Street Journal (10/23, Volz, Subscription Publication, 7.57M) reports that the
+Treasury Department on Friday sanctioned a Russian government research institution the Administration claims
+is responsible for carrying out cyberattacks against key infrastructure of US allies in the Middle East.
+The New York Times
+(10/23, Perlroth, 18.61M) reports, "The hacking group, Energetic Bear, is among Russia's stealthiest. It appears
+to be casting a wide net to find useful targets ahead of the election, experts said." Recent "intrusions marked the
+first time that researchers caught the group, a unit of Russia's Federal Security Service...targeting states and
+counties." In attacks in Germany and the US, "the group has infected websites popular in the energy sector,
+downloading malware onto the machines of anyone who visited the sites, then searching for employees with
+access to industrial systems." In other attacks elsewhere, the group "has hijacked the software updates for
+computers attached to industrial control systems."
+Louisiana National Guard Called In To Prevent Cyberattacks Weeks Prior To Election.
+In an exclusive, Reuters < https://www.reuters.com/article/us-usa-election-cyber-louisiana-exclusiv/exclusive-
+national-guard-called-in-to-thwart-cyberattack-in-louisiana-weeks-before-election-idUSKBN27823F> (10/23,
+Bing) reports the Louisiana National Guard "was called in to stop a series of cyberattacks aimed at small
+government offices across the state in recent weeks, according to two people with knowledge of the events,
+highlighting the cyber threat facing local governments in the run up to the 2020 U.S. presidential election."
+Reuters adds that "the situation in Louisiana follows a similar case in Washington state, according to a
+cybersecurity consultant familiar with the matter, where hackers infected some government offices with a type of
+malware known for deploying ransomware." It's uncertain as to whether the hackers aimed "to target systems
+tied to the election in Louisiana or were simply hoping for a payday. Yet the attacks raised alarms because of the
+potential harm it could have led to and due to evidence suggesting a sophisticated hacking group was involved."
+EFTA00137014
+
+Bipartisan Bill Would Help National Guard Support States' Cybersecurity Modernization.
+ExecutiveGov (10/23) reported that Sens. Maggie Hassan (D-NH) and
+John Cornyn (R-TX) "have introduced a bill to help the U.S. National Guard support cybersecurity
+modernization across state and local governments." The legislation "would allow state governors to request the
+National Guard for help to keep critical infrastructure systems secure, Hassan's office said Wednesday." Potential
+efforts are "cybersecurity services and training duties to be performed by the National Guard." Hassan said "we
+must ensure that the National Guard can help with these types of threats just like any other threat that states
+face."
+French Court Asks Microsoft To Guarantee Safeguards Against Sharing Health Data With US.
+The Wall Street Journal (10/23, Stupp, Subscription Publication, 7.57M) reported that a
+French court has asked Microsoft to guarantee data collected in a government-run health data gathering project
+will not be shared with US intelligence authorities. Last week's ruling comes after the European country's data
+protection authority told the court any US-based cloud provider could be compelled by US surveillance laws to
+share data, so they should not be able to host the most sensitive health-related data should. Microsoft is working
+with French authorities to put additional safeguards in place for the Health Data Hub.
+Kushner's "Close Friend" Charged With Cyberstalking.
+The New York Times
+(10/23, Hong, Drucker, 18.61M) reports Ken Kurson, described as a "close friend of the president's son-in-law
+Jared Kushner," was "arrested in connection with incidents stemming from his divorce," and "charged with
+cyberstalking." The Times says Kurson "helped write a speech for the president's 2016 campaign," and "was
+also a longtime associate of" Rudy Giuliani. According to the Times, "Federal prosecutors in Brooklyn accused
+Mr. Kurson of sending threatening and stalking messages to several people, including a friend whom he blamed
+for the deterioration of his marriage."
+Laboratory
+Police Say Body Found In Missouri Creek Was Missing Social Worker.
+The AP (10/23, Alexander, 14.2M) reports
+that in Washington, DC as well as throughout the country, "the pandemic halted jury trials." The Post adds that
+*in the District, victims and their families will continue to wait for justice, most likely into 2021." Since March,
+in excess of 300 jury trials slated to happen "in D.C. Superior Court for jailed defendants have been postponed, a
+court spokeswoman said." According to the Post, "Court officials declined to specify when the trials will resume,
+but there are indications none will be held for the remainder of the year." Anita Josey-Herring, the court's chief
+judge, said, "The health crisis is driving when the court can realistically reopen to the public at large and at what
+level the court can open."
+Proponents Of Now-Passed Virginia Sentencing Measure Feel Bill Will Have Transformational Impact.
+The Washington Post (10/23, Weiner, Vozzella, 14.2M)
+reported a Virginia measure permitting "defendants convicted in a jury trial to be sentenced by a judge" has been
+passed. Proponents of the bill claim its "effect will be transformational, because juries, which have less
+flexibility than judges in crafting sentences, tend to hand out stiffer punishments than those called for by
+guidelines. While judges can reduce a jury sentence, they rarely do."
+Springfield, Massachusetts Police Working To Repair Relationship With FBI.
+The Springfield (MA) Republican (10/25, Barry, 395K) reports that "through gritted teeth, Springfield Police Commissioner
+Cheryl C. Clapprood confirmed she is working with the new head of the local FBI office to repair bitter relations
+with the feds. The department has come under fire from the FBI and U.S. Department of Justice over the past
+four years in connection with a number of police corruption investigations." The Republican adds, "Among the
+tangible symptoms of the feud was the police department earlier this year yanking its officers from several
+federal task forces, which officials initially attributed to "manpower issues.' Meanwhile, a roundtable discussion
+on gun violence hosted by Massachusetts U.S. Attorney Andrew Lelling on Oct. 21 featured local police chiefs,
+including Clapprood, from cities across the state experiencing an uptick in shootings. Lelling touted a revival of
+federal and local partnerships to combat the problem under a national 'Project Guardian' project."
+International Relations
+After Arrest Of Former Defense Minister On Drug Charges, Mexico's President Shifts Some Blame To US
+Officials.
+The Wall Street Journal (10/23, Subscription Publication, 7.57M) reports that since the arrest of
+Mexico's former defense minister on drug trafficking charges int he US, Mexican President Andrés Manuel
+López Obrador is pulling back from efforts to reform the Mexican army and is placing some of the blame on
+EFTA00137016
+
+officials in the US.
