Date: October 21, 2021 at 11:36:34 AM EDT To: Subject: Request for Comment
+
+Hello,
+
+I am a reporter from The Hill, and I wanted to seek any comment you may have on Ghislaine Maxwell seeking private screenings of potential jurors.
+
+If you have any statement on this, please feel free to reach out.
+
+I apologize for reaching out to you via your Columbia University email address, but wanted to be sure to reach you in the event you would like to provide a statement.
+
+Best, Monique Beals
diff --git a/content-documents/ds8/dd/EFTA00026819.md b/content-documents/ds8/dd/EFTA00026819.md
new file mode 100644
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--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00026819.md
@@ -0,0 +1,103 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00026819)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00026819"
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+---
+
+
+
+## U.S. Department of Justice
+
+United States Attorney Southern District of New York
+
+The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007
+
+October 8, 2020
+
+# BY ELECTRONIC MAIL
+
+Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022
+
+Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver, CO 80203
+
+Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007
+
+# Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN)
+
+Dear Counsel:
+
+We write in response to your letters dated September 21, 2020 and October I, 2020 regarding the above-referenced case.
+
+# 1. The Government Has Met Its Discovery Obligations
+
+As an initial matter, you repeatedly assert that the Government "has not met its discovery obligations." (Sept. 21, 2020 Ltr. at 4; Oct. I, 2020 Ltr. at 1, 3). The Government respectfully disagrees. The deadline for the production of Rule 16 discovery set by the Court, including but not limited to "electronic materials" is November 9, 2020, which is more than a month away. (Dkt. 25). The deadline for "initial non-electronic discovery, generally to include search warrant applications and subpoena returns," was due on August 21, 2020, and, as you are aware, the Government in fact made a substantial initial production before that deadline. (Id. (emphasis added)).
+
+The Government has also made substantial efforts to ensure that copies of the discovery produced to defense counsel are also available to the defendant at the Metropolitan Detention Center ("MDC"). And while there have been technical difficulties with certain of the productions made to the defendant, the Government understands that defense counsel is able to access all of the material, and, as detailed herein, we have worked promptly to address each concern you have raised with respect to productions made directly to the defendant. In sum, your claim that the Government has not met its discovery obligations because of the delay caused by your requests to reformat and rebum the discovery is simply inaccurate. The Government has met its discovery obligations and will continue to do so in the remaining month prior to the relevant discovery deadline.
+
+In addition, as set forth below, the Government has conferred with MDC counsel regarding the various complaints you have raised in your September 21 and October 1 letters in order to accommodate your requests and in order to ensure that the defendant can timely review discovery.
+
+# 2. The Government's Extensive Efforts to Ensure the Defendant Can Review Discovery at MDC
+
+The Government has taken considerable efforts to address the defendant's complaints about her access to discovery in this case. As an initial matter, when making its productions, the Government had no reason to believe the defendant would be unable to review any of the discovery materials at the MDC. Indeed, the Government notes that it followed the same procedure in producing discovery to defense counsel as it did to the defendant. Nor could the Government possibly have anticipated which of the hundreds of thousands of files produced to date the defendant would be unable to view using the computer provided to her by the MDC. However, as soon as defense counsel notified the Government on August 27, 2020 that the defendant could not access a portion of the discovery materials, the Government worked with its paralegal and Information Technology staff to create new copies of the discovery materials you identified in a new format. Due to the volume of files requiring review and reprocessing, that process took several days. Once the files were reformatted, the Government loaded them onto a new drive, which it sent to the MDC on September 3, 2020.
+
+Subsequently, your September 21, 2020 letter identified a portion of the Government's first three productions that the defendant was unable to view at the MDC. The Government notes that even without being able to view those files, the defendant was still able to review tens of thousands of pages of discovery while awaiting correction of the technological problem, and the Government understands, as noted, that defense counsel has been able to view the entirety of the productions. Since learning from you that the defendant was experiencing difficulty viewing certain files, the Government has taken several steps to ensure that the defendant has access to every file.
+
+First, the Government has worked with its paralegal and Information Technology staff to create new copies of the discovery materials you identified in your September 21, 2020 letter. That process involved converting certain files into new formats, changing the names of certain files, and providing software programs to help run certain files. Due to the extent of this review and reprocessing, these steps took several days. Once the files were reformatted, the Government loaded them onto a new drive, which it sent to the MDC on October 2, 2020. The cover letter accompanying that production included instructions for how the defendant may access the files she previously had difficulty viewing.
+
+Second, the Government has asked MDC legal counsel to send an MDC Information Technology ("IT") staff member to examine the computer the defendant is using to review her discovery at the MDC. The Government has asked that the IT staff member load any software necessary to view the files that the defendant has had difficulty accessing onto her MDC computer. The Government understands from MDC legal counsel that an IT staff member has completed such a review of the defendant's computer at the MDC. Should the defendant have difficulty accessing files on the MDC computer in the future, she should alert MDC staff and request another review of the computer by IT staff.
+
+The Government also asked MDC legal counsel to ensure that the defendant has a writing surface on which to take notes while reviewing discovery. MDC legal counsel has informed the Government that MDC staff has repositioned the items on the table at which the defendant reviews discovery such that she can use the table as a writing surface. MDC legal counsel has also informed the Government that the defendant has access to a privacy screen to use when reviewing discovery on the MDC computer. MDC legal counsel further noted that the defendant currently has more access to discovery than any other inmate in the facility.
+
+Third, as a stopgap while completing the above processes, the Government reminded defense counsel that counsel is permitted to bring a laptop containing copies of any discovery materials produced to date into the MDC to review with the defendant. The Government understands from MDC legal counsel that that defense counsel is aware of this permission and has been able to visit the defendant in person at the MDC on multiple occasions.
+
+Taken together, these steps should ensure that the defendant has access to the discovery productions made to date and with many months left to review those productions before trial. The Government will continue to work with defense counsel and the MDC to address any issues that may arise regarding the defendant's access to discovery.
+
+#### 3. The Government's Efforts to Ensure that the Defendant Can Review Highly Confidential Materials
+
+Since receiving your request for your client to review Highly Confidential discovery material in the FBI's possession, the Government has taken several steps to address your request. Due to the ongoing pandemic, the United States Marshals Service ("USMS") will not produce a defendant from the MDC to the courthouse for any reason other than a court appearance. Accordingly, the Government cannot take the usual step of requesting the USMS to produce the defendant to a proffer room in the courthouse where she can review the Highly Confidential materials with defense counsel present.
+
+As an alternative, the FBI has agreed to assign two agents to bring a secure laptop containing the Highly Confidential materials to the MDC, where defense counsel and the defendant may review the Highly Confidential materials together. So long as defense counsel submits to a search to ensure that no electronic devices or electronic storage media is being brought into the attorney visiting room, the agents will permit defense counsel and the defendant to review the computer alone while the agents wait outside the room. The FBI has loaded the secure laptop
+
+with all of the approximately 43,500 images that were seized from Jeffrey Epstein's residences in New York and the Virgin Islands.' Accordingly, the FBI is prepared to facilitate the review of these items as soon as the MDC will permit such a visit. The FBI understands that defense counsel and the defendant may require multiple meetings to review all of the images and is accordingly prepared to bring the secure laptop to the MDC on multiple dates.
+
+The Government has asked MDC legal counsel to authorize the FBI to bring the Highly Confidential materials into the facility for defense counsel and the defendant to review. In response, MDC legal counsel indicated that such visits require authorization from the Warden. The Government urged MDC legal counsel to approve the proposed visits as quickly as possible, and today, the Government learned that the Warden has approved this proposal. The FBI and MDC can accommodate a visit next week, and the Government will coordinate with defense counsel, the FBI, and the MDC to assist with scheduling this first and any subsequent visits.
+
+Additionally, as the Government has repeatedly informed you, defense counsel may schedule a time to come to the FBI offices in Manhattan to review the above-referenced 43,500 images, as well as any other physical items referenced in the discovery productions. Those appointments can be made with much less notice because they do not require arranging the logistics of providing Highly Confidential images to an incarcerated defendant.
+
+Finally, the Government is still processing the 40,000 of the above-referenced images that do not contain nudity for production to counsel and to the defendant at the MDC. Due to the volume of those images, that process has taken multiple weeks. The Government expects that the images will be ready to produce within approximately one week.
+
+#### 4. Conditions of Confinement
+
+Since receiving your September 21, 2020 letter, the Government has consulted with MDC legal counsel regarding the defendant's conditions of confinement. As discussed on our September 22, 2020 call, immediately after receiving your letter, the Government contacted MDC legal counsel, and within approximately 24 hours, the Government had answers to several of the concerns raised in the letter, which the Government conveyed to you over the phone. Over the next two weeks, the Government awaited responses regarding the other complaints raised in your September 21, 2020 letter from the MDC. The Government has now received responses from MDC legal, which are incorporated herein.
+
+First, MDC legal counsel indicated that the staff assigned to the defendant have worked to minimize the delays identified in your September 21, 2020 letter. As a result, the defendant should have up to thirteen hours per day of access to discovery, though she may also use that time for other activities, such as attorney visits, calls, recreation, and personal hygiene. That amount of time far exceeds the discovery access any other MDC inmate currently enjoys. MDC legal counsel
+
+Of those 43,500 images, approximately 3,500 contain nude or partially nude images, and approximately 40,000 do not contain nudity. Per your request, the FBI has loaded all 43,500 images together onto a laptop so that defense counsel and the defendant may review all of the seized images at the same time.
+
+also confirmed that staff will not put their fingers into the defendant's mouth for any searches. The Government inquired of MDC legal counsel whether the defendant could be permitted to sleep in the rec room where her computer and shower are located instead of the isolation cell. In response, MDC legal counsel indicated that the defendant will be required to sleep in the isolation cell.
+
+Second, the Government inquired of MDC legal counsel whether it would be possible to reduce the number of body scans conducted on the defendant. In response, MDC legal counsel indicated that the defendant will be required to undergo weekly body scans.
+
+Third, MDC legal counsel has informed the Government that the defendant has the same access to commissary as any other inmate at the facility. As noted during our September 22, 2020 call, the defendant was provided with two different sizes of sports bras to choose from, and MDC legal counsel understands that at least one of those sizes was acceptable to the defendant.
+
+Fourth, as referenced during our September 22, 2020 call, the Government has been assured by MDC legal counsel that the defendant is receiving three meals per day. According to MDC legal counsel, MDC staff now wait until later in the day to pick up the defendant's meals for each day, thereby ensuring that every portion of the meal (including side dishes and vegetables) is included. MDC legal counsel has also assured the Government that MDC staff keep the defendant's meals in a refrigerator to ensure that her food remains fresh. Additionally, if the defendant misses a meal due to a legal visit or other appointment, MDC staff will leave the meal for the defendant to eat upon her return. MDC legal counsel also noted that the defendant has purchased and received a number of supplemental food items from commissary, including, among other items, granola, mackerel, cheese, nutrition bars, soup, tortillas, crackers, honey buns, sausage, eggplant parmesan, and nuts. Further, MDC legal counsel has informed the Government that the defendant is seen by medical staff once per week. At those appointments, the defendant is weighed and told her weight.
+
+Fifth, as noted during our September 22, 2020 call, MDC legal counsel has indicated that the defendant has received all mail that the MDC has received addressed to her and in compliance with Bureau of Prisons ("BOP") regulations. MDC legal counsel confirmed that letters sent on colored paper do not comply with BOP regulations and would be rejected. If a letter is rejected, the defendant will receive a notification of the rejection. MDC legal counsel further indicated that inmates are not permitted to receive care packages of food or other items from outside vendors, but the defendant can purchase legal pads and pens from commissary. MDC legal counsel further informed the Government that the MDC has not received any copies of The New York Times addressed to the defendant.
+
+* * *
+
+In sum, the Government has met and will continue to meet its discovery obligations, and has worked expeditiously to address all of the concerns you have raised regarding the defendant's access to discovery and conditions of confinement. We remain available and willing to address any questions or concerns that may arise.
+
+Very truly yours,
+
+AUDREY STRAUSS Acting United States Attorney
+
+by: Assistant United States Attorneys
diff --git a/content-documents/ds8/dd/EFTA00027095.md b/content-documents/ds8/dd/EFTA00027095.md
new file mode 100644
index 0000000000000000000000000000000000000000..4ea69f1147ef4e9bf0c0b6255eb1e24c2b912408
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00027095.md
@@ -0,0 +1,26 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00027095)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
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+---
+
+
+
+For info on attached.
+
+| Forwarded message
From:
Date: Aug 12, 2019 12:55
Subject: FW: Jeffrey Epstein 19 cr 490
To:
Cc: | | |
+|----------------------------------------------------------------------------------------------------------------|--------------|--|
+| FYI
United States Marshal
Southern District of New York
New York. NY 10007 | | |
+| -----Ori inal Messa
u •Jett: Jeffrey Epstein 19 cr 490
Importance: High | On Behalf Of | |
+
+Please see attached letter from Judge Richard M. Berman.
+
+(See attached file: Aug 12 letter.pdf)
diff --git a/content-documents/ds8/dd/EFTA00028324.md b/content-documents/ds8/dd/EFTA00028324.md
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--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00028324.md
@@ -0,0 +1,150 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00028324)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
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+---
+
+| From | |
+|---------------------------------------|--|
+| | |
+| | |
+| | |
+| Subject **UPDATE** RE: Requests | |
+| Date: Tue, 30 Jun 2020 14:45:44 +0000 | |
+
+| Attachments: QTRLY_SHU_Slides-_PSYC_ONLY.pptx | | | |
+|-----------------------------------------------|--|--|--|
+|-----------------------------------------------|--|--|--|
+
+Attached is the most recently updated Suicide Prevention slide show the Chief Psychologist uses during SHU training. It is dated 6/11/13. This is the slide show that is still being used during quarterly SHU training.
+
+I will continue to send additional docs as I obtain them.
+
+| »' | | > 6/26/2020 10:59 AM >>> |
+|----|--|--------------------------|
+| | | |
+
+Thank you very much for this extremely clear and helpful email. Just a few follow-up points:
+
+- For the "Hot List" (or the high risk list), it is dated August 30, 2019, which is after the events in question. Do you have these from the period of June 26, 2019 through August 10, 2019?
+- You are still working on getting us the following:
+ - o Finalized versions of Program Statements 5511.08 and 5500.13;
+ - o An updated suicide prevention PowerPoint presentation; and
+ - o Watch call tracking sheets
+- Finally, with respect to our request for all SROs during the time of assignment to the SHU, that seems excessively burdensome. Rather, if possible, can you locate the SROs related to Epstein only?
+ - o Is there something called a "SHU report" that is different from an SRO?
+
+| From: | | |
+|---------------------------------------|--|--|
+| Sent: Thursday, June 25, 2020 6:21 PM | | |
+| To: | | |
+| | | |
+| | | |
+
+Subject: Re: FW: Requests
+
+All,
+
+I hope my responses below serve to clear up some of the issues you had with the documentation that was provided. I continue to work to obtain the missing items and will send them as I receive any additional documents. Please let me know if you have further questions and I'll be happy to address anything that is still unclear.
+
+Many of the requests made, such as ICT agenda, cellmate policies and SHU policies are not one-stop-shops. These issues are covered in a number of different policies, therefore I tried to include all policies that reference those topics.
+
+- 1. We received unsigned Word versions of Program Statements 5511.08 and 5500.13. Are there finalized versions? Executive Assistant Lee Plourde handles the finalizing of the supplements. He's on leave and will address this upon his return on Monday, June 29, 2020.
+- 2. Why were we given the BOP Correctional Services Procedures Manual? Which of our requests is this responsive to? Section 310 of this policy covers inmate accountability in the SHU. You requested 5511.08 and this section in the CSPM overlaps some of those same policies.
+- 3. Why were we given the BOP Suicide Prevention Program Statement? Which of our requests is this responsive to? This policy covers staff training requirements for ICT and Quarterly SHU training. I included the policy because it directly correlated with other requests.
+- 4. We were also given a Powerpoint entitled Suicide Prevention for Inmates. Which of our requests is this responsive to? When is this document from? The slide show is the Psychology portion of the SHU Training you requested. It is dated 1/2 2014. I have requested an updated version that would have been used more closely to the time o ignment to SHU. I'm just waiting for Psychology staff to provide me whatever it is they used at that time.
+- 5. We were provided a document titled Introduction to Correctional Techniques from January 2020. Which of our requests is this responsive to? Is it the MCC institutional familiarization training outline? If so, we would request one from a time when the defendants were actively employed at MCC (so before August 2019). This is the Institutional Familiarization (IF) outline you requested. It hasn't been called IF for a few years. It is now Introduction to Correctional Techniques (ICT). An earlier version is attached here.
+- 6. We were provided with an undated slide presentation about the MCC SHU. Which of our requests is this responsive to? When is this document from? The slide show was created 1/2/2014 as a part of quarterly SHU training. The quarterly SHU training is primarily conducted through the BOP's online training platform that is a self-guided course that covers a number of topics related to SHU. The official SHU training course is not something I can send or save due to the nature of the course being automated by the training platform and not a hard file.
+- 7. The BOP Code of Ethics is highlighted below. Which document is this? Program Statement 3420.11 is the Standards of Employee Conduct, which covers the dos and don'ts of employment in the BOP. I've attached the DO] Ethics Handbook here. If there is something specific you're looking for, please let me know.
+- 8. We received digital lieutenant's logs. Is there also a hard copy book? There is no hard copy book of these logs. The logs are saved to a shared folder at the end of each shift. Although I have worked at places that print each log, the Lieutenant's here at NYM reported that that is not the practice here. The LTs here email their logs to the executive staff at the conclusion of each 24 hour period for review purposes. Thus, eliminating a hard copy record system.
+- 9. We were provided with a document called "SHU Logs MW" and a document called "SHU Logs." Can we confirm what these are? Our requests were for SHU Watch Call Logs and SHU Control Center Logs. Those are the digital log books from SHU for the Evening and Morning Watch shifts during the requested time period. I am working on obtaining the actual Watch Call tracking sheets from the main Control Center at MCC which is something different. However, the officer should be logging their watch calls into the digital log book every 30 minutes between 6a — 6p each day.
+- 10. Which document contains the BOP and MCC policy on SHU quarterly training, which is highlighted below as having been provided? PS 5270.11 as well as the Suicide Prevention policy covers the SHU quarterly training requirement. There is not a separate policy for that.
+- 11. We asked for P.S. 5270.10, but got P.S. 5270.11. Was P.S. 5270.10 provided to us in error? Or was our request incorrect? 5270.10 does not exist. 5270.11 is the policy covering SHU.
+- 12. Which document contains the BOP and MCC policy on cellmates? I am not aware of any such policy and have struggled to find even a mention of it in the policies I've reviewed. I will continue to search for a policy that references cellmate assignments.
+- 13. In the second email, there is a document called "Hot Lists" dated August 30, 2019. Which of our requests is this responsive to? The "Hot List" is the high risk list. Any inmate on that list who goes to SHU requires immediate notification to Psychology. This is the only "high risk" list the BOP has and I provided it in response to your rest for "All High Risk Lists reviewed during weekly SHU meetings..."
+- 14. In the second email, mentioned that most of the control center paperwork was seized by FBI and/or 01G. Do you or FBI have that paperwork? Has it been provided to us?
+- 15. Finally, what is the status of the remaining requests? As I continue to work from home, I have not personally been able to physically search for the Watch Call sheets. As I previously mentioned, those logs were reportedly seized early on in this investigation. I continue to follow up on this. With regard to the SROs, those reviews are only electronically available for inmates who are currently in SHU and only for the period of their most recent admission to SHU. SROs, assuming they were completed, would then be printed and filed in the inmate's central file. I am currently trying to figure out where Epstein's file is to see if any SROs are in it. If you really want ALL SROs for the period of assignment to SHU, that will be an extremely lengthy process of tracking down inmate files, many of whom have released from the BOP or been transferred to any number of institutions across the country, and then requesting any SROs from the specified period of time that are contained in those files be scanned to us. I'm guessing Epstein's file was taken along with all of the other documentation shortly after his death, but I have not confirmed that yet.
+
+Special Investigative Agent MCC New York 150 Park Row New York, NY 10007
+
+Special Investigative Agent MCC New York 150 Park Row New York, NY 10007
+
+>» 06/25/20 12:35 PM >>>
+
+Can you please address the questions/discrepancies noted below. Much appreciated.
+
+From: Sent: Thursday, June 25, 2020 12:30 PM
+
+To: Cc:
+
+Subject: RE: Requests
+
+Some follow up questions related to these materials:
+
+- 1. We received unsigned Word versions of Program Statements 5511.08 and 5500.13. Are there finalized versions?
+- 2. Why were we given the BOP Correctional Services Procedures Manual? Which of our requests is this responsive to?
+- 3. Why were we given the BOP Suicide Prevention Program Statement? Which of our requests is this responsive to?
+- 4. We were also given a Powerpoint entitled Suicide Prevention for Inmates. Which of our requests is this responsive to? When is this document from?
+- 5. We were provided a document titled Introduction to Correctional Techniques from January 2020. Which of our requests is this responsive to? Is it the MCC institutional familiarization training outline? If so, we would request one from a time when the defendants were actively employed at MCC (so before August 2019).
+- 6. We were provided with an undated slide presentation about the MCC SHU. Which of our requests is this responsive to? When is this document from?
+- 7. The BOP Code of Ethics is highlighted below. Which document is this?
+- 8. We received digital lieutenant's logs. Is there also a hard copy book?
+- 9. We were provided with a document called "SHU Logs MW" and a document called "SHU Logs." Can we confirm what these are? Our requests were for SHU Watch Call Logs and SHU Control Center Logs.
+- 10. Which document contains the BOP and MCC policy on SHU quarterly training, which is highlighted below as having been provided?
+- 11. We asked for P.S. 5270.10, but got P.S. 5270.11. Was P.S. 5270.10 provided to us in error? Or was our request incorrect?
+- 12. Which document contains the BOP and MCC policy on cellmates?
+- 13. In the second email, there is a document called "Hot Lists" dated August 30, 2019. Which of our requests is this responsive to?
+- 14. In the second email, =I mentioned that most of the control center paperwork was seized by FBI and/or OIG. Do you or FBI have that paperwork? Has it been provided to us?
+
+15. Finally, what is the status of the remaining requests?
+
+Please work on this as quickly as you can. Thanks!
+
+| From: |
+|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| Sent: Tuesday, June 23, 2020 3:59 PM |
+| To: |
+| Cc: |
+| Subject: FW: Requests |
+| |
+| fyi |
+| |
+| From: |
+| Sent: Tuesday, June 23, 2020 3:53 PM |
+| To: |
+| Cc: |
+| Subject: Re: Requests |
+| |
+| |
+| I've attached all the documentation I have pertaining to the below request. I am waiting for a few things from HR and
Psychology but wanted to send you what I have right now. I highlighted the items below that are attached in this email. |
+
+Let me know if you have any questions.
+
+
+
+Hope you and fam have been well, as well as MCC staff.
+
+Can you please provide the following information concerning the Epstein suicide investigation:
+
+- The BOP and MCC Employee Code of Conduct, Code of Ethics, and corresponding employee acknowledgement forms for Defendant Noel.
+- The MCC institutional familiarization training outline.
+- The BOP and MCC policy on cellmates and local Institutional Supplement on Special Housing Unit Regulations, including Institutional Supplement/Program Statement Number P.S. NYM 5270.10.
+- The BOP and MCC policy on SHU quarterly training.
+- The Inmate Accountability Institutional Supplement/Program Statement, Number I.S. NYM 5511.08.
+- The Security Inspections Institutional Supplement/Program Statement, Number I.S. NYM 5500.13.
+- SHU Watch Call Logs from August 9, 2019 and August 10, 2019.
+- All SHU Watch Call Logs completed during Defendant assignment to the SHU post which began on June 26, 2019.
+- All SHU Control Center Logs completed during Defendant assignment to the SHU post which began on June 26, 2019.
+- All SHU Operations Lieutenant Log Books completed during Defendant assignment to the SHU post which began on June 26, 2019.
+- All High Risk Lists reviewed during weekly SHU meetings during Defendant assignment to the SHU post which began on June 26, 2019.
+- All SHU reports and SRO reviews completed by the SHU Lieutenant during Defendant assignment to the SHU post which began on June 26, 2019.
+
+Many thx!
diff --git a/content-documents/ds8/dd/EFTA00028654.md b/content-documents/ds8/dd/EFTA00028654.md
new file mode 100644
index 0000000000000000000000000000000000000000..5edc09a1900436042d9c510d675f628aa1821f51
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00028654.md
@@ -0,0 +1,39 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00028654)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00028654"
+ocrPages: 0
+ocrChars: 1113
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From: ' | |
+|-------------------------------------------|--|
+| To: ' | |
+| Subject: FW: Disclosures for Robert Adams | |
+| Date: Thu, 12 Nov 2020 16:09:17 +0000 | |
+| Attachments: Adams_Disclosuressd.docx | |
+| | |
+
+My edits attached.
+
+| From: | |
+|--------------------------------------------|--|
+| Sent: Thursday, November 12, 2020 10:52 AM | |
+| To: | |
+| Subject: Disclosures for Robert Adams | |
+
+Hey Chiefs:
+
+We have our discovery deadline tomorrow in the Adams case. Nick and I have gone through the witness interviews and propose making the attached disclosures, which we'll incorporate into the discovery cover letter. We'd be grateful if you could take a look.
+
+We've also checked in with the agents to get their views on these disclosures, and to make sure we are not missing anything.
+
+Attorney United States Attorney's Office for the Southern District of New York
+
+New York NY 10007 Tel:
diff --git a/content-documents/ds8/dd/EFTA00029223.md b/content-documents/ds8/dd/EFTA00029223.md
new file mode 100644
index 0000000000000000000000000000000000000000..bdfd00173c2802369ee0322fe095ef07396c1834
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00029223.md
@@ -0,0 +1,19 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00029223)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00029223"
+ocrPages: 0
+ocrChars: 466
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+I'm attaching the 302 for from an interview on August 22, 2006. Do we have the notes? The last paragraph refers to her providing a copy of the hours she worked at Epstein's residence as well as some notes she made at her time of employment. Do we have those documents? I can also check with — let me know please. Thanks!
+
+Assistant United States Attorney United States Attorney's Office Southern District of New York One St. Andrew's Plaza New York, New York 10007
diff --git a/content-documents/ds8/dd/EFTA00031006.md b/content-documents/ds8/dd/EFTA00031006.md
new file mode 100644
index 0000000000000000000000000000000000000000..e51167f9c5e030509905563c006332b40ebc8dde
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00031006.md
@@ -0,0 +1,25 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00031006)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00031006"
+ocrPages: 0
+ocrChars: 1077
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From: "Berman, Geoffrey (USANYS)"
To: '
. (ODAG)"
Subject: Fwd: Epstein OCME
Date: Fri, 16 Aug 2019 19:36:47 +0000 | |
+|-----------------------------------------------------------------------------------------------------------------------------------------------------|--|
+| See below. Geoff | |
+| Begin forwarded message: | |
+| From: '
(USANYS)" <
Date: August 16, 2019 at 2:48:14 PM EDT
To: "Berman, Geoffre (USANYS "
(USANYS)"
(USANYS
Cc: '
(USANYS)" < | |
+
+The team has just learned from the City Medical Examiner that OCME has officially concluded Epstein's cause of death was hanging and the manner of death was suicide.
+
+OCME plans to issue a press release and the official death certificate indicating as much later this afternoon.
+
+Subject: Epstein OCME
diff --git a/content-documents/ds8/dd/EFTA00031911.md b/content-documents/ds8/dd/EFTA00031911.md
new file mode 100644
index 0000000000000000000000000000000000000000..5a2f93f2525a180e81bcf42e7c28cf8d9b1962d8
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00031911.md
@@ -0,0 +1,33 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00031911)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00031911"
+ocrPages: 2
+ocrChars: 283
+ocrElapsed: 0.3
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+### Event: Accepted: Epstein Meeting
+
+Start Date: 2020-01-06 17:30:00 +0000
+
+End Date: 2020-01-06 18:00:00 +0000
+
+Class: X-PERSONAL
+
+Comment:
+
+Date Created: 2020-01-08 02:26:51 +0000
+
+Date Modified: 2020-01-08 02:26:51 +0000
+
+Priority: 5
+
+DTSTAMP: 2020-01-06 16:16:51 +0000
+
+Attendee
diff --git a/content-documents/ds8/dd/EFTA00032382.md b/content-documents/ds8/dd/EFTA00032382.md
new file mode 100644
index 0000000000000000000000000000000000000000..bc64d71c8f25661ca096591b6c0fa9d62b2e7d6d
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00032382.md
@@ -0,0 +1,23 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00032382)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00032382"
+ocrPages: 0
+ocrChars: 253
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+Mr. Foy,
+
+Based on our phone conversation, I understand that you represent Ms. Noel and are authorized to accept service of this subpoena on her behalf. Please see attached.
+
+Thanks,
+
+Assistant United States Attorney Southern District of New York Tel:
diff --git a/content-documents/ds8/dd/EFTA00032630.md b/content-documents/ds8/dd/EFTA00032630.md
new file mode 100644
index 0000000000000000000000000000000000000000..506efd20e1352269d9b1d7b5da91b02119a7dd38
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00032630.md
@@ -0,0 +1,39 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00032630)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00032630"
+ocrPages: 0
+ocrChars: 1315
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+Date: Fri, 13 Sep 2019 02:16:02 +0000
+
+Importance: Normal
+
+Dear
+
+Travel authorization 10643456 has received final approval.
+
+Trip ID: 10643456 Traveler name: Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104) Purpose: R19NYS 13842 - U.S. v. Epstein - Witness Interviews Destination: Los Angeles, CA, United States Dates: 2019-09-17 - 2019-09-20 Current status: Authorization Approved
+
+E2 Single Sign On Login (within DOJ Network Only): https://dojnet.doj.gov/jmd/fs/e2-redirect.html
+
+E2 Manual Login (User ID and Password): https://e2.gov.cwtsatotravel.com
+
+Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
+
+Please note: Replies to this mailbox are not monitored.
