MEMY-1805 harvest: vision-joined (part 33)

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+No Images Produced
+EFTA00137561

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+Event: Accepted: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to
+Start Date: 2019-11-07 19:30:00 +0000
+End Date: 2019-11-07 20:00:00 +0000
+Location:
+Class: X-PERSONAL
+Comment:
+Date Created: 2019-11-06 08:21:07 +0000
+Date Modified: 2019-11-06 08:21:07 +0000
+Priority: 5
+DTSTAMP: 2019-11-04 21:23:03 +0000
+Attendee:
+EFTA00097151

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+From: adrian edwards
+To: 4
+Subject: Fwd:
+Date: Thu, 11 Jul 2019 10:43:40 +0000
+P.S. Also... ponder this... Why would Leon Black,
+Apollo Global,,, hand Epstein all hi:
+private monies to look after when he knew that he was a pedophile, and even after his conviction in FL the
+relationship continued strong as ever......
+Leon Black and Jeffrey Epstein.
+*hy yould a man who is a money manager, and has a huge team at Apollo hand his personal finances to Epstein
+To walk from
+to Epstein's Mansion takes all of 3 minutes tops, and that's walking slow.
+The relationship between Leon Black and Epstein is --
+-- mmmm..
+... dubious perhaps.
+The three richest money managers in NYC
+course Carl Icahn.
+. Leon Black, Steven Schwarzman, and George Soros........ and of
+Funny how there is no link between Epstein to Soros, Schwarzman or Icahn.
+Yet there is to Black ******
+Good luck digging.
+-- Forwarded message --
+From: adrian edwards
+Date: Thu, Jul 11, 2019 at 5:54 AM
+Subject: Fwd:
+To: <
+Mr Berman,
+I'Il do you a favor.
+If you invite every Domestic Agency Owner in NYC to your office, and essentially ask them all to open their
+books to all the STAFF that they placed with Epstein over the years, and then have your team of US Attorneys
+contact, and interview all these Domestic Staff,,111, Housekeepers, Chefs, Drivers, Personal Assistants, Couples,
+Butlers, etc
+... and ask for their testimony, then the case opens wide, as the Domestics see, and hear
+everything.
+EFTA00096007
+
+Everything...
+.. They know who comes, and goes, when, how long, and all the rest.
+They do the laundry, clean up, make appointments, send emails, answer phones... and have access to every bit
+of every property owned by Epstein.
+They know.
+and for sure, they will all talk.
+Sure, they all signed 'Confidentiality Papers' but you can push right past that.
+The list of Agencies...... Pavillion, Greenhouse, Robert Parry Consulting, British American Household Staffing,
+and many more. They are all licensed in NYC.
+Epstein used all the Agencies to hire his Staff, and every Domestic Agency keeps books, records, and
+payments...
+..... Fee's for placement.
+That Mr Berman is my favor to you, and in return, you may be more aggressive to take to trial those who break
+ADA Law,,, like Reading International, and Bill de Blasio and Mitchell Silver for allowing 50% of the NYC
+Historic Homes to be totally inaccessible to those who are severely Disabled.
+If Domestic Staff/ Personal Assistants are persuaded to talk, then that will be an important nail for you....
+.... and
+believe me, every Domestic Staff Employee goes through NYC Agencies, and fee's are paid up to 20% of the
+annual salary, so every Employment Agency keeps records of the transaction, and resumes of the employee's.
+Trust me. I know. I once owned a Domestic Agency, and know all about Epstein.
+Unfortunately I have no evidence for you. It was a long time ago, but Epstein still used all the Agencies long
+after I was out of the business.
+When I placed Staff with Epstein, I heard it all.... and talked to many in the press who at the time just thought
+it was a joke, but I knew it all long before he was ever convicted in Florida.
+But no-one listened. They thought it was fanciful....
+Good luck.
+If you get 5-10 ex Staff to confirm shenanigans, then surely it makes your case even more solid.
+Adrian Edwards-Smith
+Advocacy for the Disabled of New York
+EFTA00096008

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+Case 1:20-cr-00330-AJN Document 250 Filed 04/26/21 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+USDC SDNY
+DOCUMENT
+ELECTRONICALLY FILED
+DOC#:_
+DATE FILED: 4/26/21
+United States of America,
+-V-
+Ghislaine Maxwell,
+20-CR-330 (AJN)
+ORDER
+Defendant.
+ALISON J. NATHAN, District Judge:
+The Court is in receipt of the parties' proposed schedules for pretrial disclosures and
+pretrial motions practice. Dkt. Nos. 229, 230. Having considered the parties' respective
+positions, the Court hereby sets the schedule below, which it deems reasonable and fair. For
+purposes of this scheduling order, the trial commencement date shall mean the date that the
+Court will request from the Clerk's Office as the trial commencement date. It does not include
+any period involving the issuance of a jury questionnaire that may predate that trial
+commencement date. As explained at the April 23, 2021 conference, the Court is considering the
+Defendant's request for a continuance, but until such a request is resolved the parties shall
+presume that the Court will request July 12, 2021 as the trial commencement date. See also Dkt.
+No. 221. With that in mind, the Court hereby sets the following schedule:
+• Government expert witness disclosure are due April 23, 2021 (agreement of the
+parties)
+• Supplemental Pretrial Motions that pertain only to the new charges raised in the S2
+indictment (agreement of the parties):
+• Defense supplemental motions are due May 7, 2021
+• Government's response is due May 21, 2021
+EFTA00103691
+
+Case 1:20-cr-00330-AJN Document 250 Filed 04/26/21 Page 2 of 3
+• Defense replies are due May 28, 2021
+• Disclosure of the alleged victims referenced in the S2 Indictment: May 17, 2021
+(agreement of the parties)
+• Jencks Act/3500 materials, Rule 404(b) notice, Giglio materials, the Government's
+witness list, and co-conspirator statements are due seven weeks before the trial
+commencement date
+• The Government's exhibit lists and marked exhibits are due five weeks before the
+trial commencement date
+Defense Expert Witness disclosure is due four weeks before the trial
+commencement date
+• The Defendant's Rule 16(b)(1)(A) and 16(b)(1)(B) disclosures and witness list are
+due three weeks before the trial commencement date
+• Motions in limine are due four weeks before the trial commencement date
+(agreement of the parties)
+• Responses to motions in limine are due two weeks before the trial
+commencement date (agreement of the parties)
+• Requests to Charge, Verdict Sheet, and Proposed Voir Dire are due three weeks
+before the trial commencement date (agreement of the parties)
+The Court will address a process and schedule for the parties' proposals regarding a jury
+questionnaire by separate order.
+Finally, the parties are ORDERED to meet and confer on the Government's proposal that
+the Defendant submit witness statements pursuant to Federal Rule of Criminal Procedure 26.2 at
+EFTA00103692
+
+Case 1:20-cr-00330-AJN Document 250 Filed 04/26/21 Page 3 of 3
+least four weeks in advance of trial. The parties are further ORDERED to submit a joint letter
+laying out their respective positions and proposals within one week of this Order.
+SO ORDERED.
+Dated: April 26, 2021
+New York, New York
+Alie O. Notto
+ALISON J. NATHAN
+United States District Judge
+EFTA00103693

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+Inmate Name:
+Date of Birth:
+Date:
+Bureau of Prisons
+Psychology Services
+Institution Disciplinary Process Report
+EPSTEIN, JEFFREY EDWARD
+01/20/1953
+Sex:
+07/30/2019 12:01
+Provider:
+**SENSITIVE BUT UNCLASSIFIED*
+M
+Facility: NYM
+Reg #:
+76318-054
+Unit Team: 5
+Reason for Referral and Identifying Information
+Inmate Epstein was referred by
+for an evaluation of competency to proceed with the disciplinary
+process for actions resulting in an incident report. On 7/23/19, inmate Epstein was charged with code 228 (Tattooing or
+Self-Mutilation). These infractions were assigned incident report number 3282555.
+Background Information
+According to a Suicide Risk Assessment dated 7/09/19 by
+According to a Suicide Risk Assessment dated 7/09/19 by
+"Inmate Epstein denied any past or present
+suicidal ideation, intention or plan. He denied ever engaging in any suicide attempts or self-injurious behavior in the
+past."
+According to this writer's Suicide Risk Assessment dated 7/23/19, "It is unclear at this time if he had placed the string
+around his neck or if someone else did."
+Clinical Interview and Mental Status Exam
+Inmate Epstein still does not remember how he obtained the marks around his neck.
+Current Mental Status: He exhibited a neutral mood with a full range of affect. His speech was logical and coherent, with
+no loosening of associations or tangential, circumstantial or irrelevant speech. Auditory and visual hallucinations were
+denied, and delusions were not elicited. He did not engage in any bizarre or inappropriate behavior. There was no
+indication of disturbed thought process or content. Intellectual ability appeared to be above average. Personal hygiene
+was adequate. He denied current suicidal or self harm ideation and he agreed to immediately tell staff if he starts to
+have suicidal or self harm thoughts. He was future oriented. He does not appear to be an immediate danger to self. He
+denied thoughts of hurting others and he agreed to tell staff if he has these thoughts.
+Clinical Impression
+According to his last Diagnostic and Care Level Formulation Note dated 7/09/19 by
+"No Diagnosis, No Dx -
+Current."
+Findings
+The determination of whether an inmate is competent to proceed with the disciplinary process is based on a clinical
+assessment of the inmate's (1) ability to understand the nature of the proceedings, and (2) their ability to assist in their
+own defense. Depending on the outcome of the assessment, one of three findings can be made: (1) the inmate is
+COMPETENT to proceed with the disciplinary process; (2) the inmate is NOT PRESENTLY COMPETENT but could be
+restored to competence with treatment; or (3) the inmate is NOT COMPETENT and is unlikely to become competent.
+Recommendations Regarding Sanctions
+In the case of inmate Epstein, after a review of available psychological and psychiatric records as well as information
+pertaining to the offense conduct, it is determined that this inmate is:
+(X) COMPETENT to proceed with the disciplinary process.
+() NOT PRESENTLY COMPETENT, but could become competent with treatment; it is recommended that the inmate for
+an updated competency assessment in 30 days.
+() NOT COMPETENT and not likely to become competent.
+Generated 07/30/2019 12:33 by
+Bureau of Prisons - NYM
+Page 1 of 2
+CONFIDENTIAL
+SDNY_00010595
+EFTA00058504
+
+Inmate Name:
+EPSTEIN, JEFFREY EDWARD
+Date of Birth:
+01/20/1953
+Sex:
+Date:
+07/30/2019 12:01
+Provider:
+Completed by
+on 07/30/2019 12:33
+Facility: NYM
+Reg #:
+76318-054
+Unit Team: 5
+Generated 07/30/2019 12:33 by
+CONFIDENTIAL
+Bureau of Prisons - NYM
+Page 2 of 2
+SDNY_00010596
+EFTA00058505

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+From:
+To:
+Subject: RE: Monday
+Date: Mon, 16 Sep 2019 13:49:45 +0000
+I think this is probably eminently handle-able by one person, unless anybody disagrees? L
+I'm happy to join if
+you'd like, or to just handle, or if you feel like doing it then I'm totally happy to defer (and I'll just continue to prep for
+California interviews). Agree with
+that certainly in the first instance it's likely to involve getting a list of names and
+not particularly credibility-heavy, such that we'd want a couple people to be able to weigh in on the info up the chain.
+Thoughts?
+From:
+Sent: Monday, September 16, 2019 09:26
+To:
+Subject: RE: Monday
+Sorry, this got lost in my inbox. No problem at all if you still need to skip this.
+From:
+To:
+Sent: Friday, September 13, 2019 4:13 PM
+Subject: Monday
+Sorry to ask, but is it okay if I don't join you guys for Monday's interview with
+meet with another case team, and it looks like Monday morning would work best for that.
+P I'm trying to find time to
+was Epstein's long-time house manager in NY, but we don't know anything beyond that, so the purpose of the
+interview is really just to identify other employees and see what if anything he saw at the house.
+Assistant United States Attorney
+Southern District of New York
+New York, NY 10007
+EFTA00075354

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@@ -0,0 +1,8 @@
+To:
+Fri 7/12/2019 9:52:30 AM
+Subject:
+Daily Activities Report/Lieutenant's Log...7-11-2019
+Daily Activities Report 7-11-2019.docx
+LIEUTENANT'S LOG 07-11-2019.docm
+CONFIDENTIAL
+SDNY_00011947

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@@ -0,0 +1,23 @@
+From:
+To:
+Subject: [EXTERNAL EMAIL] - Fwd: This is fun
+Date: Tue, 21 Sep 2021 01:58:42 +0000
+Importance: Normal
+Embedded: mime-attachment
+More lists of her friends including Ghislaine.
+"Kindness Matters"
+Begin forwarded message:
+From: |
+Date: September 4, 2021 at 10:26:59 PM PDT
+Subject: Fw: This is fun
+EFTA00077303
+
+* *** There is an attachment in this mail. ***
+> Free email, web pages, news, entertainment, weather and MORE!
+> Check out --
+-› http://wowmail.com
+> Select your own custom email address for FREE! Get
+Ads, 6MB, POP & more! http://www.everyone.net/selectmail?campaign-tag
+>
+w/No
+EFTA00077304