+Other FBI News
+Trump Plans To Fire Wray, Haspel, Esper If He Is Reelected.
+Axios
+(10/25, Swan, Treene, 521K) reports President Trump will "move to immediately fire FBI Director Christopher
+Wray and also expects to replace CIA Director Gina Haspel and Defense Secretary Mark Esper" if he is
+reelected, according to "two people who've discussed these officials' fates with the president tell Axios." Axios
+says if Trump wins, "no matter the margin," he will be "embolden[ed]...to ax anyone he sees as constraining him
+from enacting desired policies or going after perceived enemies... There could be shake-ups across other
+departments. The president has never been impressed with Education Secretary Betsy DeVos, for example. But
+that doesn't carry the urgency of replacing Wray or Haspel."
+Fox News
+(10/25, O'Reilly, 27.59M) reports, "A senior White House official told Fox News on Sunday Trump is planning
+to remove Wray from his post if the president defeats Democratic nominee Joe Biden in the presidential election
+next week." Fox News adds, "A senior FBI official told Fox News that Wray is widely considered a popular
+leader within the bureau and among law enforcement groups across the country, but that he is 'keeping his head
+down and focusing on the work of the FBI." The Hill (10/25, 2.98M) runs a piece based on Axios'
+reporting.
+Other Washington News
+Senate Votes 51-48 On Cloture, Setting Barrett Up For Monday Confirmation.
+The Senate voted 51-48 on Sunday afternoon to invoke cloture on the nomination of Amy
+Coney Barrett to the Supreme Court, setting up a near-certain Monday vote to confirm her. The CBS Weekend
+News (10/25,
+story 6, 0:20, Yuccas, 9.26M) said Barret moves "toward final confirmation despite Democratic objections. ...
+Barrett would be just the fifth woman to ever serve on the high court, compared to 109 men."
+The AP (10/25, Mascaro) reports, "Senate Republicans voted
+overwhelmingly" to advance the nomination, "excited by the chance to install a third Trump justice on the court,
+locking in a conservative majority for years to come. Barrett's ascent opens up a potential new era of rulings on
+abortion, gay marriage and the Affordable Care Act. A case against the Obama-era health law scheduled to be
+heard Nov. 10."
+The New York Times (10/25,
+Fandos, 18.61M) reports Sens. Susan Collins (R-ME) and Lisa Murkowski (R-AK) "joined united Democrats in
+an attempt to filibuster" the nomination "to protest a decision they say should be left to the winner of the
+presidential election. But Republicans had the simple majority they needed to blow past them." Collins is
+expected to vote against confirmation, though Murkowski said this weekend that she will back Barrett on the
+final vote. The Washington Post (10/25, Kim, 14.2M) reports Barrett is
+expected to serve "a first full day as a justice as early as Tuesday and as the court continues to hear election-
+related legal challenges ahead of Nov. 3."
+The Wall Street Journal (10/25, Wise, Subscription Publication, 7.57M) reports Senate Majority Leader
+McConnell said in a floor speech, "This is something to really be proud of and feel good about. We've made an
+important contribution to the future of this country. A lot of what we've done over the last four years will be
+undone, sooner or later, by the next election. They won't be able to do much about this for a long time to come."
+The Washington Post (10/25, 14.2M) says in an
+editorial that on the Barrett nomination, "there is only one reasonable vote for any senator who claims to put
+country over party: no. We say this not primarily because of the hypocrisy [McConnell] asks his caucus to
+embrace, though that is reason enough... There is a more urgent reason to delay: the potential for Judge
+Barrett's confirmation to stain the nation's choice of president." Barrett "has refused to commit to recusing
+herself in election-related cases.
+Bloomberg
+(10/25, Swoyer, 492K), the Fox News (10/25, Treene, Baker, 521K),
+Politico (10/25, Levine, Desiderio, 4.29M), The Hill (10/25, Carney, 2.98M), Roll Call
+ (10/25, Ruger, 154K), and Townhall (10/25, Baumann, 177K)
+are among the other sources covering the Sunday votes.
+Murkowski Says She Will Vote In Favor Of Barrett's Confirmation. The Washington Post
+ (10/24, Itkowitz, 14.2M) reports Sen. Lisa Murkowski (R-AK), who
+previously "opposed voting on a new Supreme Court justice so close to the election, said Saturday she would
+vote to confirm Judge Amy Coney Barrett." The Post adds that "in a Senate floor speech, Murkowski lamented
+that the Senate was spending the weekend debating a judicial nominee" instead of a coronavirus assistance
+measure days prior to the election. However, Murkowski "said she wouldn't hold her opposition to the process
+against Barrett." Said Murkowski, "I have no doubt about [Barrett's] capability to do the job and to do it well."
+The New York Times (10/24,
+Fandos, 18.61M) reports that while speaking on the Senate floor, Murkowski said of Barrett, "While I oppose the
+process that has led us to this point, I do not hold it against her as an individual who has navigated the gauntlet
+with grace, skill and humility." Murkowski's "unexpected turnabout gave a boost to Senate Republicans looking
+to quiet intraparty dissent in the face of unified Democratic opposition. They already had the votes they needed
+to confirm Judge Barrett, President Trump's third Supreme Court nominee, but Ms. Murkowski's support means
+that only one Republican - Senator Susan Collins of Maine - is likely to defect when the roll is called on
+Monday." The Wall Street Journal (10/24, Subscription Publication, 7.57M) reports Sen. Kyrsten Sinema (D-AZ) last
+week talked with Barrett and hasn't indicated how she's going to vote.
+The CBS Weekend News (10/24, Barnes, 14.2M) says that in contrast to a number of
+President Trump's other federal judicial nominees, Judge Amy Coney Barrett "had no problem at her recent
+confirmation hearing endorsing Brown v. Board of Education, the Supreme Court's famous 1954 desegregation
+decision." Likewise, Barrett also had no issue endorsing Loving v. Virginia, "which 13 years later said states
+could not prohibit interracial marriages." However, with regard to "Obergefell v. Hodges, the court's 2015
+decision saying same-sex couples have a right to marry," Barrett refused to indicate whether the case "was
+correctly decided," and the Post says that her doing that "frustrated Senate Democrats and alarmed LGBTQ
+activists, who worry about her elevation to a Supreme Court that has only three justices remaining from the five-
+member majority in the 2015 decision."