+
+Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the emails that you receive from us.
+
+Reference ID# T0006
+
+This e-mail and any attachments may contain confidential and/or proprietary information. If you received this email in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments; any further use of such e-mail or attachments is strictly prohibited.
diff --git a/content-documents/ds8/dd/EFTA00033212.md b/content-documents/ds8/dd/EFTA00033212.md
new file mode 100644
index 0000000000000000000000000000000000000000..a1a3391245547bc9e3702c0ccc9fd67ed9c0d5f4
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00033212.md
@@ -0,0 +1,15 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00033212)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00033212"
+ocrPages: 2
+ocrChars: 22
+ocrElapsed: 0.2
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+### No Images Produced
diff --git a/content-documents/ds8/dd/EFTA00033986.md b/content-documents/ds8/dd/EFTA00033986.md
new file mode 100644
index 0000000000000000000000000000000000000000..774f3d2fcb9426ec80ec25fa69d15ce765fe3969
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00033986.md
@@ -0,0 +1,55 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00033986)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00033986"
+ocrPages: 2
+ocrChars: 1967
+ocrElapsed: 0.7
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+Good morning,
+
+Thank you.
+
+Sent from my Vcrizon, Samsung Galaxy smartphone
+
+| Original message |
+|----------------------------------------------------------------------------------|
+| From: |
+| Date: 7/28/19 7:49 AM GMT-05:00 |
+| To: |
+| Cc: |
+| Subject: Fwd: Suicide Watch/Psych Observation Update |
+| |
+| |
+| >>> '
' 07/28/2019 07:49 >>> |
+| |
+| |
+| Inmate Epstein seems psychologically stable. |
+| |
+| He complained that his right arm was numb and hanging earlier. Nurse
saw him. |
+
+He again said his right arm still feels somewhat numb and he said he cannot make a fist with that hand. He also said he has numbness on his neck. I informed Nurse
+
+He stated the toilet in his cell was running for 45 minutes last night and he could not take the noise. He is going to try the toilet before going to legal today and if it does not shut off, he will be moved to another cell.
+
+Thanks,
+
+>>> 7/28/2019 7:36 AM >>> Inmate is being taken off of Psych Observation.
+
+Suicide Watch None
+
+Psych Observation 1. Epstein #76318-054
+
+Pendin Beds ace for H 1,
+
+Thank you,
+
+
+
+EFTA00033986
diff --git a/content-documents/ds8/dd/EFTA00035547.md b/content-documents/ds8/dd/EFTA00035547.md
new file mode 100644
index 0000000000000000000000000000000000000000..a52290d601bd01b230333d250aac3e4c196e30f3
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00035547.md
@@ -0,0 +1,66 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00035547)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00035547"
+ocrPages: 0
+ocrChars: 7519
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From: | |
+|----------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------|
+| To: | |
+| | Subject: Fwd: counsel having difficulty meeting with client |
+| | Date: Sun, 07 Jul 2019 22:58:26 +0000 |
+| Importance: Normal
Attachments: TEXT.htm | |
+| | |
+| | |
+| | |
+| | |
+| | Sent from my Vcrizon, Samsung Galaxy smartphone |
+| Ori inal messa e | |
+| From: | |
+| Date: 7/7/19 6:22 PM GMT-05:00
To: | |
+| | Subject: Fwd: counsel having difficulty meeting with client |
+| | |
+| | ' 07/07/2019 18:22 >»
I have verified Martin Weinberg is an attorney in good standing in Massachusetts. He is permitted to visit Jeffrey |
+| | Epstein.Sent from my Verizon, Samsung Galaxy smartphone |
+| cdiv>
ori inalMessa e | Ori inal messa e
|
+| From: "
| |
+| | GMT-05:00
;
|
+| | Subject: RE: counsel having difficulty meeting with client
|
+| | 07/07/2019 18:18 >» |
+| Massachusetts | |
+| From:
Sent: Sunda
Jul | 07, 2019 18:18 |
+| To: | ; |
+| | Subject: Re: counsel having difficulty meeting with client |
+| Sony | just seeing this now. Where is he barred? |
+| | |
+| | Sent from my Verizon, Samsung Galaxy smartphone |
+| | |
+| | |
+
+Original message From: mailto:
+
+Date: 7/7/19 5:36 PM (GMT-05:00)
+
+mailto:
+
+Subject: RE: counsel having difficulty meeting with client
+
+## >>> ' (USANYS)" 07/07/2019 17:36 >>>
+
+With apologies for the weekend email, we have a defendant, Jeffrey Epstein, who was arrested last night and is c urrently being detained at MCC, and is expected to be presented on an indictment tomorrow. His attorney, Marti n Weinberg, has represented him in the past, and represents him in connection with our case and has been in touc h with us throughout the weekend. He went to MCC today to meet with him in advance of the presentment tomo now, but was just told he is not allowed in because he is from out-of-state.
+
+We're concerned about the defendant not having access to his attorney in advance of the presentment (as we woul d be for any defendant) and so I wanted to reach out to you-
+
+is it at allpossible to address this issue so Mr. Weinberg can meet with his client this evening? I'm available anyt ime to discuss, if that's helpful, or Mr. Weinberg can also be reached directly at
+
+if that's easier (though if you reach out directly to him if you could please just let me know afterward I'd be grateful).
+
+thanks very much,
diff --git a/content-documents/ds8/dd/EFTA00036015.md b/content-documents/ds8/dd/EFTA00036015.md
new file mode 100644
index 0000000000000000000000000000000000000000..c5e8f5b7dfa453a92a715b2cded4fff11cd40fa9
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00036015.md
@@ -0,0 +1,35 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00036015)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00036015"
+ocrPages: 0
+ocrChars: 3022
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+## DEPARTMENT OF JUSTICE I OFFICE OF THE INSPECTOR GENERAL
+
+| April 10, 2023 | |
+|-----------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| Memorandum For: | Assistant Director
Inspection Division
Federal Bureau of Investigation |
+| From: | Deputy Assistant Inspector General
Investigations Division
Office of Inspector General |
+| Subject | Office of Inspector General's Draft Report entitled Investigation and Review of the
Federal Bureau of Prisons' Custody, Care, and Supervision offeffrey Epstein at the
Metropolitan Correctional Center in New York New York |
+
+Attached to this memorandum is the Office of the Inspector General's draft report entitled Investigation and Review of the Federal Bureau of Prisons' Custody, Care, and Supervision ()Caffrey Epstein at the Metropolitan Correctional Center in New York New York which we plan to release publicly.
+
+We are providing this draft report to enable the Federal Bureau of Investigation (FBI) to conduct a factual accuracy and sensitivity review. If the FBI believes that any information in the draft report would be inappropriate for public release, please mark the information and indicate the reason the FBI believes it should not be released. Please provide us the results of your factual accuracy and sensitivity review as soon as possible, but no later than Monday, April 17, 2023. We can accept such comments informally and on a rolling basis.
+
+Because this is a draft report, it should not be disseminated to or discussed with anyone other than those FBI employees who need to review the draft report for factual accuracy or sensitivity purposes. In this regard, we request that your office maintain a log of who has been provided access to the draft report and when. We also request that your office emphasize to those reviewing the draft report or its contents the prohibition on further dissemination and discussion of the draft report with anyone other than FBI employees, as necessary for the purposes of assessing factual accuracy or sensitivity or preparation of the FBI's formal response.
+
+If you have any questions about this memorandum or the draft report, please contact me or Senior Counsel to the Inspector General . Thank you for your cooperation in this matter.
+
+cc:
+
+Associate Deputy Attorney General
diff --git a/content-documents/ds8/dd/EFTA00036329.md b/content-documents/ds8/dd/EFTA00036329.md
new file mode 100644
index 0000000000000000000000000000000000000000..204756191208a1bf28422a61961d7744f1d5991a
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00036329.md
@@ -0,0 +1,51 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00036329)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00036329"
+ocrPages: 2
+ocrChars: 1590
+ocrElapsed: 0.6
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+From: ""Editors. Federal Soup" "
+
+To:
+
+Bee: "E llig> Subject: Federal Soup: Your Federal Career & Benefits Date: Tue, 13 Aug 2019 12:01:04 +0000 Importance: Normal
+
+### FEDERAL SOUP: FOR FEDERAL EMPLOYEES
+
+Whether you're still planning retirement, or retiring this year, the Federal Employees Retirement Guide has the vital information you need.
+
+Subscribe to Federal Soup today:
+
+http://1105insight.corn/portal/wts/ugmcmQedEQ2bbbgdbeg%5EqcexBw3%7Ca
+
+Get instant access to the 2019 edition of the Federal Employees Retirement Guide, with resources and information on topics such as:
+
++ The retirement process for the major federal retirement systems
+
++ Preparations that employees need to make early in their careers, mid-career and the year immediately preceding retirement
+
++ Deposits, re-deposits and the effect of military service years and pensions on civilian retirement
+
++ Insurance issues and Medicare
+
++ Easy checklists, resource lists and estimation tools to prepare yourself for the choices you face
+
+Subscribe Here: http://1105insight.corn/portaUwts/ugmcmQedEQ2bbbgdbeg%5E%5EcexBw3%7Ca
+
+We'll see you online! — The Editors of FederalSoup.com
+
+This message was sent to:
+
+If you no longer wish to receive these types of emails, please use the link below:
+
+http://1105insight.corn/portal/unsubscribeconfirrnn3cFVNcvAFyVQHu3sr5CLNuO4ThdMxshDA
+
+To review our Privacy Policy, visit our website at http://1105insight.corn/portaUwts/ugmcmQedEQ2bbbgdbeg%5EycexBw3%7Ca 1105 Media, Inc., 6300 Canoga Ave., Woodland Hills, CA 91367
diff --git a/content-documents/ds8/dd/EFTA00036427.md b/content-documents/ds8/dd/EFTA00036427.md
new file mode 100644
index 0000000000000000000000000000000000000000..1dcab97c22bfc38e482a2ff8055e44f5edf42c83
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00036427.md
@@ -0,0 +1,27 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00036427)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00036427"
+ocrPages: 0
+ocrChars: 188
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+Subject Suicide Watch/Psych Observation Update Date: Tue, 06 Aug 2019 11:47:16 +0000 Importance: Normal Attachments: TEXT.htm
+
+Suicide Watch
+
+1
+
+### Psych Observation
+
+None
+
+Thank you,
diff --git a/content-documents/ds8/dd/EFTA00036873.md b/content-documents/ds8/dd/EFTA00036873.md
new file mode 100644
index 0000000000000000000000000000000000000000..bdfa4d4dc0612f1273172b6f4a199f3d08831ae4
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00036873.md
@@ -0,0 +1,43 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00036873)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00036873"
+ocrPages: 2
+ocrChars: 2153
+ocrElapsed: 0.6
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From: " | |
+|---------------------------------------|--|
+| To: | |
+| | |
+| Subject Operations | |
+| Date: Wed, 14 Aug 2019 20:22:53 +0000 | |
+| Importance: Normal | |
+| Attachments: TEXT.htm | |
+| | |
+
+Good Afternoon,
+
+As your supervising Associate Warden, it is my goal to have a one on one with each of you and provide you with my expectations. Due to the current situation, I am unable to do this at this time. However, I do want to pass a few things on to you until we can have a sit down discussion:
+
+(1). Please ensure you have accountability for your staff because when you are not here and something happens, I am the next in the chain of command to have to respond. If you are out, please ensure that you have an Acting and that Acting knows that he/she is/will be given the same courtesies as you.
+
+(2). Timely submission. Please ensure that you submit paperwork in a timely manner. Meaning that if you are late, please don't email it to me and expect me to print, proof, route, etc.... This is not professional and not my job. Submit your T&A in WEBTA timely.
+
+(3). Provide me with your leave requests for the entire remainder of the year. Please ensure that those previous and current requests are entered in WEBTA. I would hope that you would have a discussion with me prior to submitting them in WEBTA.
+
+(4). If you are late or call in sick, please do not leave me a voice mail message or text. Please contact me on my BOP cell phone at Once you arrive at work, please submit your leave in WEBTA.
+
+(5). Comp Time must be pre-approved by me. No exceptions. Once worked, a Comp Sheet must be completed and routed in a folder for my review and then I will forward it on to the Warden.
+
+There are additional expectations forthcoming and will be discussed in person during our meeting. You will have your opportunity to discuss any concerns you may have at that time as well. Thanks.
+
+Associate Warden MCC New York
+
+New York, New York 10007
diff --git a/content-documents/ds8/dd/EFTA00037054.md b/content-documents/ds8/dd/EFTA00037054.md
new file mode 100644
index 0000000000000000000000000000000000000000..c41791ddfa255950e33a654af192d5d4a5063906
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00037054.md
@@ -0,0 +1,13 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00037054)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00037054"
+ocrPages: 0
+ocrChars: 0
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
diff --git a/content-documents/ds8/dd/EFTA00037815.md b/content-documents/ds8/dd/EFTA00037815.md
new file mode 100644
index 0000000000000000000000000000000000000000..4fa8eb110dd00d634e2da065c06cbbc82b3f1bf4
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00037815.md
@@ -0,0 +1,44 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00037815)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00037815"
+ocrPages: 0
+ocrChars: 2589
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From: | | |
+|--------------------|---------------------------------------|--|
+| To:' | | |
+| | Cc: "a | |
+| | Subject: Re: Paris Mansion | |
+| | Date: Tue, 13 Aug 2019 13:25:41 +0000 | |
+| Importance: Normal | | |
+
+Yes, yesterday afternoon we received official requests for information from MOJ and the French Police. My understanding is the that the French want to open an investigation an are asking for our Intel on any French nexus to victims or subjects under French jurisdiction.
+
+| From: | |
+|----------------------------------------|--|
+| Sent: Tuesday, August 13, 2019 2:53 PM | |
+| To: | |
+| Subject: Re: Paris Mansion | |
+
+### Hi a,
+
+I'm happy to discuss further. I likely won't be able to get to lync until a bit later today. As far as Epsteins travel, he traveled frequently to Paris and did have an apartment there.
+
+Do you know what the present status is? Has France decided to open an investigation?
+
+On Aug 12, 2019 11:47 AM, " > wrote: Hi , FBI and DOJ in Paris received requests this morning from French authorities to furnish any additional information regarding the ongoing cases on Jeff Epstein as it relates to France? This stems from the fact that the someone in the USG asked France to furnish travel information for Epstein in and out of France. Additionally, it has come to our attention that Epstein owned an apartment on Paris France 75116. Let me know when you can discuss further over Lync is preferable? Regards • From: = > Sent: Monday, August 12, 2019 5:37 PM To: Cc: Subject: Paris Mansion and M, please reach out to ALAT Paris >; ; Byrne SSA FBI New York
+
+| On Aug 12, 2019 10:47 AM, "
> wrote: |
+|------------------------------------------------------------------------------------------------------------|
+| is the supervisor of the squad that has the case. His case agents will be reaching out to you soon.
SSA |
+| cell
ALAT |
+| Thank you, |
+| SSA
FBI HQ, TOC-East
Eurasian Organized Crime
Cell
Desk |
diff --git a/content-documents/ds8/dd/EFTA00037961.md b/content-documents/ds8/dd/EFTA00037961.md
new file mode 100644
index 0000000000000000000000000000000000000000..f0ca53aa51775aa6a6558ed19539ab30bf054fba
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00037961.md
@@ -0,0 +1,17 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00037961)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00037961"
+ocrPages: 0
+ocrChars: 13
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+Attached.
diff --git a/content-documents/ds8/dd/EFTA00038114.md b/content-documents/ds8/dd/EFTA00038114.md
new file mode 100644
index 0000000000000000000000000000000000000000..9ec87831ada77c414c408d8c962a19b791938894
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00038114.md
@@ -0,0 +1,22 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00038114)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00038114"
+ocrPages: 0
+ocrChars: 367
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From: "EIMIMIa | |
+|----------------------------------------|--|
+| To:' | |
+| Subject: FBINET to UNET Uploaded Files | |
+| Date: Thu, 05 Sep 2019 14:02:51 +0000 | |
+| Importance: Normal | |
+| Attachments: LSJ_SW.pdf | |
+| | |
diff --git a/content-documents/ds8/dd/EFTA00038714.md b/content-documents/ds8/dd/EFTA00038714.md
new file mode 100644
index 0000000000000000000000000000000000000000..279bbbd8f35d6aee76ce84945ca9b2e59fdf3dcf
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00038714.md
@@ -0,0 +1,40 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00038714)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00038714"
+ocrPages: 0
+ocrChars: 1931
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From: | | |
+|--------------------|----------------------------------------------------------------------------|-------|
+| To: | | |
+| Cc: | | |
+| | Subject: [EXTERNAL EMAIL] - FW: Voice Message Attached from
unavailable | -name |
+| | Date: Wed, 11 Aug 2021 16:55:30 +0000 | |
+| Importance: Normal | | |
+| Attachments: | 20210811 120731.wav | |
+
+Passing this along per our standard practice.
+
+Click attachment to listen to Voice Message
+
+| Ori inal Messa e |
+|------------------------------------------------------------------------|
+| From: |
+| Sent: Wednesday, August 11, 2021 12:30 PM |
+| To: |
+| Subject: FW: Voice Message Attached fromMillilli
- name unavailable |
+| Re Maxwell. |
+| Original Message |
+| From:
"
X |
+| Sent: Wednesday, August 11, 2021 12:08 PM |
+| To: |
+| - name unavailable
Subject: Voice Message Attached from |
+| Time: Aug 11, 2021 12:07:31 PM |
diff --git a/content-documents/ds8/dd/EFTA00038883.md b/content-documents/ds8/dd/EFTA00038883.md
new file mode 100644
index 0000000000000000000000000000000000000000..14d3867d1dafbc7490926086705f24c3166da19f
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00038883.md
@@ -0,0 +1,50 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00038883)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00038883"
+ocrPages: 0
+ocrChars: 1776
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+### Event: [EXTERNAL EMAIL] - GM: juror 50 hearing
+
+Start Date: 2022-03-08 15:00:00 +0000
+
+End Date: 2022-03-08 18:30:00 +0000
+
+Organizer:
+
+Location: Courtroom 110, 40 Foley
+
+Class: X-PERSONAL
+
+Date Created: 2022-03-04 02:03:28 +0000
+
+Date Modified: 2022-03-04 02:09:36 +0000
+
+Priority: 5
+
+DTSTAMP: 2022-03-04 02:01:06 +0000
+
+| Attendee: | | | |
+|-----------|--|--|--|
+| | | | |
+| | | | |
+| | | | |
+| | | | |
+| | | | |
+| | | | |
+
+Alarm: Display the following message 15m before start
+
+Reminder
+
+Docket Text:
+
+ORDER as to Ghislaine Maxwell. As noted in this Court's prior order, a hearing on the Defendant's motion for a new trial is scheduled for March 8, 2022, at 10:00 a.m. Dkt. No. 610. The hearing location is hereby changed to Courtroom 110 of the Thurgood Marshall United States Courthouse, 40 Centre Street, New York, New York....[*** See this Order ***]... Per the S.D.N.Y. Response to COVID-19, anyone who appears at any S.D.N.Y. courthouse must complete a questionnaire on the date of the proceeding prior to entering the courthouse. Only persons who meet the entry requirements established by the questionnaire will be allowed to enter the courthouse. All visitors must wear an N95, KN95, or KF94 mask at all times. Surgical masks, cloth masks, bandannas, gaiters, and masks with valves are not permitted. If a person does not have an approved mask, a screener will provide one. Anyone who fails to comply with the COVID-19 protocols that have been adopted by the Court will be required to leave the courthouse. There are no exceptions. For more information, please see https://www.nysd.uscourts.gov/covid-19-coronavirus. SO ORDERED. (Signed by Judge Alison J. Nathan on 3/3/2022)(bw)
diff --git a/content-documents/ds8/dd/EFTA00038979.md b/content-documents/ds8/dd/EFTA00038979.md
new file mode 100644
index 0000000000000000000000000000000000000000..65d2822703f0d2aa1c71caed4e82ec9aad8befff
--- /dev/null
+++ b/content-documents/ds8/dd/EFTA00038979.md
@@ -0,0 +1,42 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00038979)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00038979"
+ocrPages: 0
+ocrChars: 1384
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From: |
+|--------------------------------------------------|
+| To: |
+| |
+| |
+| Cc: |
+| Subject: RE: Witnesses |
+| Date: Mon, 13 Dec 2021 22:55:44 +0000 |
+| Importance: Normal |
+| Attachments:
docx |
+| |
+| Good evening, |
+| |
+| Attached is the work up for |
+| |
+| |
+| From:
Sent: Monday, December 13, 2021 5:05 PM |
+| To: |
+| |
+| Cc |
+| Subject: Witnesses |
+| |
+| |
+| Special Agent |
+| FBI New York Field Office |
+| Child Ex loitation Human Trafficking |
+
+Desk:
diff --git a/content-documents/ds8/de/EFTA00013428.md b/content-documents/ds8/de/EFTA00013428.md
new file mode 100644
index 0000000000000000000000000000000000000000..901c38f08c0397da0f456f7a08596b35b34b7bbf
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00013428.md
@@ -0,0 +1,36 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00013428)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00013428"
+ocrPages: 0
+ocrChars: 935
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From: | |
+|--------------|------------------------------------------|
+| To: | |
+| | |
+| | |
+| Subject: | [EXTERNAL] Re: PBPD Trash Pull & Records |
+| Date: | Mon, 11 Oct 2021 14:44:48 +0000 |
+| Attachments: | Materials_from_Sgt |
+
+Attached is a draft 302 for case files that I picked up on Friday.
+
+## Detective NYPD / FBI Child E loitation Human Trafficking Task Force Office:
+
+
+
+## CAUTION! EXTERNAL SENDER
+
+STOP WHEN UNSURE. Never click on links or open attachments if sender is unknown, and never provide user ID or password. Suspicious? Please report to this email address: reportphishing@nypd.org
+
+Hey guys,
+
+Attached is the PBPD Trash Pull along with the records received today.
diff --git a/content-documents/ds8/de/EFTA00013881.md b/content-documents/ds8/de/EFTA00013881.md
new file mode 100644
index 0000000000000000000000000000000000000000..960ee19088bae271706b3844dd78c2f672288683
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00013881.md
@@ -0,0 +1,25 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00013881)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00013881"
+ocrPages: 0
+ocrChars: 330
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+Call me when u can.
+
+--- Original Message From: To: Cc: • Richards, Jason R. Sent: Fri Jun 27 15:47:54 2008 Subject: Epstein Plea (USAFLS) < ;,•
+
+Wow, am I good. Here it is already. I think our faxes crossed in cyber-space. Sorry for the poor quality, that is how it came to me.
+
+«Epstein Plea00 I .pdf»
+
+Assistant U.S. Attorney
diff --git a/content-documents/ds8/de/EFTA00014086.md b/content-documents/ds8/de/EFTA00014086.md
new file mode 100644
index 0000000000000000000000000000000000000000..66b43dd83a8bfd158a2de079869cc01b4430418b
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00014086.md
@@ -0,0 +1,47 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00014086)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00014086"
+ocrPages: 0
+ocrChars: 1950
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From: Ted Leopold -4
To: '
(USAFLS)"
Subject: RE: Epstein Investigation
Date: Mon, 30 Jun 2008 21:22:13 +0000
Importance: Normal |
+|-----------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| Thanks
Original Message-----
From:
. (USAFLS) [mantis:
Sent: Monday, June 30, 2008 5:13 PM
To: Ted Leopold
Subject: RE: Epstein Investigation |
+| I will do so. Look forward to hearing from you.
Assistant U.S. Attorney
West Palm Beach, FL 33401
Phone
Fax |
+
+| From: Ted Leopold [mailto: |
+|--------------------------------------------------------------------|
+| Sent: Monday, June 30, 2008
5:13 PM |
+| . (USAFLS)
To: |
+| Subject: RE: Epstein Investigation |
+| |
+| I will get back to you.
Thanks |
+| |
+| p.s., Tell
hello for me. Both are good friends for mine.
and |
+| ----Original Message |
+| . (USAFLS) [mailto:
From: |
+| Sent: Monday, June 30, 2008 5:00 PM |
+| To: Ted Leopold |
+| Subject: Epstein Investigation |
+| |
+| |
+
+Dear Ted: Here is my e-mail address and contact information.
+
+Thank you for your assistance.
+
+Assistant U.S. Attorney
+
+West Palm Beach, FL 33401
+
+Phone
+
+Fax
diff --git a/content-documents/ds8/de/EFTA00014958.md b/content-documents/ds8/de/EFTA00014958.md
new file mode 100644
index 0000000000000000000000000000000000000000..eace30b34af8815cb4ff142fa940593e59a2cae9
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00014958.md
@@ -0,0 +1,21 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00014958)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00014958"
+ocrPages: 0
+ocrChars: 149
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+To:
+
+### Accepted: Call re: GM photo project
+
+Tue 8/10/2021 1:05 PM
+
+htlps.11oullook.office365.usimailldeeplink?popoutv2=18Nersion=20211025002.13 1/1
diff --git a/content-documents/ds8/de/EFTA00015697.md b/content-documents/ds8/de/EFTA00015697.md
new file mode 100644
index 0000000000000000000000000000000000000000..716288372e3cdc0780282cd8d7ea5bbea7d2585c
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00015697.md
@@ -0,0 +1,17 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00015697)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00015697"
+ocrPages: 0
+ocrChars: 71
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+I just want to be sure that you received all of these previous calls.
diff --git a/content-documents/ds8/de/EFTA00016349.md b/content-documents/ds8/de/EFTA00016349.md
new file mode 100644
index 0000000000000000000000000000000000000000..095666c545cb6e3dbfb5a4c01dfbfe34a87f0d73
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00016349.md
@@ -0,0 +1,333 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00016349)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00016349"
+ocrPages: 0
+ocrChars: 40042
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+#### APPLICATION
+
+Mag.
+
+# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK In re: Warrants and Orders For Prospective and Historical Location Information and Pen Register Information for the Cell hones Assigned Call Numbers and USAO Reference No. 2018R01618
+
+### Application for Warrants and Orders for Cellphone Location and Pen Register Information
+
+The United States of America, by its attorney, Audrey Strauss, Acting United States Attorney for the Southern District of New York, Assistant United States Attorney, of counsel, respectfully requests that the Court issue the accompanying proposed Warrants and Orders for prospective and historical location information and pen register information for two cellphones. As grounds for this Application the Government relies on the following facts and authorities.
+
+# I. Introduction
+
+I. I am an Assistant United States Attorney in the U.S. Attorney's Office for the Southern District of New York. This Application is submitted in conjunction with the accompanying affidavit of a law enforcement agent ("Agent Affidavit"), to be sworn before this Court, and incorporated by reference herein. I make this Application based on information and belief, including the Agent Affidavit, my review of other documents in the case, and information received from investigative personnel.
+
+2. The Investigating Agency, Target Cellphones, Subscribers, Target Subject, Service Providers, Subject Offenses, Successor Service Provider, and Successor Cellphone referenced in this Application are as specified in the Agent Affidavit.
+
+# II. Legal Authority
+
+#### A. Prospective Location Information
+
+3. The Government seeks to obtain both precision location information and cell site data for the Target Cellphones on a prospective basis (the "Prospective Location Information") for a period of 45 days from the date of this order — the same period of time for which a warrant for a tracking device may be granted under Rule 41(e)(2)(C). It bears noting, however, that while the Prospective Location Information may permit "tracking" the user of the phone in the colloquial sense, this is not an application for a warrant for a "tracking device" as defined in Fed. R. Crim. P. 41(a)(2)(E) and 18 U.S.C. § 3117(b). Those provisions only apply where an agent is seeking to physically install a tracking device on a given object. Instead, the Prospective Location Information will be obtained by requiring the Service Provider to provide the information.
+
+4. The authority for this application is found in 18 U.S.C. § 2703(c)(1), which authorizes a court of competent jurisdiction to require any electronic communication service provider (which includes a cellular telephone service provider') to disclose any "record or other information pertaining to a subscriber other than the "contents of communications," when the government obtains, inter cilia, a warrant under the applicable procedures of Rule 41. See 18 U.S.C. § 2703(cX1)(A). Because data concerning a subscriber's location, such as precision location information and cell site data, constitutes "information pertaining to a subscribe?' that does not include the "contents of communications," that data is among the types of information available
+
+See 18 U.S.C. § 2711(1) (incorporating by cross-reference statutory definitions set forth in 18 U.S.C. § 2510); 18 U.S.C. § 2510(15) (defining "electronic communication service" as "any service which provides to users thereof the ability to send or receive wire or electronic communications").
+
+under § 2703(c)(1)(A).2 Further, as specified in 18 U.S.C. § 2711(3), this Court is a court of competent jurisdiction under the Stored Communications Act because it has jurisdiction over the Subject Offenses.
+
+5. The Government's request for cell site data also implicates the pen register statute, because such data constitutes signaling information used by the Service Providers to route communications to and from the Target Cellphones. In order to collect such data, a valid pen register order is required.3 Accordingly, I hereby certify pursuant to 18 U.S.C. § 3122 that such signaling information is relevant to an ongoing investigation being conducted by the Investigating Agency into suspected violations of the Subject Offenses by the Target Subject.
+
+### B. Historical Location Information
+
+6. The Government also seeks historical cell site data for the Target Cellphones for the period from June I, 2020 to the present (the "Historical Location Information"). Because such data—like "Prospective Location Information"—constitutes information concerning a subscriber, the Court is authorized to order the Service Providers to provide this data pursuant to a warrant
+
+2 See In re Application, 460 F. Supp. 2d 448, 459-60 & n. 55 (S.D.N.Y. 2006) (Kaplan, J.) (cellphone location information falls within § 2703(c)(1)); accord, e.g., United States v. Caraballo, 963 F. Supp. 2d 341, 361 (D.Vt. 2013); In re Order, 632 F. Supp. 2d 202, 207 (E.D.N.Y. 2008); In re Application, 405 F. Supp. 2d 435, 444-45 (S.D.N.Y. 2005). But see In re Application, 849 F. Supp. 2d 526, 574 (D.Md. 2011) (rejecting view that cellular location data falls within the scope of the SCA and finding that phone must be treated as "tracking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5-'1'6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same).