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@@ -0,0 +1,68 @@
+From: "
+To: "
+(USANYS) [Contractor]" <
+(USANYS)" ≤
+(USANYS)" <
+(USANYS)"
+Cc: "
+(USANYS)" ≤
+Subject: Fwd: (BN) Modeling Agent Brunel Detained in France as Part of Epstein Case
+Date: Thu, 17 Dec 2020 14:46:48 +0000
+(USANYS)"
+Bloomberg reporter forwarded this story about a French modeling agent and asked about the office's interest in
+him. We'll decline to comment. Passing along FYI.
+Chief Public Information Officer
+U.S. Attorney's Office, SDNY
+Begin forwarded message:
+From: "Christian Berthelsen (BLOOMBERG/ NEWSROOM:)" <cberthelsen1@bloomberg.net>
+Date: December 17, 2020 at 9:11:47 AM EST
+To:
+Subject: (BN) Modeling Agent Brunel Detained in France as Part of Epstein Case
+Reply-To: "Christian Berthelsen" < cberthelsen1@bloomberg.net>
+Hi guys - any chance we'll be seeing the unsealing of an extradition request for this person?
+Thanks and best,
+Christian
+......
+Christian Berthelsen
+Bloomberg News
+Newsroom: (212) 617-2230
+Mobile/Signal: (917) 428-3432
+CBerthelsen1@bloomberg.net
+christian.berthelsen@protonmail.com
+Modeling Agent Brunel Detained in France as Part of Epstein Case
+2020-12-17 13:24:21.432 GMT
+EFTA00078628
+
+By Gaspard Sebag
+(Bloomberg) -
+owner of a modeling agency,
+is being detained for questioning in France as part of the
+country's investigation into the role he may have played in
+luring underage girls into the late Jeffrey Epstein's orbit.
+Paris prosecutors said
+has been in custody since
+Wednesday as part of a probe opened last year. The man was
+detained at the Paris Charles de Gaulle airport as he was about
+to board a plane to Dakar, according to a person familiar with
+the matter.
+Prosecutors say he faces charges related to rape and sexual
+assault on minors, sexual harassment and human trafficking of
+minors for sexual exploitation.
+A lawyer for
+didn't immediately respond to requests
+for comment. Agence France-Presse reported on the detention of
+earlier on Thursday.
+In the U.S., Ghislaine Maxwell, the former girlfriend and
+confidante of Epstein, is in a New York jail awaiting a July 12
+trial on sex-trafficking charges. She and
+are suspected
+of helping Epstein lure underage girls into his orbit. Epstein,
+who also faced sex-trafficking charges, killed himself in his
+Manhattan jail cell in August 2019.
+To contact the reporter on this story:
+Gaspard Sebag in Paris at gsebag@bloomberg.net
+To contact the editor responsible for this story:
+Anthony Aarons at aaarons@bloomberg.net
+To view this story in Bloomberg click here:
+https://blinks.bloomberg.com/news/stories/QLHIR3T1UM1G
+EFTA00078629

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@@ -0,0 +1,95 @@
+Dear [Name]:
+The enclosed information is provided by the United States Department of Justice Victim Notification
+System (VNS). As a victim witness professional, my role is to assist you with information and
+services. I am contacting you because you were identified by law enforcement as a victim or
+potential victim during the investigation of a matter related to the above criminal case.
+Defendant Ghislaine Maxwell was arrested and charged as the result of a criminal investigation
+conducted by the United States Attorney's Office for the Southern District of New York. These
+charges arise out of an investigation into potential co-conspirators of Jeffrey Epstein. The main
+charge is categorized as Project Safe Childhood. Additional information regarding the case is set
+forth below. The lead prosecutors on the case are
+1, and
+Victim's Rights
+Although the current charges against Maxwell do not contain allegations involving you personally,
+the Southern District of New York previously identified you as a victim or potential victim in a related
+case involving Jeffrey Epstein.
+Victims of all crimes under federal investigation are entitled to services under the Victims' Rights and
+Restitution Act (VRRA), including notification of court events. For further details, please refer to Title
+34 United States Code section 20141 or the VRRA link posted at https://www.notify.usdoj.gov.
+Although you have not been identified as a victim in the charges against Maxwell, for your
+awareness, this letter provides details regarding the rights of crime victims in federal cases. Now
+that charges have been filed in federal court, victims of the charges filed are, in addition, entitled to
+the following rights, according to the Crime Victims' Rights Act, Title 18 United States Code section
+3771: (1) The right to be reasonably protected from the accused; (2) The right to reasonable,
+accurate, and timely notice of any public court proceeding, or any parole proceeding, involving the
+crime or of any release or escape of the accused; (3) The right not to be excluded from any such
+public court proceeding, unless the court, after receiving clear and convincing evidence, determines
+that testimony by the victim would be materially altered if the victim heard other testimony at that
+proceeding; (4) The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, sentencing, or any parole proceeding; (5) The reasonable right to confer with
+the attorney for the Government in the case; (6) The right to full and timely restitution as provided in
+law; (7) The right to proceedings free from unreasonable delay; (8) The right to be treated with
+fairness and with respect for the victim's dignity and privacy; (9) The right to be informed in a timely
+manner of any plea bargain or deferred prosecution agreement; and (10) The right to be informed of
+the rights under this section and the services described in section 503(c) of the Victims' Rights and
+Restitution Act of 1990 (34 U.S.C. 20141(c)) and provided contact information for the Office of the
+Victims' Rights Ombudsman of the Department of Justice. If you want to inform the prosecutors of
+your views regarding any aspect of the case, please contact one of the prosecutors listed above or
+me at races oce
+Please understand that these rights apply only to victims of the counts charged in federal court, and
+thus you may not be able to exercise all of these rights if the crime of which you are a victim was not
+charged.
+Because you have not been identified as a victim of the charges filed against Maxwell, we will not
+rovide you with additional notifications about this specific case unless you request suc
+otifications. If you wish to receive ongoing notifications regarding this case, please contact me a
+EFTA00104354
+
+Even if you do not wish to receive notifications regarding this case, we will make our best efforts to
+ensure you are provided the rights and services to which you are entitled. You may contact the
+Victim/Witness Coordinator at the office listed above if you have questions about the progress of
+your case, your rights or the services to which you are entitled, or how you can assert them during
+the proceedings. If you believe that a Justice Department employee has not provided you with these
+rights, you may file a complaint with the Justice Department's Victims' Rights Ombudsman. For more
+information, go to http://www.justice.gov/usao/resources/crime-victims-rights-ombudsman. If you
+have questions about filing a complaint against an employee, you may contact the Ombudsman by
+email at usaeo. VictimOmbudsman@usdoj.gov. Questions concerning this case should be directed to
+office listed above.
+It is important to keep in mind that the defendants) are presumed innocent until proven guilty and
+that presumption requires both the Court and our office to take certain steps to ensure that justice is
+served. While our office cannot act as your attorney or provide you with legal advice, you can seek
+the advice of an attorney with respect to the rights above or other related legal matters.
+Hearing Information
+[INSERT MAXWELL NEXT HEARING INFORMATION]. If you plan on attending please call me at
+in case there are any last-minute changes.
+Information Regarding the Victim Notification System (VNS)
+If, and only if, you elect to receive additional notifications regarding this case, then through the Victim
+Notification System (VNS) we will continue to provide you with updated scheduling and event
+information as the case proceeds through the criminal justice system.
+You may also obtain current information about this case on the VNS website at
+https://www.notify.usdoj.gov or from the VNS Call Center at 1-866-DOJ-4YOU (1-866-365-4968)
+(TDD/TTY: 1-866-228-4619) (International: 1-502-213-2767). In addition, you may use the Call
+Center or Internet to update your contact information and/or change your decision about
+participation in the notification program.
+For many VNS registrants email will provide the most timely notification. The email address VNS
+currently has for you is [XXX]. This email address has not been verified in VNS. As a result all
+notifications sent to this email address will contain limited information. To receive subsequent emails
+with the full text of the notification you must verify this email address by accessing the VNS Internet
+web page using the login information provided above. If the email address provided above is
+incorrect, please update the email address by accessing the VNS Web site. Once you have
+verified/updated your email address, most, if not all, future notifications will be provided by email and
+not by letter. In order to continue to receive notifications, it is your responsibility to keep your contact
+information current.
+You will use your Victim Identification Number (VIN) XXXX and Personal Identification Number (PIN)
+XXXX anytime you contact the Call Center and the first time you log into VNS on the website. If you
+are receiving notifications with multiple victim ID/PIN codes please contact the VNS Call Center. In
+addition, the first time you access the VNS website, you will be prompted to enter your last name (or
+business name) as currently contained in VNS. The name you should enter is XXX. Remember,
+VNS is an automated system and cannot answer questions.
+If you have other questions which involve this matter, please contact this office at the number listed
+above.
+Sincerely,
+EFTA00104355
+
+Acting United States Attorney
+Victim Witness Coordinator
+EFTA00104356

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vision-joined/ds9-parsed-01/85a5c12103c19dd2df341f9cea99e2eb40686996fb5d7f4e0a740f4a063deda2.md

@@ -0,0 +1,25 @@
+From:
+To:
+Ce:
+Subject: This coming week
+Date: Sun, 25 Aug 2019 00:05:22 +0000
+I'm still out on vacation; back on Thursday. And this week should be pretty quiet.
+Trials Starting:
+* Fitts
+(PC). Civil rights case against Dept of Homeless Services sergeant who kicked/stomped a person
+seeking assistance. Judge Abrams.
+* Sanchez
+Ammolock case. Judge Broderick.
+Monday, August 26
+• First Day:
+Tuesday, August 27
+* Epstein conference re:
+Wednesday, August 28
+* Borge. Sentencing of defendant in College of New Rochelle case. I
+* Arrest of Michael Hild in the LiveWell Financial case.
+Thursday, August 29
+Friday, August 30
+Other:
+Criminal Division
+United States Attorney's Office, SDNY
+EFTA00077359

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@@ -0,0 +1,14 @@
+Cc:
+To:
+Cc:
+To:
+From:
+Sent:
+Tue 7/23/2019 5:07:06 PM
+Subject:
+Inmate Epstein #76318-054 (Suicide Watch)
+TEXT.htm
+ccording to the Suicide Watch Log dated 7/23/19 at about 2:15 AM, inmate Epstein told the staf
+vatching him on Suicide Watch that his cellmate tried to kill him
+CONFIDENTIAL
+SDNY_00011739

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vision-joined/ds9-parsed-01/85bda900e74bf3bdc87754405e46a6daded7deb21f9235eb7c0492413ce9b49b.md