+Pence To Continue Campaigning Even After Top Staffers Test Positive.
+The Wall Street Journal (10/25, Bender, Subscription Publication, 7.57M) reports Vice President Pence, the
+head of the White House Coronavirus Task Force, will continue to campaign on behalf of President Trump even
+though he was in close contact with Chief of Staff Mare Short, who tested positive for COVID on Saturday.
+Sources told the Journal that Pence adviser Marty Obst and at least three other staff in the Vice President's office
+have also tested positive.
+In the lead story on ABC World News Tonight
+ (10/25, lead
+story, 3:30, Llamas, 4.45M), Rachel Scott reported that Short "was by the Vice President's side at several
+campaign stops in the past week," including "an Ohio rally Friday." CNN
+ (10/25, Diaz, Klein,
+83.16M) reports on its website that according to two sources, one of the staffers who tested positive was Zach
+Bauer, "Pence's "body man,' meaning his job is to accompany Pence throughout the day and night helping him
+with a wide range of duties, putting him in close proximity to the vice president," but a source "told CNN that
+Bauer has not been in the office since Tuesday, when he went home to quarantine after coming into contact with
+Obst. Bauer tested positive Saturday."
+However, Kelly O'Donnell reported on NBC Nightly News
+ (10/25, lead
+story, 2:40, Snow, 3.43M) that aides "say [the Vice President] and the second lady tested negative again" on
+Sunday, so "he headed to North Carolina." According to O'Donnell, "Top White House officials defend that
+choice, calling candidate Pence an essential worker." O'Donnell added, "Under CDC guidance, essential workers
+should wear masks and keep distance, but are not required to stay home 14 days." She also reported the Vice
+President's aides "say he has canceled local interviews in order to keep distance, and also dropped the usual
+practice politicians have of what's known as a rope line, a chance to greet supporters after event events, like the
+rally he's holding now. That's been dropped as well. He will be traveling this week with stops in Minnesota and
+the Carolinas on his agenda."
+The AP (10/25, Colvin, Weissert, Miller, Madhani) reports Pence "has an
+aggressive travel schedule planned for the final days of the campaign," while CNN
+
+(10/25, Cole, 83.16M) reports on its website that Pence "emerged maskless from Air Force Two in Florida,
+running down the steps and jogging across the tarmac, fist pumping as he approached the podium."
+The AP
+EFTA00137019
+
+(10/25, Miller, Colvin) reports President Trump "commented on Short early Sunday after his plane landed at
+Joint Base Andrews, outside Washington." Trump said, "I did hear about it just now." He added, 'I think he's
+quarantining. Yeah. I did hear about it. He's going to be fine. But he's quarantining."
+In the lead story on the CBS Weekend News
+ (10/25, lead story,
+3:20, Yuecas, 9.26M), Paula Reid said that on CBS' Face The Nation, Margaret Brennan pressed National
+Security Advisor O'Brien, "who also had the virus earlier this year, on Pence's refusal to quarantine." O'Brien
+said, "The free election is foundation of our democracy, so I think campaigning and voting are the most essential
+thing we can be doing." O'Brien added, "I think is he taking all the precautions and my understanding is he
+tested negative as has the second lady."
+Chief of Staff Meadows, on CNN's State Of The Union
+ (10/25, 1.29M),
+said, "Obviously Mark Short and a couple of the key staff around the Vice President have come down with the
+coronavirus. It just goes to show you that we continue to face this enemy that came from China and, yet, what
+we also know is the one area that where we are rounding the corner is really the death rate. Our ability to handle
+this has improved each and every day and each and every month. When there were estimates that as many as
+10% of the population that got this would actually experience a fatal result, you know, we are now down to
+2.6%. Every death is too many. But hopefully we are going to get this to the point where it's not as lethal as the
+flu."
+In addition, The Hill (10/25, Coleman, 2.98M) reports Meadows "said Centers of Disease Control
+and Prevention guidelines indicate that essential personnel can do their jobs while wearing a mask." USA Today
+ (10/25, 10.31M) reports Meadows "also declined to share the
+identity of the other staffers who had tested positive, noting that "sharing personal information is not something
+that we should do.' But he added, 'Anytime there's someone in harm's way, we have an obligation to let people
+know for contract-tracing.**'
+Trump campaign adviser Corey Lewandowski, on NBC's Meet The Press
+ (10/25, 3.09M),
+said, "I would make sure the Vice President is taking all of the precautions necessary as he's always done. I'm
+sure he's tested regularly and he's in the best care of the best physicians in the world at the White House. I'm
+sure he will do what is necessary and what is appropriate. Look, we've also seen Kamala Harris' team, members
+of her team come down with COVID and she took the necessary precautions. Let's see where this goes. I have
+not spoken to the team directly on that.*
+According to the New York Times (10/25, A1, Shear, Karni, Haberman, Stolberg, 18.61M), the coronavirus outbreak among
+Pence's aides is "raising new questions about the Trump administration's cavalier approach to the worst health
+crisis in a century." The Times highlights that while Trump "made no reference to the new cases during
+campaign rallies in New Hampshire and Maine on Sunday," the infections at the White House "just over a week
+before Election Day was a visceral reminder of the president's dismissive and erratic handling of the virus, even
+in one of the most secure spaces in the country. And it comes just as the United States suffers its third surge in
+infections across the nation, with a record number of daily new cases on Friday and a death toll that has risen to
+almost 225,000.*
+The Washington Post (10/25, A1, Rucker, Dawsey, Wang,
+14.2M) similarly says the new White House outbreak "spotlighted the administration's failure to contain the
+pandemic" and "undermines the argument Trump has been making to voters that the country is "rounding the
+turn,' as the president put it at a rally Sunday in New Hampshire," as does the "extraordinary admission" from
+EFTA00137020
+
+Meadows that the Administration has "effectively given up on trying to slow the virus's spread." Meadows told
+CNN, "We're not going to control the pandemic," Meadows continued, "We are going to control the fact that we
+get vaccines, therapeutics and other mitigations." The Post adds that Joe Biden, "who regularly wears a mask on
+the campaign trail and strictly adheres to social distancing guidelines, sought to capitalize on the remark."