+
+3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 3127(3) & (4) (defining pen register and trap and trace device to include devices or processes that record, inter alio, signaling information). Although cell site data constitutes "signaling" information within the meaning of the pen register statute, a separate statute precludes the Government from relying "solely" on the authority provided by the pen register statute to ascertain a subscriber's location. 47 U.S.C. § 1002(a). Here, the Government seeks to obtain such data pursuant to 18 U.S.C. § 2703(c) as well as the pen register statute, rather than "solely" under the latter statute. See In re Application, 460 F. Supp. 2d at 456-59.
+
+application under 18 U.S.C. § 2703(c), under the applicable procedures of Rule 41. See 18 U.S.C. § 2703(c)(1)(A). I respectfully submit that the same probable cause supporting the Government's request for a warrant to obtain the Prospective Location Information requested above also supports the issuance of a warrant under § 2703(c) for the requested Historical Location Information. In addition, the Government seeks toll records for the same period as the Historical Location Information. Pursuant to 18 U.S.C. § 2703(d), I respectfully submit that the Agent Affidavit offers specific and articulable facts showing that there are reasonable grounds to believe that the toll record information sought is relevant and material to an ongoing criminal investigation.
+
+### C. Pen Register Information
+
+7. Finally, the Government seeks an order pursuant to 18 U.S.C. §§ 3121-26 authorizing the use of a pen register on the Target Cellphones for a period of 45 days from the date of this order. Specifically, the Government seeks an order directing the Service Providers to furnish any information, facilities, and technical assistance necessary to operate, unobtrusively and with minimum disruption of service, a pen register and trap and trace device to capture all dialing, routing, addressing, or signaling information associated with each call transmitted to or from the Target Cellphones, as specified further in the proposed Warrants and Orders (the "Pen Register Information").4
+
+The Government is also not seeking authorization to obtain post-cut-through dialed digits ("PCTDD"), or digits that are dialed after a telephone call from the Target Cellphones has been connected. Pursuant to the attached Order, if possible, the Service Provider will forward only precut-through-dialed digits to the Investigating Agency. However, if the Service Providers' technical capabilities require it to forward all dialed digits, including PCTDD, to the Investigating Agency, the Investigating Agency will only decode and forward to the agents assigned to the investigation the numbers that are dialed before the call is cut through.
+
+8. I hereby certify pursuant to 18 U.S.C. § 3122 that the Pen Register Information is relevant to an ongoing investigation being conducted by the Investigating Agency into suspected violations of the Subject Offenses by the Target Subject.
+
+### D. Sealing and Non-Disclosure Order to Service Providers
+
+9. When the Government obtains records or information under § 2703(c), it is not required to notify the subscriber or customer. 18 U.S.C. § 2703(c)(3). Additionally, the Government may obtain an order precluding the Service Providers from notifying the subscriber or any other thirdparty of the warrant or order obtained, for such period as the Court deems appropriate, where there is reason to believe that such notification will result in endangering the life or physical safety of an individual, flight from prosecution, destruction of or tampering with evidence, or intimidation of potential witnesses, or will otherwise seriously jeopardize the investigation. 18 U.S.C. § 2705(b).
+
+10. Further, 18 U.S.C. § 3I23(d) provides that an order directing installation of a pen register or trap and trace device shall direct the pertinent service provider "not to disclose the existence of the pen register or trap and trace device or the existence of the investigation to the listed subscriber, or to any other person unless or until otherwise ordered by the Court."
+
+II. Accordingly, as explained further in the Agent Affidavit, in light of the confidential nature of the continuing criminal investigation and the adverse consequences expected in the event of premature notification, the Government respectfully requests that the Court direct the Service Providers not to notify the Subscribers or any other person of the Warrants and Orders sought herein for a period of one year, subject to extension upon application to the Court, if necessary.
+
+12. For similar reasons, I respectfully request that the proposed Warrants and Orders, this Application, and the accompanying Agent Affidavit, be maintained under seal until the Court orders otherwise, except that the Government be permitted without further order of this Court to serve these Warrants and Orders on the Service Providers; provide copies of the Warrants and Orders or the supporting Application and Agent Affidavit as need be to personnel assisting the Government in the investigation and prosecution of this matter; and disclose these materials as necessary to comply with discovery and disclosure obligations in any prosecutions related to this matter.
+
+# III. Prior Requests
+
+13. Except as may be set forth above, no prior request for the relief requested herein has been made.
+
+Dated: New York, New York
+
+June 29, 2020
+
+
+
+| UNITED STATES DISTRICT COURT |
+|-----------------------------------------------|
+| SOUTHERN DISTRICT OF NEW YORK |
+| |
+| re:
Warrants
and
Orders
For
In |
+| Prospective
and
Historical
Location |
+| and
Register
Information
Pen |
+| Information
for
the
Cell hones |
+| Assigned Call Numbers |
+| and
USAO Reference |
+| No. 2018R01618 |
+| |
+
+#### AGENT AFFIDAVIT
+
+Mag.
+
+# Agent Affidavit in Support of Warrants and Orders for Cellphone Location and Pen Register Information
+
+STATE OF NEW YORK ) ) ss. COUNTY OF NEW YORK )
+
+being duly sworn, deposes and states:
+
+# I. Introduction
+
+I. I have been a Special Agent with the Federal Bureau of Investigation ("FBI" or "Investigating Agency") since 2017. As such, I am a "federal law enforcement officer within the meaning of Federal Rule of Criminal Procedure 41(a)(2)(C), that is, a government agent engaged in enforcing the criminal laws and duly authorized by the Attorney General to request a search warrant. I am currently assigned to investigate violations of criminal law relating to the sexual exploitation of children as part of an FBI Task Force. I have gained expertise in this area through classroom training and daily work related to these types of investigations. As part of my responsibilities, I have been involved in the investigation of cases involving sex trafficking, enticement of minors, and transportation of minors for illegal sex acts, and have participated in the execution of search warrants involving electronic evidence.
+
+2. Requested Information. I respectfully submit this Affidavit pursuant to 18 U.S.C. §§ 2703(c) and (c)(1)(A) and the applicable procedures of Federal Rule of Criminal Procedure 41; 18 U.S.C. §§ 2703(d) & 2705; and 18 U.S.C. §§ 3121-3126, in support of two warrants and orders for prospective location information, historical location information, toll records, and pen register information, for the Target Cellphones identified below (collectively, the "Requested Information").
+
+3. Basis for Knowledge. This Affidavit is based upon my participation in the investigation, my examination of reports and records, and my conversations with other law enforcement agents and other individuals, as well as my training and experience. Because this Affidavit is being submitted for the limited purpose of obtaining the Requested Information, it does not include all the facts that I have learned during the course of this investigation. Where the contents of documents and the actions, statements, and conversations of others are reported herein, they are reported in substance and in part, except where otherwise indicated. In addition, unless otherwise indicated, statements by others referenced in this Affidavit were not necessarily made to me, but may have been provided to me by someone else to whom I have spoken or whose report I have read (and who in turn may have had either direct or indirect knowledge of the statement). Similarly, unless otherwise indicated, information in this Affidavit resulting from surveillance does not necessarily set forth my personal observations, but may have been provided to me by other law enforcement agents who observed the events, and to whom I have spoken or whose report I have read.
+
+4. Target Cellphones, Subscribers, Target Subject, and Service Providers. The Target Cellphones referenced in this Affidavit are the cellphone assigned call number
+
+("Target Cellphone-1") and the cellphone assigned call number ("Target Cellphone-2," and collectively with Target Cellphone-1, the "Target Cellphones"). As further discussed below, Target Cellphone-1 is subscribed to in the name of "Terramar Project, Inc."
+
+("Subscriber-1"), and Target Cellphone-2 is subscribed to in the name of "G Max" ("Subscriber-2," and collectively with Subscriber-I, the "Subscribers"). GHISLAINE MAXWELL is believed to use the Target Cellphones and is a Target Subject of this investigation. T-Mobile is the Service Provider for Target Cellphone-1, and AT&T is the Service Provider for Target Cellphone-2.
+
+5. Precision Location Capability. Cellphone service providers have technical capabilities that allow them to collect at least two kinds of information about the locations of the cellphones to which they provide service: (a) precision location information, also known as E-911 Phase II data, GPS data, or latitude-longitude data, and (b) cell site data, also known as "tower/face" or "tower/sector" information. Precision location information provides relatively precise location information about a cellphone, which a provider can typically collect either via GPS tracking technology built into the phone or by triangulating the device's signal as received by the provider's nearby cell towers. Cell site data, by contrast, reflects only the cell tower and sector thereof utilized in routing any communication to and from the cellphone, as well as the approximate range of the cellphone from the tower during the communication (sometimes referred to as "per-call measurement" ("PCM") or "round-trip time" ("RTT") data). Because cell towers are often a half-mile or more apart, even in urban areas, and can be ten or more miles apart in rural areas, cell site data is typically less precise than precision location information. Based on my training and experience, I know that the Service Providers have the technical ability to collect precision location information from any cellphone on its network, including by initiating a signal on the Service Providers' network to determine the phone's location. I further know that cell site data is routinely collected by the Service Providers in the course of routing calls placed to or from any cellphone on their network.'
+
+6. Successor Service Provider. Because it is possible that the Target Subject may change cellphone service provider during the course of this investigation, it is requested that the warrant and investigative order requested apply without need for further order to any Successor Service Provider who may provide service to the Target Cellphones during the time frames at issue herein.
+
+### II. Facts Establishing Probable Cause
+
+7. Although I understand that probable cause is not necessary to obtain all of the Requested Information, I respectfully submit that probable cause exists to believe that the Requested Information will lead to the location of a person, GHISLAINE MAXWELL, to be arrested for the crimes of conspiracy to entice minors to travel to engage in illegal sex acts, in violation of 18 U.S.C. § 371; enticement of a minor to travel to engage in illegal sex acts, in violation of 18 U.S.C. § 2422; conspiracy to transport minors with intent to engage in criminal sexual activity, in violation of 18 U.S.C. § 371; transporting a minor with intent to engage in criminal sexual activity, in violation of 18 U.S.C. § 2423(a); and perjury, in violation of 18 U.S.C. § 1623 (the "Subject Offenses").
+
+8. On June 29, 2020, a grand jury in the Southern District of New York returned an indictment charging GHISLAINE MAXWELL with the Subject Offenses. The Indictment charging MAXWELL is attached as Exhibit A hereto (the "Indictment"). That same day, United States Magistrate Judge Lisa Margaret Smith signed a warrant for MAXWELL's arrest, which is attached as Exhibit B hereto (the "Arrest Warrant").
+
+' Toll records are sometimes necessary or helpful in order to obtain or interpret historical cell site data and are therefore also requested herein.
+
+9. In light of these pending charges in the Indictment and the issuance of the Arrest Warrant, GHISLAINE MAXWELL is subject to arrest for the Subject Offenses.
+
+10. Based on my review of T-Mobile records, I have learned that Target Cellphone-1 is subscribed in the name of "Terramar Project, Inc." Based on my review of publicly available videos and related information, I know that GHISLAINE MAXWELL has given multiple public addresses in her capacity as the founder and president of an organization known as the TerraMar Project, a non-profit organization that, as noted, was founded and run by MAXWELL and devoted to ocean protection.
+
+II. As set forth in Paragraph 3 of Exhibit A, MAXWELL was a close associate and employee of Jeffrey Epstein's. Additionally, as set forth in Paragraphs 1 through 19 of Exhibit A, MAXWELL is charged with committing four of the Subject Offenses together with Epstein. I know from my participation in this investigation that on or about July 6, 2019, Epstein was arrested by the FBI on federal sex trafficking charges. During that arrest, the FBI seized an iPhone from Epstein's possession (the "Epstein Phone"). Pursuant to a judicially authorized search warrant, the FBI subsequently searched the contents of the Epstein Phone. Among other things, that search revealed that the phone number associated with Target Cellphone-1 was saved as a contact in the Epstein Phone under the name "Ghislaine."
+
+12. I further know from my review of T-Mobile records the following:
+
+a. Target Cellphone-1 has been active within the last 30 days.
+
+b. Target Cellphone-1 has been in contact with a phone subscribed to in the name of "Joshua Perry," which I know from my review of a law enforcement database is the name of the husband of a former employee of Jeffrey Epstein (the "Joshua Perry Phone"). The most recent contact between Target Cellphone-1 and the Joshua Perry Phone occurred in or about May 2020.
+
+c. Target Cellphone-1 has also been in contact with a phone subscribed to the business "Haddon, Morgan, & Foreman," which I know from my review of court records is the name of a law firm that currently represents GHISLAINE MAXWELL in civil litigation (the "Haddon, Morgan, & Foreman Phone"). The most recent contact between Target Cellphone-1 and the Haddon, Morgan, & Foreman Phone occurred in or about February 2020.
+
+d. Target Cellphone-1 has also been in contact with a phone subscribed to in the name of "Isabel Maxwell," which I know from my review of a law enforcement database is the name of GHISLAINE MAXWELL's sister (the "Isabel Maxwell Phone"). The most recent contact between Target Cellphone-1 and the Isabel Maxwell Phone occurred in or about August 2019.
+
+e. Target Cellphone-1 has also been in contact with a phone subscribed to in the name of "Laura Menninger," which I know from my review of court records is the name of an attorney who currently represents GHISLAINE MAXWELL in civil litigation (the "Laura Menninger Phone"). The most recent contact between Target Cellphone-I and the Laura Menninger Phone occurred in or about August 2019.
+
+f. Target Cellphone-1 has also been in contact with a phone subscribed to in the name of "Scott Borgerson," which I know from my review of bank records and Amazon records is the name of an individual with whom GHISLAINE MAXWELL shares a joint bank account and to whom MAXWELL's Amazon account has sent multiple packages within approximately the last year (the "Scott Borgerson Phone"). The most recent contact between Target Cellphone-1 and the Scott Borgerson Phone occurred in or about August 2019.
+
+13. Accordingly, I respectfully submit there is probable cause to believe that the location of Target Cellphone-1 will reveal the location of GHISLAINE MAXWELL.
+
+14. Based on my review of AT&T records, I have learned that Target Cellphone-2 is subscribed in the name of "G Max," which appears to be a shortened version of GHISLAINE MAXWELL's name. I further know from my review of AT&T records that Target Cellphone-2 has been active within the last 30 days. In particular, within the last 30 days, Target Cellphone-2 has been in contact with the Isabel Maxwell Phone, the Laura Menninger Phone, the Haddon, Morgan, & Foreman Phone, and the Scott Borgerson Phone.
+
+15. Accordingly, I respectfully submit that there is probable cause to believe that the location of Target Cellphone-2 will reveal the location of GHISLAINE MAXWELL.
+
+### III. Request for Warrants and Orders
+
+16. Based on the foregoing, I respectfully request that the Court require the Service Providers to provide the Requested Information as specified further in the Warrants and Orders proposed herewith, including prospective precision location and cell site data for a period of 45 days from the date of this Order, historical cell site data and toll records for the period from June I, 2020 through the date of this Order, and pen register information for a period of 45 days from the date of this Order.
+
+1. Nondisclosure. The scope of this ongoing criminal investigation and existence of the Indictment and Arrest Warrant are not publicly known. As a result, premature public disclosure of this affidavit or the requested Warrants and Orders could alert GHISLAINE MAXWELL that she is under investigation and subject to arrest, causing her to destroy evidence, flee from prosecution, or otherwise seriously jeopardize the investigation. Specifically:
+
+a. As evidenced by the charges alleged in the Indictment, MAXWELL is known to have participated in acts of sexual abuse of minors. Alerting her to the existence and scope of the investigation may lead her to intimidate witnesses. See 18 U.S.C. § 2705(b)(1),(4).
+
+b. Additionally, the Target Subject is at liberty in the community. Premature disclosure of the existence of this application and the charges contained in the Indictment could result in the Target Subject fleeing from prosecution if she were made aware of the pending charges before arrest. See 18 U.S.C. § 2705(b)(2).
+
+17. Accordingly, there is reason to believe that, were the Service Providers to notify the subscribers or others of the existence of the warrant, the investigation would be seriously jeopardized. Pursuant to 18 U.S.C. § 2705(b), I therefore respectfully request that the Service Providers be directed not to notify the subscribers or others of the existence of the Warrants and Orders for a period of one year, and that the Warrants and Orders and all supporting papers be maintained under seal until the Court orders otherwise, as specified in the Application submitted in conjunction with this Affidavit.
+
+> Special Agent Federal Bureau of Investigation
+
+Sworn to before me this day of June, 2020
+
+HONORABLE KATHARINE H. PARKER United States Magistrate Judge Southern District of New York
+
+| UNITED STATES DISTRICT COURT |
+|----------------------------------------------|
+| SOUTHERN DISTRICT OF NEW YORK |
+| |
+| In it: Warrant and Order For Prospective |
+| and Historical Location Information and |
+| Register
for
Pen
Information
the |
+| Cellphone Assigned Call Number MI |
+| ,
No.
USAO
Reference |
+| 2018R01618 |
+| |
+
+#### WARRANT AND ORDER
+
+Mag.
+
+### Warrant and Order for Cellphone Location Information and Pen Register Information and for Sealing and Non-Disclosure
+
+- TO: T-Mobile ("Service Provider), and any subsequent provider of service to the Target Cellphone specified below ("Subsequent Service Provide?)
+Federal Bureau of Investigation ("Investigative Agency")
+
+Upon the Application and Agent Affidavit submitted by the Government in this matter:
+
+# I. Findings
+
+The Court hereby finds:
+
+1. The Target Cellphone (the "Target Cellphone") that is the subject of this Order is assigned call number , is subscribed to in the name of "Terramar Project, Inc." (the "Subscriber"), and is currently serviced by the Service Provider.
+
+2. Pursuant to 18 U.S.C. § 2703(c)(1)(A) and the applicable provisions of Rule 41 of the Federal Rules of Criminal Procedure, the Government's application sets forth probable cause to believe that the prospective and historical location information for the Target Cellphone will reveal the location of a person to be arrested for suspected violations of 18 U.S.C. §§ 371, 2422, 2423(a), and 1623 ("the Subject Offenses").
+
+3. Pursuant to 18 U.S.C. § 2703(d), the Government's application also sets forth specific and articulable facts showing that there are reasonable grounds to believe that the toll records for the Target Cellphone are relevant and material to an ongoing criminal investigation.
+
+4. Pursuant to 18 U.S.C. § 3123(b)(1), the Government has certified that the pen register information for the Target Cellphone is relevant to an ongoing investigation by the Investigating Agency of GHISLAINE MAXWELL and others unknown in connection with suspected violations of the Subject Offenses.
+
+5. Pursuant to 18 U.S.C. § 2705(b), there is reason to believe that notification of the existence of this Warrant and Order will result in flight from prosecution, and/or intimidation of potential witnesses, or otherwise will seriously jeopardize an ongoing investigation.
+
+NOW, THEREFORE, pursuant to Fed. R. Crim. P. 41, 18 U.S.C. §§ 3121 et seq., 18 U.S.C. §§ 2701 et seq., and 18 U.S.C. § 3103a, IT IS HEREBY ORDERED:
+
+### H. Order to Service Provider
+
+6. Service Provider. This Order shall apply to the Service Provider specified above, and to any subsequent provider of service to the Target Cellphone without need for further Order of this Court.
+
+7. Prospective Location Information. The Service Provider shall provide to the Investigating Agency on a prospective basis, for a period of 45 days from the date of this Order, information concerning the location of the Target Cellphone ("Prospective Location Information"), including all available:
+
+a. precision location information, including GPS data, E-911 Phase II data, and latitude-longitude data; and
+
+b. cell site data, including any data reflecting (a) the cell towers and sectors thereof utilized in routing any phone, text, or data communication to or from the Target Cellphone, and (b) the approximate range of the target phone from the cell towers during the communication (including per-call measurement ("PCM") or round-trip time ("RTT") data);
+
+8. Historical Location Information and Toll Records. The Service Provider shall provide to the Investigating Agency all available historical cell site location information reflecting the cell towers and sectors thereof utilized in routing any phone, text, or data communication to or from the Target Cellphone, and the approximate range of the target phone from the cell towers during the communication (PCM/RTT data), for the period from June I, 2020 through the present, as well as all available toll records (including call detail, SMS detail, or data session detail records) for the communications.
+
+9. Pen register with caller identification and/or trap and trace device. The Service Provider shall provide to the Investigating Agency, for a period of 45 days from the date of this order, all dialing, routing, addressing, or signaling information associated with each voice, text, or data communication transmitted to or from the Target Cellphone, including but not limited to:
+
+a. any unique identifiers associated with the phone, including ESN, MEIN, MSISDN, IMSI, IMEI, SIM, MIN, or MAC address;
+
+b. source and destination telephone numbers and/or Internet protocol ("IF') addresses;'
+
+c. date, time, and duration of the communication; and
+
+d. cell-site information as specified above.
+
+' The Service Provider is not required to provide post-cut-through dialed digits ("PCTDD"), or digits that are dialed after a telephone call from the Target Phone has been connected. If possible, the Service Provider will forward only pre-cut-through-dialed digits to the Investigative Agency. However, if the Service Provider's technical capabilities require it to forward all dialed digits, including PCTDD, to the Investigative Agency, the Investigative Agency will only decode and forward to the agents assigned to the investigation, the numbers that are dialed before the call is cut through.
+
+10. Technical Assistance. The Service Provider shall furnish the Investigating Agency all information, facilities, and technical assistance necessary to accomplish the disclosure of all of the foregoing information relating to the Target Cellphone unobtrusively and with the minimum interference to the service presently provided to the Subscriber.
+
+II. Non-Disclosure to Subscriber. The Service Provider, including its affiliates, officers, employees, and agents, shall not disclose the existence of this Warrant and Order, or the underlying investigation, to the Subscriber or any other person, for a period of one year from the date of this Warrant and Order, subject to extension upon application to the Court, if necessary.
+
+# Ill. Additional Provisions
+
+12. Compensation for Costs. The Investigating Agency shall compensate the Service Provider for reasonable expenses incurred in complying with the Warrant and this Order.
+
+13. Sealing. This Warrant and Order, and the supporting Application and Agent Affidavit, shall be sealed until otherwise ordered by the Court, except that the Government may without further order of this Court: serve this Warrant and Order on the Service Provider; provide copies of the Warrant and Order or the supporting Application and Agent Affidavit as need be to personnel assisting the Government in the investigation and prosecution of this matter; and disclose these materials as necessary to comply with discovery and disclosure obligations in any prosecutions related to this matter.
+
+Dated: New York, New York
+
+Date Issued Time Issued
+
+UNITED STATES MAGISTRATE JUDGE Southern District of New York
+
+| UNITED STATES DISTRICT COURT | |
+|----------------------------------------------|--|
+| SOUTHERN DISTRICT OF NEW YORK | |
+| | |
+| In it: Warrant and Order For Prospective | |
+| and Historical Location Information and | |
+| Register
for
Pen
Information
the | |
+| Cellphone Assigned Call Number MI | |
+| ,
No.
USAO
Reference | |
+| 2018R01618 | |
+| | |
+
+#### WARRANT AND ORDER
+
+Mag.
+
+### Warrant and Order for Cellphone Location Information and Pen Register Information and for Sealing and Non-Disclosure
+
+- TO: AT&T ("Service Provider), and any subsequent provider of service to the Target Cellphone specified below ("Subsequent Service Provide?)
+Federal Bureau of Investigation ("Investigative Agency")
+
+Upon the Application and Agent Affidavit submitted by the Government in this matter:
+
+# I. Findings
+
+The Court hereby finds:
+
+1. The Target Cellphone (the "Target Cellphone") that is the subject of this Order is assigned call number is subscribed to in the name of "G Max" (the "Subscriber"), and is currently serviced by the Service Provider.
+
+- 2. Pursuant to 18 U.S.C. § 2703(c)(1)(A) and the applicable provisions of Rule 41 of the Federal Rules of Criminal Procedure, the Government's application sets forth probable cause to
+believe that the prospective and historical location information for the Target Cellphone will reveal the location of a person to be arrested for suspected violations of 18 U.S.C. §§ 371, 2422, 2423(a), and 1623 ("the Subject Offenses").
+
+3. Pursuant to 18 U.S.C. § 2703(d), the Government's application also sets forth specific and articulable facts showing that there are reasonable grounds to believe that the toll records for the Target Cellphone are relevant and material to an ongoing criminal investigation.
+
+4. Pursuant to 18 U.S.C. § 3123(b)(1), the Government has certified that the pen register information for the Target Cellphone is relevant to an ongoing investigation by the Investigating Agency of GHISLAINE MAXWELL and others unknown in connection with suspected violations of the Subject Offenses.
+
+5. Pursuant to 18 U.S.C. § 2705(b), there is reason to believe that notification of the existence of this Warrant and Order will result in flight from prosecution, and/or intimidation of potential witnesses, or otherwise will seriously jeopardize an ongoing investigation.
+
+NOW, THEREFORE, pursuant to Fed. R. Crim. P. 41, 18 U.S.C. §§ 3121 et seq., 18 U.S.C. §§ 2701 et seq., and 18 U.S.C. § 3103a, IT IS HEREBY ORDERED:
+
+### H. Order to Service Provider
+
+6. Service Provider. This Order shall apply to the Service Provider specified above, and to any subsequent provider of service to the Target Cellphone without need for further Order of this Court.
+
+7. Prospective Location Information. The Service Provider shall provide to the Investigating Agency on a prospective basis, for a period of 45 days from the date of this Order, information concerning the location of the Target Cellphone ("Prospective Location Information"), including all available:
+
+a. precision location information, including GPS data, E-911 Phase II data, and latitude-longitude data; and
+
+b. cell site data, including any data reflecting (a) the cell towers and sectors thereof utilized in routing any phone, text, or data communication to or from the Target Cellphone, and (b) the approximate range of the target phone from the cell towers during the communication (including per-call measurement ("PCM") or round-trip time ("RTT") data);
+
+8. Historical Location Information and Toll Records. The Service Provider shall provide to the Investigating Agency all available historical cell site location information reflecting the cell towers and sectors thereof utilized in routing any phone, text, or data communication to or from the Target Cellphone, and the approximate range of the target phone from the cell towers during the communication (PCM/RTT data), for the period from June I, 2020 through the present, as well as all available toll records (including call detail, SMS detail, or data session detail records) for the communications.
+
+9. Pen register with caller identification and/or trap and trace device. The Service Provider shall provide to the Investigating Agency, for a period of 45 days from the date of this order, all dialing, routing, addressing, or signaling information associated with each voice, text, or data communication transmitted to or from the Target Cellphone, including but not limited to:
+
+a. any unique identifiers associated with the phone, including ESN, MEIN, MSISDN, IMSI, IMEI, SIM, MIN, or MAC address;
+
+b. source and destination telephone numbers and/or Internet protocol ("IF') addresses;'
+
+c. date, time, and duration of the communication; and
+
+d. cell-site information as specified above.
+
+' The Service Provider is not required to provide post-cut-through dialed digits ("PCTDD"), or digits that are dialed after a telephone call from the Target Phone has been connected. If possible, the Service Provider will forward only pre-cut-through-dialed digits to the Investigative Agency. However, if the Service Provider's technical capabilities require it to forward all dialed digits, including PCTDD, to the Investigative Agency, the Investigative Agency will only decode and forward to the agents assigned to the investigation, the numbers that are dialed before the call is cut through.
+
+10. Technical Assistance. The Service Provider shall furnish the Investigating Agency all information, facilities, and technical assistance necessary to accomplish the disclosure of all of the foregoing information relating to the Target Cellphone unobtrusively and with the minimum interference to the service presently provided to the Subscriber.
+
+II. Non-Disclosure to Subscriber. The Service Provider, including its affiliates, officers, employees, and agents, shall not disclose the existence of this Warrant and Order, or the underlying investigation, to the Subscriber or any other person, for a period of one year from the date of this Warrant and Order, subject to extension upon application to the Court, if necessary.
+
+# Ill. Additional Provisions
+
+12. Compensation for Costs. The Investigating Agency shall compensate the Service Provider for reasonable expenses incurred in complying with the Warrant and this Order.
+
+13. Sealing. This Warrant and Order, and the supporting Application and Agent Affidavit, shall be sealed until otherwise ordered by the Court, except that the Government may without further order of this Court: serve this Warrant and Order on the Service Provider; provide copies of the Warrant and Order or the supporting Application and Agent Affidavit as need be to personnel assisting the Government in the investigation and prosecution of this matter; and disclose these materials as necessary to comply with discovery and disclosure obligations in any prosecutions related to this matter.
+
+Dated: New York, New York
+
+Date Issued Time Issued
+
+UNITED STATES MAGISTRATE JUDGE Southern District of New York
diff --git a/content-documents/ds8/de/EFTA00018132.md b/content-documents/ds8/de/EFTA00018132.md
new file mode 100644
index 0000000000000000000000000000000000000000..eb357fc8ebbd395f7c4e787514a3cfadf9d86746
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00018132.md
@@ -0,0 +1,62 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00018132)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00018132"
+ocrPages: 0
+ocrChars: 5885
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+From: To: Cc:
+
+Subject: Hammad Memo - Epstein Death Investigation Date: Wed, 14 Aug 2019 22:49:41 +0000
+
+Hommad Memos under NY Rule of Professional Conduct 4.2 are approved seriatim by the Unit Chief (criminal) or Deputy Chief (civil); avil or Criminal Professional Responsibility Officer; and Division Chief.