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+Case 1:20-cr-00330-AJN Document 66 Filed 10/23/20 Page 1 of 7
+HADDON
+MORGAN
+FOREMAN
+Haddon, Morgan and Foreman, P.C
+Jeffrey Pagliuca
+150 East 10th Avenue
+Denver, Colorado 80203
+PH 303.831.7364 x 303.832.2628
+www.hmflaw.com
+jpagliuca@hmflaw.com
+October 23, 2020
+VIA ECF
+The Honorable Alison J. Nathan
+United States District Court
+Southern District of New York
+40 Foley Square
+New York, NY 10007
+Re:
+Response to the Government's October 7, 2020 letter,
+United States v. Ghislaine Marwell, 20 Cr. 330 (AJN)
+Dear Judge Nathan,
+At the initial conference in this case, the Government promised Ms. Maxwell and the
+Court that it would review and produce "prior investigative files from another investigation in
+the Southern District of Florida," which it characterized as part of "the core of the case" against
+Ms. Maxwell,? after a "careful and exhaustive and through review of all of the materials," with
+the "bulk" of the discovery produced by "the end of this summer [2020]."3 Summer is gone,
+Winter is coming, and the Government has failed to make good on its promises.
+Although it casts the October 7, 2020 letter to the Court as a "response to the Court's
+prior inquiry regarding" its plan to produce discovery, the Government is, in fact, abandoning the
+deadlines to which it already agreed and reneging on (or redefining) its assurances to the Court
+that it would engage in "thoughtful and critical pushing and pressing of questions and issues with
+respect to actively retrieving any appropriate files.'" In fact, the promised "substantial"
+production of discovery is "substantial" in size, not substance. Approximately one fourth of the
+production relates to materials gathered in civil litigation to which Ms. Maxwell was a party. The
+remainder of the discovery contains documents from the 2000s that relate largely to Jeffrey
+Epstein and therefore have nothing to do with the time period of the conspiracy charged in the
+' July14, 2020 Tr. p. 12:20-13.
+- Id., 12:11.
+" Id., 13:8-14.
++ Id., 15:13-18.
+EFTA00100925
+
+Case 1:20-cr-00330-AJN Document 66 Filed 10/23/20 Page 2 of 7
+The Honorable Alison J. Nathan
+October 23, 2020
+Page 2
+Indictment. Although the Government represented to this Court during the detention hearing that
+"the strength of the Government's evidence" provided a strong incentive for Ms. Maxwell to
+flee, it has failed to produce any of the corroborating documentation that they claimed to have at
+the initial hearing in this case. And, to the contrary, the dearth of evidence reinforces why Ms.
+Maxwell has never intended to flee. She steadfastly maintains her innocence and vehemently
+denies the charges against her, as she has in prior civil lawsuits since the allegations against her
+first surfaced.
+Furthermore, the Government's production of discovery to Ms. Maxwell in the MDC has
+been deficient and inadequate. For example, Ms. Maxwell only received the Government's
+October 2, 2020 production yesterday afternoon, almost three weeks after the production date,
+and she still cannot read all of the documents in the government's prior productions. Defense
+counsel have discussed these issues at length with the Government, and despite the
+Government's assurances that it has spoken to the BOP and that the problems have been or will
+be corrected, the problems persist. The defense has done what it can to alert the Government to
+these issues so that they can be remedied, including three letters, three conference calls,
+numerous emails, and countless hours of time and effort that should have been spent on
+preparing the defense. It should not be Ms. Maxwell's responsibility to intercede with the
+Government and the BOP to ensure that the discovery is produced on time and in a readable
+format. The Government created these problems by insisting that Ms. Maxwell be detained
+before trial, and it is up to the Government to properly discharge its discovery obligations, which
+they have not done.
+The Government's failure to produce relevant discovery in a timely manner, and in a
+format that Ms. Maxwell can effectively review, is prejudicing her ability to investigate, prepare
+substantive motions, and defend against these charges. Given that these allegations are decades
+old and were investigated over many years by the Government prior to indictment, it should not
+have been difficult for the Government to produce the relevant discovery by the appropriate
+deadlines. Its October 7, 2020 letter is simply the harbinger of future delay, obfuscation, and
+impairment of Ms. Maxwell's ability to defend herself.
+Background Regarding the Lack of Substantive Disclosure by the Government Regarding
+Counts One Through Fours
+The "speaking" indictment in this case is remarkable because it fails to identify an
+accuser, a specific date that Ms. Maxwell is alleged to have committed a crime, or when
+anything in furtherance of any alleged conspiracy occurred. The only dates contained in the
+indictment are the years 1994-1997. Fed.R. Crim.P. 7 provides that "[Jhe indictment ... shall be a
+plain, concise and definite written statement of the essential facts constituting the offense
+charged." Fed.R.Crim.P. 7(c)(1). A criminal defendant is entitled to an indictment that alleges
+the essential elements of the charge against him. See Jones v. United States, 526 U.S. 227, 232
+5 Similar discovery problems exist regarding Counts Five and Six. Evidence of Ms. Maxwell's non-involvement
+with other Epstein accusers after 1997 would, in fact, undercut the Government's perjury theory because the
+materiality of any statements must be evaluated in the context of the allegations made in the civil proceeding, i.e.,
+EFTA00100926
+
+Case 1:20-cr-00330-AJN Document 66 Filed 10/23/20 Page 3 of 7
+The Honorable Alison J. Nathan
+October 23, 2020
+Page 3
+(1999); Hamling v. United States, 418 U.S. 87, 117 (1974) ("[A]n indictment is sufficient if it,
+first, contains the elements of the offense charged and fairly informs a defendant of the charge
+against which he must defend, and, second, enables him to plead an acquittal or conviction in bar
+of future prosecutions for the same offense."); Fed.R.Crim.P.7(c). An indictment that fails to
+allege the essential elements of the crime charged offends both the Fifth and Sixth Amendments.
+See Russell v. United States, 369 U.S. 749, 760-61 (1962).
+Ms. Maxwell recognizes that in most cases the bar for sufficiency of an indictment is
+very low. It is also true that courts find, in certain cases, that the discovery provided in
+connection with the matter may cure various pleading deficiencies. See, e.g., United States v.
+Jain, No. 19-CR-59 (PKC), 2019 WL 6888635, at *2 (S.D.N. Y. Dec. 18, 2019) (When
+supplemented by discovery material, no additional information is necessary for trial preparation
+or to prevent surprise, so a bill of particulars is unwarranted...".): United States v. Rodriguez,
+No. 99 CR. 367 (DLC), 1999 WL 820558, at *2 (S.D.N.Y. Oct. 13, 1999) ("IT]he indictment,
+particularly when coupled with the discovery already provided to the defendant, allows [him]
+both to prepare his defense and to avoid prejudicial surprise at trial. It also gives him sufficient
+protection from a prosecution that would violate his rights under the Double Jeopardy Clause.").
+This, however, is not those cases. Neither the indictment nor the discovery inform Ms.
+Maxwell about critical information necessary to prepare her defense. For example, the discovery
+provides no information about exactly when and where the alleged instances of sexual abuse
+took place. Because there are no dates provided, other than a three-year period beginning 26
+years in the past, Ms. Maxwell cannot properly investigate where she and other witnesses were
+when the alleged crime supposedly occurred. And because the crimes alleged in Counts One
+through Four are based largely on vaguely stated, non-criminal acts of so-called "grooming"
+(talking to or being nice to someone, or taking them to a movie), it is impossible to know what
+act or acts she needs to defend against at trial.
+The Discovery Provided to Date Contains No Corroborating Information and Omits
+Exculpatory Evidence
+At this point, roughly two months after the Government promised to produce the "core"
+of their evidence against Ms. Maxwell, their case appears to rest almost exclusively on claims of
+three unidentified accusers, as to which they have not provided any detail about the dates or
+exact locations of the alleged encounters, or the specific acts taken by Ms. Maxwell. Nor has
+this information been provided in the discovery. There is no identified witness who claims Ms.
+Maxwell did any of the things alleged in the indictment. Apart from the bare allegations in the
+indictment, there are no statements from any witness claiming Ms. Maxwell did anything and
+there has been almost nothing in the discovery for Ms. Maxwell to investigate.
+Importantly, the Government has not produced any of the potentially exculpatory
+information necessary to conduct an adequate defense investigation. We know, for example that
+dozens of women accused Jeffrey Epstein of misconduct and that the Government interviewed
+these women in connection with the Florida proceedings. None of these women implicated Ms.
+Maxwell in any wrongdoing, nor was Ms. Maxwell accused or involved in the Florida
+EFTA00100927
+
+Case 1:20-cr-00330-AJN Document 66 Filed 10/23/20 Page 4 of 7
+The Honorable Alison J. Nathan
+October 23, 2020
+Page 4
+investigation. The substance of this information is critical to the defense because it negates the
+entire theory of prosecution.
+The Government has not provided any information about the genesis of the Non-
+Prosecution Agreement ("NPA") that the Government entered into with Jeffrey Epstein in 2007.
+This is information will form the basis of substantial defense motions and argument.
+According to recent press reports, lawyers for the accusers met with the Government in
+2016 during the pendency of ongoing civil litigation against Ms. Maxwell in an effort to
+convince the Government to open an investigation of Ms. Maxwell - an effort which did not
+ultimately succeed. Neither the fact of these meetings nor the content has been disclosed. This is
+significant exculpatory information that is needed to investigate, prepare motions, and defend at
+trial.®
+We assume that many of the potential Government trial witnesses either participated or
+benefited from Epstein's NPA because the plea agreement provided for a mechanism where the
+claimants were paid money by Epstein, who could not challenge liability, only the amount. The
+Government presumably has this information which is unquestionably favorable evidence which
+"includes not only evidence that tends to exculpate the accused, but also evidence that is useful
+to impeach the credibility of a government witness...." United States v. Teman, No. 19-CR-696
+(PAE), 2020 WL 3034034, at *43 (S.D.N.Y. June 5, 2020) (citations omitted); see also, Bagley
+v. Lumpkin, 798 F.2d 1297, 1301 (9th Cir. 1986); United States v. Librach, 520 F.2d 550, 554
+(8th Cir. 1975).
+The Government is the Team
+In an attempt to minimize what it promised, the Government redefines who it believes is
+on the Team. The Government claims no responsibility for investigations into these allegations
+by either the Federal Bureau of Investigation or the Office of the United States Attorney unless
+part of the Southern District of New York. This stands in stark contrast to the on-the-record
+assurances that it gave the Court on July 14, 2020:
+"...the materials with respect to the core of the case also include prior investigative files
+from another investigation in the Southern District of Florida...." Tr. p. 12:10-13
+"The physical files [from the Florida investigation] were shipped to New York and are at
+the New York F.B.I. office. They have been imaged and scanned and photographed to
+make sure that a comprehensive review can be conducted, and they are physically in New
+York so that we can have access to those files." Id., 14:10-14
+Now, the Government seeks to distance itself from its own files, which are in New York,
+not Florida, by arguing that they are excused from reviewing or producing information because it
+• Pursuant to this Court's practice standards regarding discovery, Ms. Maxwell, on October 13, 2020, sent a detailed
+letter requesting the production of discovery materials under Rule 16 of the Federal Rules of Criminal Procedure,
+Brady v. Maryland, 373 U.S. 83 (1963) and Giglio v. United States, 405 U.S. 150 (1972). The Government has yet
+to respond.
+EFTA00100928
+
+Case 1:20-cr-00330-AJN Document 66 Filed 10/23/20 Page 5 of 7
+The Honorable Alison J. Nathan
+October 23, 2020
+Page 5
+came from another state, agents, or lawyers. In addition, the Government has disclosed the
+existence, for example, of additional files and investigations including 28 boxes of material from
+the United States Attorney's Florida office, the Department of Justice, and the United States
+Attorney's Georgia office.
+It is unclear precisely what the Government will do with this material. On the one hand
+the Government suggests it 'intends' to review the files for "materials that warrant disclosure in
+this case." On the other hand, the Government's letter includes a lengthy disclaimer about why
+the Government believes it has no obligation to locate, obtain, or produce the discovery. The
+authority cited by the Government in support of its disclaimer is easily distinguishable. This case
+does not involve material gathered independently by the SEC, the Public Company Accounting
+Oversight Board, or the New York Stock Exchange. See United States v. Collins, 409 F. Supp.
+3d 228, 241-43 (S.D.N.Y. 2019) ("SEC""); United States v. Middendorf, No. 18 Cr. 36 (JPO),
+2018 WL 3956494, at *4-5 (S.D.N. Y. Aug. 17, 2018) ("PCAOB"); United States v. Finnerty,
+The Government does not ask the Court to rule on its view of itself and clearly this
+argument will be held on another day. It is troubling, however, that instead of simply providing
+the information to Ms. Maxwell the Government goes to great effort to preview why it may not.
+Ms. Maxwell submits that all this material is discoverable for the reasons already discussed.
+The Method and Timing of the Government's Revised Discovery Plan is Inadequate and
+Prejudicial to Ms. Maxwell.
+Ms. Maxwell agreed, in advance of her detention hearing, to a trial more than one year
+from her detention. She agreed to this plan on the representation that she would be provided with
+full discovery no later than November 9, 2020. See ECF #25, "Completion of Discovery to
+include electronic materials is due by Monday, November 9, 2020." This representation now
+seems incorrect. The Government, in its letter to the Court, is simply fronting the reasons why
+the completion of discovery will likely not occur by November 9, 2020.
+Ms. Maxwell, when agreeing to a trial in July 2021, outside the time limits established by
+18 U.S.C. § 3161, thought that she would be provided with meaningful discovery with sufficient
+time to prepare. This assumption also seems incorrect. In its letter to the Court the Government
+proposes that witness statements be provided a mere four weeks prior to trial, for the important
+witnesses, and eight weeks for the unimportant witnesses. This is a case with 26-year-old
+claims, allegedly occurring in multiple states and countries. It is a certainty that material
+witnesses live in other countries, and that these witnesses cannot be compelled to appear in New
+York. Securing out-of-country testimony is difficult even where a defendant has been provided
+with the names of her accusers and details about the allegations. The parties have not yet met and
+conferred about the timing of disclosure of witness statements, so it is premature to discuss these
+issues with the Court. We note, however, that under the Government's proposed timetable, it
+will be impossible for Ms. Maxwell to adequately prepare for trial.
+The Government's suggested timeline also impairs Ms. Maxwell's ability to effectively
+address significant legal issues including motions to suppress evidence, motions to dismiss the
+EFTA00100929
+
+Case 1:20-cr-00330-AJN Document 66 Filed 10/23/20 Page 6 of 7
+The Honorable Alison J. Nathan
+October 23, 2020
+Page 6
+indictment, severance of counts, disclosure of expert testimony, disclosure of materials to
+potential experts, F.R.E. 702 challenges to experts, and various motions in limine. Without
+substantive discovery Ms. Maxwell cannot be prepared to advance or meet any of these matters.
+The Government Has Not Complied with Its Discovery Obligations to Ms. Maxwell in the
+MDC.
+Setting aside what the Government has not produced, the discovery that it has produced
+to Ms. Maxwell in the MDC thus far has been incomplete and portions are still unreadable. On
+August 27, 2020, after the Government had completed its first three discovery productions, the
+defense alerted the Government that there were a substantial number of documents in all three
+productions that Ms. Maxwell was unable to access on the hard drives that had been sent to the
+MDC, and even proposed possible technological solutions that we thought might alleviate the
+problem. Later that same day, the defense sent the Government a follow-up letter listing the
+unreadable documents and requesting that the Government immediately reproduce to Ms.
+Maxwell a new set of all of the discovery materials produced to date in a format that she could
+access on her computer at the MDC, and shipped a new hard drive to load the replacement
+production.
+The new hard drive was not made available to Ms. Maxwell at the MDC until the late
+afternoon of September 9, 2020, almost two weeks later. While some of the previously
+unreadable documents were fixed, Ms. Maxwell still could not access a substantial portion of the
+discovery materials. The defense sent another letter to the Government on September 21, 2020,
+listing the unreadable documents and demanding that the problems be addressed. On conference
+calls on September 22, 2020 and September 29, 2020, the Government advised that it was
+working on resolving the issues, but that the defense could, in the meantime, create its own
+laptop computer with a copy of the production that it could bring to the MDC to review the
+discovery with Ms. Maxwell. The defense responded that, while it would create the laptop, it
+was the Government's responsibility to ensure that Ms. Maxwell had a complete set of readable
+discovery which she could access at the MDC herself, without defense counsel present.
+It was not until October 2, 2020 that the Government created a replacement set of the
+unreadable discovery, which it said it would include on the same hard drive as the next
+production of discovery materials. That production was only made available to Ms. Maxwell in
+the MDC yesterday afternoon, almost three weeks since the production date. The Government
+also advised that it had asked MDC legal counsel to send an IT staff member to examine the
+computer and load any necessary software to view the files on the existing hard drives. But the
+IT staff member did not look at the computer until October 7, and did not fix the problem.
+Instead, the IT staff member collected Ms. Maxwell's computer and hard drives and kept them
+for two days. When Ms. Maxwell inquired about them, the IT staff member said he had been too
+busy to look at them. And when they were finally returned to Ms. Maxwell in the afternoon on
+October 9, several files were still unreadable. As of the date of this letter, Ms. Maxwell still does
+not have a complete, readable set of the discovery produced to date, which severely impairs her
+ability to prepare her defense. Accordingly, we ask the Court to order the Government to
+address this problem immediately.
+EFTA00100930
+
+Case 1:20-cr-00330-AJN Document 66 Filed 10/23/20 Page 7 of 7
+The Honorable Alison J. Nathan
+October 23, 2020
+Page 7
+The BOP, for their part, has only exacerbated these problems. For example, on a legal
+visit today to review images on a laptop computer provided by the Government, we were told
+that we could not sit on the same side of the table as Ms. Maxwell to review the images
+simultaneously. Instead, we were directed by MDC prison guards to sit across from Ms.
+Maxwell, such that we could not see what she was reviewing or meaningfully discuss the
+materials.
+To compound the problem, we were told by the team leader that defense counsel would
+not be permitted to pass Ms. Maxwell papers for her to review or sign. This required a break in
+the meeting so that defense counsel could call the prosecutors to intervene. The prosecutors
+agreed to call the MDC to ensure that defense counsel could pass legal papers to Ms. Maxwell.
+But that message was clearly not received by the MDC. After returning to the MIDC, we were
+told that we could pass Ms. Maxwell only documents that required her signature, but not
+documents that needed her review. It is impossible for Ms. Maxwell to participate in her defense
+and adequately prepare for trial if she cannot review documents prepared by her attorneys.
+Accordingly, we ask the Court to order the BOP to allow defense counsel to pass legal papers to
+Ms. Maxwell for her review during prison visits.
+The Government cannot discharge its discovery obligations by partially completing them.
+The Government must fully complete them and do so on the deadlines they agreed to with the
+Court. And it goes without saying that the Government cannot discharge its discovery
+obligations by producing the discovery to defense counsel. Ms. Maxwell has a right to review all
+the discovery to participate in her own defense. As such, she must have a complete set of
+readable discovery in the MDC, which she does not have. The Government has created these
+problems by insisting on detention prior to trial. It is their burden to fix them.
+The Government has not requested any relief in its letter of October 7, 2020. Ms.
+Maxwell anticipates that once the Government responds to her discovery requests and after
+further conferrals the parties will be in a better position to seek relief from the Court. It may be
+appropriate for the Court to schedule a status conference after November 9 to consider these
+issues.
+Respectfully Submitted,
+Jeffrey S. Pagliuca
+CC: Counsel of Record (via ECF)
+EFTA00100931