+Reuters (10/25, Shalal, Scheyder) reports Biden in a statement "seized
+on those comments, saying Meadows 'stunningly admitted this morning that the administration has given up on
+even trying to control this pandemic, that they've given up on their basic duty to protect the American people.""
+He added, "This wasn't a slip by Meadows, it was a candid acknowledgment of what President Trump's strategy
+has clearly been from the beginning of this crisis: to wave the white flag of defeat and hope that by ignoring it,
+the virus would simply go away. It hasn't, and it won't." USA Today
+ (10/25, Hayes, 10.31M) reports Biden "and others say Trump has
+never tried to control the spread of the virus, citing actions ranging from his mocking of mask wearing to his
+insistence on holding campaign rallies with maskless people packed close together."
+Breitbart (10/25, Mora, 673K) reports Sen. Kamala Harris (D-CA) on
+Sunday used Meadows' comments "about controlling the spread of the coronavirus to lambast...Trump's
+handling of the pandemic. " Harris told reporters, "They are admitting defeat." She continued, "This is the
+greatest failure of any presidential administration in the history of America." Harris added, "This administration
+fails to take personal responsibility or responsibility in terms of leading the nation through this dangerous and
+deadly mass casualty event. And that's why they have forfeited their right to a second term in office.
+House Speaker Pelosi, on CNN's State Of The Union
+ (10/25, 1.29M),
+said, "I wish them safety and hope they pay attention to the reality of how this spreads. I'm sorry it's reached
+close to the Vice President and I hope he will and his wife will keep their distance from those who are infected.
+It's really sad. Now, look. They have all of the protections in the world, all of the anticipation of how this could
+spread, all of the prevention from it and, yet, they are susceptible. Just think of America's working families and
+especially America's essential workers how susceptible they are to this virus and that is really part of our
+discussion on the coronavirus negotiations."
+Politico
+(10/25, McCaskill, 4.29M) reports Senate Republicans "were forced to address Meadows' comments." Politico
+adds that whereas Senate Majority Whip Thune and Sen. Roy Blunt (R-MO) "disagreed with Meadows," Senate
+Judiciary Chairman Lindsey Graham "took a different tack, appearing to defend Meadows."
+The New York Daily News (10/25, Shahrigian, 2.52M) reports
+former New Jersey Gov. Chris Christie (R), who tested positive for COVID last month after working with the
+President to prepare for the first debate, delivered "muted criticism" of Pence's decision not to quarantine. On
+ABC's This Week, Christie stated that he was "a little bit surprised" to hear Pence would continue to campaign
+and he "said the Trump White House's disdain of wearing masks in spite of warning from health officials 'has
+been a problem."'
+The AP(10/25,
+Marchione) reports "health policy specialists" on Sunday "questioned White House officials' claim that federal
+rules on essential workers allow…..Pence to continue to campaign and not quarantine himself after being exposed
+to the coronavirus." Axios (10/25, 521K) reports former FDA commissioner Scott Gottlieb "said 'the short answer is
+yes' when asked whether...Pence is putting others at risk by continuing to campaign after several aides tested
+positive for COVID-19, stressing that the White House needs to be 'very explicit about the risks that they're
+EFTA00137021
+
+taking."
+Ashish Jha, Dean of the Brown University School of Public Health, said on CNN's Inside Polities
+ (10/25, 1.11M)
+the Vice President "should be in quarantine, period. A negative test doesn't get you out of quarantine. And the
+quarantine is not a nice thing to do if you have the luxury to do it. It is essential to protect other people around
+him so he doesn't become a vector for more cases. I think that is really not an area of debate, and no public
+health expert would say he should be on the road right now."
+Fox News
+(10/25, Stabile, 27.59M) reports on its website that Amesh Adalja, an infectious disease expert, on Sunday said
+Pence remains "at very high risk for developing coronavirus" and should "self-quarantine for 14 days based on
+the amount of people around him that are positive."
+Toluse Olorunnipa of the Washington Post said on CNN's Inside Politics
+ (10/25, 1.11M),
+"This is the head of the White House coronavirus task force, openly flouting some of the guidelines and
+recommendations from the CDC, which essentially say that if you are in close contact with someone, at least out
+of abundance of caution, even if you test negative, you should not be traveling. You should not be spending a lot
+of time around other people.... The fact is Vice president is openly flouting some of the recommendations is not
+a good message to send to people who are trying to actually get this virus under control."
+The Hill (10/25, Coleman, 2.98M), the Daily Beast
+ (10/25, Baragona, 1.39M), and The Intelligencer (10/25, Danner, 1.IM) provide similar coverage.
+Fox News President, Several Anchors Advised To Quarantine After Exposure To Coronavirus. The Hill
+ (10/25, Bowden, 2.98M) cites the New York Times
+ (10/25, James) reports NIAID Director Fauci "said
+on Sunday it would be clear whether a COVID-19 vaccine was safe and effective by early December, but that
+more widespread vaccination would not be likely until later in 2021." Fauci told the BBC, "We will know
+whether a vaccine is safe and effective by the end of November, the beginning of December." Fauci added,
+"When you talk about vaccinating a substantial proportion of the population, so that you can have a significant
+impact on the dynamics of the outbreak, that very likely will not be until the second or third quarter of the year."
+The Hill (10/25, Choi, 2.98M) reports Fauci "made the remarks during a discussion on President
+Trump's claims of having a vaccine ready by the end of the year."
+Trump, Administration Officials Defend Response To Coronavirus.
+President Trump was asked in an interview with CBS' 60 Minutes
+ (10/25, 8.66M)
+about increases in coronavirus cases in 40 states. Trump said, "You know why cases are up also? Because we do
+more testing. The fake news media loves to say cases are up." Trump added, 'We have turned the corner. We
+understand the disease. We understand the elderly, and we are taking care of them like nobody's ever taken care
+of them. So we are taking care of our people."
+In an interview with Fox News' Life, Liberty, and Levin, Vice President Pence criticized the Obama
+lost more than two million American lives." Pence contrasted that with President Trump, who, he said, took
+"decisive action to put the health of America first. And all along the way, he listened to the scientists ... I'm
+absolutely convinced that because of the President's leadership, because of our partnership with state health
+officials, because of doctors and nurses, and because of the cooperation of the American people, that we literally
+saved hundreds of thousands of American lives."