+
+Requesting AUSA: Donaleski/ Roos
+
+USAONo: 2019R01059
+
+Investigation/Complaint/Arrest/Indictment: Investigation
+
+Covert or Overt Contact: Overt
+
+Ongoing, Additional, Different Crime (Yes/No):Yes
+
+Any Special Precautions (discuss below) (Yes/No): Yes
+
+Bar(s) of Admission: New York
+
+## Discussion:
+
+We are currently investigating the circumstances surrounding the August 10, 2019 apparent suicide of Jeffrey Epstein while in the custody of the Bureau of Prisons ("BOP") at the Metropolitan Correctional Center ("MCC"). In particular, we are investigating MCC staff's (i) decision not to reassign a cellmate to Epstein on August 9, 2019, contrary to regular BOP practice and direct orders from the Warden; (ii) the failure of correctional officers assigned to the Special Housing Unit ("SHU") at which Epstein was housed the night of August 9, 2019, to perform the required overnight counts and 30 minute checks; and (iii) the falsification of records related to those count slips and 30-minute checks, in violation of Title 18, United States Code, Section 1519. We would like to have agents interview three inmates who were housed in the same area of the SHU with Epstein on August 9 and 10, 2019, in order to discuss what they saw and heard that night, including whether officers performed any overnight checks, or said or did anything upon discovering Epstein in his cell. While we anticipate interviewing other cooperating witnesses who were in the SHU that night, no cooperating witness was housed in the same area of the SHU as Epstein. Thus, these three inmates would be the most likely to have overheard or seen something of relevance. While ten other inmates were housed in the same area as Epstein and these three inmates, we have conferred with the AUSAs assigned to those matters and do not believe that those inmates would be appropriate individuals to approach, given their pending charges.
+
+Each of the three inmates is considered a potential witness in our investigation, and each is also currently being prosecuted by our Office in connection with other crimes. Investigating agents will seek to interview the inmates at MCC, will advise them of their Miranda rights prior to speaking with them, and will direct them not to discuss their ongoing criminal case. None of the investigating agents have had any involvement in the investigations of the conduct for which these individuals have already been charged, and they will make that clear to the inmates before trying to interview them. Nor do we intend to ask any of the inmates about why they are in the SHU or about facts which may implicate them in misconduct while housed at the MCC. Instead, our questioning will be narrowly focused on the general behavior of the guards while the inmates have been housed in the SHU (including whether checks are or are not regularly done) and, more specifically, the events on the night of August 9-10. We believe that the inmates may be more likely to cooperate and be forthcoming in this setting, rather than going through their attorneys. An overview of each of the inmates is set forth below.
+
+| • | | is currently charged by Indictment in
counts of |
+|---|--------------------|----------------------------------------------------------------------------------------|
+| | | , in violation of Title |
+| | | I). These charges relate to |
+| | | . A trial date has not yet been set. We have conferred with |
+| | | to whom the case is assigned, and he has no objection to us proceeding in this manner. |
+| • | | with one count of =,
is currently charged by Indictment in
in |
+| | violation of Title | I, in connection with an incident in which he |
+| | | to whom the case is
We have conferred with AUSA |
+| | | assigned, and he has no objection to us proceeding in this manner. |
+
+EFTA00018132
+
+, in violation of-
+
+. His guidelines are months' imprisonment. His sentencing is
+
+scheduled for . We have conferred with AUSAs and to whom the case is assigned, and they have no objection to us proceeding in this manner.
+
+The proposed contact is permissible under Hammad because the inmates are not represented in connection with their status as potential witnesses to the events of August 9 and 10, 2019. Moreover, agents will be instructed to advise the inmates of their Miranda rights, make clear they are not part of the investigation that gave rise to the inmates' pending charges, not ask any questions about their open criminal cases, and direct the inmates not to speak about their open criminal cases. Additionally, while there is no question that the Sixth Amendment, including its right to counsel, ordinarily applies at the point of indictment, none of these defendants have been indicted for the conduct about which we propose to question them. Nor, as noted, do we intend to question them about anything that might require them to implicate themselves in misconduct while being housed as a result of the crimes for which they have previously been charged. Accordingly, we believe the proposed contact is permissible.
+
+Assistant United States Attorney Southern District of New York
diff --git a/content-documents/ds8/de/EFTA00018732.md b/content-documents/ds8/de/EFTA00018732.md
new file mode 100644
index 0000000000000000000000000000000000000000..b832dcb226ab0525eafc141f7e8d2eb9520a1f88
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00018732.md
@@ -0,0 +1,75 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00018732)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00018732"
+ocrPages: 0
+ocrChars: 2941
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA Date: Wed, 10 Mar 2021 23:23:55 +0000
+
+You can send a round-robin to the Civ Div. In addition to Radar, I did an Epstein search in caseview and here are another couple civ div matters that I think you're familiar with: NYT v BOP, 2020V00220 Epstein victim Touhy requests, 2019V01791
+
+FYI, FOIA litigation can be brought in the home district of the requester, or in DDC.
+
+| From: | |
+|-----------------------------------------------------|--|
+| Sent: Wednesday, March 10, 2021 5:45 PM | |
+| To: | |
+| Cc: | |
+| Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA | |
+
+Ok thanks, that's helpful to know. How would we go about determining whether the civil division litigated any cases based on FOIA requests to other components?
+
+
+
+Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
+
+Oh, sorry: our FOIA Tracking Database is designed to cover FOIA requests that are directed to our Office; it does not track FOIA requests to, e.g., the FBI, that end up in litigation in the SDNY and that our Civ Div defends.
+
+| From: | | | | |
+|-----------------|-------------|-----|--|---|
+| Senliagilagida6 | 021 5:40 PM | | | |
+| To: | | l>; | | > |
+| Cc: | < | n | | |
+| | | | | |
+
+Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
+
+Thanks, could you please check your records and let us know if there are any other cases? Fro,, s list, it seems like at least one case is missing (there is a civil case involving a FOIA request from Radar Online).
+
+| Sent: Wednesday, March 10, 2021 5.23 PM | |
+|-----------------------------------------|--|
+| | |
+| To: | |
+| Cc:
;
< | |
+
+Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA
+
+As we just discussed:
+
+Here is what we have in our FOIA tracking database regarding Epstein FOlAs. And also attached is the letter in PPI about discovery vs FOIA (see p. 8)
+
+
+
+Hope you're doing well.-am nd I are trying to assemble a list of every FOIA request our office has ever received (at any point) relating to Jeffrey Epstein and/or Ghislaine Maxwell. suggested that you'd be the best point of contact to help us figure this out. Could you please send us the following information:
+
+- A list of all FOIA requests our office has received;
+- For each case, whether a production was made in response to the request; and
+- Who the AUSA point of contact for the request is.
+
+That would be a big help. Please let us know if you need any information from us to run the search.
+
+Thanks very much,
+
+Assistant United States Attorney Southern District of New York
+
+New York, NY 10007
diff --git a/content-documents/ds8/de/EFTA00019162.md b/content-documents/ds8/de/EFTA00019162.md
new file mode 100644
index 0000000000000000000000000000000000000000..b874a5c3c6dcaa10e7894d74a7e0ade678811b36
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00019162.md
@@ -0,0 +1,43 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00019162)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00019162"
+ocrPages: 0
+ocrChars: 1322
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+## From:
+
+To: mathonn@jeffersoncompanies.comm
+
+Subject: Conference Information
+
+Date: Thu, 14 Apr 2011 20:00:35 +0000
+
+Importance: Normal
+
+Good afternoon,
+
+After calling 1-800-648-8411 for general conference information, the young lady there suggested that I email you as the conference coordinator.
+
+I am a special agent with the Miami Division/West Palm Beach Office of the FBI. The phone number below, 561-833-7517, is the main office number in West Palm Beach, and Miami's office number is 305-944-9101. (The switchboard operators at either number can verify my identity.)
+
+I am trying to locate the financial and /or investment conference that two individuals attended in New Orleans between approximately 1998-2000 and what hotels your conference would have used during those time periods. I believe your conference may be the one I am looking for.
+
+I am trying to determine if the following two individuals attended the New Orleans Investment Conference between 1998- 2000;
+
+1. Jeffrey Epstein
+
+Any information or assistance you could provide would be greatly appreciated.
+
+Thank you,
+
+2.
+
+SA J. FRI Miami Division 505 Hagler Dr. Ste. 500 West Palm Beach, FL 33401 (561) 833.7517 (561) 650-6951 fax
diff --git a/content-documents/ds8/de/EFTA00019870.md b/content-documents/ds8/de/EFTA00019870.md
new file mode 100644
index 0000000000000000000000000000000000000000..7f4c037121afb5aec86df256c7521d6fd7522593
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00019870.md
@@ -0,0 +1,41 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00019870)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00019870"
+ocrPages: 2
+ocrChars: 1295
+ocrElapsed: 0.5
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+Court Subpoena
+
+### PlashStates Piztrict (gond SOUTHERN DISTRICT OF NEW YORK
+
+TO:
+
+### GREETINGS:
+
+WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before the United States District Court for the Southern District of New York, 40 Foley Square, in the Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the following date, time and place:
+
+Appearance Date: November 29, 2021 Appearance Time: 9:00 a.m. Appearance Place: 40 Foley Square, Courtroom 906 to testify and give evidence in the following matter: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
+
+and not to depart the Court without leave thereof, or of the United States Attorney, and that you bring with you and produce at the above time and place the following:
+
+PERSONAL APPEARANCE IS REQUIRED
+
+Failure to attend and produce any items hereby demanded will constitute contempt of court and will subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.
+
+DATED: New York, New York July 13, 2021
+
+A REY STRAUSS United States Attorney for the Southern District of New York
+
+Assistant United States Attorney One St. Andrew's Plaza New York New York 10007 Email:
+
+
+
+rev. 02.01.12
diff --git a/content-documents/ds8/de/EFTA00020627.md b/content-documents/ds8/de/EFTA00020627.md
new file mode 100644
index 0000000000000000000000000000000000000000..540be85c545d292a70e4313f8305098dc3b60c00
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00020627.md
@@ -0,0 +1,64 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00020627)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00020627"
+ocrPages: 0
+ocrChars: 2058
+ocrElapsed: 0.0
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+---
+
+| From: | (USANYS)" | k's |
+|-------|-----------|-----|
+| To: ' | (USANYS)" | |
+
+| Subject: FW: Epstein | | |
+|----------------------|--|--|
+|----------------------|--|--|
+
+Date: Thu, 25 Jul 2019 19:28:22 +0000
+
+Attachments: EPphotos.pdf; ATT00001.htm; EP.staffmemos.pdf; ATT00002.htm
+
+As discussed, these have not yet been reviewed by anyone. If you could have a walled off AUSA review and report back to me, I'd appreciate it. Thanks
+
+| From: |
+|---------------------------------------------------------------------|
+| Sent: Thursday, July 25, 2019 3:24 PM |
+| To:
(USANYS) |
+| Subject: Fwd: Epstein |
+| |
+| As discussed, I have not opened the attachments to the below email. |
+| |
+
+Begin forwarded message:
+
+
+
+Thank you. Attached please find the staff memos and photos that were taken. Please advise if you need to share this with Main Justice so that I can make appropriate notifications on BOP's end.
+
+Thank you,
+
+Supervisory Staff Attorney CLC New York Metropolitan Correctional Center
+
+New York, New York 10007 P:
+
+f:
+
+>» I 0 < > 7/25/2019 2:08 PM >» Thanks Please consider this email my request for any and all documents and other materials, including photographs, related to the investigation regarding the incident involving Jeffrey Epstein earlier this week.
+
+On Jul 25, 2019, at I:49 PM, > wrote:
+
+Hi
+
+I left you a voicemail, but wanted to follow up via email as well.
+
+Our Regional Office reminded me that we need a written request from your office to produce the documents you seek. It does not have to be a subpoena. An email from you requesting the investigation documentation will suffice.
+
+Thank you,
+
+Supervisory Staff Attorney CLC New York Metropolitan Correctional Center New York, New York 10007 P: f:
diff --git a/content-documents/ds8/de/EFTA00020836.md b/content-documents/ds8/de/EFTA00020836.md
new file mode 100644
index 0000000000000000000000000000000000000000..af149ab14a9c4be78342a8329722a032f31ceb49
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00020836.md
@@ -0,0 +1,41 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00020836)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00020836"
+ocrPages: 0
+ocrChars: 1469
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+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+From: "etravelservices®cwtsatotravel.com"
+
+To:
+
+Subject: Travel Authorization 11061344 has received final approval Date: Fri, 21 Feb 2020 18:47:32 +0000
+
+Importance: Normal
+
+Dear
+
+Travel authorization 11061344 has received final approval.
+
+Trip ID: 11061344 Traveler name: Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104) Purpose: R2ONYS 13402 - Epstein Investigation - Witness interview Destination: Los Angeles, CA, United States Dates: 2020-02-26 - 2020-02-29 Current status: Authorization Approved
+
+E2 Single Sign On Login (within DOJ Network Only): https://dojnet.doj.gov/jmd/fs/e2-redirect.html
+
+E2 Manual Login (User ID and Password): https://e2.gov.cwtsatotravel.com
+
+Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link.
+
+Please note: Replies to this mailbox are not monitored.
+
+Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the emails that you receive from us.
+
+Reference ID# T0006
+
+This e-mail and any attachments may contain confidential and/or proprietary information. If you received this email in error, please notify the sender immediately by reply e-mail and delete the e-mail and any attachments; any further use of such e-mail or attachments is strictly prohibited.
diff --git a/content-documents/ds8/de/EFTA00020969.md b/content-documents/ds8/de/EFTA00020969.md
new file mode 100644
index 0000000000000000000000000000000000000000..186cd8a4d3022e1696d2da88c0bdb3a4ae76892b
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00020969.md
@@ -0,0 +1,35 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00020969)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00020969"
+ocrPages: 0
+ocrChars: 312
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| Event: Accepted: |
+|------------------|
+| |
+
+Start Date: 2019-12-04 20:00:00 +0000
+
+End Date: 2019-12-04 23:00:00 +0000
+
+Class: X-PERSONAL
+
+Comment:
+
+Date Created: 2019-12-04 17:51:35 +0000
+
+Date Modified: 2019-12-04 17:51:35 +0000
+
+Priority: 5
+
+DTSTAMP: 2019-12-04 17:26:23 +0000
+
+Attendee: <
diff --git a/content-documents/ds8/de/EFTA00021252.md b/content-documents/ds8/de/EFTA00021252.md
new file mode 100644
index 0000000000000000000000000000000000000000..b3a5f08b21841e50ae97f3e073dfca0b3e70ebf5
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00021252.md
@@ -0,0 +1,161 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00021252)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00021252"
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+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA INDICTMENT 19 Cr. JEFFREY EPSTEIN, Defendant.
+
+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 minor girls to be similarly abused by EPSTEIN. In this way, EPSTEIN created a vast network of
+
+underage victims for him to sexually exploit, often on a daily basis, 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. Moreover, EPSTEIN, who intentionally sought out minors, knew that many of victims were in fact under the age of 18, including because, in some instances, victims expressly told him that they were underage.
+
+4. In creating and maintaining this network of minor victims in multiple states to sexually abuse and exploit, JEFFREY EPSTEIN, the defendant, worked 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 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.
+
+7. 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, became 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 minor girls to be similarly sexually abused. EPSTEIN incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each minor girl that they brought to EPSTEIN to be sexually abused. 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 sex acts with him, after which EPSTEIN would provide the victims with hundreds of dollars in cash.
+
+9. When a victim arrived at the New York Residence, she 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 victims' 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 for each encounter.
+
+11. JEFFREY EPSTEIN, the defendant, knew that certain of his 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 for "massages" at the New York Residence. In other instances, EPSTEIN directed 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 minor girls to perform "massages" and similarly engage in sex acts with EPSTEIN. When a victim would recruit another minor girl for EPSTEIN, he paid both the victim-recruiter and the new victim hundreds of dollars in cash. Through these victimrecruiters, 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 minor girls by offering to pay these victim-recruiters for every additional minor girl they brought to EPSTEIN to be sexually abused. When a victim-recruiter accompanied a new minor victim to the New York Residence to be exploited by EPSTEIN, 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 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, including on occasions in which an employee or associate would ensure that minor victims were available for encounters upon his return to 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 who, as described herein, were also responsible for scheduling the sexual encounters with minor victims ("Employee-2" and "Employee-3"). 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 victims'
+
+genitals. EPSTEIN would also typically masturbate during these encounters, ask victims 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 return 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.
+
+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 minor girls to engage in sex acts. EPSTEIN paid hundreds of dollars to victimrecruiters for each additional minor girl they brought to the Palm Beach Residence to be sexually abused by EPSTEIN.
+
+### STATUTORY ALLEGATIONS
+
+# COUNT ONE (Sex Trafficking Conspiracy)
+
+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 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, respectively, 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 sex acts, which she did, and was paid hundreds of dollars for each additional girl she brought to EPSTEIN. 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 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 Residence 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 sex acts, which she did, and was paid hundreds of dollars for each additional girl she brought to EPSTEIN.
+
+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 at the Palm Beach Residence.
+
+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-2 to recruit other girls to engage in sex acts, which she did, and was paid
+
+hundreds of dollars for each additional girl she brought to EPSTEIN. EPSTEIN asked Minor Victim-3 how old she was, and Minor Victim-3 answered truthfully.
+
+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 order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN at the Palm Beach Residence.
+
+h. In or about 2004, Employee-3 placed a phone call to Minor Victim-3 in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN at the Palm Beach Residence.
+
+(Title 18, United States Code, Section 371.)
+
+# COUNT TWO (Sex Trafficking)
+
+23. 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, 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
+
+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 (b)(2), and 2.) 1591(a),
+
+### FORFEITURE ALLEGATIONS
+
+24. As a result of committing the offense alleged in Count Two of this Indictment, JEFFREY EPSTEIN, the defendant, shall forfeit to the United States, States Code, Section 1594(d), that was used, or intended to the commission of the offense property, real pursuant to Title 18, United any property, real and personal, be used to commit or to facilitate alleged in Count One, and any and personal, constituting or derived from, any proceeds obtained, directly or indirectly, as a result of the offense alleged in Count One, or any property traceable to such property, and the following specific property:
+
+a. The lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 9 East 71st Street, New York, New York, with block number 1386 and lot number 10, owned by Maple, Inc.
+
+## Substitute Asset Provision
+
+25. 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 18 U.S.C. 2253(b), 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, Sections 981 and 1594; and Title 28, United States Code, Section 2461.)
+
+FOREPERSON GEOFFREY S. BERMAN United States Attorney 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.
+
+### INDICTMENT
+
+(18 U.S.C. §§ 371, 1591(a), (b)(2), and 2)
+
+GEOFFREY S. BERMAN
+
+United States Attorney
+
+Foreperson
diff --git a/content-documents/ds8/de/EFTA00021916.md b/content-documents/ds8/de/EFTA00021916.md
new file mode 100644
index 0000000000000000000000000000000000000000..b68df7485ec1f7d2351af80134c1dcf69ed14259
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00021916.md
@@ -0,0 +1,17 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00021916)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00021916"
+ocrPages: 2
+ocrChars: 429
+ocrElapsed: 0.2
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+So I obviously had to do this pretty quickly today, and it doesn't help that Westlaw has been down all afternoon, but one way or the other we gotta get something filed. Does either of you have a moment to take a look at this in the next hour or so? I'm sorry, I know you have something at 2:001 If the answer is no, totally understand, I can just pass it up to . and . Thanks either way and talk soon.
diff --git a/content-documents/ds8/de/EFTA00021952.md b/content-documents/ds8/de/EFTA00021952.md
new file mode 100644
index 0000000000000000000000000000000000000000..86904d2568fc53d0b46ee5df1b20431e3d730fc3
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00021952.md
@@ -0,0 +1,335 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00021952)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00021952"
+ocrPages: 0
+ocrChars: 36864
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+# EXHIBIT 2
+
+## Lisa M. Rocchio. Ph.D.
+
+## EDUCATION
+
+| 1995 | PhD. Clinical Psychology
University of Rhode Island, Kingston, RI |
+|------|----------------------------------------------------------------------|
+| 1992 | MA Clinical Psychology
University of Rhode Island, Kingston, RI |
+| 1989 | BA Psychology and English
Emory University. Atlanta. Georgia |
+| 1988 | Visiting Student
Westfield College, London. England |
+
+## ACADEMIC APPOINTMENT
+
+| 2020 - present | Clinical Instructor |
+|----------------|---------------------------------------------|
+| | Department of Psychiatry and Human Behavior |
+| | Alpert Medical School of Brown University |
+| | Providence, RI |
+
+### LICENSURE
+
+| 11/14 - present | Licensed Psychologist (MA) #10025 |
+|-----------------|------------------------------------|
+| 02/12 - present | Licensed Psychologist (NY) #019490 |
+| 12/97 - present | Licensed Psychologist (RI) #00631 |
+
+#### CLINICAL EXPERIENCE
+
+| 7/98 - present | Clinical Director and Owner, Inter-Disciplinary Independent Group Practice
Lisa M. Rocchio. Ph.D. & Associates. Inc. Johnston. RI
Psychotherapy. Assessment, Consultation. Education and Training.
Forensic Assessment. Forensic Consultation, Expert Testimony |
+|----------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| 12/97 - 6/98 | Independent Practice
Associates in Psychotherapy, North Kingstown, RI
Psychotherapy. Assessment, Education and Training |
+| 7/96 - 11/97 | Post-Doctoral Fellow in Psychology
Ann Begin. Ph.D Associates in Psychotherapy, Nonh Kingstown, RI
Women's Day Hospital Program. Butler Hospital, Providence, RI |
+
+3502-006 Page 1 of I I
+
+| | Lisa Marie Rocchio, Ph.D. 2 |
+|-------------|-----------------------------------------------------------------------------|
+| 7/94 - 7/95 | Pre-Doctoral Intern in Psychology |
+| | Yale University School of Medicine, New Haven, CT |
+| | New Haven Hospital and Yale Psychiatric Institute |
+| 9/93 - 5/94 | Clinical Psychology Extern |
+| | Counseling Center, University of Rhode island, Kingston, RI |
+| 5/91 - 5/94 | Clinical Psychology Trainee |
+| | Psychological Consultation Center, University of Rhode Island. Kingston, RI |
+| 9/92 - 5/93 | Clinical Psychology Extern |
+| | Psychological Services. Brown University, Providence. RI |
+| 6/90 - 8/90 | Family Service Student Counselor |
+| 7/91 - 8/91 | Pre-Natal Clinic, St. Joseph's Hospital |
+| | Department of Family Service, Providence, RI |
+
+## TRAINING AND CONSULTATION EXPERIENCE
+
+| 2000 - 2002 | Psychological Consultant
North Providence School Department
Performed comprehensive psychological evaluations of elementary school students
to determine the impact of psychological difficulties on school performance and
functioning. Evaluations involved clinical diagnostic interviews, psychological
testing, classroom observations and collateral interviews. |
+|-------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| 2000 - 2001 | Psychological Consultant
Diagnostic Assessment Services, Middletown, RI
Performed comprehensive psychological evaluations of adolescents who had been
court ordered for outpatient psychological, cognitive and educational testing. |
+| 1999 - 2002 | Consultant: Professional Development, Education and Training
Department of Children. Youth, and Families. Providence, RI
Developed and presented workshops to DCYF employees in the areas of trauma,
vicarious traumatization, and stress management. |
+| 1994 | Mock Trial Expert Witness
Yale University School of Medicine, New Haven. CT |
+| 1992 - 1994 | Workshop Leader
College Counseling Center, University of Rhode island, Kingston, Ri
Eating Disorders Workshops presented across campus to various student groups
and organizations |
+| 1992 | Mock Trial Expert Witness
Travelers Worker's Compensation Trial Advocacy Program, Hartford, CT |
+
+## RESEARCH EXPERIENCE
+
+| 1999 - 2003 | Research Group Member
Trauma Science Research Group, Providence, RI |
+|-------------|------------------------------------------------------------------------|
+| 6/93 - 9/93 | Research Assistant |
+
+3502-006 Page 2 of I I
+
+| | Lisa Marie Rocchio, Ph.D. 3
Outpatient Eating Disorders Research Group, Butler Hospital, Providence, Ri |
+|--------------|------------------------------------------------------------------------------------------------------------------------------------|
+| 10/89 - 8/91 | Research Project Coordinator
The Social Behavior of Developmentally Disabled Children, Bradley Hospital,
East Providence. RI |
+
+## TEACHING EXPERIENCE
+
+| 9/96 - 12/96 | Adjunct Assistant Professor |
+|---------------|-----------------------------------------------------------------------------|
+| | University of Rhode Island. College of Continuing Education, Providence, Ri |
+| | Introduction to Women's Studies (2 sectionsl |
+| 1/96 - 5/96 | Special Instructor in Psychology |
+| | Providence College. Providence. RI |
+| | Psychology of Women
(2 sections) |
+| 9/92 - 5/94 | Instructor |
+| | Counseling Center. University of Rhode Island. Kingston, Ri |
+| | Workshop Training for Eating Disorders Prevention |
+| 5/92 and 5/93 | Teaching Assistant |
+| | University of Rhode island, Continuing College of Education, Providence, RI |
+| | Psychology of Sexual Equality |
+| 9/91 - 5/92 | Teaching Assistant |
+| | University of Rhode Island, Kingston, RI |
+| | Towards Self Understanding |
+
+### SELECTED SPECIALIZED PROFESSIONAL TRAINING
+
+| 2011 - 2012 | Leadership Institute for Women in Psychology
Sponsored by the American Psychological Association, Committee on Women in
Psychology
Selected (through a competitive selection process) to participate in a leadership
training program for women in psychology, the mission of which
"is to prepare, support, and empower women psychologists as leaders to promote
positive changes in institutional and organizational life and increase the diversity,
number, and effectiveness of women psychologists as leaders". |
+|-------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| 2011 | Continuing Education in Forensic Psychology (14 hours)
American Academy of Forensic Psychology (AAFP)
Comprehensive Assessment of Feigning in Forensic Settings
Forensic & Correctional Applications of the Personality Assessment Inventory |
+| 2006 | Continuing Education in Forensic Psychology (28 hours)
American Academy of Forensic Psychology (AAFP)
Stalking: The State of the Science
Assessment of Response Style in Forensic Contexts
Excusing and the New Excuses
Psychological Evaluation and Testimony in Cases of Clergy or Teacher Sexual
Abuse |
+| 2005 - 2006 | Psychotherapy Training Course for Dissociative Disorders (22.5 hours) |
+
+3502-006 Page 3 of I I
+
+| | Lisa Marie Rocchio. Ph.D. 4 |
+|-------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| | International Society for the Study and Treatment of Trauma and Dissociation
(ISSTD) |
+| 2004 | Continuing Education in Forensic Psychology (21 hours)
American Academy of Forensic Psychology (AAFP) |
+| | Advanced Topics in Clrimthat Forensic Assessment |
+| | Forensic Consultation. Expertise & Testimony |
+| | Forensic Mental Health Assessment: Principles and Cases |
+| 2001 | Eye Movement Desensitization and Reprocessing, Levels I & II (34 hours)
Eye Movement Desensitization and Reprocessing International Association
(EMDRIA) |
+| 1999 - 2000 | Dialectical Behavior Therapy, Intensive Training, Parts I & II (72 hours)
Behavioral Technology Transfer Group |
+
+## PUBLICATIONS
+
+- Bailey, T.D. & Rocchio, L.M. (2020). Evaluating the effects of repeated psychological injury: Introduction to the Special Issue. Psychological Injury and the Law. NY: Springer
+- Rocchio, L.M. (2020). Ethical and professional considerations in the forensic assessment of complex trauma and dissociation. Psychological Injury and the Law. NY: Springer
+- Rocchio, L.M. (Fall. 2015). Ethics corner: Psychologists Coping with Serious Health Concerns: Ethical, Professional. and Risk Management Issues. The Newsletter of the Rhode Island Psychological Association.
+
+Rocchio, L.M. (Spring 2011). Ethics corner: Ethical Considerations in Trauma Psychology: Vicarious Traumatization and Self-Care. The Newsletter of the Rhode Island Psychological Association.
+
+Rocchio, L.M. (Spring 2009). Ethics corner: How should I respond to a subpoena? The Newsletter of the Rhode Island Psychological Association.
+
+- Lott, B. & Rocchio, L M. (1998). Standing up, talking back, and taking charge: Strategies and outcome in collective action against sexual harassment. In L.H. Collins, J. Chryslers. and K. Quina (Eds.) Career strategies for women academics: Arming Athena. NY: Sage.
+- Lott, B. & Rocchio, L. M. (1997). Individual and collective action: Social approaches and remedies for sexist discrimination. In H. Landrine and E. A. Klonoff (Eds.) Sexist discrimination: Prevalence, correlates, and remedies. CA: Sage.
+- Rocchio, L. M., Feinstein, C., & Appareddy, V. (1997). The sibling of the psychiatrically disturbed child. In J. Nashpitz (Ed), Handbook of Child and Adolescent Psychiatry.
+- Baker's Dozen (1997). Feminist student voices. In J. Worell and N. Johnson (Eds.) Feminist visions: New directions for education and practice. American Psychological Association.
+
+#### PROFESSIONAL PRESENTATIONS
+
+- Rocchio, L.M. (August, 2020). Ethical and professional considerations in the forensic assessment of trauma and PTSD. In J. Scroppo (Chair), Ethics and Risk Management in Forensic Evaluations and Settings. Symposium conducted virtually at the National Meeting of the American Psychological Association, Washington. DC.
+3502-006 Page 4 of I I
+
+#### Lisa Marie Rocchio, Ph.D. 5
+
+- Rocchio, L.M. (August, 2020). Ethical challenges when a client is engaged in a lawsuit: Dr. Helpful wants to help. In APA Ethics Committee, Ethics Hot Topics. Panel presentation conducted visually at the National Meeting of the American Psychological Association, Washington. DC.
+- Rocchio, L.M. (August, 2015). Ethical dilemmas in the treatment of trauma in independent practice settings. in Rocchio (Chair), Trauma treatment in independent practice settings: Ethical and relational issues. Skill Building session conducted at the National Meeting of the American Psychological Association, Washington, DC
+- Rocchio, L.M. (August, 2014). Trauma psychologists with serious health concerns: Ethical issues. in L. Rocchio (Chair), Trauma psychologists with serious health concerns: Ethical, clinical and professional issues. Symposium conducted at the National Meeting of the American Psychological Association. Washington. DC.