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@@ -0,0 +1,56 @@
+USDC SDNY
+DOCUMENT
+ELECTRONICALLY FILED NITED STATES DISTRICT COURT
+DOC#:
+DATE FILED:
+7/111 SOUTHERN DISTRICT OF NEW YORK
+UNITED STATES OF AMERICA
+V.
+JEFFREY EPSTEIN,
+Defendant
+MEMO ENDORSED
+CRIMINAL. NO. 19-CR.190
+DEFENDANT JEFFREY EPSTEIN'S MOTION FOR LEAVE TO FILE
+SUPPLEMENTAL FINANCIAL DISCLOSURE UNDER SEAL
+Defendant Jeffrey Epstein, by and through undersigned counsel, hereby respectfully moves
+this Honorable Court for leave to file under seal his supplemental financial disclosure. As noted in
+Mr. Epstein's bail submission, on advice of counsel, he has not yet provided a complete financial
+disclosure. Counsel's advice on this point was motivated by a desire to ensure the accuracy and
+completeness of the information provided to the Court. Mr. Epstein seeks leave to file his
+forthcoming supplemental disclosure under seal. As grounds and reasons therefor, Mr. Epstein relies
+on the exceptional amount of publicity that has been generated by this case, much of which relates
+specifically to his finances. Under the Bail Reform Act, financial information provided by a
+defendant to a pretrial services officer "shall be used only for the purposes of a bail determination
+and shall otherwise be confidential." 18 U.S.C. § 3153(c)(1). Here, in the event Mr. Epstein is
+required to publicly file his financial statement, the information contained therein will inevitably be
+widely disseminated in the news media, contravening the statutory requirement of confidentiality.
+1
+EFTA00092114
+
+WHEREFORE, Mr. Epstein respectfully requests that this Honorable Court allow him leave
+to file his supplemental financial disclosure under seal.
+Respectfully Submitted,
+Jeffrey Epstein
+By His Attorneys,
+Is/ Reid Weingarten
+Steptoe & gainson, LLP NYC
+1114 Avenue of the America
+New Vork NY 10036
+Is/ Martin G. Weinberg
+Bastar MA 02116
+1s/ Mare Allan Fernich
+Mare Allan Fernich
+Law Office of Marc Fernicl
+So Seventh AvI. Suite 620
+Dated: July 11, 2019
+2
+Defense Moton granted
+Matericle to ke Rand deliri
+to chambers (owe opposung
+counsel) 6y 9800 AM, Tuly12,
+201%
+SO ORDERED
+Date: 7/11/19
+Richard M. Bernan
+Richard M. Berman, U.S.D.J.
+EFTA00092115

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vision-joined/ds9-parsed-01/85dfc1030e92042969c19da7bd50a602aaf20dc0ad6fce23f0d3fbc7572598a9.md

@@ -0,0 +1,24 @@
+From: "
+To: "
+(CRM)" _
+(USANYS)" <
+Cc: "
+(CRM)" _
+Subject: Referral of MLAT Request from France (BRUNEL)
+Date: Wed, 30 Dec 2020 10:57:39 +0000
+Attachments: 2020002015-
+I: 2020002015-
+Brunel_Referral_Letter_(SDNY)_(December_2020) pdf
+(USANYS)"
+Dear
+I hope you are both doing well, and have been enjoying the end of year festivities.
+I am referring for your attention an MLAT request from the French in relation to their investigation of Jean-Luc BRUNEL
+(who was recently arrested and placed under examination here in Paris). Since I have been in touch anyway with
+about the Maxwell bail proceedings, I took the opportunity to mention that this might be
+coming their way.
+Thanks in advance, and happy new year! -
+DOJ Attaché/Magistrat de liaison américain
+U.S. Embassy, Paris
+Ofc.
+Mob.
+EFTA00079596

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+}

vision-joined/ds9-parsed-01/85f468310070976ae570eca11935c1aa51b4b1207f2286850b6547085ef8a76f.md

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+DEPARTMENT OF JUSTICE | OFFICE OF THE INSPECTOR GENERAL
+MEMORANDUM OF INVESTIGATION
+Case Number:
+2019-010614
+Reporting Office:
+Boston Area Office
+Interview of
+On July 14, 2021, Senior Special Agent
+and Special Agent
+I, U.S. Department of
+Justice Office of the Inspector General (OIG), conducted a voluntary interview of Lieutenant
+Federal Bureau of Prisons (BOP), Metropolitan Correctional Center (MCC) New York, New York, within the MCC
+New York. The interview was conducted in reference to an official OIG investigation surrounding the death of
+BOP inmate Jeffrey Epstein, Register Number 76318-054, who was previously housed at the MCC New York.
+was an MCC New York staff member assigned to the MCC New York Special Housing Unit on August 9,
+2019, the day before Epstein was found unresponsive within his cell at the MCC New York. The interview was
+recorded, and the recording has been transcribed. The interview transcript and documents discussed with
+| during the interview are attached to this report. The audio recorded interview has been saved
+separately to the case file due to its large file size.
+Attachments:
+1. Transcribed interview of the recorded interview of
+| conducted on July 14, 2021
+2. OIG Warnings and Assurances Form signed by
+dated July 14, 2021
+3. MCC New York Daily Assignment Roster from August 9, 2019
+4. MCC New York Daily Assignment Roster from August 10, 2019
+5. Email from
+dated July 30, 2019
+6. Sign saying Mandatory Epstein Rounds
+7. Memorandum written by l
+dated August 12, 2019
+8. MCC New York Daily Activity Report and Lieutenant Log on August 9, 2019
+9. MCC New York Form PP38 Daily Log on August 9, 2019
+10. MCC New York Count documentation from August 9, 2019, at 5 a.m.
+11. MCC New York Count documentation from August 9, 2019, at 4 p.m.
+12. MCC New York Count documentation from August 9, 2019, at 10 p.m.
+13. MCC New York Count documentation from August 10, 2019, at 12 a.m.
+14. MCC New York Count documentation from August 10, 2019, at 5 a.m.
+15. MCC New York Count documentation from August 10, 2019, at 10 a.m.
+16. MCC New York Count documentation from August 10, 2019, at 4 p.m.
+17. MCC New York SHU 30 Minute Round Sheet from August 9, 2019
+18. MCC New York Lieutenant Rounds on August 9 and 10, 2019
+Prepared By:
+Preparer Title:
+Senior Special Agent
+Reviewed By:
+Reviewer Title:
+Assistant Special Agent in Charge
+Signature:
+Signature:
+OIG Form III-210/4 (09/06/2018) This document contains neither recommendations nor conclusions of the IG. It is the property of the IG
+and is loaned to your agency; it and its contents are not to be distributed outside of your agency.
+EFTA00116351
+
+19. MCC New York SHU Cell Search on August 9, 2019
+20. MCC New York Quarters History for Jeffrey Epstein
+21. MCC New York SHU Map
+22. MCC Camera screenshots
+23. Pictures of the MCC New York SHU and Epstein's MCC New York cell from August 10, 2019
+Memorandum of Investigation
+Case Number: 2019-010614
+Page 2
+EFTA00116352

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vision-joined/ds9-parsed-01/860dd684f5fa12ef04fe146d082f93eb1ee44ca268631ea661167ee41eb2a2c2.md