+Pence was asked in an interview with CBS' 60 Minutes
+ (10/25, 8.66M)
+about the President's criticism of NIAID Director Fauci and other public health experts. Pence said, "The
+scientists who've worked around the White House Coronavirus Task Force, who will meet again today here at
+the White House have provided a great public service. They've brought the perspective of scientists all along the
+way. And I have a strong relationship with Dr. Fauci and Dr. Birx. But remember, the President of the United
+States has to consider the whole of America. The President's been balancing the broad interests of the country -
+and the health of the American people, and we'll continue to do that every day."
+Chief of Staff Meadows, on CNN's State Of The Union
+ (10/25, 2.68M),
+said, "It is spiking in Europe. It is running rampant through Europe. I was just in Brazil and South America to
+sign three new trade deals, and it is running rampant through Brazil. This is a terrible virus. At the end of the day,
+what we need to do is flatten the curb and protect the most vulnerable. We need to protect the elderly and those
+who are frail and have pre-existing conditions. Ultimately, the only thing that is going to stop this virus - there is
+no magic way — what will is a vaccine. We're on track to have a vaccine for Americans in less than a year. It is
+really incredible."
+Whitmer: Trump's Plans For Rally In Lansing Is "Recipe For Disaster."
+EFTA00137023
+
+The Detroit Free Press < https://www.freep.com/story/news/politics/elections/2020/10/25/gretchen-whitmer-
+trump-rally-lansing-coronavirus-covid-19/6032266002/> (10/25, Egan, 1.52M) reports Michigan Gov. Gretchen
+Whitmer (D) on Sunday called President Trump's "planned campaign rally in Lansing on Tuesday *a recipe for
+disaster" among soaring coronavirus case numbers and urged the public not to attend the event." Whitmer "also
+urged parents to pull their children out of high school winter sports such as hockey, basketball and wrestling if
+some of the other students involved in those activities are not wearing masks."
+Administration Cancels Plan To Offer Santa Impersonators Early Access To Vaccine.
+The Wall Street Journal (10/25, Wernau, Grimaldi, Armour, Subscription Publication, 7.57M)
+reports HHS on Friday announced it has halted plans to spend $250 million on an advertising campaign that
+would offer Santa Claus performers early access to a vaccine in exchange for promoting vaccination to the
+public. A HHS spokesman said that Secretary Azar was not aware of HHS Assistant Secretary Michael Caputo's
+outreach effort, which was revealed by audio recordings. The Journal adds that the chairman of the Fraternal
+Order of Real Bearded Santas expressed disappointment in the announcement.
+US Records "Biggest Two-Day Surge" In Coronavirus Cases.
+On ABC World News Tonight
+(10/25, story 3,
+2:35, 4.45M), Tom Llamas reported on "the alarming new COVID numbers. The biggest two-day surge in the
+US since the pandemic began. More than 167,000 new cases in just 48 hours." Trevor Ault added the US is
+"entering a dangerous new phase in the pandemic. The most infections we've ever seen. New cases soaring
+above 83,000 each of the past two days."
+On NBC Nightly News (10/25, Ramer, Sainz) reports that data from
+Johns Hopkins University "shows that 83,718 new cases were reported Saturday, just shy of the 83,757
+infections reported Friday. Before that, the most cases reported in the United States on a single day had been
+77,362, on July 16."
+The Wall Street Journal (10/25, Krouse, Subscription Publication, 7.57M) reports public health experts say
+the coronavirus is spreading across the US due to large gatherings and the easing of lockdown restrictions.
+However, the Washington Times (10/25, Howell, 492K) reports the situation "is not as dire as it was last spring,
+when a crush of patients forced state and federal governments to lock down wide swaths of the economy,"
+although "the trend line is worrying, with hospitalization rates up 40% since last month. Hospitalizations
+increased in 39 states over the past week and declined in only 11."
+Arkansas Gov. Asa Hutchinson (R), on CBS' Face The Nation
+https://playvideo.bulletinintelligence.com/6423f271c742477abc86418fe66a0c8?pubid=fbi> (10/25, 2.24M),
+discussed the recent surge in coronavirus cases in the state. Hutchinson said, "It's very concerning. And that's a
+EFTA00137024
+
+statistic I watch, both the deaths and hospitalizations. I do think that people who get ill want to go into the
+hospital quicker because they can start their treatment. They have a better chance of recovery. So I think that's a
+little bit of a factor. Right now our hospitalization space is tight. We have adequate space, but we watch it very
+carefully. And the spike in cases that we've seen is a concern. I think it reflects what we're all looking at
+nationwide in terms of going into the winter, a combination of flu, the combination of more indoor settings. So it
+is concerning. And we're making preparations for it. But we have to really pull together to follow the guidelines
+that are necessary to keep the economy moving, but at the same time make sure we don't increase that spread."
+Kansas City Mayor Quinton Lucas (D), on CBS' Face The Nation
+ (10/25,
+14.2M) says the US "is not turning the corner on the coronavirus pandemic, as President Trump claims, but
+spiraling toward a devastating new wave of illness and death, spread across many states and intensifying as
+winter cold approaches." According to the Post, "This calamity could and should have been met head-on by Mr.
+Trump and was not. But given the enormity of the loss - at least 223,000 people have died directly from the virus
+and tens of thousands indirectly - this is a moment to look beyond hapless leadership." The Post adds, "We, too,
+can bend the trajectory of this pandemic, and we must."
+San Francisco Has Been A "COVID-19 Success Story." In an article headlined "How San Francisco Became A
+COVID-19 Success Story As Other Cities Stumbled," the Los Angeles Times
+ (10/25,
+Dolan, 4.64M) reports San Francisco "has become the first urban center in California to enter the least restrictive
+tier for reopening. Risk of infection, according to the state's color-coded tiers, is considered minimal, even
+though San Francisco is the second-densest city in the country after New York." However, the Times adds city
+officials "still are not declaring victory. Characteristically, they warn, the virus still lurks around the corner. And
+as they have before, they will follow local metrics rather than reopen just because the state allows it." According
+to the Times, experts "credit San Francisco's success to a long partnership between public health officers and
+universities, most notably during the AIDS crisis," and San Francisco residents "largely followed health
+guidelines."