+- Hughes, D.M. & Rocchio, L.M. (August, 2014). Essentials of forensic assessment of trauma in civil and criminal litigation. Skill building session presented at the National Meeting of the American Psychological Association, Washington. DC.
+- Rocchio, L.M. (August. 2013). Trauma in the treatment room: What the independent practitioner needs to know. Skill building session presented at the National Meeting of the American Psychological Association, Honolulu, HI
+- Rocchio, L.M. (August, 2012). The forensic evaluation of traumatic stress and dissociation in civil litigation. In L. Rocchio (Chair), The forensic evaluation of traumatic stress and dissociation: Malpractice and personal injury cases. Symposium conducted at the National Meeting of the American Psychological Association, Orlando, FL.
+- Rocchio, L.M. (April. 2012). Trauma psychology: Legal considerations and ethical dilemmas in treatment. Workshop presented at the 32nd Annual Meeting of the Anxiety Disorders Association of America. Arlington, VA.
+- Courtois, C.A. & Rocchio, L.M. (April, 2012). Relationship dimensions and ethical factors in the treatment of complex trauma. Workshop presented at the 32nd Annual Meeting of the Anxiety Disorders Association of America, Arlington, VA.
+- Anthony, J., Feil. L., Rocchio, L.M., Plante, W., Sabo, R., and Spencer, M. (March 2012). Mental health professionals in transition: Clinical, ethical, and practical considerations when life changes. Professional Continuing Education Workshop sponsored by the Rhode island Psychological Association. Providence. RI.
+- Rocchio, L.M. (November 2011). Conceptualization and assessment of sexual harassment in civil litigation. In D. Hughes (Chair), The conceptualization of trauma in a forensic context. Symposium conducted at the 27th Annual Meeting of the International Society for Traumatic Stress Studies, Baltimore. MD
+- Rocchio, L.M. (August 2011). Assessment of complex trauma in a clinical setting. in L. Rocchio (Chair), Assessment of complex trauma and dissociation in clinical, forensic and research settings. Symposium conducted at the National Meeting of the American Psychological Association. Washington, D.C.
+- Rocchio, L.M. (March 2011). Conceptualization, assessment, and treatment of trauma and dissociation: Translating research into practice. in K. Rose (Chair), Advancing the applications and boundaries of traumatic stress research: Translation between empirical inquiry and clinical case findings. Symposium conducted at the National Meeting of the American Anxiety Disorders Association, New Orleans. LA.
+
+3502.006 Page 5 of I I
+
+## Lisa Marie Rocchio, Ph.D. 6
+
+- Rocchio, L.M. (March, 2011). The effects of trauma on the therapist. Paper presented at the National Meeting of the American Anxiety Disorders Association, New Orleans, LA.
+- Hughes, D.M. & Rocchio, L.M. (November 2010). Forensic assessment of psychological trauma and PTSD. Workshop presented at the 26th Annual Meeting of the International Society for Traumatic Stress Studies, Montreal, Canada.
+- Rocchio, L.M. (August 2010). Professional and ethical considerations in trauma psychology: Psychotherapy. in L Rocchio (Chair), Professional and ethical considerations in trauma psychology: Psychotherapy, forensics, research. Symposium conducted at the National Meeting of the American Psychological Association, San Diego, CA.
+- Rocchio, L.M. (March 2010). Trauma psychology: What the anxiety disorders specialist needs to know. Paper presented at the National Meeting of the American Anxiety Disorders Association, Baltimore, MD.
+- Ethics Committee of the Rhode Island Psychological Association (June 2008). From In Treatment to our treatment: Ethical considerations raised in the television program In Treatment. Continuing education salon presentation sponsored by the Rhode Island Psychological Association, Providence, Ri.
+- Ethics Committee of the Rhode island Psychological Association (January 2007). Sex, lies & confidentiality: A discussion of the top ten ethical issues posed to the RIPA Ethics Committee. Professional Continuing Education Workshop sponsored by the Rhode island Psychological Association, Providence. RI.
+- Rocchio, L.M. (October 1999). The effects of trauma on the professional. Workshop presented at the Fifth Annual Conference of the Ri Coalition Against Domestic Violence, Providence. RI.
+- Rocchio, L.M. (April 1999). Discussant. in J.C. Christer (Chair). Addressing fat oppression: Research and practice. Symposium conducted at the National Meeting of the Eastern Psychological Association. Providence. Ri.
+- Rocchio, L.M. (October 1997). Discussant. In J.C. Christer (Chair), Current issues in feminist therapy. Symposium conducted at the National Meeting of the New England Psychological Association. Easton, MA.
+- Johnston-Robledo, I., Rocchio, L. M., & Chrisler, J. C. (March 1997). MVP program content 1981 1996: Where we've been, where we're heading. Discussion facilitated at the National Meeting of the Association for Women in Psychology, Pittsburgh. PA.
+- Rocchio, L.M. (October 1996). Discussant. in J.C. Chrisler (Chair). Women and weight: Gendered messages from the media. Symposium conducted at the National Meeting of the New England Psychological Association, New London, Cf.
+- Rocchio, L. M. (August 1996). The pursuit of beauty through thinness and the impact of advertising on college women's attitudes. in C. Smith (Chair), Empirical investigations of women's pursuit of beauty. Symposium conducted at the National Meeting of the American Psychological Association. Toronto, Canada.
+- Cogan, J. & Rocchio, L. M. (March 1995). Fat oppression and body hatred: Strategies for change. One-half day training workshop presented at the National Meeting of the Association for Women in Psychology, Indianapolis, iN.
+
+3502-006 Page 6 of I I
+
+#### Lisa Marie Rocchio, Ph.D. 7
+
+- Cogan, J. & Rocchio, L. M. (March 1994). Celebrating and redefining our diverse beauty: Rejecting body hatred. Workshop presented at the National Meeting of the Association for Women in Psychology, Oakland, CA.
+- Rocchio. L. M. (March 1993). Battered women who kill, psychology, and the law. Paper presented at the National Meeting of the Association for Women in Psychology, Atlanta, GA.
+- Gregory, CJ., Minugh. P. A., Riedford, M., Rocchio, L. M., & Saris. R. (March 1993). Women Against Sexual Harassment (WASH): Working to eliminate sexual harassment from the academic community. Workshop presented at the National Meeting of the Association for Women in Psychology, Atlanta. GA.
+- Silver, B., Rocchio, L. M., & Gregory, C.J., (November 1992). A model for gender role assessment. Paper presented at the meeting of the New England Psychological Association. Fairfield, CT.
+- Rocchio-Giordano, L. M. (February 1992). Moral reasoning related to gender and dilemma content. Paper presented at the National Meeting of the Association for Women in Psychology, Long Beach. CA.
+
+## INVITED ADDRESSES
+
+Rocchio, L.M. (January, 2021). Trauma psychology: What the trauma psychotherapist needs to know Invited presentation to the PGY 3 Residency Seminar at Brown Alpert School of Medicine. Providence, RI.
+
+- Rocchio, L.M. (March, 2016, 2017, 2018). Vicarious traumatization: The effect of trauma exposure on the helping professional. invited continuing education presentation to the New England Society for the Treatment of Trauma and Dissociation workshop: Fundamentals of Complex Trauma and Dissociation, Cambridge, MA.
+- Rocchio. & Mills, M.A.M. (May, 2017). The anxiety• and obsessive compulsive disorders: Overview and treatment strategies. Invited continuing education presentation to the members of the Behavioral Health Pod of the Rhode Island Primary Care Physician's Corporation, Cranston, RI.
+- Hughes, D.M. & Rocchio, L.M. (August, 2016). Forensic work with trauma populations. Invited hospitality suite presentation sponsored by Division 56 of the American Psychological Association. Presented at the National Meeting of the American Psychological Association, Denver, CO.
+- Rocchio, L.M. (2016). Trauma psychology: What the therapist needs to know. Invited continuing education presentation to the members of the Behavioral Health Pod of the Rhode Island Primary Care Physician's Corporation, Cranston, RI
+- Rocchio, L.M. (2016, 2015, 2013, 2012, 2011, 2010, 2009, 2008). Ethical considerations in the practice of clinical and forensic psychology: Business and forensic issues. Invited presentation to the participants of the Fellows Ethics Workshop, Brown University, Providence, Ri.
+- Rocchio, L.M. (2015, 2014). Ethical considerations in the practice of clinical and forensic psychology: Multiple Relationships. invited presentation to the participants of the Fellows Ethics Workshop, Brown University, Providence. RI.
+- Brown, LS., Gold, S., & Rocchio. L.M. (August, 2014). The forensic assessment of trauma. invited hospitality suite presentation sponsored by Division 56 of the American Psychological Association. Presented at the National Meeting of the American Psychological Association, Washington, DC
+- Brown, LS., Gold, S., & Rocchio. L.M. (August, 2013). The forensic assessment of trauma. invited hospitality suite presentation sponsored by Division 56 of the American Psychological Association.
+
+3502.006 Page 7 of I I
+
+Lisa Marie Rocchio, Ph.D. 8 Presented at the National Meeting of the American Psychological Association, Honolulu, HI.
+
+- Rocchio. L.M. (August 2011). Development of a successful independent group practice in psychology. Hospitality suite conversation hour sponsored by Division 42 of the American Psychological Association. Presented at the National Meeting of the American Psychological Association, Washington, D.C.
+- Rocchio, L.M. (April 2009). Practical, legal and ethical considerations in establishing an independent practice in psychology. Invited salon presentation to Early Career Psychologists sponsored by the Rhode Island Psychological Association, Providence. RI.
+- Rocchio, L.M. (April 1996). The pursuit of beauty through thinness and the impact of advertising on college women's attitudes. invited colloquium presented to the Providence College Department of Psychology, Providence RI.
+- Rocchio, L.M., Gregory, C.J., & Minugh, P.A. (1993). Women Against Sexual Harassment (WASH): Dealing with sexual harassment in the workplace. invited presentation to the participants of the Feminist Lecture Series. Butler Hospital. Providence. RI.
+- Rocchio, L.M. (April 1993). Women and weight. Panel discussion participant, Brown University, Providence. RI.
+- Rocchio, L.M. (May 1991). Images of women in the media, the pursuit of beauty, and eating disorders. invited presentation to Psychology of Sexual Equality class, University of Ri, Kingston, Ri.
+
+## DISSERTATION AND THESIS
+
+- Rocchio, L. M. (1995). The pursuit of beauty through thinness and the impact of advertising on college women's attitudes. Doctoral dissertation. University of RI. Kingston. RI.
+- Rocchio, L. M. (1993). Moral reasoning related to gender and dilemma content. Master's thesis, University of RI. Kingston, RI.
+
+#### PROFESSIONAL ACTIVITIES
+
+American Psychological Association
+
+| Division 56 (Trauma Psychology) President-Elect |
+|--------------------------------------------------------------------------------|
+| APA Ethics Committee Member: Forensic Slate |
+| Division 56 Journal, Trauma Psychology: Theory, Research, Practice and Policy, |
+| Editorial Review Board Member |
+| Division 56 Member at Large |
+| Division 56 Treasurer |
+| Division 56 Representative to the Committee on Women in Psychology (CWP) |
+| APA Committee for State Leaders, Past-Chair |
+| State Leadership Convention (SLC) 2020 initiative Task Force, CSL |
+| Representative |
+| APA Committee for State Leaders. Chair |
+| APA Committee for State Leaders, Member-at-large |
+| Division 56 Membership Chair; Program Review Committee Member |
+| Division 35 Student Research Prize Reviewer |
+| Division 35 Student Committee Member |
+| |
+
+3502-006 Page 8 of I I
+
+Association for Women in Psychology
+
+| 2011, 1992 - 2000
1996 - 2000 | Program Review Committee Member
Student Research Prize Review Committee Member |
+|----------------------------------|-----------------------------------------------------------------------------------|
+| 1999 | Conference Planning Committee Member |
+| 1991 - 1995 | Co-Coordinator. RI Chapter |
+| 1992 - 1995 | Student Caucus Coordinator |
+
+## Blue Cross Blue Shield of RI
+
+| 2020 - present | Grant Recipient for Behavioral Health Provider Quality Support
Grant Pilot Program | |
+|----------------------------------------------------------------------------|---------------------------------------------------------------------------------------|--|
+| 2015 - present | Quality Measures Workgroup Member | |
+| Coalition of Mental Health Providers in RI | | |
+| 2004 — present | Founding Committee Member | |
+| Healthsource RI | | |
+| 2014 — 2015 | Expert Advisory Panel, Member | |
+| New England Psychological Association | | |
+| 1995 | Program Review Committee. Member | |
+| Rhode Island Primary Care Physicians Corporation Behavioral Health Network | | |
+| 2014 — present
2013 — present | Vision Committee Member
Communications Committee Member | |
+| Rhode Island Psychological Association | | |
+
+| 2020 — present | Social Justice Committee Member |
+|----------------|--------------------------------------------------|
+| 2016 — present | APA Council Representative |
+| 2013 — present | Healthcare Task Force/Committee Member |
+| 2011 — present | Legislative Affairs Committee Member |
+| 1996 - present | Ethics Committee Member |
+| 2015 - 2016 | Secretary |
+| 2010 — 2014 | Colleague Assistance Task Force/Committee Member |
+| 2014 - 2015 | Past-President |
+| 2012 — 2014 | President |
+| 2011 — 2012 | President-Elect |
+| 2006 - 2008 | Ethics Committee Chair |
+
+#### Rhode Island and Southeastern Massachusetts Trauma Study Group
+
+2010 - 2016 Co-founder and member
+
+3502-006 Page 9 of I I
+
+## Lisa Marie Rocchio. Ph.D. 10
+
+## PROFESSIONAL ADVOCACY
+
+#### Congressional Visits
+
+Visits organized by the American Psychological Association:
+
+| March, 2016 | Medicare and Mental Health Reform. Senators Jack Reed and Sheldon Whitehouse
(Rhode Island) |
+|-------------|---------------------------------------------------------------------------------------------------------|
+| March, 2016 | Medicare and Mental Health Reform. Representatives David Cicilline and James
Langevin (Rhode Island) |
+| March, 2015 | Medicare. Senators Jack Reed and Sheldon Whitehouse (Rhode Island) |
+| March, 2015 | Medicare. Representatives David Cicilline and James Langevin (Rhode Island) |
+| March, 2014 | Medicare. Senators Jack Reed and Sheldon Whitehouse (Rhode Island) |
+| March, 2014 | Medicare. Representatives David Cicilline and James Langevin (Rhode Island) |
+| Feb., 2012 | Medicare and Healthcare Reform. Senators Jack Reed and Sheldon Whitehouse
(Rhode Island) |
+| Feb 2012 | Medicare. Representatives David Cicilline and James Langevin (Rhode Island) |
+
+#### Rhode Island Legislative Advocacy
+
+| 0912013 — 02/ 2014 | Special Joint Commission to Study the Integration of Primary Care and Behavioral
Health. Co-Chaired by Senator Joshua Miller and Representative David Bennett.
Commission Member. |
+|--------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| 2004 - present | Advocacy regarding legislation: |
+| | The increased oversight of Blue CrossiBlue Shield of RI by the office of the Insurance
Commissioner. Changes to the RI licensing law for psychologists |
+| | The inclusion of psychologists in corporate practice of medicine legislation |
+| | Ensuring that psychologists' scope of practice was not restricted by the passage of
statutes related to the practice of applied behavioral analysis |
+| | Local mental health parity legislation |
+| | Marriage equality in the state of RI. |
+
+## PROFESSIONAL AFFILIATIONS
+
+American Psychological Association (APA), Fellow Divisions 42 and 56
+
+3502-006 Page 10 of II
+
+Lisa Marie Rocchio, Ph.D. II
+
+American Psychological Association (APA), Member Divisions 12. 29. 31, 35, 41, Association for Women in Psychology (AWP) Eye Movement Desensitization and Reprocessing International Association (EMDRIA) International Society for the Study of Trauma and Dissociation (ISSTD) International Society for Traumatic Stress Studies (ISTSS) Massachusetts Psychological Association New England Society for the Treatment of Trauma and Dissociation (NESTTD) Rhode Island Psychological Association (RIPA)
+
+## COMMUNITY ACTIVITIES
+
+| 2019 — present | Governance Committee Member. Moses Brown School, Providence. RI |
+|----------------|-------------------------------------------------------------------------|
+| 2011 — 2019 | Nominating Committee Member, Moses Brown School, Providence. RI |
+| 2013 — 2017 | Clerk, Nominating Committee. Moses Brown School, Providence. RI |
+| 2013 -2017 | Executive Committee Member, Moses Brown School, Providence. RI |
+| 2011 — 2017 | Board of Trustees, Moses Brown School. Providence RI |
+| 2008 — 2015 | Trustee Committee Member. Moses Brown School, Providence. RI |
+| 2002 — 2006 | Founding Director, Board of Directors, Quest Montessori School, Exeter. |
+
+3502-006 Page II of II
diff --git a/content-documents/ds8/de/EFTA00023292.md b/content-documents/ds8/de/EFTA00023292.md
new file mode 100644
index 0000000000000000000000000000000000000000..757d5f26ef620a038a8fe67bd03a503e94744de8
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00023292.md
@@ -0,0 +1,215 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00023292)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00023292"
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+---
+
+## UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
+
+JANE DOE 1000,
+
+Plaintiff, CASE NO:
+
+v.
+
+DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN,
+
+Defendants.
+
+COMPLAINT
+
+BOIES SCHILLER FLEXNER LLP
+
+Plaintiff Jane Doe 1000, by her attorneys Boies Schiller Flexner LLP, for her Complaint against Defendants, Darren K. Indyke and Richard D. Kahn in their capacities as the executors of the Estate of Jeffrey Edward Epstein ("Epstein"), avers upon personal knowledge as to her own acts and status and upon information and belief and to all other matters as follows:
+
+## NATURE OF THE ACTION
+
+1. This suit arises out of Jeffrey Epstein's sexual abuse of Plaintiff.
+
+2. Jane Doe 1000 was sexually trafficked by Epstein as part of his organized ring of procuring young and underage girls for sex. One of Epstein's co-conspirators contacted Jane Doe after a modeling appearance and arranged to have Jane Doe meet Epstein under the false pretense that he was involved in the modeling industry and wanted to interview her about opportunities. Rather than help her with her modeling career, Epstein manipulated and intimidated Jane Doe and subjected her to years of sexual abuse in his New York mansion.
+
+3. Epstein's trafficking scheme involved recruiting young females by making false promises and using his wealth, power and threats to intimidate the females into submission to his demands. This same pattern was repeated numerous times with numerous young women.
+
+4. As United States District Judge Kenneth Marra found, "From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls . . . at his mansion in Palm Beach Florida, and elsewhere in the United States and overseas. . . . In addition to his own sexual abuse of the victims, Epstein directed other persons to abuse the girls sexually. Epstein used paid employees to find and bring minor girls to him. Epstein worked in concert with others to obtain minors not only for his own sexual gratification, but also for the sexual gratification of others." Doe 1 v. United States, 359 F. Supp. 3d 1201, 1204 (S.D. Fla. 2019) (internal citations omitted).
+
+#### Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 3 of 14
+
+5. Epstein organized this sex trafficking network to obtain hundreds of young females for himself for sex, and also lent these females out to other powerful and wealthy individuals to be sexually abused.
+
+6. Epstein conspired with others and hired staff to maintain and keep secret this network of sexual abuse for years, which sprawled throughout Epstein's residences in New York, Florida, New Mexico, the United States Virgin Islands, and Paris. Epstein's preference was to have three different young females a day for his sexual pleasure.
+
+7. Despite his significant criminal activity, in 2008 Epstein received a shockingly minimal charge pleading guilty to a single Florida state law charge of procuring a minor for prostitution and a non-prosecution agreement (a "NPA") with the U.S. Attorney for the Southern District of Florida. Unknown to the public and the victims at the time, Epstein's lawyers were pressuring the Government to commit to the NPA without informing the victims. Epstein's multiple victims were kept in the dark and told to be "patient" while Epstein's lawyers worked to protect him and other potential co-conspirators from prosecution. Epstein served one year in jail, but was afforded the privilege of being able to leave the jail to go to work for twelve hours per day, six days per week.
+
+8. The NPA allowed Epstein to escape proportionate punishment for his actions and to continue operating his sex trafficking enterprise with liberty.
+
+9. A few years later, Epstein flippantly referred to his sexual abuse of multiple minors, and the slap on the wrist he had received for it, in a 2011 interview with the New York Post: "Billionaire pervert Jeffrey Epstein is back in New York City — and making wisecracks about his just-ended jail stint for having sex with an underage girl. 'I am not a sexual predator, I'm an offender,' the financier told The Post yesterday. 'It's the difference between a murderer and a
+
+#### Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 4 of 14
+
+person who steals a bagel,' said Epstein." Amber Sutherland, Billionaire Jeffrey Epstein: I'm a Sex Offender Not a Predator, N.Y. Post (Feb. 25, 2011),
+
+https://nypost.com/2011/02/25/billionaire-jeffrey-epstein-im-a-sex-offender-not-a-predatort
+
+10. In August 2018, just one year before his death, Epstein told a New York Times reporter "that criminalizing sex with teenage girls was a cultural aberration and that at times in history it was perfectly acceptable." James B. Stewart, The Day Jeffrey Epstein Told Me He Had Dirt on Powerful People, N.Y. Times (Aug. 12, 2019),
+
+https://www.nytimes.com/2019/08/12/business/jeffrey-epstein-interview.html.
+
+II. When Plaintiff was a young woman, Epstein added her to his long list of victims by committing sexual assault and battery against her. As such, Epstein is responsible for battery and intentional infliction of emotional distress pursuant to New York common law. The damage to Plaintiff has been severe and lasting.
+
+12. This action has been timely filed pursuant to N.Y. C.P.L.R. § 215(8)(a), which provides that a plaintiff shall have at least one year from the termination of a criminal action against the same defendant to commence an action with respect to the event or occurrence from which the criminal action arose. A criminal action against Epstein with respect to the same sex trafficking enterprise from which Plaintiff's claims arise was terminated on August 29, 2019.
+
+13. This action has also been timely filed pursuant to N.Y. C.P.L.R. § 213-C, which provides that a plaintiff shall have 20 years to file civil claims "for physical, psychological or other injury or condition suffered by such person as a result of conduct which would constitute" certain sex crimes under New York Penal Law Article 130. Epstein and Ghislaine Maxwell sexually assaulted Plaintiff by forcible compulsion within 20 years of filing this Complaint, and that sexual assault constitutes one or more sex crimes described in N.Y. C.P.L.R. § 213-C.
+
+### Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 5 of 14
+
+14. Any statute of limitations applicable to Plaintiff's claims, if any, is tolled due to the continuous and active deception, duress, threats of retaliation, and other forms of misconduct that Epstein and his co-conspirators used to silence his many victims, including Plaintiff. Epstein's actions deprived Plaintiff of the opportunity to commence this lawsuit before his death. Until his death, Plaintiff feared that Epstein and his co-conspirators would harm her or her family, or ruin her life, if she came forward.
+
+15. Defendants are equitably estopped from asserting a statute of limitations defense. Allowing Defendants to do so would be unjust. Epstein and his co-conspirators intimidated each of his victims into silence by threatening their lives and their livelihoods. They therefore prevented Plaintiff from commencing this lawsuit before his death. By using threats, along with his wealth and power, Epstein was able to escape punishment for his intolerable and brutal crimes against countless young women and underage girls for the duration of his life.
+
+### PARTIES
+
+16. Plaintiff Jane Doe 1000 is a citizen and resident of New Jersey.
+
+17. Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the Estate of Jeffrey E. Epstein.
+
+18. Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the Estate of Jeffrey E. Epstein.
+
+### JURISDICTION AND VENUE
+
+19. Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin Islands at the time of his death. Jeffrey Epstein maintained a residence in the Southern District of New York. As the legal representatives of the Estate of Jeffrey E. Epstein, Darren K. Indyke and Richard D. Kahn are deemed citizens of the U.S. Virgin Islands.
+
+### Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 6 of 14
+
+20. The amount in controversy in this action exceeds the sum or value of \$75,000.00 excluding interests and costs and is between citizens of different states. Accordingly, jurisdiction is proper under 28 U.S.C. § 1332.
+
+21. Venue is proper in this Court as Epstein's sexual abuse of Plaintiff began and occurred in New York, New York, where he recruited her, physically molested her, and began grooming her for sex in his organized sex trafficking ring.
+
+22. Many of the events giving rise to these causes of action occurred in the Southern District of New York, where a substantial amount of Epstein's property is located. Thus, venue in this district is proper. 28 U.S.C. § 1391(b)(2).
+
+### FACTUAL ALLEGATIONS
+
+## A. Epstein's Sex Trafficking Enterprise
+
+23. Jeffrey Epstein was widely renowned as a billionaire who used his vast connections to powerful individuals, and seemingly unlimited wealth and resources, to create a web of transcontinental sex trafficking that served himself, his coconspirators, and some of the most powerful people in the world.
+
+24. Epstein owned multiple residences and frequently travelled between them, including at 9 East 71" Street, New York, New York 10021, where the illegal sexual crimes against Plaintiff occurred. Epstein conservatively valued his New York townhome at \$55,931,000.00. Epstein conservatively valued his ranch at 49 Zorro Ranch Road, Stanley, New Mexico 87056, at \$17,246,208.00. In addition, Epstein owned residences in the Virgin Islands, Florida, France, and even on his own island, Great St. James Island, where his transcontinental sex trafficking of hundreds of young girls servicing him, his co-conspirators, and wealthy and powerful individuals around the world occurred.
+
+### Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 7 of 14
+
+25. The allegations herein concern Epstein's tortious acts against Plaintiff while in New York, where Epstein was staying at his mansion.
+
+26. At all times material to this cause of action, Jeffrey Epstein utilized his seemingly unlimited power, wealth, and resources, as well as his deep connections to powerful and politically connected individuals to intimidate and manipulate his victims of sexual abuse. 27. Epstein and his co-conspirators had perfected a scheme for manipulation and abuse of young females. As part of the scheme, a female "recruiter" would approach a young female and strike up a conversation in an effort to quickly learn about the young female's background and any vulnerabilities they could expose. The recruiter would then manipulate the young female into coming back to one of Epstein's residences by offering the young female something she needed. At times the recruiter's lure would be a modeling opportunity, money for education, help for the young female's family, and a whole host of other related offers depending on their target's situation. Once in the residence, the recruiter and Epstein would work in concert to impress and intimidate the young female with displays of vast wealth, including having employees that were butlers and maids formally dressed around the house. They would also strategically place photographs of very powerful political and social figures amongst photographs and art displaying nude females in an effort to normalize the sexual abuse. They would also normalize the sexual abuse by placing a massage table and spa related products around the massage area in an effort to legitimize the area where the abuse was set to occur. Once abused, Epstein and his co-conspirators continued to manipulate the victims, using their financial power, promises, and threats to ensure that the victim returned as directed and remained compliant with their demands.
+
+## B. The Arrest, Prosecution, and Death of Epstein
+
+28. The sexual trafficking ring described herein started at least as early as 1995 and continued up until at least July 2, 2019, when the U.S. Attorney's Office for the Southern District of New York ("SDNY") charged Epstein with sex trafficking conspiracy and sex trafficking in violation of 18 U.S.C. § 1591. He was arrested on July 8, 2019, pursuant to the SDNY's Sealed Two Count Indictment, which is attached as Exhibit A.
+
+29. The Indictment described Epstein's conduct and his abuse and trafficking of females in the same trafficking operation he used to abuse and traffic Plaintiff.
+
+30. Epstein's last will and testament (the "Will") was executed on August 8, 2019, at the Metropolitan Correctional Center. The witnesses were Martel Colon Miro and Gulnora Tali. The Will included affidavits from Darren K. Indyke and Richard D. Kahn, in which they swear an "Oath of Willingness to Serve as Executor and Appointment of Local Counsel."
+
+31. Epstein was found dead in his cell at the Metropolitan Correctional Center on August 10, 2019.
+
+32. Epstein's last will and testament was filed on August 15, 2019, in the Probate Division of the Superior Court of the Virgin Islands.
+
+33. Darren K. Indyke and Richard D. Kahn filed a Certificate of Trust in the Superior Court of the Virgin Islands for Epstein's 1953 Trust on August 26, 2019. See Certificate of Trust, In the Matter of the Estate of Jetey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019).
+
+34. Epstein's will was entered into probate on September 6, 2019, and the Superior Court of the Virgin Islands accordingly authorized Darren K. Indyke and Richard D. Kahn to administer Epstein's estate. See Order for Probate, In the Matter of the Estate ofJqffrey E. Epstein, Probate
+
+No. ST-19-PB-80 (Super. Ct. V.I. Sept. 6, 2019); Letters Testamentary, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Sept. 6, 2019).
+
+35. The Will's first article directs Epstein's executors "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." The Will further directs that "after the payments and distributions provided in Article FIRST," Epstein "give[s] all of my property, real and personal, wherever situated...to the then acting Trustees of The 1953 Trust."
+
+36. Following Epstein's death, SDNY submitted a proposed nolle prosequi order in the criminal matter against him because it was required by law to do so after Epstein was deceased. On August 29, 2019, U.S. District Judge Richard Berman formally dismissed SDNY's indictment against Epstein, terminating the criminal action against him. Plaintiff's claims are therefore timely under N.Y. C.P.L.R. § 215(8)(a).
+
+## C. Jane Doe 1000
+
+37. Jane Doe 1000 grew up in extreme poverty. At various times throughout her childhood, her mother had been homeless. Jane Doe was unable to enroll in high school because she did not have a residence and often lived without running water or electricity.
+
+38. In late 1999, Jane Doe made a modeling appearance. A man called her and told her that Jeffrey Epstein had connections to various modeling jobs and asked her if she would like to meet with Epstein to discuss opportunities. The opportunity sounded enticing to Jane Doe, so she agreed and met Epstein at his New York City mansion on 7 Is" Street.
+
+39. Upon meeting Jane Doe, Epstein offered her a position modeling with Victoria's Secret, a lingerie retailer. He explained that he was friends with Les Wexner, the chief executive of
+
+### Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 10 of 14
+
+Victoria's Secret's parent company. Epstein reiterated his connection to Victoria's Secret each time he saw and spoke with Jane Doe.