@@ -0,0 +1,75 @@
+From:
+To:
+(USANYS)" ≤
+Subject: RE: Epstein
+Date: Fri, 26 Apr 2019 21:44:14 +0000
+Importance: Normal
+Sorry, forgot to make the swap. It's "
+----Original Message-
+From:
+(USANYS) 4
+Sent: Friday, April 26, 2019 5:44 PM
+Subject: RE: Epstein
+Do you have a first name/last initial for "Victim-3"?
+-----Original Message-..
+From:
+Sent: Friday, April 26, 2019 5:17 PM
+To:
+(USANYS) ≤
+(USANYS)
+Subject: RE: Epstein
+Thanks. I've added a section on the CVRA suit and incorporated comments/edits. I wasn't sure how to address
+two of the comments, so I'll swing by in a minute to quickly discuss, if you're free.
+-----Original Message-.....
+From:
+(USANYS) <
+Sent: Friday, April 26, 2019 3:57 PM
+To:
+(USANYS) <
+Subject: RE: Epstein
+Thanks. Some comments/suggestions in track.
+is not up to speed on the Florida victims litigation which she'll want to have some familiarity with as
+well - is there anything you guys have already (including media reports) that might be helpful in that regard?
+-----Original Message----
+From:
+To:
+Sent: Friday, April 26, 2019 3:17 PM
+(USANYS) <
+Cc:
+(USANYS) <
+Subject: RE: Epstein
+Attached is the most recent ODAG memo, along with a short memo for |
+that summarizes updates since
+the last memo. Please let me know if there are any edits you'd like me to make, or additional information you
+need.
+hasn't reviewed this, because he's in transit, but we spoke briefly this morning to discuss what should
+go in the update.
+EFTA00080463
+
+-----Original Message-----
+From:
+(USANYS) <
+Sent: Friday, April 26, 2019 11:43 AM
+To:
+Cc:
+(USANYS) <
+Subject: Re: Epstein
+would you be able to do this?
+Sent from my iPhone
+> On Apr 26, 2019, at 11:36 AM,
+→ wrote:
+>
+> I'm traveling today, back on Sunday so could do it then or otherwise have to defer to.
+>
+> Sent from my iPhone
+>
+sorry.
+>> On Apr 26, 2019, at 10:35,
+| (USANYS) <
+> wrote:
+is going to meet with Brad Weinshiemer on Monday - can you guys put together an update memo this
+afternoon on where we are, what we've done since the last update memo, and next steps? This just for
+for now, not for sending down to DC.
+>>
+>> Sent from my iPhone
+EFTA00080464

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@@ -0,0 +1,11 @@
+From:
+To:
+Bc: "USAHUB-USAJournal111"
+Subject: RE: Epstein-related files
+Date: Tue, 13 Oct 2020 14:19:48 +0000
+Embedded: RE:_Epstein-related_files.msg
+Sender:
+Subject: RE: Epstein-related files
+Message-Id: ≤8h4ba1 7408664fo8a638a5fa4cb25623@MAIL-4.sa15.state.fl.us>
+Recipient:
+EFTA00098794

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vision-joined/ds9-parsed-01/862c5f21f98cd20ffb264e0a2f6848fa0675ec95a32e62c2bad957cfa1a54994.md

@@ -0,0 +1,40 @@
+From:
+To: "
+• (NY) (FBI)" <
+Subject: RE:
+Date: Sun, 08 Mar 2020 20:20:27 +0000
+Attachments: INT_000294_-_INT_000631_
+_(student_rosters_1994-98,_pw_Butzel123!) pdf; 2020-02-
+21, Interlochen_cover_letter_ &_custodian_declarations.pdf; INT_000001_-
+INT_000293_(Epstein
+&_Maxwell _records, _pw_Butzel123!) pdf
+Thanks! Records are attached.
+From:
+|. (NY) (FBI) <
+Sent: Sunday, March 8, 2020 11:27 AM
+To:
+Cc:
+Subject: Re:
+We will connect with her and keep you updated. Could you also pass along the records from Interlochen?
+Thanks!
+On Mar 8, 2020 6:35 AM, "
+• wrote:
+Yes I remember listening to this podcast a few months ago. I texted |
+Tand a copy of this podcast back in
+January and I agree she is definitely someone we should talk with. I'm pretty sure she claims she was not abused
+(although im not sure if that's true) but either way could be a very fruitful interview.
+I'm at the airport now headed to Aruba so I'll be out of phone contact until next Sunday. I'll check in with you guys when I
+get back.
+On Mar 7, 2020, at 17:00,
+> wrote:
+In reviewing the records we received from Interlochen, it looks like Epstein paid the summer camp tuition of a student
+named |
+1. She was interviewed on a podcast about her dealings with Maxwell and Epstein, and we'd like
+to interview her. Are you able to reach out to her about an interview?
+Looks like this is her (it notes she lives in|
+I which is also where|
+is):
+And here's the podcast interview:
+EFTA00088216
+
+EFTA00088217

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+From: "
+To: "
+Subject: thoughts?
+Date: Thu, 07 Nov 2019 19:20:00 +0000
+TO:
+FROM:
+THE OFFICE OF THE ATTORNEY GENERAL
+THE OFFICE OF THE DEPUTY ATTORNEY GENERAL
+UNITED STATES ATTORNEY
+SOUTHERN DISTRICT OF NEW YORK
+PHONE:
+DISTRICT POC:
+SYNOPSIS:
+As described in Urgent Report 2019-11-47430, USAO-SDNY plans to seek an indictment charging two correctional officers
+at the Manhattan Correctional Center ("MCC") with counts of making false statements and conspiring to (i) make false
+statements and (ii) interfere with or obstruct the lawful function of the MCC. The charges stem from their conduct on the
+night that Jeffrey Epstein committed suicide. USAO-SDNY previously indicated that it would seek the Indictment on
+November 14. For operational reasons, USAO-SDNY now plans to seek the Indictment on November 19, and FBI-NY will
+conduct the arrests the same day.
+EFTA00068871

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+C/O
+was assigned to staff watch; however, the wrong book was used (I/M companion log) in lieu of Staff Suicide Watch log.
+, DTS discovered the wrong log was used.
+completed a 2nd log using Suicide Watch log (
+initialed the log for
+Entries are identical in both logs.
+Associate Warden
+MCC New York
+New York. NY 10007
+CONFIDENTIAL
+SDNY_00009687

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vision-joined/ds9-parsed-01/86ac94d8658b3f0c6a4f9fdb834752387b0b9217f84c8bfd88c9eef3d67b871a.md