+Native Americans "Disproportionately" Impacted By COVID Ahead Of Election Day.
+According to USA Today (10/25, Cava, 10.31M), "COVID-19 has disproportionately
+sickened or killed Native Americans across the U.S., creating another Election Day challenge for a poor and
+geographically isolated population already fighting to overcome steep voting barriers ranging from
+discriminatory election laws to distant polling stations." USA Today reports that while "many Americans" this
+election turned "to voting by mail to avoid COVID-19 exposure, some Indigenous Americans risk having their
+votes ignored given the limited and inefficient nature of postal service on many rural reservations. Spotty
+internet access also makes it challenging to access information on how to vote in a pandemic."
+False Positives Having "Serious Consequences" In Some Communities.
+The New York Times (10/25, Wu, 18.61M) reports that while false positives in
+coronavirus testing "are widely considered to be benign in comparison with false negatives, which can deprive
+infected people of treatment and embolden them to mingle with others, hastening the spread of disease," but they
+"can have serious consequences as well, especially in places where the virus is scarce." According to the Times,
+false positives can "erod[e] trust in tests and, under some circumstances, prompt...outbreaks of their own."
+Protesters Burn Masks In Pushback Against Restrictions.
+On NBC Nightly News (10/25,
+McDonnell Nieto Del Rio, 18.61M) reports that in Green Bay, Wisconsin, "a town that lives or dies with its
+Packers, the metaphor takes on a somewhat chilling hue in the middle of a pandemic." The Times says that on a
+recent game day "when the Packers were taking it to the Texans in Houston, the scene back home was noticeably
+subdued, as the coronavirus surged in Wisconsin and people mostly avoided the bars that are usually jammed
+when the Packers are playing."
+Fox's Baier, MacCallum, Perino Advised To Quarantine.
+The New York Times (10/25, Crowley,
+Astor, 18.61M) reports several "top anchors" at Fox News including Bret Baier, Martha MacCallum, and Dana
+Perino "have been advised to quarantine after being exposed to someone on a private flight who later tested
+positive for the coronavirus, two people with direct knowledge of the situation said on Sunday. The infected
+person was on a charter flight to New York from Nashville with a group of network executives, personalities and
+other staff members who attended the presidential debate on Thursday," sources said.
+EFTA00137026
+
+Biden Tweet From 2019 Warning Of Pandemic Trends On Anniversary Of Post.
+Bloomberg (10/25, Yang, 4.73M) says Joe Biden's tweet "warning about a
+pandemic was trending on Twitter on Sunday, the one-year anniversary of the post." Bloomberg adds that the
+tweet, "now gathering over 112,000 likes, has gone viral several times before as the coronavirus raged."
+Pelosi "Optimistic" About Coronavirus Relief Bill Before Election.
+The AP «https://www.chicagotribune.com/coronavirus/ct-nw-second-stimulus-check-updates-20201025-
+wnlwc4x3prasle317kj26ewwom-story.html> (10/25) reports House Speaker Pelosi told CNN's State Of The
+Union Sunday
+that she is not giving up on passing a coronavirus relief measure before the election. Politico
+ (10/25,
+Hooper, 4.29M) quotes Pelosi as saying, "I never give up hope. I'm optimistic. We put pen to paper and had been
+writing the bill based on what we hope will be the outcome, what they said they would get back to us on."
+Bloomberg (10/25, Litvan, House, 4.73M) reports Chief of Staff Meadows, who also
+appeared on CNN's State Of The Union
+
+(10/25, Wakabayashi, Nicas, 18.61M) reports the agreement reached between Apple and Google 15 years ago
+under which Google's search engine is "the preselected choice on Apple's iPhone and other devices" was "worth
+billions of dollars to both companies and cemented their status at the top of the tech industry's pecking order."
+However, "the partnership is in jeopardy," after the Justice Department "filed a landmark lawsuit against
+Google...and homed in on the alliance as a prime example of what prosecutors say are the company's illegal
+tactics to protect its monopoly and choke off competition in web search." The Wall Street Journal
+ (10/25, Subscription Publication, 7.57M) says according to analysts and investors, losing the
+agreement would be a significant setback for Apple since it has been estimates that payments from Google are
+responsible for up to a fifth of Apple's overall profit.
+Senators Request IG Investigation Of CBP's Warrantless Utilization Of Cellphone Location Data.
+The Washington Post (10/23, Harwell, 14.2M) reported, "U.S. Customs and Border Protection officials who have used
+cellphone location data to track people inside the country without a warrant are refusing to tell members of
+Congress what gives them the legal right to do so, a group of Democratic senators said Friday." When
+individuals utilize "any one of a broad assortment of weather, gaming and other apps, their location data is
+bundled and resold by companies such as Venntel to advertisers, commercial buyers - and, in recent months,
+federal agencies such as CBP." However,
+"the practice has raised alarms among" legislators as well as privacy
+proponents, and the Post added that five Democratic senators on Friday requested Department of Homeland
+Security Inspector General Joseph Cuffari to probe "the practice, saying CBP had refused to provide any legal
+analysis defending the warrantless searches."
+USA Today Analysis: Under Administration, Refugees Must Wait Longer To Receive Visas.
+A USA Today (10/24, King, 10.31M) analysis says, "Across the U.S., thousands of
+refugees are desperately waiting to be reunited with their children, parents, spouses and other siblings. Under the
+Trump administration, these families have had to wait even longer for their relatives to receive visas to travel to
+the United States, if they are approved at all." USA Today adds that after the President assumed office, the
+Administration "halted the resettlement program entirely for 120 days; banned people from the Muslim-majority
+countries of Iraq, Syria, Iran, Sudan, Libya, Somalia and Yemen from entering the country for 90 days; and cut
+the amount of refugees admitted into the country during that fiscal year from 110,000 to 50,000." The
+Administration "has since gone further, limiting the number of refugees allowed into the U.S. during this fiscal
+year to 15,000 applicants, the lowest rate in the resettlement program's 40-year history."
+Undocumented Farmworker Died After Experiencing Brutal Treatment During Arrest.