+
+40. Eventually, Epstein moved Jane Doe into his apartment building on 66'h Street, where he housed other models and young women that he sexually abused, so that he could have complete control over her life. Her relationship with Epstein quickly turned into one of sexual abuse. Ghislaine Maxwell, one of Epstein's main "recruiters," along with additional unidentified co-conspirators, would call Jane Doe and direct her to go to Epstein's mansion to give him a massage. The massages quickly escalated into Epstein forcing himself on Jane Doe against her will and engaging in one or more sex act with her for his own sexual gratification. Jane Doe was terrified of Epstein, who repeatedly threatened her and made representations about his wealth, power, and connections.
+
+41. During Jane Doe's time with Epstein, he forced her to give him sexual massages and made her use sex toys.
+
+42. Epstein also flew Jane Doe to his residence in Palm Beach, Florida, where she was also forced to give Epstein sexual massages.
+
+43. On one occasion, Epstein forced Jane Doe to meet with a lawyer, even though she did not express any need for a lawyer to Epstein. The lawyer she met with was a prominent attorney and a law professor who was described to Jane Doe as Epstein's close friend and lawyer. The lawyer appeared to be interviewing her, asking personal questions about her family's financial situation. The meeting had no legal purpose, and Epstein later used the information that the lawyer had obtained through his meeting with Jane Doe to intimidate her and to keep her compliant in his sex-trafficking scheme.
+
+# Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 11 of 14
+
+44. Epstein made very clear to Jane Doe that he was incredibly wealthy, powerful and regularly in contact with world leaders. In fact, in his New York mansion he had photographs displayed of significant political figures to ensure that any young female entering the home would know that he had extensive government connections. Epstein was not to be disobeyed and he made clear by his words and actions that there would be consequences if Jane Doe did not comply with his demands.
+
+45. Epstein constantly promised Jane Doe modeling opportunities with Victoria's Secret each time she saw him. He continued to make that promise for years, up until the last time Jane Doe saw Epstein.
+
+46. One day, Epstein had someone call Jane Doe to his mansion. When Jane Doe arrived, Maxwell was waiting for her and led her upstairs to Epstein's master bedroom. When they got to the bedroom, sex toys were laid out on the bed. Epstein and Maxwell proceeded to sexually assault Jane Doe simultaneously and by forcible compulsion. Maxwell forcibly penetrated Jane Doe with a sex toy. She was horrified and terrified by the experience and knew she had to try to get away from Epstein even though she risked harm to herself by disobeying Epstein. She proceeded to move out of the 66th Street apartment building and, having nowhere else to go, found shelter at the Salvation Army housing facility.
+
+47. Jane Doe was deeply affected by her harrowing experiences at the hands of Epstein. She suffers extreme emotional distress from an experience that has affected her for her entire life.
+
+48. Epstein's sexual assault and battery of Jane Doe continues to cause her significant distress and harm.
+
+II
+
+## FIRST CAUSE OF ACTION
+
+## (Battery)
+
+49. Plaintiff repeats and re-alleges the allegations stated above in paragraphs 1-48 as if fully set forth herein.
+
+50. Epstein intentionally committed battery by sexually assaulting Plaintiff when she was a young woman. As described above, on multiple occasions, Epstein intentionally sexually assaulted and touched Plaintiff in an offensive and sexual manner without her consent.
+
+51. Epstein's actions constitute sexual offenses as defined in New York Penal Law Article 130, including but not limited to Article 130.35, inasmuch as Epstein and Maxwell sexually assaulted Plaintiff by forcible compulsion within 20 years of filing this Complaint. See N.Y. C.P.L.R. § 213-C.
+
+52. A criminal action against Epstein with respect to the same sex trafficking enterprise from which Plaintiff's first cause of action arises was terminated on August 29, 2019, less than one year prior to the filing of this Complaint. See N.Y. C.P.L.R. § 215(8)(a).
+
+53. As a direct and proximate result of Epstein's conduct, Plaintiff has in the past and will in the future continue to suffer extreme emotional distress, humiliation, fear, psychological trauma, loss of dignity and self-esteem, and invasion of her privacy.
+
+## SECOND CAUSE OF ACTION
+
+## (Intentional Infliction of Emotional Distress)
+
+54. Plaintiff repeats and re-alleges the allegations stated above in paragraphs 1-48 as if fully set forth herein.
+
+55. As a direct result of these allegations as stated, Epstein committed intentional infliction of emotional distress against Plaintiff.
+
+### Case 1:19-cv-10577-LJL-DCF Document 1 Filed 11/14/19 Page 13 of 14
+
+56. Epstein's actions, described above, constitute extreme and outrageous conduct that shocks the conscience. Epstein's plan to recruit, entice, and assault Plaintiff on multiple occasions goes beyond all possible bounds of decency and is intolerable in a civilized community.
+
+57. Epstein knew or disregarded the substantial likelihood that these actions would cause Plaintiff severe emotional distress.
+
+58. A criminal action against Epstein with respect to the same sex trafficking enterprise from which Plaintiff's second cause of action arises was terminated on August 29, 2019, less than one year prior to the filing of this Complaint. See N.Y. C.P.L.R. § 215(8)(a).
+
+59. As a direct and proximate result of Epstein's conduct, Plaintiff has in the past and will in the future continue to suffer extreme emotional distress, humiliation, fear, psychological trauma, loss of dignity and self-esteem, and invasion of her privacy.
+
+## PRAYER FOR RELIEF
+
+WHEREFORE, Plaintiff respectfully requests judgment against Defendants, awarding compensatory, consequential, exemplary, and punitive damages in an amount to be determined at trial; costs of suit; attorneys' fees; and such other and further relief as the Court may deem just and proper.
+
+### JURY DEMAND
+
+Plaintiff hereby demands a trial by jury on all causes of action asserted within this pleading.
+
+Dated: November 14, 2019.
+
+/s/ Joshua I. Schiller
+
+David Boies BOIES \$CHILLER FLEXNER LLP 333 Main Street Armonk, NY 10504 (914) 749-8200
+
+Joshua I. Schiller BOIES SCHILLER FLEXNER LLP 55 Hudson Yards New York, NY 10001 (212) 446-2300
+
+Sigrid McCawley (Pro Hac Vice Pending) BOIES \$CHILLER FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011
diff --git a/content-documents/ds8/de/EFTA00024736.md b/content-documents/ds8/de/EFTA00024736.md
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+++ b/content-documents/ds8/de/EFTA00024736.md
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+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00024736)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00024736"
+ocrPages: 0
+ocrChars: 241
+ocrElapsed: 0.0
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+---
+
+
+
+Sender Subject: RE: GM -- search warrant returns Message-Id:
+
+' | |
+| Subject: FW: Application for Amended SW | |
+| Date: Thu, 22 Oct 2020 17:45:49 +0000 | |
+
+### Looking now and will send to you.
+
+| From: | | |
+|-------------------------------------------------|--|--|
+| Sent: Thursday, October 22, 2020 1:07 PM
To: | | |
+| Cc:
Subject: Application for Amended SW | | |
+
+Chiefs,
+
+Thanks very much for talking this morning. As discussed, attached is a draft application for an amended search warrant correcting the FBI barcode numbers for 3 devices that were seized from Epstein's NY residence. In case it's useful, I'm also attaching the exhibits that are referenced in the draft application.
+
+Thanks,
diff --git a/content-documents/ds8/de/EFTA00026909.md b/content-documents/ds8/de/EFTA00026909.md
new file mode 100644
index 0000000000000000000000000000000000000000..9654383658f582d25f1d161d71c8d6c6a79283c0
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00026909.md
@@ -0,0 +1,49 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00026909)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00026909"
+ocrPages: 0
+ocrChars: 1994
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+Subject: RE: Epstein Documents from BOP without Green Watermark Date: Mon, 12 Apr 2021 16:07:52 +0000
+
+## Hi
+
+Thank you. Let me circle up with a few folks, including BOP, about how best to proceed here, and I will get back to you.
+
+Thanks,
+
+| From:
(USANYS) | |
+|-----------------------------------------------------------------|-----|
+| Sent: Monday, April 12, 2021 11:36 AM | |
+| (usANys)
To:
(USANYS)4 | ::. |
+| Subject: RE: Epstein Documents from BOP without Green Watermark | |
+
+## Hi
+
+We requested these from the BOP, and they provided a set of documents, which we then produced to defense counsel. We did not do a page by page comparison between the redacted set and the unredacted set, so we can't guarantee that they are "comprehensive." But we can provide you with what we have, assuming that there aren't any issues with us sharing in that way.
+
+Best,
+
+| From:
(USANYS) < | | |
+|-------------------------------------------------------------|-----------|--|
+| Sent: Sunday, April 11, 2021 12:27 PM | | |
+| To:
(USANYS) | (USANYS)4 | |
+| Subject: Epstein Documents from BOP without Green Watermark | | |
+
+and
+
+I recall that at some point you requested a version of the Epstein FOIA documents from BOP without the translucent green watermark they put on the withheld documents. Do you have those saved down somewhere? Although the Court has not put in a specific order yet, I think it's likely that we'll need to produce documents without the translucent green marking to the Court. I have versions without the watermark for some of the does, but it looks like not all. Do you have a comprehensive set somewhere?
+
+Thanks,
+
+Assistant United States Attorney 300 Quarropas Street White Plains, NY 10601 Telephone:
diff --git a/content-documents/ds8/de/EFTA00027650.md b/content-documents/ds8/de/EFTA00027650.md
new file mode 100644
index 0000000000000000000000000000000000000000..e13ffab68d94b9a9ad8d2be54e3d2b173bee8eb0
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00027650.md
@@ -0,0 +1,19 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00027650)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00027650"
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+
+
+
+## Hi
+
+Attached please find a fact witness travel request for another witness in the Maxwell trial— I expect he'll testify on 12/2, but he could possible bleed over into 12/3, so I'd like to have him fly in on 12/1 and out on the evening of 12/3. Please let me know if you have any questions, and thank you, as always, for your help.
diff --git a/content-documents/ds8/de/EFTA00027845.md b/content-documents/ds8/de/EFTA00027845.md
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+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00027845)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
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+---
+
+| From: | |
+|----------------------|---------------------------------------------------------------------|
+| To: | |
+| | Subject: Accepted: FW: GHISLAINE MAXWELL Removal Hearing 20mj132-01 |
+| | Date: Thu, 02 Jul 2020 16:26:33 +0000 |
+| Importance: Normal | |
+| Attachments: unnamed | |
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@@ -0,0 +1,75 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00028272)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00028272"
+ocrPages: 0
+ocrChars: 8021
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+Thank you for doing this. The defense's November 8 letter (attached) lists a bunch of Government discovery in 12 subcategories. Could you please take a look at the letter and put copies of the bates numbers the defense has identified and put them in subfolders in the folder that created (e.g., AT&T, Federal Express, etc). I added a subfolder as an example. Let me know if you have any questions.
+
+| Thanks! | | |
+|---------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------|
+| From: | USANYS) [Contractor] | |
+| | Sent: Tuesday, November 9, 202112:51 PM | |
+| To | | |
+| Cc: | (USANYS) [Contractor] | (USANYS) |
+| | | |
+| | Subject: RE: Defense Rule 16 Disclosure | |
+| | | |
+| | Thanks I Saved here: \ Usa.doj.gov \cloud \ NYS \StAndrewASharecAUSvEpstein-2018R01618Wiscovery \ GM \ Defense Rule
16 Disclosures \ 2021.11.08 Defense Rule 16 Disclosure | |
+| | | |
+| From: | | |
+| | Sent: Tuesday, November 9, 2021 12:44 PM | |
+| To: | USANYS) [Contractor] | |
+| Cc: | USANYS) [Contractor] | (USANYS) |
+| | | |
+| | u ject: Re: Defense Rule 16 Disclosure | |
+| | | |
+| | In the discovery folder. Thanks! | |
+| | | |
+| | On Nov 9, 2021, at 12:25 PM,
(USANYS) [Contractor] | wrote: |
+| | | |
+| | Hi team — apologies for just getting to this now. Where on the shared would you like these saved? Thanks! | |
+| | | |
+| From: | | |
+| | Sent: Monday, November 8, 2021 9:40 PM | |
+| To: | SANYS) [Contracto | (USANYS) [Contractor] |
+| | | |
+| Cc: | (USANYS) | |
+
+### Subject: FW: Defense Rule 16 Disclosure
+
+### Hi .—could you please save these on the shared? Thanks!
+
+| From: Christian Everdell | |
+|------------------------------------------------|--|
+| Sent:
Monday, November | |
+| To: | |
+| (USANYS) | |
+| Cc: Jeff Pag luta < | |
+| Subject: (EXTERNAL) Defense Rule 16 Disclosure | |
+| and. | |
+| Attached is the defense Rule 16 disclosure. | |
+| Regards, | |
+| Chris | |
+
+Christian R Everdell
+
+
+
+
+
+New York I Paris I Washington DC I London
+
+CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended robe 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 al: httpsikewre.cohengressercom/privacpolicx
diff --git a/content-documents/ds8/de/EFTA00029515.md b/content-documents/ds8/de/EFTA00029515.md
new file mode 100644
index 0000000000000000000000000000000000000000..6955116149c7d6c021e0d73b70468f37f229402f
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00029515.md
@@ -0,0 +1,63 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00029515)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00029515"
+ocrPages: 4
+ocrChars: 6490
+ocrElapsed: 1.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| Subject: RE: US v. Epstein - Status Hearing Notification |
+|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| Date: Thu, 01 Aug 2019 21:24:47 +0000 |
+| Attachments: JBAGOYO_20190726095441587_DRAFT.pdf;
JBAGOYO_20190719165055822_DRAFT.pdf |
+| Hi
so, I was the one editing the letters |
+| Attached are the 2 previous notifications for this case that were sent to the Victims and they both don't those edits you
requested. |
+| From: |
+| Sent: Thursday, August 01, 2019 5:01 PM
To: |
+| Subject: RE: US v. Epstein - Status Hearing Notification |
+| =, |
+| has been able to edit the previous letters, so it might be worth checking with her to see how she was able
Thanks.
to do that. |
+| Thanks, |
+| |
+| From: |
+| Sent: Thursday, August 1, 20194:45 PM
To: E
)'; |
+| Subject: RE: US v. Epstein - Status Hearing Notification |
+| . Attached is the updated version. I'm sorry but I could only update the hearing information. The other edits
Thanks
can't be done due to the template in VNS which can't be changed. Frustrating I know, but I did my best to make it look |
+| decent. Let me know if I can send it out. Thanks and sorry again! |
+| From: |
+| Sent: Thursday, August 01, 2019 4:24 PM
To: |
+| Subject: RE: US v. Epstein - Status Hearing Notification |
+
+M,
+
+Thanks. A few things:
+
+- In the case caption, please delete "defendant(s)," so that it does not read "defendant(s) Jeffrey Epstein". I'm not sure if that's the form language, but it looks like a typo.
+- Regarding the hearing information, there are several other court dates. I'll forward you the scheduling order so that you can add them.
+- Please swap out this language:
+
+Because of the Court's schedule, hearing dates could change on very short notice. If you plan on attending, you may want to call the VNS Call Center or check the website to confirm the date and time. Please note, there is a 24-hour delay in information transfer to the website.
+
+And replace it with this language:
+
+If you plan on attending, please call me at in case there are any last minute changes.
+
+### Thanks!
+
+| From: | |
+|----------------------------------------|--|
+| Sent: Thursday, August 1, 2019 4:11 PM | |
+| To: | |
+| | |
+
+### Subject: US v. Epstein - Status Hearing Notification
+
+Hi there, attached is a status hearing notification which showed up on VNS today for this case. Did you want me to send it out? Thank you.
+
+Victim-Witness Assistant U.S. Attorney's Office — SDNY 1 St. Andrews Plaza New York, NY 10007 Office:
diff --git a/content-documents/ds8/de/EFTA00030168.md b/content-documents/ds8/de/EFTA00030168.md
new file mode 100644
index 0000000000000000000000000000000000000000..003a5131e1a81b4ca27a3941e1b8dabf73cc7f4f
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00030168.md
@@ -0,0 +1,31 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00030168)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00030168"
+ocrPages: 0
+ocrChars: 551
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+From: "Weingarten, Reid"
+
+To: ' Subject: Re: U.S. v. Epstein, 19 Cr. 490 Date: Mon, 08 Jul 2019 10:00:37 +0000
+
+Thanks see you in the morning
+
+Sent from my iPhone
+
+On Jul 7, 2019, at 11:16 PM, C wrote:
+
+Reid,
+
+I understand you'll also be appearing for Mr. Epstein tomorrow, so I wanted to send the full contact information for our team, as we did previously for Marty. As the case goes forward, please feel free to reach out to any of us at the below contacts, and we'll see you in the morning.
+
+
+
+Assistant U.S. Attorney Southern District of New York
diff --git a/content-documents/ds8/de/EFTA00032511.md b/content-documents/ds8/de/EFTA00032511.md
new file mode 100644
index 0000000000000000000000000000000000000000..b224fdcdc79bedabbd0f83f7294ae32c4880978c
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00032511.md
@@ -0,0 +1,45 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00032511)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00032511"
+ocrPages: 0
+ocrChars: 1358
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+thanks again,
+
+
+
+| | 19, 2019 11:59 AM
Sent: Tuesday, February | |
+|-----|----------------------------------------------|--|
+| TC1 | OPR | |
+| | PR) | |
+| | Subject: RE: RE: SDNY investigation | |
+
+call that if there's ever a time-sensitive issue, but I'll be at my desk tomorrow morning.
+
+Unfortunately I'm in the grand jury and meetings most of the afternoon, but I'll be free (and in the office) anytime this evening starting at 5:00, or could talk anytime tomorrow before 2:00. What works best for you?
+
+thanks,
+
+Assistant U.S. Attorney Southern District of New York From: OPR) Sent: Tuesday, February 19, 019 11:35 To: Cc: 0PR) Subject: RE: RE: SDNY roves iga ion
+
+
+
+Subject: RE: SDNY investigation
+
+Mind
+
+I am one of the AUSAs working on the current investigation of Jeffrey Epstein in the Southern District of New York, and I was given your contact information by nd so wanted to be in touch for any deconfliction or discussion that might be useful with respect to our respective matters. Is there a good time to be in touch sometime this week? I should generally be able to make myself available at your convenience, and please let me know if any information would be helpful in advance.
+
+thank you,
+
+Assistant U.S. Attorney • of New York
diff --git a/content-documents/ds8/de/EFTA00033343.md b/content-documents/ds8/de/EFTA00033343.md
new file mode 100644
index 0000000000000000000000000000000000000000..d214329ce17889a8dfec6fba5159ce3da416dc58
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00033343.md
@@ -0,0 +1,15 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00033343)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00033343"
+ocrPages: 0
+ocrChars: 22
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+### No Images Produced
diff --git a/content-documents/ds8/de/EFTA00034747.md b/content-documents/ds8/de/EFTA00034747.md
new file mode 100644
index 0000000000000000000000000000000000000000..ead71513e4c3ad2278fde7c6a911bfdbc55d7273
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00034747.md
@@ -0,0 +1,29 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00034747)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00034747"
+ocrPages: 0
+ocrChars: 755
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| To:
From:
Sent:
Subject:
TEXT htm | Sat 7/27/2019 2:26:38 PM
Re: Epstein |
+|-----------------------------------------------|-----------------------------------------|
+| Thanks | |
+
+Sent from my Verizon, Samsung Galaxy smartphone
+
+Original message From: Date: 7/27/19 9:53 AM (GMT-05:00) To: Subject: Epstein
+
+| >>r; | 07/27/2019 09:53 >>> |
+|---------------|----------------------|
+| Good morning, | |
+
+Inmate Epstein was assessed by a Psychologist today prior to his Attorney visit and he will remain on Psychological Observation. He will be assessed again on tomorrow. Thanks.
+
+Sent from my Verizon, Samsung Galaxy smartphone
diff --git a/content-documents/ds8/de/EFTA00035118.md b/content-documents/ds8/de/EFTA00035118.md
new file mode 100644
index 0000000000000000000000000000000000000000..12a26a2f5d297213f0a250cb553cbc0bb6aa5faf
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00035118.md
@@ -0,0 +1,27 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00035118)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00035118"
+ocrPages: 0
+ocrChars: 389
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+From
+
+Subject Epstein, Jeffrey Edward, Reg. No. 73618-054 re: Atty Conf Log book (Pt 1-4) Date: Sun, 11 Aug 2019 01:59:16 +0000
+
+Importance: Normal
+
+Attachments: TEXT.htm; Epstein_Atty_Conf_Pt_1.pdf; Epstein_Atty_Conf Pt 2.pdf; Epstein_Atty_Conf_Pt_3.pdf; Epstein_Atty_Conf_Pt_4.pdf;
+
+see attachment:
+
+Associate Warden MCC New York 150 Park Row New York, NY 10007
+
+NYM/AW-Programs-@bop.gov
diff --git a/content-documents/ds8/de/EFTA00035383.md b/content-documents/ds8/de/EFTA00035383.md
new file mode 100644
index 0000000000000000000000000000000000000000..94018f717973e20565db24ef5c046ca35abcefe0
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00035383.md
@@ -0,0 +1,72 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00035383)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00035383"
+ocrPages: 0
+ocrChars: 5039
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From: " | |
+|-----------------------|---------------------------------------|
+| To: | |
+| | Subject: Re: Epstein |
+| | Date: Wed, 24 Jul 2019 15:54:53 +0000 |
+| Importance: Normal | |
+| Attachments: TEXT.htm | |
+| | |
+
+He is pending a Code 228, Tattooing or Self-Mutilation and I spoke with Dr. who indicated that most likely he will be found competent because he is not mentally ill. Therefore, he will be pending a UDC hearing. I am looking at the SHU Roster now to see who can be a good cell mate.
+
+| Associate Warden |
+|-----------------------------------------------------------------|
+| MCC New York |
+| 150 Park Row |
+| New York. New York 10007 |
+| Office: |
+| Black Be |
+| |
+| > 7/24/201910:47 AM >>>
>> > |
+| Looks good |
+| Sent from my Verizon, Samsung Galaxy srnartphone |
+| Original message |
+| From: ' |
+| Date: 7/24/1910:10 AM (GMT-05:00) |
+| To: |
+| Subject: Re: Epstein |
+| |
+| > »
07/24/2019 10:10 >>>
" |
+| This is the response I am sending the RD. Are you ok with this? |
+
+Below is the definition of Psychological Observation provided by Dr. =, Chief Psychologist. He will remain on Psychological Observation until tomorrow, where he will be reassessed.
+
+DEFINITION:A Psychological Observation occurs when an inmate who suffers from a mental illness, a serious personality disorder, a medical problem (impairing their mental status), or drug intoxication and/or withdrawal symptoms begins to deteriorate. The inmate is no longer mentally stable and therefore, it is inappropriate for s/he to remain in general population or the Special Housing Unit (SHU). Inmates placed on psychological observation differ from inmates placed on suicide watch as they are not imminently suicidal (e.g., have not expressed self-harm or engaged in self-harming behavior), but rather, due to his/her impairment in mental status or functioning (e.g., not eating, not sleeping, disorganized/unusual thinking, poor self-care), his/her behavior can be unpredictable. Psychological Observation status is intended as a temporary designation to be utilized until such time as the inmate becomes sufficiently stable (e.g., able to function independently in general population) to be returned to his/her housing assignment or transferred to an inpatient psychiatric facility such as a Federal Medical Center.
+
+He has a pending incident report for Self-Mutilation and therefore, he will return to the Special Housing Unit (SHU) and will be celled with inmate I . Inmate pleaded guilty. in March to mailing improvised explosive devices to 13 people, including many prominent Democratic figures, among them former President Barack Obama, former Vice President Joe Biden, former Secretary of State Hillary Clinton and Sens. Cory Booker (N.J.) and Kamala D. Harris (Calif.), as well as CNN. He drove around in a van festooned with political stickers and rants, one of them targeting CNN. His case has been highly publicized and he is in SHU because he requested Protective Custody.
+
+Associate Warden MCC New York 150 Park Row New York. New York 10007 Office: Black Berr
+
+» 7/24/2019 9:42 AM >»
+
+Thanks. Where and with who will he be housed after his Attorney visit? Also, what does "Psychology Observatior!" status mean?
+
+Regional Director Northeast R ion
+
+>>> 7/24/2019 9:39 AM > »
+
+Hello,
+
+Inmate Epstein #76318-054 was removed from Suicide Watch and stepped down to Psychological Observation. He was just escorted to Health Services for a follow-up assessment/evaluation. Once completed, he will be escorted to Attorney Conference to meet with his Attorney. I will provide you with information concerning the medical assessment, once I receive it. Thanks.
+
+Associate Warden MCC New York 150 Park Row New York. New York 10007 Office: Black Be
+
+>» 7/24/2019 8:45 AM >»
+
+- Please provide me with a daily update on this inmate, including his status and any changes/activities I should be aware of. Thanks!
+
+Regional Director Northeast Re ion
diff --git a/content-documents/ds8/de/EFTA00035660.md b/content-documents/ds8/de/EFTA00035660.md
new file mode 100644
index 0000000000000000000000000000000000000000..7e47dd4dce34facbfe5129f91939417c3978ad7d
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00035660.md
@@ -0,0 +1,21 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00035660)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00035660"
+ocrPages: 2
+ocrChars: 526
+ocrElapsed: 0.3
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+Good morning,
+
+This is just a follow-up to our conversation this morning concerning Epstein, Jeffrey, Register No. 76318-054, who was found unresponsive in his cell at 6:33 a.m. Life-saving measures were performed by institution staff and EMS staff. He was escorted to the local hospital where he was later pronounced dead at 7:36 a.m. Should you require any additional information, please contact me. Thanks.
+
+Associate Warden MCC New York 150 Park Row New York, New York 10007 Office: Black Berr
diff --git a/content-documents/ds8/de/EFTA00035970.md b/content-documents/ds8/de/EFTA00035970.md
new file mode 100644
index 0000000000000000000000000000000000000000..38db9cbe2de5fbb77dea9fa5f984b49702f79eb7
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00035970.md
@@ -0,0 +1,136 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00035970)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00035970"
+ocrPages: 0
+ocrChars: 18832
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+
+
+### LIMITED
+
+### OFFICIAL
+
+
+
+The attached information must be protected and not released to unauthorized individuals. Use of this cover sheet is in accordance with the Department of Justice regulation on the control of Limited Official Use information.
+
+LIMITED OFFICIAL USE ONLY-NOT FOR PUBLIC RELEASE
+
+
+
+Investigation and Review of the Federal Bureau of Prisons' Custody, Care, and Supervision of Jeffrey Epstein at the Metropolitan Correctional Center in New York, New York
+
+> * * March 202:;
+
+Notice: This Draft Is Restricted to Limited Official Use.
+
+This document is a WORKING DRAFT prepared by the U.S. Department of Justice Office of the Inspector General. It has not been fully reviewed within the Department and is, therefore, subject to revision. This report may contain sensitive law-enforcement or privacy-protected information and is for authorized recipients only. Recipients of this draft must not, under any circumstances, show or release its contents for purposes other than official review and comment. It must be safeguarded in accordance with Department of Justice Order 2620.7 to prevent publication or other improper disclosure of the information it contains.
+
+If you have received this draft report in error, please contact (202) 768-2643 to arrange its return.
+
+Additionally, the Day Watch SHU Officer in Charge on August 9, 2019, said he and all other SHU staff were aware of Epstein's cellmate requirement.
+
+ge said that since he had the most experience and seniority, he was considered by everyone to be the SHU Officer in Charge,'
+
+The Day Watch SHU Officer in Charge told the OIG that he knew that Epstein had to have a cellmate. He said that, as a general practice, every inmate who is transferred from suicide watch and/or psychological observation to the SHU is placed with a cellmate. He also confirmed that the SHU Lieutenant had instructed him that Epstein was to be housed with a cellmate at all times. According to the Day Watch SHU Officer in Charge, between July 30 and August 9, 2019, he told all other MCC New York staff members who worked in the SHU of Epstein's cellmate requirement and further stated that everyone who worked in the SHU should have known that Epstein was required to have a cellmate due to their knowledge, training, and experience.
+
+The Day Watch SHU Officer in Charge confirmed that on the morning of August 9, 2019, the SHU staff received an inmate call out list that listed Inmate 3 as "WAB," which he explained meant that Inmate 3 was being removed from MCC New York. He told the O16 that sometime between 8:00 a.m. and 9:00 a.m., he escorted Epstein from the SHU to the attorney conference room for Epstein's daily legal visit, during which time Epstein joked around with him. The Day Watch SHU Officer in Charge said that he and Epstein were accompanied by Correctional Officer 1, who was escortin: Inmate 3 to Receiving and Discharge. The Day Watch SHU Officer in Charge told the OIG that Inmate 3 was escorted to Receiving and Discharge with all of his belongings said that during the escort the Day Watch SHU Officer in Charge informed Epstein that he would be assigned a new cellmate due to Inmate 3's departure and the requirement that Epstein have a cellmate
+
+The Day Watch SHU Officer in Charge told the OIG that when he and Correctional Officer 1 left the SHU with Epstein and Inmate 3, both the Day Watch Operations Lieutenant and the Day Watch Activities Lieutenant should have been physically present in the Lieutenants' Office and should have seen that Inmate 3 was departing the institution when they passed the office.
+
+The Day Watch SHU Officer in Charge said that while he did not expect Inmate 3 to return to MCC New York, there had been times when inmates had been escorted to Receiving and Discharge as an expected removal, only to be returned to the SHU later that same day due to unforeseen circumstances. According to the Day Watch SHU Officer in Charge, he did not select a new cellmate for Epstein because he was not certain that Inmate 3 had been discharged from the institution, although he assumed that Inmate 3 would not return to the SHU. The Day Watch SHU Officer in Charge told the OIG that when his shift ended at approximately 2:00 p.m., he informed the Evening Watch SHU Officer in Charge and Senior Officer Specialist 5 that, if Inmate 3 did not return to the SHU, Epstein would need a new cellmate upon Epstein's return from his attorney visit. The Day Watch SHU Officer in Charge said he specifically recalled telling the Evening Watch SHU Officer in Charge, in the presence of Senior Officer Specialist 5, "Make sure this guy gets a bunkie," to which the Evening Watch SHU Officer in Charge replied, "All right." The Day Watch SHU Officer in Charge said that, at
+
+some point that day, it was likely that he also informed the Day Watch Operations Lieutenant, but he could not specifically recall if he had done so.