@@ -0,0 +1,1127 @@
+From: Chris Dilorio <
+To:
+Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR &
+Appendix
+Date: Mon, 13 Jul 2020 16:50:54 +0000
+Attachments: KCC Appendix 3-20_13 penultimate doc: KCG TCR 3-20-1320 13 menulimate pot
+_TCR_3-20-13-penultimate_draft.doex; KCG_Appendix_3-20_
+Janey, Hoecker, Jay et al
+still MORE SEC attempts to cover up illegal activity at the expense of the public it is mandated to protect.
+The SEC latest Rule change proposal
+https://www.sec.gov/news/press-release/2020-152
+SEC.gov | SEC Proposes Amendments to Update Form 13F for Institutional
+Investment Managers; Amend Reporting Threshold to Reflect Today's
+Equities Markets
+The Securities and Exchange Commission today announced that it has proposed to amend Form 13F to
+update the reporting threshold for institutional investment managers and make other targeted changes.
+www.sec.gov
+Will exempt 90% of current 13F filers from future equity holdings disclosures.
+WHO does that benefit? Certainly not the public the SEC is mandated to protect. LESS transparency still for the
+likes of Keener,Sason, Asher/Kramer,IBC, Ironridge/Coulston, Alpha, Dutchess, Crede, etc etc etc
+EFTA00069011
+
+Costs to file: pocket change
+https://www.netacn.com/Service.aspx?id=dLfmwmZHCkOs|L-sP3V8Dw
+Form 13F EDGAR Filing Agent Service :: Advisor Consultant Network
+ACN will compile your 13F Report and act as your Filing Agent in order to submit the report to EDGAR.
+Send us your Holdings List, we compile the Form 13F Report and send you a Proof for your review and
+approval. Upon your approval we will submit the report to EDGAR. You will receive an email notification as
+will ACN that the report has been accepted.
+www.netacn.com
+So, WHY does the SEC want LESS transparency for the investing public it is mandated to protect?
+The SEC is bought and paid for by criminals.
+Cheers!
+Christopher J Dilorio
+Whistleblower
+From: Chris Dilorio ‹
+Sent: Wednesday, July 8, 2020 9:35 AM
+Subject Fw: Formal appeartor premminary dental covered action 2015-016/ Knign Capial TOR & Appendix
+Janey, Hoecker et al,
+Is Trump prolific Bag Man Jonathan Farkas related to Bag Man Michael Farkas: Skyway largest shareholder:
+REVOKED
+https://www.hollywoodreporter.com/rambling-reporter/inside-hamptons-fundraisers-netted-trump-12m-
+election-1230690
+EFTA00069012
+
+Inside the Hamptons Fundraisers That Netted
+Trump $12M for Re-election | Hollywood
+Reporter
+The numbers are in and President Donald Trump's quick trip to
+the Hamptons on Friday raked in $12 million for his re-election
+campaign as his Republican allies were quick to declare it a win ...
+www.hollywoodreporter.com
+Now Michael Farkas is CEO of Jaclin money laundering shell New Image Concepts/Blink charging
+How did Farkas (Michael) escape the SkyWay SEC complaint?
+https://www.sec.gov/litigation/complaints/2009/comp20960.pdf
+Would explain the Milken/Drexel flunkie Engel on the BLNK BoD as well.
+Also explains why the grossly corrupt SEC let Bag Man JMJ/Keener up and running in 2020 and the
+Crede/Milken/Putin etc NETE CFO New now CFO at BLNK
+Some BLNK/Trump/rinsing. With help from "issuer/bag man funded research" Zacks aka Seethroughequities
+2.0. Rusian money?
+Cheers!
+Christopher J Dilorio
+Whistleblower
+From: Chris Dilorio <
+Sent: Tuesday, July 7, 2020 6:09 AM
+Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
+Janey,
+EFTA00069013
+
+MORE EXTRAORDINARY SEC corruption and criminal obstruction designed to protect criminals and screw
+whistleblowers like me. Despite my very generous 4 day offer to produce the entire record which is the basis of
+my award application/denial/appeal AND REQUIRED by the statute I have referenced:
+240.21F-12 "Materials that may form the basis of an award determination and that may comprise the record on
+appeal", The several hundred e mails I have sent you, Hoecker et al MUST be part of this record. Janey, you
+failed to produce this record. As I made clear: my 6/23/2020 emails to you Hoecker, SEC commissioners were
+merely re re re sent previously sent e mails: the record. Further, my 6/23/2020 e mail: Formal appeal for
+preliminary denial covered action 2015-016 Knight Capital & Appendix was merely a summary of several
+hundred e mails sent to you, Hoecker et al. These e mails SHOULD be the record. You failed to produce the
+record. Which begs the question: WHAT "record" was used to determine the SEC preliminary denial exactly IF
+the SEC can't produce the record? The preliminary denial was completely fabricated and must be reversed.
+But, it doesn't end there: per my 6/23/2020 summary based on several hundred e mails sent to the SEC, the
+RECORD of EXTRAORDINARY corrupt obstruction designed to protect criminals and screw whistleblowers is not
+confined to Opco, NITE, UBSS, Sason, Keener etc etc etc. I have filed 2 TCR's with the OWB related to the money
+laundering/transaction
+laundering/Putin/Rakishev/Trump/Kushner/Alfa/Crede/Peizer/Milken/Hapoalim/SBNY/CardWorks/ESQ/WireCa
+rd/AQR etc etc etc fraud known as Net Element. For YEARS the SEC has been in possession of not just my TCR's
+but HUNDREDS of e mails supporting my TCR's comprising the extensive record. Here again, the SEC is covering
+up a MASSIVE fraud perpetrated on the public and well within even the grossly corrupt SEC ability to shut down
+the fraud IF they had used my information to execute its mandate to do so. Instead, the SEC obstructed a
+thorough investigation. Per my previous e mails: the record: NETE claimed to be a payment processing entity.
+Claiming further to process BILLIONS of dollars worth of transactions every year. Its subsidiary Pay Online is
+linked to the massive fraud Wire Card. How's the SEC Wire Card investigation coming along? For years, based on
+my extensive financials research and other research, I pleaded and pleaded with the SEC to shut down this
+massive fraud. They did not. email after email. Year after year I wrote the SEC "NETE is a money
+laundering/transaction laundering fraud". Rather than shut it down, the SEC with the help of NASDAQ allowed
+fraud public offerings by Crede/Peizer/Milken related entities: Esousa and Cobblestone and a reverse split so
+NETE could keep its NASDAQ listing. The balance sheet has been grossly insolvent for years: goodwill.
+ALL of my allegations were confirmed when NETE decided to "unlock value in its payment processing" business
+by doing a reverse merger with a CA EV "manufacturer" started by a musician. This fraud transaction is quite
+common in money laundering shell land dominated by NITE/VIRT. The SEC cover up of criminal activity while
+screwing whistleblowers:ME: The "payment processing business" is to be "sold". Related of course was the SEC
+cover up of criminal activity while screwing whistleblowers: ME: The Goldman/Sull Cromm advised purchase by
+ALLY of CardWorks: Merrick Bank: NETE and then the recent unwinding of this fraud transaction. No doubt the
+brain child of Chair Clayton and his Sull Cromm colleague Jared Fishman who has played a key role in keeping
+the criminal entity NITE/VIRT up and running.
+NETE/Mullen: "here glitchy glitchy" cover up. But, who the hell would EVER touch the massive fraud: NETE?
+Only another fraud: Mullen.
+Mullen doesn't "manufacture" ANYTHING. Mullen is simply a car dealership.
+The K50 EV is manufactured in China by Qiantu a subsidiary of CH-Auto. Qiantu/CH have a production facility in
+China. There will be no Mullen "production" of EV vehicles in Washington or anywhere else in the US.
+But, the SEC facilitated fraud doesn't end at protecting criminals and screwing whistleblowers: ME. Per my TCR
+attached, there is a well orchestrated eco system of fraud. Including "issuer/bag man funded research" that
+facilitates P&D. In fact, on 11/8/2018 the SEC brought a complaint against an entity I cited in 1 of my emails to
+the SEC: the record: known as SeeThroughEquity
+https://www.sec.gov/litigation/complaints/2018/comp-pr2018-259.pdf
+EFTA00069014
+
+Seethruequity, LLC, Ajay Tandon, and Amit Tandon
+THE DEFENDANTS 6. SeeThruEquity, LLC is a Delaware limited liability company that was co-founded in
+2011 by brothers Ajay Tandon and Amit Tandon.
+www.sec.gov
+SeeThroughEquity was engaged in a Pump and Dump promotion of NETE in April and August 2018
+https://www.netelement.com/press-releases/release-content/1062906#.XwRXEOWSnlV
+SeeThruEquity Issues Update on Net Element, Inc.
+NEW YORK, NY / ACCESSWIRE / April 10, 2018 / SeeThruEquity, a leading
+independent equity research and corporate access firm focused on smallcap
+and microcap public companies, today announced that it has issued an update
+on Net Element, Inc. (). The note is available here: NETE April 2018 Update
+Note. Net Element, Inc. (NASDAQ: NETE, "Net Element") is a global financial
+www.netelement.com
+https://www.netelement.com/press-releases/release-content/10734671#.XwRXGuWSnlV
+SeeThruEquity Issues Update on Net Element, Inc.
+NEW YORK, NY / ACCESSWIRE / August 6, 2018 / SeeThruEquity, a leading
+independent equity research and corporate access firm focused on smallcap
+and microcap public companies, today announced that it has issued an update
+on Net Element, Inc. O. The note is available here: NETE August 2018 Update
+Note. Net Element, Inc. (Nasdaq CM: NETE, "Net Element") is a global financial
+www.netelement.com
+So, the SEC SeeThroughEquity complaint acknowledges the fraud associated with NETE. Well orchestrated. This
+P&D campaign was part of the 2 fraud offerings : Esousa and Cobblestone: I alerted the SEC to. Who PAID for
+the SeeThrough P&D? Crede/Peizer/Esousa/Cobblestone?
+The cherry on top of the SEC corrupt obstruction: NETE was still in business in 2020 to receive taxpayer Cares
+Act money.
+A summary of the record.
+Janey, Hoecker et al,
+Please update my Net Element and AQR TCR's
+Cheers!
+Christopher J Dilorio
+Whistleblower
+Not just irony but a massive fraud on the
+EFTA00069015
+
+From: Chris Dilorio <
+Sent: Tuesdav lune 20. 2020 1:01 PM
+Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
+Janey,
+the purpose of your 5 years in the waiting PRELIMINARY denial of my OpCo Award application could not be any
+more clear: run the clock out and protect NITE, UBSS, Magna et al while denying me rightful compensation. But,
+As I have repeatedly told you, Hocker, your colleagues: the last overt act of this vast conspiracy has not yet
+occurred:
+NITE/VIRT is insolvent today 6/30/2020 as a direct result of the SEC facilitated fraud on the public which is and
+always has been the core business at NITE/VIRT: Abusive naked shorting publicly traded shells to facilitate
+money laundering. The public is STILL at risk. The SEC has facilitated NITE intentionally misleading the public as
+to the true nature of its business. The SEC still facilitates this massive fraud on the public while it intentionally
+misleads the public there is no naked shorting because the SEC authorized the DTCC to create the illegal,
+shadow clear mechanism Obligation Warehouse (OW) so NITE's criminal activity can continue and it can
+circumvent close out REQUIREMENTS of Rule 204 of Reg SHO. ALL very much ongoing in June 2020 as a direct
+result of the SEC (OWB/Hoecker/Enforcement etc etc) criminal obstruction and ACTIVE facilitation of the
+criminal enterprise known as Knight/KCG/VIRT: NITE.
+Clayton never disclosed his Sull Crom/Fishman/NITE conflicts. He must step down from the SEC IMMEDIATELY
+until a criminal investigation can be concluded. NITE must be halted IMMEDIATELY as it still poses a
+monumental risk to the investing public. FINRA should go back to being a cheerleader as it is just another
+enabler of this criminal activity. It has NO business enforcing SECURITIES LAWS. It should not be overseeing the
+OTCM. FINRA fines are a joke and not meant to be a deterrent. INTENTIONALLY siding with criminals over the
+investing public the SEC is mandated to protect. The cesspool known as the OTCM MUST be shut down. It exists
+SOLEY for the purpose of facilitating a massive fraud on the public. The OW must be shut down IMMEDIATELY
+so the public can see just how pervasive naked short selling: MANIPULATION really is. EVERYONE at the SEC
+who has had contact with my information MUST resign/be terminated IMMEDIATELY. ALL of the AQR blank
+check shells must be shut down IMMEDIATELY as they pose a serious national security risk. AQR MUST be shut
+down IMMEDIATELY.
+Certainly not exhaustive BUT a good start
+Cheers!
+Christopher J Dilorio
+EFTA00069016
+
+Whistleblower
+From: Chris Dilorio <
+Sent: Tuesday, June 30, 2020 7:36 AM
+Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
+Janey,
+please add the following info to my appeal of your preliminary denial of my Opco award.
+More evidence the SEC is using/has used my information to both bring complaints and protect/obstruct
+complaints. Again, you, McKessy, Hoecker have been in possession of my 2013 TCR filed with Berger for several
+years. In addition to hundreds of e mails continuing into 2020 showing irrefutable and overwhelming evidence
+to support my allegations.
+Highlighted in my attached TCR and related to my Opco Award application: Joshie Sason/Hanover/Magna:
+CGFIA, IMDS,NewLead,FreeSeas, PRTH etc etc etc. The SEC Sason/NewLead complaint is also my information as
+I filed separate but related NewLead, and FreeSeas TCR's with your office. The SEC complaint: Sason
+assignments: bogus notes. NO SH!T? Really? detailed by me. In addition to Bag Man Sason/Hanover/Magna, I
+detailed the illegal activity of Bag Man Justin Keener/JMJ in my 2013 TCR. Keener was the customer in the
+FINRA World Trade Financial complaint.
+https://www.finra.org/media-center/news-releases/2013/finra-fines-three-firms-900000-inadequate-anti-
+money-laundering
+FINRA Fines Three Firms $900,000 for Inadequate Anti-Money Laundering
+Programs | FINRA.org
+WASHINGTON - The Financial Industry Regulatory Authority (FINRA) announced today that it has fined
+three firms a total of $900,000 for failing to establish and implement adequate anti-money laundering
+(AML) programs and other supervisory systems to detect suspicious transactions.
+www.finra.org
+EFTA00069017
+
+Related to the billions of OTCM money laundering shells traded through World Trade, the BD SRO FINRA
+requested information from Keener related to his assignments and acquisition of bogus convertible notes
+including bank statements to prove the notes weren't bogus. Keener told FINRA to 'F Off"
+https://www.finra.org/sites/default/files/OHODecision/p182993_O_0.pdf
+FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING
+OFFICERS
+5 distributions of securities in violation of Section 5 of the Securities Act of 1933. Tr. 158, 179-180.6 On
+September 22, 2011, FINRA staff served a request on Keener, pursuant to FINRA