+The New York Times
+(10/24, Dobbins, 18.61M) says Officer Coltynn Williams "was the first person at the Hidalgo County Jail to
+actually see Jorge Gonzalez Zuniga," who "was still in the drunk tank, 20 hours after his arrest." Gonzalez, "an
+undocumented farmworker from Mexico, had been arrested at a party the day before for public intoxication and
+violating the curfew imposed across parts of the Rio Grande Valley to help control the widening coronavirus
+pandemic. Now, he lay motionless." When Gonzalez couldn't "hold his head up for a mug shot, Mr. Williams
+sent him to the hospital, where doctors diagnosed a crushed vertebra and a body temperature of 82.4 degrees."
+After "several weeks on a ventilator," Gonzalez "died on July 15." The Times acquired a partial copy of the
+Texas Ranger's investigation, which "found evidence of brutal treatment during Mr. Gonzalez's arrest, during
+which witnesses said he was Tased, tripped, punched and knelt on before being pushed chest-first into a patrol
+car." l
+Tropical Storm Zeta Strengthens In Caribbean.
+The AP (10/25)
+reports Tropical Storm Zeta "strengthened Sunday in the western Caribbean and will probably become a
+hurricane before hitting Mexico's resort-dotted Yucatan Peninsula and the U.S. Gulf Coast in coming days. Zeta
+was the earliest named 27th Atlantic storm recorded in an already historic hurricane season." Florida Today
+ (10/25, 180K) reports heavy rainfall associated with Zeta is expected to hit the
+Gulf Coast region by Wednesday. The Baton Rouge Advocate
+
+(10/25, 399K) says that if Zeta "makes landfall in Louisiana, it would be the fifth named storm to do so this year,
+EFTA00137028
+
+the most since hurricane record-keeping began in 1851." The New York Times
+ (10/25, Pietsch, 18.61M), the Washington
+Post (10/25, Cappucci,
+14.2M), and the Wall Street Journal (10/25, McWhirter, Subscription Publication, 7.57M) are among the
+national outlets covering the progress of the storm.
+Kushner, Ivanka Trump Threaten To Sue Over Lincoln Project Billboards.
+Reuters (10/25, Landay) reports Jared Kushner and Ivanka Trump are
+threatening to sue the "anti-Trump Republicans" of the Lincoln Project "for posting billboard ads in New York
+City's Times Square linking them to the country's almost 225,000 coronavirus deaths." A lawyer representing the
+couple, in a letter to the Lincoln Project, "call[ed] the ads 'false, malicious and defamatory" and saying they
+constituted 'outrageous and shameful libel.""
+USA Today (10/25, Elbeshbishi, 10.31M) reports one billboard depicts
+Ivanka Trump "gesturing to the number of national and statewide deaths due to the coronavirus. The other
+includes a smiling Kushner — a senior adviser to the president - and a quote attributed to him saying, '[New
+Yorkers[ are going to suffer and that's their problem.' The bottom of the ad is also lined with body bags." The
+New York Times
+(10/25, Rubinstein, 18.61M) reports attorney Mare E. Kasowitz wrote in the letter, "Of course, Mr. Kushner
+never made any such statement, Ms. Trump never made any such gesture, and the Lincoln Project's
+representations that they did are an outrageous and shameful libel."
+The Daily Caller (10/25, 716K) reports the Lincoln Project vowed "to leave the billboards up in a Friday
+night statement," saying in part, "The level of indignant outrage Jared Kushner and Ivanka Trump have shown
+towards The Lincoln Project for exposing their indifference for the more than 223,000 people who have lost their
+lives due to their reckless mismanagement of COVID-19 is comical."
+State Department Confirms It Has Suspended Diversity Programs.
+Reuters (10/25) reports the State Department said
+Sunday that it has "suspended employee training programs related to diversity and inclusion, confirming a
+Reuters exclusive a day before, but affirmed its commitment to fostering a more diverse workplace." A State
+Department spokesman said in an email, "As an Executive Branch Agency, the Department of State complies
+with all Executive Orders."
+WTimes Analysis: State Department Hopes For Renewed Clout Under Biden. The Washington Times
+
+(10/25, Taylor, 492K) writes that the prospect of a Joe Biden presidency "has sent hopes soaring in the
+diplomatic establishment that the State Department could be in for more money and more clout over the next
+four years as it claws back power lost in recent decades to the Pentagon and National Security Council." The
+Times says Biden aides say a Biden Administration "would swiftly reverse President Trump's trademark
+transactional foreign policy, including toward allies like NATO and adversaries such as China, Russia and Iran."
+EFTA00137029
+
+Pelosi Says She Plans To Seek Another Term As Speaker.
+The Washington Post
+(10/25, Zakrzewski, 14.2M) reports House Speaker Pelosi told CNN on Sunday that she plans to seek another
+term as speaker if Democrats hold the House, as is expected. The Washington Times
+
+(10/25, Richardson, 492K) reports Rep. Alexandria Ocasio-Cortez (D-NY) said she would back Pelosi if Pelosi
+"is the most progressive contender." Politico < https://www.politico.com/news/2020/10/25/pelosi-speaker-dems-
+control-house-432246> (10/25, Hooper, 4.29M) also reports.
+High Winds Increase California Wildfire Risk.
+Tom Llamas said on ABC World News Tonight
+https://playvideo.bulletinintelligence.com/d29b65c992c04ab695be6fc5466f168b?pubid=fbi> (10/25, story 4,
+1:20, 4.45M) that "high winds across California have fire officials so concerned that Pacific Gas and Electric has
+protectively shut off power to hundreds of thousands of customers." ABC's Will Carr: "California is on high
+alert. The state is facing the highest fire risk this year, with powerful winds up to 70 miles per hour." Jamie
+Yuccas similarly reported on the CBS Weekend News
+ (10/25, story 3,
+1:40, 9.26M) that PG&E is "shut[ting] down some lines to prevent them from sparking new fires."
+The Washington Post (10/25, Leonard, 14.2M) reports, "The combination of hurricane-force wind gusts and extremely dry
+conditions mean that the potential of a fire starting, and spreading rapidly, is unusually high. In the San Francisco
+Bay and areas from Sacramento northward, high winds of up to 80 mph are expected in higher elevations, with
+gusts to 50 mph possible even in downtown San Francisco." The Los Angeles Times
+ (10/24, Pamuk)
+reports the State Department "has suspended all training programs for employees related to diversity and
+inclusion, an internal cable obtained by Reuters showed, after President Donald Trump directed federal agencies
+last month to end programs deemed divisive by the White House." The cable reads, "Beginning Friday, October
+23, 2020, the Department is temporarily pausing all training programs related to diversity and inclusion in
+accordance with Executive Order...on Combating Race and Sex Stereotyping." It adds, "The pause will allow
+time for the Department and Office of Personnel Management (OPM) to review program content."