+
+The Day Watch SHU Officer in Charge told the OIG that a replacement cellmate should have been identified as soon as it was confirmed that Inmate 3 had left the institution. He said a new cellmate could have been reassigned before the 4:00 p.m. SHU count if it was known that Inmate 3 was not coming back, but the SHU staff members had until Epstein returned from his attorney visit to assign Epstein a new cellmate. According to the Day Watch SHU Officer in Charge, SHU staff definitely should have realized that Inmate 3 was not returning both during the 4:00 p.m. count and when Epstein returned from his attorney visit later that evening. The Day Watch SHU Officer in Charge told the OIG that Epstein's daily routine was that he would be with his attorneys in the attorney conference room until approximately 8:00 p.m., so SHU personnel had time to make a new cellmate assignment. He said all SHU staff members shared the responsibility to find a replacement cellmate and that anyone assigned to the SHU could have found another inmate to replace Inmate 3. However, he also said that due to Epstein's high profile, the SHU personnel should have asked a lieutenant to contact the Psychology Department to see which inmate should be placed with Epstein.
+
+On August 12, 2019, following Epstein's death, the Day Watch SHU Officer in Charge wrote a memorandum to the Warden stating, "On Friday August 9, 2019 at approximately 1:50 p.m., I S/O/S [the Day Watch SHU Officer in Charge] passed on to oncoming staff member [the Evening Watch SHU Officer in Charge] and present shift staff [Senior Officer Specialist 5] and [Correctional Officer 2] that Inmate [3] was going WAB [i.e., with all of his belongings] and possibly may not return. Also that Inmate Epstein #76318-054 will be needing a cell mate upon arrival from his attorney visit" The Day Watch SHU Officer in Charge departed the SHU at approximately 2:00 p.m. and worked an overtime shift as a driver for MCC New York. He stated that he did not follow up with the SHU staff to verify that Epstein had been assigned another cellmate.
+
+il lEM=1 the Day Watch SHU Officer in Charge, told the OIG that' knew stein was required to have a cellmate pursuant to the Psychology Department's determination. confirmed that everyone who regularly worked in the SHU knew of this requirement, and that it was the E responsibility of all SHU staff to notify a supervisor upon learning that Epstein needed to be assigned a new cellmate due to Inrnate 3's transfer to another prison. The Day Watch SHU Officer in Charge
+
+| | tou the OIG that | aware of Inmate 3's transfer and the need to |
+|-------------------------------|------------------|----------------------------------------------|
+| assign Epstein a new cellmate | | |
+
+in Charge told the OIG that he made a number of notifications,
+
+I
+
+the Day Watch SHU Officer
+
+the Day Watch
+
+SHU Officer in Charge told the OIG that SHU staff maintain a "cheat sheet," which lists the number of inmates believed to be in the SHU at any given time.
+
+When interviewed by the OIG, the Day Watch SHU Officer in Charge reviewed the 4:00 p.m. SHU count slip from August 9, 2019, which was signed by the Evening Watch SHU Officer in Charge and Correctional Officer Noel. Based on his review, the Day Watch SHU Officer in Charge told the OIG that the Evening Watch SHU Officer in Charge and Noel probably did not count the inmates in the SHU. He said they likely wrote down the numbers they thought should have been entered for the count because the count slip inaccurately included an inmate (Inmate 4) among the number of inmates in the SHU after that inmate had been transferred to another housing unit. According to what he told the OIG and wrote in an email on August 9, earlier that afternoon the Day Watch SHU Officer in Charge observed Inmate 4 attempt to retrieve an unknown item from his visitor in h MCC New YorkS ' • '
+
+According to
+
+the Day Watch SHU Officer in Charge, the inaccurate 4:00 p.m. count slip told him "that the count was not done and they just assumed and went by the cheat sheet because the body wasn't even there, l The Day Watch SHU Officer in
+
+Charge told the OIG that if the 4:00 p.m. SHU count had been accurately conducted, then the Evening Watch SHU Officer in Charge and the SHU staff should have realized that Inmate 4 was no longer in the SHU.
+
+The Day Watch SHU Officer in Charge told the OIG that SHU staff spoke about conducting rounds on Epstein
+
+every day. He said that the Warden, lieutenants, and other MCC New York staff members frequently told the SHU staff to conduct rounds and to keep an eye on Epstein. To reinforce this message, the Day Watch SHU Officer in Charge created a sign on orange paper that he hung on a computer in the SHU officers area that said, "MANADATORY [sic] ROUNDS MUST BE CONDUCTED EVERY 30 MINUTES ON EPSTEIN # 76318.054 AS PER GOD!!!!" The Day Watch SHU Officer in Charge said the sign was hangin on the com uter on Au ust 9 and 10, 2019, and it was clearly visible to everyone who worked in the SHU.
+
+### Figure 5.2: Sign Created by the Day Watch SHU Officer in Charge
+
+MANADATORY ROUNDS MUST BE CONDUCTED EVERY 30 MINUTES ON EPSTEIN #76318-054 AS PER GOD!!!!
+
+the Day Watch SHU Officer in Charge OIG that lieutenants should have walked down all of the SHU tiers when conducting a lieutenant told the nd in
+
+Limited Official Use Only—Not for Public Release
+
+The Day Watch SHU Officer in Charge told the O16 that at least five cell searches should be conducted on the day and night watch shifts within the SHU, and that cell searches are conducted in cells every time the inmate departs the cell. He said the SHU Officer in Charge was responsible for making sure the searches were conducted and logged into the BOP TRUSCOPE database. The Day Watch SHU Officer in Charge said that only one cell search was entered into TRUSCOPE on August 9, 2019, because cell searches were tedious to enter, and he was busy. He did not believe that it was a problem that only one cell search was logged on August 9, because he said the SHU staff would have gone into every cell when the inmates took their showers. He said that during the period of Epstein's custody, SHU inmates showered on Mondays, Wednesdays, and Fridays. The Day Watch SHU Officer in Charge said that during showers, SHU staff searched every cell. He explained that all of the SHU cells should have been searched on Friday, August 9 because it was a shower day. He said SHU staff should also conduct cell searches when inmates go to the recreation area or for attorney visits. According to the Day Watch SHU Officer in Charge, Epstein's cell should have been searched because both Epstein and Inmate 3 left the cell on the morning of August 9. He further stated that he believed that the majority of cells in the SHU were searched
+
+a Mil
+
+The Day Watch SHU Officer in Charge told the O16 that in August 2019, each inmate would have been authorized to have two sheets and one blanket. He said that in the winter, inmates are allowed to have an additional blanket. When interviewed by the OIG, the Day Watch SHU Officer in Charge reviewed a picture of Epstein's cell from August 10, 2019, after Epstein had been removed from the cell. The Day Watch SHU Officer in Charge said there appeared to be an excess number of linens and blankets in the cell, which he believed were for both Epstein and Inmate 3, and that there were possibly a couple of extra sheets as well. He noted that there were two mattresses in the cell and deduced that Inmate 3's assigned items had not yet been removed even though he had departed MCC New York earlier that day. According to the Day Watch SHU Officer in Charge, Inmate 3's items should have been removed as soon as the SHU staff knew Inmate 3 was not returning. He told the OIG that any extra linens or blankets should be removed when the inmates take showers and their cells are searched. He told the OIG that he believed the purpose of limiting the linens provided to the inmates was to ensure
+
+there was enough to go around and that it was more of an administrative matter rather than a security
+
+matter.
+
+On August 9, the Day Watch SHU Officer in Charge,
+
+were each assigned to the MCC New York SHU as their permanent quarterly assigned post and served as the SHU Officer in Charge during their respective shifts.S9 The OIG investigation found that each of these employees knew that Epstein was required to have a cellmate at all times per the Psychology Department's directive.
+
+### The OIG further found that on August 9 the Day Watch SHU Officer in Charge,
+
+became aware at various times during their respective shifts that Epstein's cellmate, Inmate 3, had been transferred from the institution with all of his belongings, a status known to all MCC New York staff members as meaning the inmate was being permanently transferred out of the institution. Specifically, the OIG investigation found that on the morning of August 9, the Day Watch SHU Officer in Chargear—r-a Ireviewed the MCC New York daily call out list, a document that identifies all inmates who were leaving their housing units each day, which listed Inmate 3 as being scheduled to depart MCC New York with all of his belongings.
+
+t he Day Watch SHU Officer in Charge escorted Epstein from the SHU to the attorney conference room fort daily meeting with his attorneys. 6° During the escort, the Day Watch SHU Officer in Char,,. • discussed the need to assign Epstein with a new cellmate due to Inmate 3's transfer.b1 I he Day Watch SHU Officer in Charge told the OIG that he notified his relief, the Evening Watch SHU
+
+Officer in Charge, of the need to assign Epstein a new cellmate, and that he likely notified an unspecified lieutenant. However, the OIG did not credit the Day Watch SHU Officer in Charge's account because no other witnesses or evidence confirmed that he had in fact passed on information regarding Epstein's need for a new cellmate, either to a supervisor or his relief.
+
+The OIG investigation concluded that on August 9, 2019, the Day Watch SHU Officer in Charge,
+
+failed to notify a supervisor as required after Epstein's ce mate was permanently removed from the MCC New York SHU, which constituted a violation of BOP standards of conduct. Additionally, their inaction violated MCC New York SHU Post Orders because n individuals documented the fact the Epstein needed a new cellmate as required. Finally, officers failed to exercise good judgment and common sense, as required by the SHU Post Orders, by not immediately undertaking steps through their chain-of-command to ensure that a high-profile inmate who had been released from suicide watch and psychological observation 10 days earlier had an appropriate cellmate.
+
+Continued
+
+| As discussed above, the Day Watch SHU Officer in Charge
to;ci
the OIG that they notified supervisory personnel regarding the need to assign Epstein a new cellmate.
Based on a lack of corroborating evidence for these as1 et 'ions, the OIG found that they lacked candor in
■
their OIG interviews in violation of BOP policy |
+|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| |
+| |
+| |
+| |
+
+is interview with the OIG, the Day Watch SHU Officer in Charge stated that multiple cell searches were conducted in the MCC New York SHU on August 9; however, the Day Watch SHU Officer in Charge stated that he failed to document the cell searches within the TRUSCOPE system as required because he was too busy with other duties. The Day Watch SHU Officer in Charge further stated that any of the SHU staff could have logged the cell searches into TRUSCOPE, but that it was primarily h SHU Officer in arge s responsibility to do so.
+
+The OIG found that on August 9, 2019, the Day Watch SHU Officer in Charge either failed to conduct the required cell searches or failed to document the cell searches that he conducted in the SHU,)
+
+Additionally, the OIG found that it was a performance failure for the Day Watch SHU
+
+Officer in Charge who served as the SHU Officer in
+
+Charge during their respective shifts on August 9 and 10, 2019, to have permitted Epstein to have an excessive amount of linens in his cell.
diff --git a/content-documents/ds8/de/EFTA00036169.md b/content-documents/ds8/de/EFTA00036169.md
new file mode 100644
index 0000000000000000000000000000000000000000..7ffe4c34bfa99ed23d66f6e79aced80a6f9781d4
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00036169.md
@@ -0,0 +1,43 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00036169)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00036169"
+ocrPages: 0
+ocrChars: 907
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| Amazon | |
+|--------|--|
+| | |
+
+### Message From Customer Service
+
+Hello
+
+This is Joey, the agent that talked to you earlier. I apologize for the inconvenience,
+
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+
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+
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+
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+
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+
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+
+### Amazon.com
+
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+
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+
+Your feedback is helping us build Earth's Most Customer-Centric Company.
diff --git a/content-documents/ds8/de/EFTA00036765.md b/content-documents/ds8/de/EFTA00036765.md
new file mode 100644
index 0000000000000000000000000000000000000000..28cb68315ae78a2bb25a7b45191b23f5141f2918
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00036765.md
@@ -0,0 +1,59 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00036765)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00036765"
+ocrPages: 0
+ocrChars: 1288
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+From: "UGG® "
+
+To: "UGG®" ,
+
+Subject: UGG + Eckhaus Latta
+
+Date: Thu, 15 Aug 2019 17:38:34 +0000
+
+### Importance: Normal
+
+
+
+Shop UGG.
+
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+
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+
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+
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diff --git a/content-documents/ds8/de/EFTA00036886.md b/content-documents/ds8/de/EFTA00036886.md
new file mode 100644
index 0000000000000000000000000000000000000000..61559ba75789eb1c6a0c7f4b4bcecda307f2ff79
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00036886.md
@@ -0,0 +1,23 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00036886)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00036886"
+ocrPages: 0
+ocrChars: 414
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+## Good morning,
+
+Thanks. I can only imagine. Take care.
+
+
+
+You don't know me, but I have some idea of what you are going through right now as the Exec and P1O. I was the PIO at was killed, so trust me when I say, I have a good idea of what you are going through when dealing with the media and union during this difficult situation and the information that is being shared. Stay strong!!
+
+Associate Warden (O) FCI
diff --git a/content-documents/ds8/de/EFTA00036960.md b/content-documents/ds8/de/EFTA00036960.md
new file mode 100644
index 0000000000000000000000000000000000000000..02d9d6358668550e266642e70a26885e3c19e3ce
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00036960.md
@@ -0,0 +1,17 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00036960)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00036960"
+ocrPages: 0
+ocrChars: 186
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+## Hello,
+
+I hope all is well with you and the gang. I need your help. I am looking for the checklist that you guys use when there is an outgoing bus. Can you send me a sample? Thanks.
diff --git a/content-documents/ds8/de/EFTA00038031.md b/content-documents/ds8/de/EFTA00038031.md
new file mode 100644
index 0000000000000000000000000000000000000000..fe0149527145a045731f6c32e23579d9ca09fb3d
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00038031.md
@@ -0,0 +1,31 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00038031)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00038031"
+ocrPages: 0
+ocrChars: 1629
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+### Case # 50D-NY-3027571
+
+FBI New York, in coordination with the Southern District of New York's United States Attorney's Office, has been investigating the sexual exploitation and abuse of minors committed by JEFFREY EPSTEIN. EPSTEIN was charged and arrested with sex trafficking and conspiracy in July 2019. In addition to EPSTEIN, co-conspirators have also been investigated, including GHISLAINE MAXWELL. MAXWELL assisted, facilitated, and contributed to EPSTEIN's abuse of minors by recruiting, grooming, and abusing minors they knew to be under the age of 18. MAXWELL was charged and arrested in July 2020 with enticement of a minor, transportation of a minor, conspiracy to entice a minor, conspiracy to transport a minor, and perjury.
+
+During the course of the investigation, a witness, date of birth who resides in London and is a UK citizen, has been identified to have information into the crimes committed by EPSTEIN and MAXWELL. is represented by counsel, JILL GREENFIELD, and has readily and voluntarily agreed to speak with the FBI. FBI agents, along with Assistant United States Attorneys, intend to travel to the UK to interview with her counsel present. expressed that all communication should be coordinated through counsel. GREENFIELD's information is as follows:
+
+| Jill Greenfield | | |
+|-----------------|--|--|
+| Fieldfisher LLP | | |
+| Email | | |
+| | | |
+| M: | | |
+| | | |
+
+Legal London (ALAT concurs with this travel and is currently working to assist FBI New York in arranging this travel and interview.
+
+Names of FBI NY travelers:
diff --git a/content-documents/ds8/de/EFTA00038250.md b/content-documents/ds8/de/EFTA00038250.md
new file mode 100644
index 0000000000000000000000000000000000000000..302186422b53f2b76e441eb3dcf5a6b699c003e6
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00038250.md
@@ -0,0 +1,35 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00038250)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00038250"
+ocrPages: 0
+ocrChars: 1006
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From: |
+|-----------------------------------------------------------------------|
+| |
+| Subject: Fw: 20-cv-01527 - Clemente v. FBI -- Epstein FOIA Litigation |
+| Date: Mon, 16 Nov 2020 15:59:49 +0000 |
+| Importance: High |
+| Attachments: 163G.pdf |
+
+Including this one along with the 9A-NY file.
+
+Thank you!
+
+
+
+
+
+The attached processed document is responsive to an ongoing FOIA litigation on subject Jeffrey Epstein. We have reviewed and processed for release. The upcoming release date is next Monday. The file this document was pulled from is a closed file, but we wanted to double check that if released, this document would not impact any ongoing investigations, that you are aware of.
+
+Thank you,
+
+FBI IMD - Litigation Support Unit.
diff --git a/content-documents/ds8/de/EFTA00038412.md b/content-documents/ds8/de/EFTA00038412.md
new file mode 100644
index 0000000000000000000000000000000000000000..b2f747eba1200b3b2b164fea3128f6936265e661
--- /dev/null
+++ b/content-documents/ds8/de/EFTA00038412.md
@@ -0,0 +1,35 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00038412)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00038412"
+ocrPages: 0
+ocrChars: 1543
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From: ' |
+|------------------------------------------------------------|
+| '
To: |
+| Cc: "la |
+| Subject: Fwd: Epstein victims therapy resources in Florida |
+| Date: Wed, 13 May 2020 20:27:43 +0000 |
+| Importance: Normal |
+| |
+| - see below. Do you know who she is? |
+| Forwarded messa ge |
+| From: |
+| Date: May 13, 2020 12:25 PM |
+| resources in Florida
Subject: E stein victims theca |
+| To:" |
+| Cc: |
+
+I am working on some of the Jeffrey Epstein matters with ' office. I have a couple of clients in South Florida that are in serious need of some counseling resources and I understand from that the FBI has made some options available to those in NY, including to one of our other clients in The City.
+
+Would you be able to provide me with information about the options available to those who are still living in the West Palm Beach area? Or could you direct me to a counterpart in that office who could assist me? Any assistance you can provide would be greatly appreciated. Thank you.
+
+Of Counsel
diff --git a/content-documents/ds8/df/EFTA00009976.md b/content-documents/ds8/df/EFTA00009976.md
new file mode 100644
index 0000000000000000000000000000000000000000..557aef3fee1c63a89b17d997c199dc11eaa97f03
--- /dev/null
+++ b/content-documents/ds8/df/EFTA00009976.md
@@ -0,0 +1,64 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00009976)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00009976"
+ocrPages: 0
+ocrChars: 4799
+ocrElapsed: 0.0
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From: | |
+|--------------------|-------------------------------------------------------------------------------------------|
+| To: | |
+| Cc: | |
+| | Subject: Re: Jeffrey Epstein: About the sex trafficking case & accusations I Miami Herald |
+| | Date: Sat, 01 Dec 2018 01:27:08 +0000 |
+| Importance: Normal | |
+
+Great! Would be happy to add another investigation if there's something.
+
+| > On Nov 30, 2018, at 8:22 PM,
wrote: |
+|-----------------------------------------------------------------------------------------------|
+| |
+| > May have something else for you |
+| |
+| >
Original Message |
+| > From: |
+| > Sent: Fla, .l.
oven
er
PM |
+| > To |
+| > Cc |
+| > Subject: Re: Jeffrey Epstein: About the sex trafficking case & accusations I Miami Herald |
+| |
+| > No problem, sounds like an interesting case! |
+| |
+| >> On Nov 30, 2018, at 7:58 PM,
wrote: |
+| >> |
+| I fear it is. Sony!
» |
+| >> |
+| >> Sent from my iPhone |
+| |
+| >>> On Nov 30, 2018, at 7:11 PM,
wrote: |
+| >» |
+| |
+| |
+| >» Is it staffed already? |
+| >» |
+| >>>
Ori inal Messa e |
+| >» From: |
+| >>> Sent: Friday, November 30, 2018 7:06 PM |
+| >» To: |
+| >» Cc: |
+| >>> Subject: Re: Jeffrey Epstein: About the sex trafficking case & accusations I Miami Herald |
+| >» |
+| >» Yes. As of today. On the d/l for now. |
+| >» |
+| >» Sent from my iPhone |
+| >» |
+| »»
On Nov 30, 2018, at 6:56 PM,
wrote: |
+| >>» |
+| »»
Are we open on this? Can we be?
>>» |
diff --git a/content-documents/ds8/df/EFTA00011363.md b/content-documents/ds8/df/EFTA00011363.md
new file mode 100644
index 0000000000000000000000000000000000000000..49550e6293b37eebf944a0dfe5dc4bb596678675
--- /dev/null
+++ b/content-documents/ds8/df/EFTA00011363.md
@@ -0,0 +1,35 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00011363)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00011363"
+ocrPages: 2
+ocrChars: 2010
+ocrElapsed: 0.8
+parseTier: "internal"
+engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
+---
+
+| From: Sigrid McCawley | | |
+|------------------------------------------------|---|
+| To:" | > |
+| Subject: FW: GM vs. Estate | |
+| Date: Wed, 18 Mar 2020 15:32:08 -4)000 | |
+
+Attachments: sean.pdf; ATT0000I.htm
+
+Hello - I just received this from a reporter. It is an indemnification action filed in USVI by Maxwell. It contains statements that are directly contradictory to Maxwell's previous sworn depositions including that Epstein was not assisting in any of her legal bills and she didn't receive anything of value from him etc. and it also references correspondence that she never produced in that case and lists companies that she was apparently employed by.
+
+I am still reviewing but I wanted to get it to you quickly. Looks like ABC is doing a story on it.
+
+Sigrid McCawley Partner BOIES SCHILLER FLEXNER LLP Fort Lauderdale. FL. 33301 (I) (n)
+
+www.bsfllp.com
+
+From: Hill, James E. [mailto: Sent: Wednesday, March 18, 2020 11:12 AM To: Sigrid McCawley Subject: GM vs. Estate
+
+CAUTION: External email. Please do not respond to or click on links/attachments unless you recognize the sender.
+
+The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) 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. Iv 1 082018318SF)
diff --git a/content-documents/ds8/df/EFTA00014178.md b/content-documents/ds8/df/EFTA00014178.md
new file mode 100644
index 0000000000000000000000000000000000000000..cec1c3780e2b0ec3919c4db2e2ea1e1431505d68
--- /dev/null
+++ b/content-documents/ds8/df/EFTA00014178.md
@@ -0,0 +1,77 @@
+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00014178)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
+eftaNumber: "EFTA00014178"
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+ROY BLACK HOWARD M. SREBNICK Saint A. KORNSPAN LARRY A. STUMPF MARIA NEYRA JACKIE PERCZEK MARK A.J. SHARRO JARED LOPEZ
+
+
+
+JESSICA FONSECA-NADER KATHLEEN P. Minns AARON ANTHON MARCOS BEATON, JR. MATDIEW P. O'BRIEN JENIPER J. SOULIKIAS NOAH Fox
+
+E-Mail:
+
+December 9, 2009
+
+Assistant United States Attorney United States Attorney's Office Southern District of Florida 500 South Australian Avenue Suite 400 West Palm Beach, Florida 33401
+
+### RE: Jeffrey Epstein
+
+Dear=
+
+You emailed me a letter on November 2, asking whether Jeffrey Epstein's place of employment remained constant. It has. I reviewed a Google map to confirm that the distance between that place of employment and the location where he was stopped by Palm Beach Police is less than 3 miles (and that the location where he was walking was on a direct mute to his place of work).
+
+It has taken us a while to respond to your letter because other matters have consumed our time and effort. Over the past five weeks, the massive billion-dollar conspiracy created and run by Scott Rothstein has been exposed. On Monday, Mr. Epstein filed a state civil RICO lawsuit charging Rothstein, his partner Brad Edwards, and others with tortuous and fraudulent abuses of process that resulted in serious injury to Mr. Epstein. A copy of the Complaint is enclosed with this letter.
+
+As ou know, Rothstein's firm represents and
+
+three of the plaintiffs who have brought civil actions against Mr. Epstein. The Rothstein firm was a criminal enterprise that used the litigation against Mr. Epstein to lure investors into its billion-dollar ponzi scheme. We believe that Rothstein and his co-conspirators used the government's criminal investigation as a means to perpetrate and further their fraud. For example:
+
+201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 • Phone: 305-371.6421 • Fax: 30S-358.2006 • whw.RoyBlack.eom
+
+December 9, 2009 Page 2
+
+1. The Rothstein lawyers sought disclosure of the NPA to prove who the victims were, and used the NPA to "corroborate" their false claims.
+
+2. Rothstein and his co-conspirators abused the legal process in other cases. They forged the signature of judges, and even forged an Eleventh Circuit opinion.
+
+3. Rothstein lawyers demanded phony protective orders.
+
+4. In our case, they sought discovery of Epstein's plane logs to fish for celebrities to extort and convince investors that huge amounts of settlement money was available from them.
+
+5. Rothstein lawyers litigated claims using Jane Doe names to make the phony settlements appear plausible to investors, and also to prevent any investigation into the claims by the investors.
+
+6. Rothstein and others told investors that your office directed the women to the Rothstein firm.
+
+7. Rothstein and his co-conspirators gathered information illegally, and shared it with the other plaintiffs' attorneys in this case.
+
+8. Rothstein deceived investors into believing that he had the confidential victim list you prepared, and that he had a copy of the NPA.
+
+9. Rothstein told investors that his investigators had sophisticated electronic bugging equipment to gather evidence against Epstein.
+
+10. Rothstein told investors that Epstein had offered to settle the cases for \$200 million, when there have been no such discussions about any settlement at any price.
+
+And it does not stop there. Rothstein, his partners, and his employees investigated and litigated the M, and cases with funds derived from their criminal enterprise and their fraud and misrepresentations to investors. But we have been stymied from debunking fraudulent claims brought by the Rothstein criminal enterprise because you have threatened that such action on
+
+December 9, 2009 Page 3
+
+our part would constitute a breach of the NPA. So the Rothstein lawyers, once again, are using the power of the federal government to perpetrate and further their fraud. And the expense of litigating these cases has been extreme. For example, who I do not believe was aware of the Rothstein crimes, is now demanding over \$2 million in legal fees.
+
+As a lawsuit brought by some of the investors' claims, Rothstein and his partner Edwards used Jeffrey Epstein as bait. The litigation strategy, media pronouncements, and investigatory initiatives of Rothstein and Edwards were calculated to support Rothstein's deceptions rather than to advance the position of his clients. I bring these facts to your attention so that if you had contact with Edwards or those associated with him in the past concerning Mr. Epstein, you consider not continuing communications with any of them in the future.
+
+I would like a short conference with you in person to talk about Mr. Epstein's progress through the state criminal justice system, to discuss several outstanding issues that I want to make sure you have accurate information about, and, from my perspective, most importantly, so that I can provide Mr. Epstein with proper counsel going forward. If you email me some dates when you are available this month, we can schedule a short meeting in your office hopefully before the year ends.
+
+Roy Black
+
+RB/wg
+
+Enclosure
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+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00014376)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
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+
+| From | |
+|---------------------------------------|--|
+| To | |
+| Subject | |
+| Date: Mon, 26 Aug 2019 21:24:15 +0000 | |
+
+I am currently on trial before the Honorable Ronnie Abrams. I will be checking email at the ' ed immediate assistance in connect" " " Cr. 490 (RMB), please contact AUS For all other matters, please contact AUSA Thank you.
diff --git a/content-documents/ds8/df/EFTA00014576.md b/content-documents/ds8/df/EFTA00014576.md
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+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00014576)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
+category: "DOJ Data Set"
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+
+## MARTIN G. WEINBERG, P.C. ATTORNEY AT LAW
+
+EMAIL ADDRESSES:
+
+
+
+August 1, 2019
+
+By Electronic Mail
+
+
+
+Assistant United States Attorneys U.S. Attorney's Office for the Southern District of New York One St. Andrew's Plaza New York, New York 10007
+
+- Re: United States v. Jeffrey Epstein, No. 19-cr-00490 Supplement to Defendant's First Request for Discovery
+De
+
+We write to supplement our first request for discovery that was electronically mailed to you on July 26, 2019 that sought the preservation and production of documents relating to the NPA and issues arising from the NPA. We wanted to particularize certain requests that were applicable to the United States Attorney's Office (hereinafter "USAO") for Southern District of Florida and the FBI Office that were working with them as follows:
+
+To request that AUSA who was the lead prosecutor investigating Mr. Epstein in 2006-8 produce or in the alternative agree to preserve any and all documents, communications whether emails from any and all email accounts from which she was sending or receiving relevant emails, texts, letters, papers, voice messages, tapes or any other information that:
+
+- I. Relate to any investigation and any interviews conducted by the USAO for the Southern District of Florida and/or the USAO for the Southern District of New York and FBI agents from either or both offices in 2008 in and around New York City, includin but not limited to an interview of a with , any other potential witness, and/or communications and any other
+representative of any USAO for the Southern District of New York between January I — June 30 2008. This request includes any communications prior to or during AUSA March 2008 trip to New York and any communications that resulted from the trip.
+
+- 2. Relate to her communications with her victim witnesses either directly or through their counsel wherein she discussed their right to confer with a USAO other than the Southern District of Florida.
+- 3. Relate to any communications with the USAO for the Southern District of New York or FBI agents working with them at any time from 2007-2019.
+- 4. Relate to the providing of any investigatory information or evidence to the USAO for the Southern District of New York or FBI agents working with them at any time from 2007-2019.
+
+Very truly yours,
+
+Reid Weingarten Michael Miller Ste toe & Johnson LLP Martin G. Weinberg Martin G. Weinber P.C.