+www.finra.org
+FINRA barred Keener/JMJ in 2013 as a "Bad Actor"
+The SEC was certainly aware of the FINRA action
+https://www.sec.gov/litigation/opinions/2012/34-68014.pdf
+As recently as 2019 Bag Man Keener/JMJ was involved in ANOTHER money laundering shell called Blink
+Charging fka New Image Concepts
+https://www.sec.gov/cgi-bin/browse-edgar?
+action=getcompany&CIK=0001429764&owner=exclude&count=40&hidefilings=0
+https://www.sec.gov/Archives/edgar/data/1429764/000114420419004046/0001144204-19-004046-index.htm
+EDGAR Filing Documents for 0001144204-19-004046
+Blink Charging Co. (Subject) CIK: 0001429764 (see all company filings) IRS No.: 030608147 | State of
+Incorp.:NV | Fiscal Year End: 1231 Type: SC 13G/A | Act: 34 ...
+www.sec.gov
+New Image Concepts was detailed by the SEC in their Jaclin et al "Shell factory" complaint in 2016. PRIOR to
+Keener involvement.
+https://www.sec.gov/litigation/complaints/2016/comp-pr2016-86.pdf
+Case No. 2:16-cv-03250
+123456789101112131415 16 17 18 19 20 21 22 23 24 25 26 27 28 Case 2:16-cv-03250 Document
+1 Filed 05/12/16 Page 1 of 45 Page ID #:1 AMY JANE LONGO, Cal ...
+www.sec.gov
+But Keener not the only 1 involved who knew New Concept was a money laundering shell.
+CEO of Blink is Michael Farkas. SEC knows him well from his Skyway Communications days.
+The SEC revoked the registration of Farkas/Skyway in 2007
+EFTA00069018
+
+https://www.sec.gov/cgi-bin/browse-edgar?
+actionegetcompany&CIK=0001128723&owner=exclude&count=40&hidefilings=0
+The CFO of Blink is Jonathan New. Formerly CFO of the AQR/Crede: Milken money laundering/Transaction
+laundering blank check shell: Cazador/Arco: Net Element
+A director of Blink is a guy named Donald Engel who worked at Drexel with Milken.
+New Concepts was HO'd in Santa Monica: Milken
+But it gets better
+the Jaclin shell factory also linked to Honig,Stetson, Alpha Cap, Frost as well
+http://www.teribuhl.com/2019/08/06/honigs-shell-factory-attorney-gregg:jaclin-barred-as-sec-lawyer/
+Honig's Shell Factory Attorney Gregg Jaclin
+Barred as SEC lawyer - TERI BUHL
+Your Voice. High Times Admits SEC Filing is Wrong: Stormy Simon
+off the Board - L.A. Cannabis News on Text messages show
+Cannabis investors Defrancesco & Serruya allegedly Colluded
+with Clarus Securities Christodoulis in Multiple Stocks; High
+Times Admits SEC Filing is Wrong: Stormy Simon off the Board -
+www.teribuhl.com
+Where the SEC said multi billionaire Frost risked ALL to make a few million. NO, Frost,Alpha (also in my attached
+TCR), Stetson, Honig were LAUNDERING. Frost bought Ladenburg from Milken flunkie Icahn AFTER Icahn rolled
+Gruntal int Ladenburg. Gruntal: Icahn, Sater,SAC, Feinberg et al: Milken
+The SEC intentionally omitted a Honig/Stetson shell from this complaint:
+Millenium Bio/Inergetics
+linked to Trump Cleveland fundraiser and healthcare fraud felon: Brian Colleran
+In typical SEC "cover up", revoked the Millenium/Inergetics registration in 2019.
+https://www.sec.gov/cgi-bin/browse-edgar?
+action getcompany&CIK=0000072170&owner=exclude&count=40&hidefilings=0
+Finally,
+SEVEN F'n Years AFTER FINRA barred (not exactly) Keener/JMJ and my Berger TCR filed with your office Janey,
+The SEC is going after Keener/JMJ related to my information AGAIN
+17.5 BILLION shares of money laundering penny stocks.
+https://www.sec.gov/litigation/litreleases/2020/lr24779.htm
+Justin W. Keener d/b/a JMJ Financial (Release No. LR-24779; Mar. 24, 2020)
+SEC Charges Unregistered Penny Stock Dealer Litigation Release No. 24779 / March 24, 2020 Securities and
+Exchange Commission v. Justin W. Keener d/b/a JMJ Financial, No. 20-cv-21254 (S.D. Fla. March 24, 2020)
+www.sec.gov
+EFTA00069019
+
+WHO was/were executing BD's/MM's in these billions of shares of worthless Keener/JMJ money laundering
+shells????
+What are odds that bogus note/worthless certs/assignments Sason/Magna would be involved with bogus
+notes/worthless certs/assignments Keener/JMJ in money laundering shells like IMDS and CGFIA etc) AND
+CGFIA was detailed by me to the SEC/FINRA AND CGFIA was 1 of the shells in the FINRA Opco AML complaint
+AND where NITE and UBSS traded billions of shares of CGFIA
+AND where NITE and UBSS traded billions of shares of IMDS also
+Now, what are the odds of all of that?
+All you have to do is read my attached TCR Janey.
+Cheers!
+Christopher J Dilorio
+Whistleblower
+From: Chris Dilorio <
+Sent: Tuesday, June 23, 2020 4:11 PM
+Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
+small typos/corrections:
+Mirror trade activity peaked in 1H2014 not 2H2014 and this coincides with OTCM astronomical share volume
+data in 102014 and 202014 that were expunged from KCG 10Q SEC filings. Not 202014 and 302014 SEC
+reviewed 10Q's as I previously stated
+corrected below
+Chris
+From: Chris Dilorio «|
+Sent: Tuesday, June 23, 2020 9:48 AM
+EFTA00069020
+
+Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
+Ms Norberg,
+I am in receipt of the SEC OWB correspondence allowing me more time to respond to the preliminary denial of
+my award application for the Oppenheimer 2015 covered action. This e mail was the last 1 | sent to your office
+related to my appeal. It will serve as the basis of my appeal. Including the attachments of my 2013 TCR
+submitted with Berger Montague to the SEC. I will also forward correspondence from 2012 and following
+detailing my extensive correspondence with Robin Traxler at FINRA as well as Sean McKessy in the OWB. Even
+though, I have previously forwarded your office as well as the SEC IG office the exact same corroborating
+evidence. My response to you will be lengthy and detailed. However, given that it took your office FIVE YEARS to
+send me a preliminary denial notice, that is understandable and in fact a result of YOUR lengthy delay in
+notifying me. ALL of my response pertains to the denial appeal at hand.
+In 2011, I filed my first Whistleblower complaint with the SEC. Detailing a massive fraud on the public directly
+implicating dozens of entities. The center of my claims: Knight/KCG/VIRT: collectively NITE and the Swiss
+banking giant UBS:UBSS. By far, NITE was and still is today the largest MM/executing BD in the OTCM space. I
+was shocked to find the Swiss banking Giant UBSS was trading many of the same stocks as NITE and to the
+extent they were. This came on the heels of the FINRA UBSS Reg SHO complaint where the extent of the UBSS
+activity "threatened to undermine the integrity of our markets" while the SEC analysis of this activity was simply
+a case of "sloppy record keeping". My experience as an Institutional Sales trader: executing multi million share
+equity trades for the largest institutions in the world like Fidelity and Putnam. In addition, as a Research Sales
+person: analyzing financial statements and making investment recommendations formed the basis of my
+expertise. In fact, the SEC OWB has paid out awards for information just like mine. In August of 2011, I informed
+the SEC that NITE was insolvent having reported just $105 mil in working capital at June 30, 2011. AND, for the
+resaons cited in my TCR detailing massive accounting fraud as a direct result of illegal naked shorting/self
+clearing/reverse splits/cusip changes etc. The SEC had a choice: investigate these extremely serious allegations
+and shut down this massive fraud on the public OR cover up their failure and allow this massive fraud on the
+public to continue. Unfortunately for the American public the SEC is mandated to protect, the SEC chose the
+latter. As a direct result, ALL of the activity detailed by me in this TCR and other TCR's filed with the SEC as well
+as 9 years of additional correspondence with the SEC, this is very much an ongoing, massive scheme. One that
+the SEC actively facilitates. Countless losses have been incurred as a result. NITE as I detailed is in a constant
+state of insolvency. The SEC has time and again intentionally misled the investing public that there is no abusive
+naked shorting. NITE is still in business TODAY.
+The core business at NITE is and always has been: abusive naked shorting OTCM shells to facilitate money
+laundering. Not DMM, FCM, reverse mortgages, or even HFT. This illegal business is EXTREMELY profitable and
+virtually riskless. AND, both the SEC and FINRA know this. In 2016, FINRA brought a Rule 204 complaint against
+NITE. The fine was pathetic and not meant to be a deterrent. This is WHY the OTCM exists. But it's not JUST
+OTCM as my AQR TCR filed with the SEC clearly proves: NASDAQ Blank check shells as well. I have also filed
+separate TCR's related to NewLead and FreeSeas: 2 massive money laundering shells which began on
+NASDAQ, de listed to the OTCM. NONE of the activity detailed in the Opco/Gibraltar complaint takes place
+without a willing executing BD/MM who ultimately turns worthless certs into real money. That #1 trader is
+NITE. As you read in my Knight TCR CGFIA is at the heart and, because it was based in Colorado, became a
+template of sorts for my extensive research. See Ms Norberg, unlike the SEC "investigators" on the
+Opco/Gibraltar complaint, I've actually seen first hand the CGFIA "world HQ" as well as the rented Littleton
+home of CGFIA CEO Guyer. I've done extensive research on Properties claimed to be owned and M&A
+transactions done for the sole purpose of cert printing and distribution (Aurelio AMNP) where the ultimate
+EFTA00069021
+
+acquisition amounted to a distributor of Ukrainian folk music. I've also done extensive research on domestic
+and foreign financial institutions claiming to "invest" in these scam companies like Josh Sason/Hanover/Magna
+also cited in my 2013 Berger/Knight TCR linked. So, as I detailed to Ms Traxler, I followed Guyer to Neuchatel
+Switzerland and his previous endeavor: Antelope Technologies also with an office in Highlands Ranch CO.
+Where I discovered a connection to Swiss/German individuals/entities that were also related to another OTCM
+shell in the OpCo/Gibraltar complaint as well as my Knight TCR: AppTech. Offices in the Woodlands TX and Boca
+Raton. AND very much up and running today. SHOCKING. The SEC OpCo/Gibraltar complaint is based on the
+FINRA complaint. That is absolutely irrefutable. As the Gibraltar complaint alleges just 1 OTCM shell and just a
+million shares while Commissioners Stein and Aguilar referenced BILLIONS of shares in their OpCo waiver
+dissent. Who executed those BILLIONS of shares? Was OpCo even a MM? If I ask a question it's typically a
+rhetorical: I know the answer. The SEC knows the answer also. The SEC OpCo complaint does not mention the
+executing BD/MM. The SEC complaint doesn't mention Sason/Hanover/Magna either. The SEC complaint makes
+no mention of illegal naked shorting which is clearly evident in the CGFIA 10Q referenced below. THIS IS MY
+INFORMATION. So, why aren't NITE, Hanover/Magna and UBSS implicated in the SEC OpCo/Gibraltar complaint?
+What my TCR clearly and irrefutably proves: NITE was engaged in illegal activity both BEFORE and AFTER the
+SEC et al orchestrated August 1 2012 "trading glitch". So, the SEC bailed out a KNOWN criminal entity.
+Unfortunately for the investing public, the SEC has doubled downed on facilitating this illegal activity into 2020.
+The "glitch". Knight was insolvent in August 2011. I told the SEC this. The "glitch" proved my allegations. Key
+point in my TCR: NITE inadvertently sent 4000 worthless securities to JPM to secure an emergency bridge
+financing as collateral. These were open, naked short fails that could not be covered/closed due to a cusip
+change (SEC/FINRA approved rev split) booked as an "asset"(receivable) due to self clearing: MASSIVE
+accounting fraud. Ironically, the "glitch" proved my allegations: despite claiming to have a "highly liquid balance
+sheet" NITE had to raise the entire amount of the "glitch". AND the ultimate "financing" was not collateral
+based. Rather a 50% discounted convert when the stock had already been crushed to $3 OR $1.50. ALL of the
+financing participants knew the NITE balance sheet was complete fraud. NITE also committed securities fraud in
+pledging those 4000 worthless securities as collateral to JPM: SCOTUS Rubin: pledging collateral to secure
+financing is an offer to sell. JPM looked the other way. As did the SEC.
+Further, I submitted my amended TCR with Berger in March 2013, In August of 2013, FINRA brought a penny
+stock AML complaint against OpCo. Sale of unregistered penny stocks. WHO ultimately executed the trades?
+2008-2010. In July 2013, the "glitch" financing Gen Atlantic/Getco reverse merger with Knight to form KCG
+closed. The new CEO of KCG was Dan Coleman who ran Equities at UBSS during their Reg Sho and cross border
+activity. For UBSS, the DOJ (Acosta Downing et al) dropped their DPA in 2010. My claims: the FINRA
+OpCo/Gibraltar complaint clearly implicates UBSS criminal activity AFTER the DoJ dropped its UBSS x border
+DPA. This is what the SEC is protecting in the OpCo/Gibraltar complaint: NITE/UBSS/Hanover/Magna illegal
+activity.
+Also in my Knight/Berger 2013 TCR: IMDS. A multi year money laundering shell kept up and running by the SEC.
+Also NITE,UBSS, and Hanover Magna. In addition to other entities like JMJ, Southridge, and Alpha Capital
+Anstalt. Alpha Capital Anstalt is very much in business today as a result of SEC obstruction while the SEC
+recently brought a complaint against JMJ for activity like that in IMDS even AFTER he was barred by FINRA. In
+IMDS, the SEC allowed 2 barred individuals (CEO/CFO) to do an offering that created 37 BILLION shares of IMDS
+at .0001 with Chinese Nationals before revoking the IMDS registration. What do you do with 37 billion shares of
+IMDS at .0001 when there are no bids below that? NOTHING. The stock never traded. The SEC orchestrated a
+NITE/UBSS/Hanover/Magna/JMJ/Alpha etc MASSIVE naked shorting to facilitate money laundering scheme
+bailout so that the MASSIVE naked short position didn't need to be covered in the open market as is mandated
+by Rule 204. Thus insuring profits and not MASSIVE losses for NITE and UBSS.
+I also filed separate TCR's for NewLead and FreeSeas. 2 "Greek shipping" money laundering shells started on
+NASDAQ and delisted to OTCM. NITE top trader in BOTH. Hanover/Magna in both. I contacted the Ky Div of
+Mines and notified the SEC that these "transactions" were complete fraud. The SEC Feb 2019 complaint against
+Hanover/Magna is my information: Bogus obligations, assigned, converted to worthless certs. Then dumped on
+EFTA00069022
+
+the public and converted to REAL money by the executing BD/MM:NITE. Who generates illegal trading profits
+by abusive naked shorting. Very symbiotic relationship. 1 of the Hanover/Magna entities was Gibraltar/Hanover.