+WPost Analysis: Trump Has "Presided Over A Norm-Shattering Expansion Of Private Interests In Government."
+In a roughly 3,500 word analysis, the Washington Post (10/24, Dawsey, Helderman,
+Fahrenthold, 14.2M) says that "during his four years in office, [President] Trump has taken few steps to clean up
+Washington. He has instead presided over a norm-shattering expansion of private interests in government."
+EFTA00137030
+
+According to the Post, "The government has had to spend money at Trump's private hotels as his family has
+traveled around the globe. Trump sidestepped rules that had been designed to prevent nepotism, allowing his
+son-in-law to serve in a top government role. He has touted companies run by supporters and allies who received
+government contracts. His administration has allowed former lobbyists to serve in jobs in which they have
+oversight of policies that affect their former employers."
+WPost Al: Trump Has Made Sustained "Assault" On Civil Service.
+In a front-page article titled "Trump's Historic Assault On The Civil Service Was Four Years In The Making," the
+Washington Post (10/23, A1, Rein, Dawsey, Olorunnipa, 14.2M) reports that the
+President's "extraordinary directive allowing his administration to weed out career federal employees viewed as
+disloyal in a second term is the product of a four-year campaign by conservatives working from a little-known
+West Wing policy shop." According to the Post, the effort "threatens to be the most significant assault on the
+nonpartisan civil service in its 150 history: a sweeping executive order that strips job protections from employees
+in policy roles across the government. Exactly which roles would be affected will be up to personnel officials at
+federal agencies, who were tasked on Friday with reviewing all of their jobs and deciding who would qualify."
+NYTimes Al: Trump's Financial Records "Cast Doubt" On Philanthropic Claims.
+In a front-page article titled "Trump's Philanthropy: Big Tax Write-Offs And Claims That Don't Always Add
+Up," the New York Times (10/23, A1,
+Craig, Buettner, McIntire, 18.61M) reports that while the President describes himself as "a committed
+philanthropist with strong ties to many charities" and according to his tax records, "has given back at least $130
+million since 2005, his second year as a reality TV star," his "long-hidden tax records, obtained by The New
+York Times, show that Mr. Trump did not have to reach into his wallet for most of that giving. The vast bulk of
+his charitable tax deductions, $119.3 million worth, came from simply agreeing not to develop land - in several
+cases, after he had shelved development plans." The Times adds the records "show that much of his charity has
+come when he was under duress - facing damage to his reputation or big tax bills in years of high income."
+WPost Analysis: Trump Has To Pay Off $400M In Loans By 2024.
+The Washington Post (10/23, Fahrenthold, O'Connell, Partlow, 14.2M) reports that 'in the
+next four years," President Trump "faces payment deadlines for more than $400 million in loans - just as the
+pandemic robs his businesses of customers and income, according to a Washington Post analysis of Trump's
+finances." The Post adds, "The bills coming due include loans on his Chicago hotel, his D.C. hotel and his Doral
+resort, all hit by a double whammy: Trump's political career slowed their business, then the pandemic ground it
+down much further." The Post goes on to report that "if Trump is reelected, these loan-saddled properties could
+present a significant conflict of interest: The president will owe enormous sums to banks that his government
+regulates."
+International News
+European Countries Impose New Restrictions Amid Second Wave Of COVID Cases.
+EFTA00137031
+
+The Wall Street Journal (10/25, A1, Walker, Bisserbe, Subscription Publication, 7.57M) reports Italy,
+Spain, France, and other European countries are responding to an increase in coronavirus cases by enacting new
+restrictions.
+The AP (10/25) reports the Spanish government on Sunday "declared a national
+state of emergency that includes an overnight curfew in hopes of not repeating the near collapse of the country's
+hospitals." Prime Minister Pedro Sánchez "said the decision to restrict free movement on the streets of Spain
+between 11 p.m.-6 a.m. allows exceptions for commuting to work, buying medicine, and caring for elderly and
+young family members." Reuters < https://www.reuters.com/article/us-health-coronavirus-spain-
+emergency/spain-announces-new-state-of-emergency-as-covid-infections-soar-idUSK BN27AOHU> (10/25,
+Carreño, Jones) reports the new rules "go into force from Sunday night and will require all regions except the
+Canary Islands to impose a nighttime curfew and limit the number of people allowed to meet to six."
+The New York Times (10/25, Kwai, 18.61M) reports Spain in March had "invoked
+emergency powers to enact one of the world's strictest lockdowns," which "was lifted in June, but as cases
+spiked after the country reopened over the summer, officials reinstated a partial lockdown in swaths of the
+country, including the capital of Madrid." According to the Times, Spain was "the first Western European
+country to surpass one million cases this week, though Mr. Sánchez has said the number of cases may be as high
+as three million people."
+Meanwhile, the AP (10/25, D'Emilio) reports Italian Premier Giuseppe Conte "imposed at
+least a month of new restrictions across the country Sunday to fight rising coronavirus infections, shutting down
+gyms, pools and movie theaters, putting an early curfew on cafes and restaurants and mandating that people keep
+wearing masks outdoors." The New York Times (10/25, Pianigiani, 18.61M)
+reports Italy "was the first Western country to go on a general lockdown last March," but the government
+"introduced the new restrictions starting on Monday with the hope of avoiding a second lockdown that would
+severely damage the country's economy."
+The Washington Post (10/25, Mellen, 14.2M) reports
+Italy "had 1,208 covid-19 patients in intensive care on Sunday - more than on March 9, when Conte announced
+the lockdown."
+Colombia Passes 1M Confirmed Coronavirus Cases.
+The AP (10/25) reports Colombia "reached 1 million confirmed coronavirus
+cases on Saturday, becoming the second country in Latin America to report that number in less than a week."
+According to the AP, Colombia, a nation of 50 million, "saw cases peak in August and has seen a decline since
+but still continues to register around 8,000 new infections a day."
+Malaysia's King Rejects PM's Proposal To Declare COVID State Of Emergency.
+The AP