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+---
+title: "DOJ Epstein Files, Data Set 8 (EFTA00015770)"
+source: "DOJ Epstein Files, Data Set 8"
+sourceUrl: "https://www.justice.gov/epstein"
+date: "2026-01-01"
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+---
+
+| From: Christian Everdell |
+|-----------------------------------------------------------------------------------------------------------------------------------|
+| To: 'Laura lvlenninuer' , " |
+| |
+| (USANYS)" |
+| Cc: Jeff Pagliuca ,13OBB1 C STERNHEIM'
|
+| Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential
materials, scenes |
+| Date: Thu, 08 Apr 2021 21:05:54 +0000 |
+| Inline-Images: image001.jpg |
+| |
+| |
+| |
+| I plan to arrive at the warehouse on April 12 with an investigator and a paralegal at around 9:30am. Does that work? |
+| Thanks, |
+| Chris |
+| From: Laura Menninger [mailto:lmenninger@hmflaw.com] |
+| Sent: Wednesday, April 07, 20214:23 PM
To: 1
);
(USANYS) |
+| Cc: Jeff Pagliuca; Christian Everdell; 'BOBBI C STERNHEIMI |
+| Subject: RE: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential materials, scenes |
+| |
+| |
+
+My apologies, I meant to include in my previous email that we could have the Bronx view on Monday April 12. Thank you for the logistics.
+
+Regarding the spreadsheets you provided, I have several issues.
+
+First, there are a couple of items that you have noted for the Bronx Warehouse but will in fact need to be brought to 500 Pearl for review because you labeled them as "Highly Confidential" and not "bulky." These appear to include:
+
+NY Evidence List
+
+- Items 16127-130 (4 boxes).
+- Item 1B13 (1 box)
+
+Florida Evidence List
+
+- Item 1, Subitem 26 one large framed photo from Master Bedroom.
+Second, with regard to the "Bulky" photos (Florida Items 1, Subitems 8, 15a, 15b and 15c), are we permitted to photograph those or not? If not, we will need them transported to 500 Pearl.
+
+Third, Florida Item 8, Subitem 8, says it is Sixteen DVD-R Discs from PBSO but you do not indicate that we can review those. Why? We need to address with the Court promptly any issues related to our request to view all evidence.
+
+Fourth, Electronic surveillance — Your email yesterday stated that these were all "electronic files" with no corresponding physical item. However, for several, the chart indicates "Blu-Ray Disks;" is there a reason we cannot inspect these? Another Florida item is listed as "one original recording of an interview dated 4/24/07"; I am suspicious that "one original recording of an interview" is not truly only an "electronic" file? I was practicing law in 2007 and do not recall "electronic files" being the standard then. Can you please confirm? I know that Chris has written separately about the many files for which the metadata has apparently been stripped, so we will have to address purely electronic information at another date.
+
+Shredded Paper — Yes, we need to review that as well.
+
+"Missing from Assigned Box" items — can you please provide more of an explanation for all "missing items"?
+
+I will let you know any other issues as I see them. However, now that we have made travel plans in reliance on your agreement to produce all evidence items, I am hoping that you can promptly answer these questions so that we can resolve any of them as needed this week.
+
+Thank you, -Laura
+
+Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. 150 E. 10th Avenue I Denver, CO 80203 +I 303 831 7364 (Office) Imenninger(ulnflawcorn
+
+| From:
< |
+|---------------------------------------------------------------------------------------------------------------------------------------------|
+| Sent: Wednesday, April 7, 2021 1:44 PM |
+| To: Laura Menninger ; |
+| (USANYS) |
+| Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengressercom) |
+| ; 'BOBBI C STERNHEIM' |
+
+Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
+
+Hi Laura,
+
+The Bronx warehouse is located at 2350 Lafayette Ave, Bronx, NY. There is plenty of street parking outside of the building. Whatever day you wish to have the review conducted at the warehouse, an AUSA and an agent will meet the attorney, investigator, and paralegal at the warehouse to escort them into the building to the evidence review room. The AUSA will remain present at the warehouse to answer any questions that may arise.
+
+The FBI has informed me that they can make the evidence available for review at the warehouse any day next week or the week of April 19th. Please just let me know what day you prefer, and we will coordinate with the FBI to arrange for the review.
+
+Best,
+
+Assistant United States Attorney Southern District of New York St. Andrew's Plaza New York, NY 10007
+
+| From: Laura Menninger
Sent: Wednesday, April 7, 2021 3:30 PM |
+|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| >;
To:
(USANYS) |
+| Cc: Jeff Pagliuca • Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
. 'BOBBI C STERNHEIM' |
+| Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes |
+| Thank you for the updated spreadsheets and the information regarding the timing of the review at 500 Pearl. |
+| I believe we will be able to have an attorney, investigator and paralegal present at the Bronx warehouse to take photos of
the "excluded from transportation" items. Please let us know the particulars for that visit when you have a moment. |
+| Thank you,
Laura |
+| Laura A. Henninger I Partner
Haddon, Morgan & Foreman, P.C.
150 E. 10th Avenue I Denver, CO 80203
+I 303 831 7364 (Office)
Imenninger@hrnflaw.com |
+
+| From: |
+|---------------------------------------------------------------------------------------------------------------------------------------------|
+| Sent: Wednesday, April 7, 2021 10:06 AM |
+| To: Laura Menninger ; |
+| (USANYS) |
+| Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
Cc: Jeff Pagliuca • |
+| 'BOBBI C STERNHEIM'
ceverdell@cohengresseccom>. |
+| Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes |
+
+Good morning,
+
+Attached please find the revised spreadsheets, which reflect designations under the Protective Order for the three mini-VHS tapes that I referenced below.
+
+I learned this morning that the Marshals intend to bring Ms. Maxwell back to the MDC each review day at 4:30pm. So we can plan for the review to take place at 500 Pearl Street from 9:30am to 4:30pm each day beginning on April 13th.
+
+Best,
+
+Assistant United States Attorney Southern District of New York St. Andrew's Plaza New York, NY 10007
+
+#### From:
+
+Sent: Wednesday, April 7, 2021 12:09 AM
+
+To: 'Laura Menninger' < =';
+
+(USANYS) Cc: 'Jeff Pagliuca' ipagliuca@hmflaw.com>• 'Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com). • 'BOBBI C STERNHEIM'
+
+Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
+
+Good evening,
+
+Today, the Marshals confirmed that they will produce Ms. Maxwell to 500 Pearl Street on April 13, 2021 and every day thereafter until the evidence review is complete. My understanding is that Ms. Maxwell should arrive to 500 Pearl Street
+
+at approximately 9:30am each morning. So we are confirmed for evidence review in the proffer rooms on the 5th floor of the 500 Pearl Street courthouse beginning at 9:30am on April 13th. I will plan to be present and to continue assisting with logistics. If any questions or concerns arise, please feel free to call my cellphone at
+
+To assist in preparing for this review, attached please find annotated versions of the three evidence spreadsheets I previously emailed to you: (1) a spreadsheet of New York evidence; (2) a spreadsheet of Florida evidence; and (3) a more detailed spreadsheet of the sub-items contained in the Florida evidence spreadsheet. A couple things to note:
+
+- These spreadsheets now indicate the Protective Order designation, if any, for each item to be reviewed. As you will see, there are three mini-VHS tapes that I need to double check before assigning a final designation. I expect to be able to access a mini-VHS cassette player later this week, at which point I will be able to provide an updated spreadsheet with a confirmed designation for those three items. Additionally, please note that there is one item about which we plan to provide you with a letter later this week.
+- These spreadsheets also indicate where each item will be made available for the defense to review. As you will see, we have now learned that one item (consisting of shredded paper) is currently at FBI headquarters and will not be available for review next week. Please let me know if you believe you need to review that item, and I will inquire as to whether and how it can be relocated to New York. Additionally, all 1D items consist of electronic data (as opposed to 1B items, which are physical items). As is noted in the spreadsheets, the electronic data that constitute the 1D items in this case have either already been produced to you in discovery (e.g., pen register data, CPS data, and aerial footage), or are digital recordings of interviews that will be produced as non-testifying witness statements. Because these 1D items are data files stored in the FBI system, there is no corresponding physical item to produce for you to review.
+
+Please let me know when you would like to schedule a time for a smaller group from the defense team to review evidence at the Bronx warehouse.
+
+Best,
+
+Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007
+
+From: Sent: Monday, April 5, 2021 10:48 PM To: Laura Menninger • 1S;
+
+## (USANYS)
+
+Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) • 'BONI C STERNHEIM' Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
+
+## Laura,
+
+Thank you for your email and for your understanding as we work through the logistics of arranging this review. Your modifications and clarifications are acceptable to us. Below I address each specifically:
+
+- The FBI can arrange for a lawyer, investigator, and paralegal to inspect and photograph the precluded items at the Bronx warehouse either next week or the week after. Please let us know what day you would like to arrange for that inspection, and I will coordinate with the FBI accordingly. I would suggest trying to schedule this visit early next week if possible so that if there are items that you believe need to be produced to 500 Pearl Street, we will have time to do so during a subsequent day of review at 500 Pearl if the FBI agrees to transport the item(s).
+- Tomorrow, I will send you evidence spreadsheets with annotations of which items the FBI will not be producing to 500 Pearl Street, and which items we are designating under the Protective Order. Please note that certain items will be designated "Confidential," in which case they may be photographed, but the photographs should be treated as Confidential under the Protective Order. Other items will be designated "Highly Confidential," in which case they may not be photographed, absent specific authorization from an AUSA. I note the possibility of authorization to photograph this latter category because some Highly Confidential evidence items include both nude and non-nude portions, in which case we would permit photography of the non-nude portions.
+- In light of our decision to produce non-testifying witness statements beginning on April 12, 2021, we are no longer segregating any electronic media that contain witness statements during this review. This is because all of the witness statements on the electronic media in the FBI's possession are from witnesses whom the Government does not expect to call at trial in this case. Please note that we intend to produce digital audio files to you containing the contents of the electronic media with these non-testifying witness statements, but you are of course welcome to review the original recordings themselves.
+- In terms of space, I have been informed that we will not be permitted to conduct this review in a courtroom and will instead be required to do so in the proffer rooms. I have reserved the two largest proffer rooms available at 500 Pearl. We can use the largest proffer room for evidence review, and the slightly smaller proffer room as a private meeting space for the defense team.
+- Confirmed, I will ask the FBI to bring all electronic highly confidential images to 500 Pearl Street, including the 2,100 that were not previously reviewed and the electronic images that were previously provided for review at the MDC.
+- Confirmed, I will ask the FBI to bring the 7 hard-copy highly confidential materials to 500 Pearl Street.
+
+As I mentioned earlier today in a separate email, the FBI and AUSAs are prepared to facilitate this review beginning April 13thand continuing every day thereafter until your review is complete. I have also formally requested that the Marshals produce Ms. Maxwell to 500 Pearl Street on April 13th and every day thereafter until the review is complete. The Marshals previously confirmed their willingness to produce Ms. Maxwell for such a review in general, but they have not yet confirmed their ability to do so on any particular dates. I will let you know as soon as the Marshals inform me whether they can accommodate these specific dates.
+
+## Best,
+
+Assistant United States Attorney Southern District of New York 1 St. Andrew% Plaza New York, NY 10007
+
+| From: Laura Menninger |
+|---------------------------------------------------------------------------------------------------------------------------------------------|
+| Sent: Friday, April 2, 2021 5:36 PM |
+| ) ca;
>;
To: |
+| (USANYS) < |
+| Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
Cc: Jeff Pagliuca ; |
+| .
'BOBBI C STERNHEIM' |
+
+Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
+
+Thank you for your email. Your proposal is largely acceptable to us, with the following modifications and clarifications.
+
+- For the items that you propose below to exclude from the evidence transported to 500 Pearl Street (with the exception of the cash held at 26 Federal Plaza), we will need to have access for a lawyer, investigator and paralegal to inspect and photograph those items at the Bronx warehouse. This seems to include the bulky items, electronic devices and "fragile" items.
+ - o Once they are photographed and shared with the team and our client, we can decide whether a separate inspection by our client and/or any expert is necessary at a later time. To be clear, the government's photos of these same items are insufficient.
+ - o If there are any items we are not permitted to photograph (and perhaps you will be able to tell us by April 5 which those are), we likely will need to have those transported because there is no way for our client to inspect the evidence. We can wait to finalize this issue until you have finished deciding what items you consider non-photographable, and if we can't agree, then discuss next steps.
+ - o Please let us know when these "non-transportable" items can be inspected and photographed at the Bronx warehouse. It makes sense that it would be done soon so that we can raise any issues as necessary with the Court.
+- For playing any of the electronic media, we will obtain the necessary equipment to play at 500 Pearl Street and seek permission to bring those devices into the Courthouse. You can segregate out the section of recordings that contain "witness statements" and advise us then which ones cannot be played, but we still need to inspect the outside of those recordings.
+- As far as space, can you please advise whether the largest proffer room will be available for review of evidence? It is my understanding that it can accommodate a large number of the team members at one time. If not, is a locked courtroom available for us to review the evidence? The agents could bring out a limited number of boxes at a time for inspection.
+- We understand that the evidence will not be taken outside of the monitoring of the agents or your staff and appreciate that you will have a separate room for us to consult with our client privately (without the evidence).
+- We understand that all of the highly confidential materials, including not only the 2,100 images not previously disclosed as well as the electronic images that were only shown to NY counsel and the client at the MDC, will be available for review on a singular laptop at 500 Pearl Street.
+- We also understand the 7 hard-copy highly confidential materials will also be available for inspection at 500 Pearl Street.
+
+Please let me know if you have any questions or disagree with my understanding. If you agree, we can then proceed as scheduled on April 12 and continue day to day until we are finished, with a break if necessary for the arraignment.
+
+Laura A. Menninger I Partner Haddon, Morgan & Foreman, P.C. 150 E. 10th Avenue I Denver, CO 80203 +I 303 831 7364 (Office) Imenninger(alnflaw.com
+
+#### From:
+
+Sent: Saturday, March 27, 2021 4:38 PM To: Laura Menninger • (USANYS)
+
+<
+
+Cc: Jeff Pagliuca • Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) ceverdell@cohengresser.com>. 'BOBBI C STERNHEIM'
+
+Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
+
+## Counsel,
+
+Thank you for your email. Below please find our response. If this is acceptable to you, then we will proceed with arranging the logistics of having your client produced to 500 Pearl the week of April 12th and the week April 19th. We will also arrange for the FBI to transport evidence to 500 Pearl for review the week of April 12th.
+
+## Physical Evidence
+
+- It is not reasonable or feasible to insist that the FBI bring all physical evidence to 500 Pearl Street. That said, we are certainly willing to work with you to ensure that your client can review any physical items that are material to the preparation of her defense.
+- We would propose excluding the below items from production to 500 Pearl:
+ - o We appreciate your note that the massage tables are not needed, which will certainly help with the logistics of transport.
+ - o We also appreciate your indication that the cash items from 26 Federal Plaza do not need to be produced. Those are the only items not located in the Bronx warehouse.
+ - o The FBI has seized dozens of electronic devices, including desktop computers, servers, and laptops, from Jeffrey Epstein's residences in 2019. Photographs of those devices were produced in our August 2020 productions as part of the search warrant photographs, and you have received copies of the data that was seized from those devices pursuant to a warrant. The production of these devices would be very cumbersome, and we do not see any value in looking at an electronic device that cannot be turned on.
+ - o The framed pictures are bulky and cumbersome to transport. These are also very delicate and are difficult to transport. Photographs of those seized images were already provided to you as part of the photographs from the searches of Epstein's residences.
+ - o Certain items seized from the New York residence are bulky, fragile, and/or difficult to transport. These include plaster busts of female torsos and a stuffed dog. Photographs of these items were already provided to you from the search of the New York residence.
+- The remaining physical items of evidence would fit into approximately 15 to 20 boxes. The FBI has indicated that it would be feasible to transport those boxes to 500 Pearl Street.
+- Regarding your request for equipment that can play the recordings, we believe they would require a VCR, a cassette player, a CD player, an adapter for a micro VHS tape, and a microcassette player. If you wish to play these recordings at 500 Pearl, you will need to provide that equipment. We have asked the FBI whether any other equipment would be necessary and will let you know if that is the case prior to the date of your review. It is our understanding that any recordings that are not witness statements and that are not highly confidential have been produced to you in discovery. We are not aware of any discoverable, non-highly confidential, recordings that were not produced to you as part of the Government's discovery productions in the fall. To confirm that understanding, we are working with the FBI to physically doublecheck each recording. If we identify any discoverable recordings that have not already been produced, we will promptly provide them to you.
+- The segregation of highly confidential material will require the FBI and an AUSA to physically review each item to confirm the item's status. We will endeavor to do so by your requested date of April 5, 2021.
+- We can confirm that neither the AUSA(s) nor the agent(s) will record or attempt to record any part of the evidence review or conversations among the defense team or with the defendant during this review. Although the evidence cannot be left outside of the presence of an agent, we will ensure that a room is available for the defense team and the defendant to confer privately away from the agent(s) and the AUSA(s) without monitoring.
+- As for your request for a space large enough to fit 8 members of the defense team, the defendant, an agent, an AUSA, and the evidence, my office cannot control the space that the Marshals allow us to use at 500 Pearl outside of the proffer rooms. We will certainly request as large a space as possible, but if we are required to use the proffer rooms, then members of the defense team may need to rotate in and out of the room. I know members of the defense team have been in those proffer rooms before, and they can hopefully provide some thoughts on how we might use the proffer room space effectively for your purposes. If the Court grants authorization for the defense to bring electronic devices into 500 Pearl, that is certainly fine with the Government, and you may note our consent in your request to Judge Nathan for such authorization.
+
+# Highly Confidential Electronic Images
+
+- . The 2,100 electronic images were recovered during the responsiveness review of images and videos seized from Jeffrey Epstein's devices, which review was not complete until early November 2020. We indicated on page 4 the cover letter to our November 9, 2020 production, which included all other images and videos from those devices, that "the Federal Bureau of Investigation ('FBI') seized multiple nude and partially nude images from several for the above-listed electronic devices. All such images have been designated Highly Confidential. The FBI will make these images available for review by the defense upon request." We did not receive a request from the defense to review these images until your March 8, 2021 letter, which requested to "view and inspect all materials designated by your office as 'Highly Confidential' under the terms of the Protective Order".
+- We did not ask the FBI to bring the 7 hard copy images to the MDC in the fall because we did not understand you to be requesting a review of physical, non-electronic evidence during those meetings. Our understanding of the defense request at that time was to review the electronic highly confidential images that were recovered from CDs from Epstein's residence. We will ensure that the 7 hard copy images are available to you for review at 500 Pearl.
+
+# Best,
+
+Assistant United States Attorney Southern District of New York 1 St. Andrew% Plaza New York, NY 10007
+
+From: Laura Menninger Sent: Monday, March 22, 2021 5:19 PM
+
+To: ) ; )
+
+Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) • 'BOBBI C STERNHEIM'
+
+Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
+
+All,
+
+We have considered your proposal. Unfortunately, it does not permit us an adequate ability to review the evidence in the case and does not permit our client to meaningfully participate in her own defense.
+
+First, we are unable to meaningfully review the evidence without the benefit of our laptops and other electronic devices which are needed to take notes of our review. We also need access to our devices during the review to compare the physical evidence with the electronic discovery and with our work product.
+
+Second, we need to provide our client the ability to review all discovery, including any recordings, in order to assist in her own defense. Presuming that she will not be taken to the FBI downtown office, then your proposal offers no means by which she can both inspect a recording in its physical form and listen to the recording at the same time.
+
+In order to address the deficiencies in your proposal, we believe the following are necessary:
+
+# Physical Evidence
+
+- All of the physical evidence currently located in the FBI Bronx warehouse will be transported to 500 Pearl Street and made available during the week of April 12, with our client present, in a room sufficiently large to accommodate 8 attorneys and investigators.
+ - o We do not need the "bulky" massage tables transported; if there are any other extremely large evidence pieces, let us know what they are and we can consider whether we can have someone review and photograph those at the Bronx warehouse at an earlier time.
+ - o From your email, it appears that only two items are not located at the Bronx warehouse both envelopes with cash. Please confirm this. We do not need the two "cash" evidence items transported to 500 Pearl.
+ - o If there are other evidence items housed somewhere other than the Bronx, please let us know what they are and where they are.
+- We will be permitted to bring our laptops, and a camera, into 500 Pearl Street; we are happy to seek permission from Judge Nathan to do so.
+- Either the FBI can provide the equipment necessary to listen to any of the recordings at 500 Pearl Street or we can bring the necessary equipment. If we are to provide the equipment, we will need to know in advance the formats of each recording so that we can be prepared. You can note that on your Excel spreadsheet by the item number by March 29 to give us adequate time to secure the necessary equipment.
+- The FBI can segregate any physical evidence that you deem "highly confidential." You can identify any "highly confidential" physical evidence items on your Excel spreadsheets by April 5 (one week before the evidence view). If we need to photograph or reproduce any such item for expert evaluation, we will seek leave of court. Otherwise, we will not photograph any such items during the review during the week of April 12. This will ensure the evidence review proceeds smoothly and there will not be any need to ask permission to photograph on an item by item basis.
+- The FBI also can segregate any recordings which we will be able to inspect, but not listen to, during the evidence view the week of April 12. You can note such designation on your Excel spreadsheet. If we disagree, we can seek leave of the Court in advance.
+- We understand that an FBI Agent and/or AUSA may be present during our physical evidence review at 500 Pearl Street but of course must ensure that no recordings are made of our conversations and also ensure that there is a separate, secure room in which we can confer with our client during the evidence view without monitoring by the government.
+- Please confirm whether all electronic recordings (other than the highly-confidential images and videos described below) have previously been produced to us, and if not, please explain which ones were not produced by the discovery deadlines last fall and why.
+
+# Highly Confidential Electronic Evidence
+
+- Can you please explain why 2,100 + 7 "highly confidential" images have not been shared with us yet? It was our understanding that you previously provided all "highly confidential" images to our client — and to defense counsel for review at the MDC in November. We are confused about where these previously undisclosed items were located and why they have not yet been made available for inspection and review.
+- During the week of April 19, Ms. Maxwell should be produced to 500 Pearl Street to review (with counsel and a defense staff member, on the 1 laptop provided) all of the 5,507 electronic images and video marked "highly confidential". These should be segregated into the three categories you describe (never-before produced, previously produced, and the 7 hard-copy images).
+
+Please let us know if you will not agree to any of these steps so that we can address the issues with the Court.
+
+Thank you.
+
+Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. 150 E. 10th Avenue I Denver, CO 80203 +I 303 831 7364 (Office) hnenningerghmflaw.com
+
+From:
+
+Sent: Tuesday, March 16, 2021 4:40 PM
+
+To: Laura Menninger : (USANYS)
+
+Cc: Jeff Pagliuca . Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) . 'BOBBI C STERNHEIM'
+
+Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
+
+All,
+
+Attached please find two spreadsheets documenting all physical evidence in the FBI's custody, as well as a corresponding discovery cover letter. We are sending a copy of these files to the MDC for your client as well.
+
+In response to your questions, the FBI has informed me of the following:
+
+Regarding the Highly Confidential nude/partially nudge images to be reviewed at 500 Pearl:
+
+- There are three categories of these images:
+ - o Approximately 2,100 electronic images and videos seized from Epstein's electronic devices (which have not been previously provided to you)
+ - o Approximately 3,400 electronic images from discs seized from Epstein's residences in 2019 (which have previously been provided to you and your client for review at the MDC)
+ - o Approximately 7 hard copy nude images located in the file from the FBI Florida office's investigation of Epstein (which have not been previously provided to you)
+- The FBI will make all three of those categories available to you. The electronic files will be provided on hard drives, and the FBI will provide you with the hard copy images for review as well.
+ - o All electronic images should be viewable as thumbnails, except those seized from Apple devices, which must be viewed using Cellebrite.
+ - o The Cellebrite software will be provided on the drive for your review of images and videos seized from Apple devices.
+ - o The electronic files have the same metadata on the hard drive that was available when the FBI seized each image. For images that were carved or deleted, no metadata was recovered, so none is viewable. For all other images, the metadata recovered should be viewable on the hard drive.
+ - o The approximately 2,100 electronic images and videos seized from Epstein's devices are separated by folder to indicate which device each image was seized from.
+- Because these images are considered obscene material, the FBI is not permitted to make duplicates of them, and there is a limited number of clean laptops on which these images can be reviewed. As a result, the FBI is only able to provide a single laptop for review of these images.
+
+Regarding the physical evidence:
+
+- Attached are two lists of all physical items in the FBI's custody relating to this case. The first list relates to items associated with the FBI Florida office's investigation of Epstein. The second list relates to items associated with the FBI New York office's current investigation.
+- The vast majority of physical evidence in the FBI's custody is located at the FBI's warehouse in the Bronx. Two items (18 77 & 1B 79) are located at 26 Federal Plaza, but the case agents can check those items out from 26
+
+Federal Plaza and bring them to the Bronx warehouse on whatever day you choose to conduct your review so that you will have all evidence in one place.
+
+- The FBI is able to arrange for the defense team to review all physical evidence at the Bronx warehouse under the following conditions:
+ - o The warehouse requires at least two weeks' notice in order to pull all of the items for the entire case and place them in a location where a large group of people can view them.
+ - o The warehouse is open during normal business hours between 9am and 5pm on weekdays.
+ - o At least two FBI agents and an AUSA will be present at the Bronx warehouse to assist and answer questions.
+ - o The evidence will be placed in a loading dock at the warehouse to provide additional space for the review. To ensure that there is sufficient space, please let me know how many members of the defense team intend to be physically present for this review.
+ - o Electronic devices such as cellphones and laptops are not permitted in the warehouse. The defense team may bring a digital camera that is not connected to the Internet or a cellular network into the warehouse. If the defense team wishes to photograph an item of evidence, the defense will need to inform the agents who are present, so that they may confirm that the photographed item is not Highly Confidential based on the presence of nudity.
+ - o Electronic media such as VHS tapes, cassette tapes, and CDs will not be playable at the warehouse.
+- To the extent the defense requests that the FBI bring any physical items to 500 Pearl Street for your client to review, the FBI is prepared to bring items that are reasonably sized to 500 Pearl Street. With respect to bulky or large items, the defense team should be able to photograph those for your client to review, unless they are deemed Highly Confidential, in which case the FBI can make arrangements to transport the item to 500 Pearl Street if necessary.
+- The FBI is in the process of confirming that it can provide devices to play all of the electronic media in the case in a single location at the FBI's offices in downtown Manhattan. We are also double-checking to confirm that all media that does not contain witness statements have already been produced to you and your client in discovery. The FBI anticipates that we can arrange for you to review all non-witness statement electronic media at the FBI's office in downtown Manhattan in approximately three weeks.
+ - o To the extent you wish to review all of the discs containing photographs, which were seized from Epstein's residences in 2019, we note that all of those images have already been produced to you in discovery. For your awareness, the FBI has informed me that it took their team several weeks to review all of the images on all of those discs.
+
+Please let me know how you wish to proceed.
+
+Best,
+
+Assistant United States Attorney Southern District of New York 1 St. Andrew% Plaza New York, NY 10007
+
+From: Sent: Monday, March 15, 2021 6:00 PM To: 'Laura Menninger' • (USANYS)
+
+Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengressercom) • 'BOBBI C STERNHEIM'
+
+Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
+
+Laura,
+
+I expect to be able to answer all of your questions about the evidence review by tomorrow.
+
+We have been looking into the discovery request you made last week, and we hope to have a response ready to provide to you by next week.
+
+Best,
+
+Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007
+
+From: Laura Menninger Sent: Monday, March 15, 2021 3:01 PM To: ) >; -)sca; (USANYS) Cc: Jeff Pagliuca . Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)
+
+. 'BOBBI C STERNHEIM' Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
+
+Now that the FBI team is back, when do you expect to have answers to all of the questions posed? If I had an idea of when you would have answers, it could help me answer your question.
+
+At a minimum, it would not seem to take too much time to know when someone can open the FBI vault and allow the attorneys to make an initial view of the evidence. Also, I understand the FBI did not prepare an inventory of their evidence when they seized it from NY and LSJ, so I don't think we need to wait for them to now prepare an inventory before we start reviewing evidence.
+
+Also, when do you believe you will have a response regarding the discovery I requested last Monday?
+
+Thanks, Laura
+
+Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. 150 E. 10th Avenue I Denver, CO 80203 +I 303 831 7364 (Office) Imenninger(khmflaw.com
+
+| From: | |
+|----------------------------------------------------------------------|--|
+| Sent: Friday, March 12, 2021 11:44 AM | |
+| To: Laura Menninger . | |
+| (USANYS) | |
+
+Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) ; 'BOBBI C STERNHEIM' Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
+
+Counsel,
+
+The FBI team on this case has been out of the office this week and will not be able to answer all of the questions you asked during our Wednesday call until they are back in the office next week. Please let me know if you would like to wait until all of those questions can be answered to schedule a day for your client to be brought to 500 Pearl Street to review the highly confidential images. My understanding is that the FBI is able to provide at least one laptop containing those highly confidential images in time for such a review to take place on Thursday 5/18, but I may not have the answers to all of your questions about those images before that date, and I do not know whether you will also be able to visit the evidence vault that same week.
+
+Please let me know how you would like to proceed. I will reach back out once I have answers to your questions.
+
+Thank you,
+
+Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007
+
+From:
+
+Sent: Tuesday, March 9, 2021 4:56 PM
+
+To: c >; Laura Menninger : (USANYS)
+
+Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com) ; 'BOBBI C STERNHEIM' Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes
+
+That is the only excel spreadsheet indexing physical evidence that we have produced in discovery. That spreadsheet does not include every physical item currently in the FBI's custody related to this case. For example, the August 20, 2020 discovery production also included search warrant returns listing the physical items seized by the FBI's New York Office during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Islands (see Bates range SDNY_GM_00166007-SDNY_GM_00166043), but they are not contained in a spreadsheet.
+
+As a courtesy, I have asked the FBI whether it would be possible to provide us with a similar excel index reflecting the physical evidence seized by the FBI's New York Office, though it may take some time to compile such an index.
+
+Best,
+
+Assistant United States Attorney Southern District of New York
+
+From: Laura Menninger Sent: Tuesday, March 9, 2021 3:44 PM To: ) < >; ) (USANYS)< > Cc: Jeff Pagliuca ; Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengresser.com)