+Somehow omitted from the SEC OpCo/Gibraltar complaint. In NewLead, then SEC White and Ceresney firm
+Debevoise did a "fairness opinion" of a Russian Nickel wire transaction where the NewLead CEO had back dated
+documents. That has been expunged from SEC reviewed filings. FreeSeas: a structured tax evasion/money
+laundering shell. Also involved Credit Suisse and Deutsche Bank. Both Debevoise clients. Both involved in the
+tens of billions Russian Mirror trade scheme. In addition to Hanover/Magna a Milken related entity Crede: Run
+by Milken/Drexel/Obstruction of justice/Parking: Terren Peizer and his felon partner Michael Wachs. This led me
+to Net Element NETE. Peizer again. This time with more AML red flags than be counted. Well known to the SEC
+through TWO of my separate TCR's. CEO is Oleg Firer. Firer former money laundering shell Acies shut down by
+the SEC while NETE was left up and running. Acies very much up and running also in MA. In NETE: NASDAQ.
+AQR Blank check shell. SEC allowed 2 offerings so that NETE could keep its NASDAQ listing. 1 was with entity
+Esousa: felon Wachs ex wife. 2nd was with Cobblestone: felon Wachs sister. I told the SEC. They still approved
+the offerings. I discovered AQR money laundering blank check shell activity doing research on NITE and
+Hanover/Magna. A top traded NITE OTCM shell was Cereplast. Another AQR blank check shell.
+Hanover/Magna/NITE/ and Alpha Capital Anstalt. Alpha is Liechtenstein based and controlled by Martin Schlaff:
+Austria/Israel. AlsolMDS (w/Schlaff controlled Balmore) and the Frost/Honing/Stetson et al complaint. Schlaff
+also LH Financial/Wolfson/Sulphco and Bawag: Sedona/Scan Graphics: Refco: Naked shorting. NITE is Refco on
+steroids. Cereplast ended in bankruptcy.
+NETE claims to be a "payment processor". BILLIONS in transactions processed. Never break even let alone
+profitable. Balance sheet complete fraud. AML red Flags: Firer is Grenada Amb to Russia living in Miami,
+Apockinas/Grinshpun/Antonov/Rakishev/Trump/Kushner/SBNY/CardWorks/Merrick Bank/ESQ/Cohen etc etc
+etc money laundering/transaction laundering BILLIONS shell. Kept up and running for years since filing my
+NETE/AQR SEC TCR's. ALL of my allegations proved accurate in 2020 when NETE received Cares Act taxpayer
+money then announcing it was "unlocking the value in its misunderstood payment processing business" by
+doing a reverse merger with a CA electric car company started by a former musician. The payment processing
+business to be "sold" and the new company (Mullen) will own 80-90%. All made possible by SEC obstruction
+and ACTIVELY facilitating illegal activity. Another AQR blank check shell is Astra/Phunware. More Greek shippers
+related to massive swindler Economou originally intended to do an "energy logistics company" acquisition and
+somehow settled on "mobile app developer" Austin TX: Phunware. PHUN CEO is well known to the SEC with
+shells going back 15 years. I alerted the DoJ and SEC that PHUN was a money laundering shell. In addition to the
+"genius quant" AQR, AIPAC: Gerber/Hudson Bay, Nordlicht: Ari Glass/Boothbay, 1MDB: Khazanah Nasional,
+Global Crown/Rani Jarkas/EFG/BS|/Optima/Max Fang. AG Barr 1MDB waivers: Kirkland also AQR. Broidy: |
+Trump: 1MDB money laundering. PHUN also received Cares Act money. AND PHUN is Trump/Kushner/Parscale
+campaign mobile App. PHUN should have also been shut down long ago. AQR too. OTHER AQR blank check
+shells: CIS/Delta/Urban Tea, Ability/Cambridge, Hunter Maritime, and MI Acquisition/Priority Tech Holdings.
+Ability/Cambridge: Israeli cellular intercept/surveillance. Israel sent employees to jail. In the US it was
+"securities fraud". The SEC Ability/Cambridge complaint was handled by Ansu Banerjee in the SECLA office.
+Milken/Mogilevich/BoNY money laundering entity Sinex: Debasish Banerjee. WHY did SECLA have jurisdiction
+over ABILF/Cambridge? Result: ABILF is very much up and running today. I believe this is the
+PHUN/Trump/Kushner/Parscale mobile app technology.
+Hunter Maritime:HUNTF: Never consummated an acquisition. Just cert printing/dumping. Also involved: Milken
+family office: Silver Rock. MI/Priority:PRTH. CEO Tom Priore: well known fraudster to the SEC. Also
+transaction/money laundering like NETE. Also involved: Hanover/Magna.
+ALL AQR money laundering shells up and running today thanks to the SEC. Only recently did the SEC revoke
+CGFIA and NewLead. well after going dark and the massive fraud on the public had already been perpetrated. In
+NewLead, FreeSeas, etc etc etc a common tool used is reverse splits to perpetuate and facilitate illegal activity.
+SEC/FINRA approved. The result is the massive accounting fraud at NITE. WHEN not IF there is an open naked
+short fail when a rev split takes place, a new CUSIP/security is issued. Trades in the old cusip/security cease.
+EFTA00069023
+
+This creates a structural liability. The fail/short can NOT be closed. Like covering a short in AAPL with MSFT.
+Because NITE is self clearing it books a prop naked short as a receivable. An asset. But, because NITE won't or
+CAN'T deliver, massive accounting fraud. Literally a liability booked as an asset. This is how "glitches" are born.
+But the SEC facilitated fraud doesn't end there. The definition of a failed trade: 1 that hasn't settled. The
+SEC/DTCC issue new securities where trades in the old haven't settled yet AND not authorized by the issuer.
+Settlement: buyer brings cash/seller brings securities. The DTCC simply makes journal entries. But there are still
+"IOU's" in the system. The SEC authorized the DTCC to create a shadow clear,non guaranteed, ILLEGAL (clearly
+contrary to 34' Act "prompt and accurate settlement) Obligation Warehouse so criminals like NITE et al can
+circumvent close out REQUIREMENS of Rule 204. The OW is just what it sounds like. Per my Knight TCR, DTCC
+suspends services (Chill/Lock) and trades are deemed "ex clearing". In a FOIA request made with POGO,Berger
+and I asked the SEC fails data on dozens of NITE/UBSS top traded stocks like CGFIA, APCX and IMDS. The SEC
+response: see our website. The SEC fails data is for DTCC cleared trades only. The SEC knows exactly the level of
+fails sitting in the OW. They don't disclose. Intentionally misleading the public there is no naked shorting. In
+1Q,2020, the receivable at NITE/VIRT increased $1.2 BILLION sequentially. Up almost 90%. AND the tangible
+book value is grossly insolvent. When it comes down to it, there really isn't ANYTHING in the receivable that
+NITE can convert into cash for its own use. There are prior commitments on those "assets": SETTLEMENT of
+transactions. Because the SEC has never shut down this activity, NITE is in a constant state of insolvency.
+Other examples of SEC attempts to cover up NITE illegal activity so that it can continue include:
+Cerberus/Feinberg/VIRT bidding on NITE post "glitch". Wasn't their turn. First, Gen Atlantic needed to monetize
+its GETCO "investment". The HFT business at GETCO was in a death spiral when the rev merger took place. So
+what was the attraction to NITE? The business that had absolutely ZERO overlap/synergies: OTCM. As low tech
+as it gets. Literally a trader sitting in a chair. As I have asked the SEC on hundreds of occasions over the years:
+what would happen to NITE trading profits if their OTCM share volumes went to ZERO? Cerberus is Feinberg:
+Gruntal/Milken. Also bailed out Bawag:Refco, HSH, and Deutsche Bank ($50 bil Bad Bank to Goldman). Another
+Milken/NITE connection is Rich Handler: Jefferies. Also a Milken/Drexel protege. Milken was Gruntal:
+Feinberg,SAC, Icahn, Sater etc. Gruntal was "sold" to Ladenburg. Controlled by
+Vector/NewValley:|cahn/Lorber/Elliman etc. And, was sold to multi billionaire Frost. Who, according to the SEC
+risked it all trying to "make" a few million when he, Honig, Stetson, Alpha et al were really LAUNDERING. Milken
+also Whiterock ,D H Blair (Morty Davis) and AR Baron (Bressman/D H Blair) which was the precursor to Bear
+Stearns collapse. So, Milken and his merry crew of flunkies are really at the nexus of JUNK. They own Trump
+and his White House (Trump casino junk) and they own the SEC. It was Milken, Leon Black, Handler, Moelis,
+Virtue: Drexel that caused the S&L taxpayer bailout stuffing them with junk like Trump's. It is no coincidence
+that these same flunkies are also the largest CLO originators/managers. CLO's: Junk on steroids. AGAIN Bailed
+out by taxpayers in Cares Act HY. There also connections to Epstein. Treasury Sec Mnuchin and Black:
+HY/Junk/S&L's and Epstein. Black: Money laundering shell ESWW kept up and running by the SEC was/is an
+Epstein money laundering vehicle: JUNK IS JUNK.
+THIS EXPLAINS the Handler/Jefferies/Milken repeated bailouts of NITE. It also explains the SEC criminal
+obstruction.
+SEC Chair Clayton is also directly linked to this criminal obstruction. His firm Sullivan Cromwell and Jared
+Fishman are ACTIVELY facilitating this massive fraud on the public. Clayton did not disclose these conflicts in his
+disclosures. Sull Crom/Fishman have advised Knight/KCG/VIRT and several transactions designed to facilitate
+this ongoing and ongoing fraud on the public. Many of the same players involved in the "glitch" were involved in
+the VIRT acquisition of KCG in July 2017. In addition to Sull Crom/Fishman and Handler/Jefferies: JPM and
+Goldman. The SEC facilitated fraud in the NITE/VIRT transaction is egregious illegal activity. The transaction
+NEVER should have happened. KCG was an SEC reporting company until the deal closed on July 31 2017.
+Despite this FACT, VIRT CEO Cifo refused to "publish" KCG 2Q2017 financials. I estimate
+Cifu/Coleman/Handler/GS/JPM wrote down more than $4 billion in open naked short fails: "leverage". The SEC
+let him. Meaning: "assets" used to determine the take out/ tangible book of KCG was complete fraud. VIRT
+grossly OVER paid for insolvent KCG.
+EFTA00069024
+
+Prior to the NITE/VIRT transaction closing in July 2017, NITE would report its trading stats monthly. Including
+OTCM share volumes. Cifu stopped this post merger. The SEC let him. In fact, you will find NO reference to
+NITE/VIRT OTCM share volumes in any SEC reviewed filing, sell side research or investor presentation. A well
+orchestrated fraud on the public. Omissions to Intentionally mislead the public as to the true representation of
+the NITE/VIRT business model. These share volumes are also at the center of my 2013 Berger TCR. There are no
+affirmative disclosures in any SEC filings to this day as to the AML risks posed in trading these OTCM and other
+shells. In a 2014 letter to the SEC, I detailed the first 2 months of NITE OTCM share volumes. When the 102014
+10Q was filed, these volumes were confirmed: An ASTRONOMICAL increase sequentially as well as year over
+year. These share volumes/my letter/TCR SHOULD have triggered an immediate SEC investigation. It did not.
+This portion of the KCG 1Q2014 10Q was expunged as well as 2Q2014 OTCM share volumes. I have detailed this
+to the SEC/OWB/Enforcement/IG. In the months leading up to the NITE/VIRT closing in July 2017, KCG put out
+monthly trade stat pr's showing KCG trading more volume than the overall market. Also indicative of naked
+shorting. Those pr's were also expunged. I also including electronic forms to the SEC OWB/Enforcement/IG.
+The SEC has essentially outsourced the ENTIRE OTCM market to the Broker Dealer SRO FINRA. Including:
+management of the OTCM share volume website fka OtcBB.com. Today, there is very little transparency into
+trading activity by MM as a result. Also: ISSUER corporate actions: rev splits, Short interest reporting: an
+absolute farce given there is still no CAT. AND BD compliance with the BSA. Per my TCR: WHY did NITE and UBSS
+trade Billions of shares of CGFIA and IMDS AFTER a Chill or Lock was placed (ex clear/OW)? CLEAR AML red
+flags. Because they had an open naked short position. Why not pull a market? Because they had an open naked
+short position. SAR'S? WHEN? BEFORE OR AFTER THEY TRADED BILLIONS OF SHARES? There were no SAR'S
+either. NITE can not outsource its compliance responsibilities to 3rd parties (like OpCo) when executing trades
+as MM. In 2015 at a SIFMA conference, Ceresney was "shocked" by the number of BD's under his supervision
+filing 1 or ZERO SAR's. NITE SHOULD have been investigated for egregious BSA violations long ago based on my
+TCR. Knight/KCG/VIRT:NITE is and always has been a criminal enterprise. Spitzer Russian/US mob bust:
+"worthless paper". Ashton Tech became VIE became Optimark became Knight/Trimark NITE literally "made by
+the mob". The SEC has known this for years. ALL of the "worthless paper" shells were SEC reporting companies.
+Today, Trump PA Campaign Mgr David Urban sits on the NITE BoD. AND is also on the BoD of his very own
+money laundering shell: Canadian/Pakastani/pot/COVID: FSD Parma: HUGE. Trump advisers/campaign staff
+Bannon and Parscale also involved in OTCM money laundering shells. Parscale Cloudcommerce fka Roaming
+Messenger also receiving taxpayer Cares Act money.
+Madoff: more money laundering than Ponzi. HOW THE HELL did the SEC let that scam go on for as long as it
+did? Criminal obstruction. The former SEC IG Kotz actually investigated his "bosses" at the SEC unlike current IG
+Hoecker. Years of SEC obstruction. Bullshit "investigations" into "running ahead" meant to distract. Similar to
+the SEC "glitch" "market access complaint" where former SEC "glitch" Enforcement Dir Khuzami/Kirkland(Barr)
+also rep'd NITE. Can't make this up. The center of IG Kotz scathing failure of the SEC in Madoff: SEC NY and Mr
+John McCarthy who ended up being Knight/KCG Chief Counsel. As I said: can't make this up. And, as we know
+Madoff started his career in NASDAQ penny stocks exactly like the 1's in the Spitzer/Mob complaint.
+OTCM: This is WHY the OTCM exists: abusive naked shorting publicly traded shells to facilitate money
+laundering. CEO Cromwell Coulson CHAIRED the FINRA market Regulation Cmte. Say it with me: Can't make this
+shit up: CMTSU. A founding OTCM Board member is former NITE trader Andrew Wimpfheimer: CMTSU. This is a
+very well orchestrated and ongoing fraud on the public. Russian mirror trades: no SEC OR DOJ investigation
+HOW? According to stories: activity peaked in 1H2014. Coinciding with NITE astronomical OTCM 1Q2014 share
+volume increase. In additional to money laundering penny stock shells, the OTCM is also home to many ADR's.
+Including Russian ADR's cited in the NYDFS/DBTCA/mirror trade complaint. Little/no disclosures. Also in my TCR:
+P&D is just a tool used to facilitate the fraud and NOT a stand alone fraud. The SEC intentionally stops short of
+thorough investigations into much bigger frauds. The same way it has the public believe the "penny stock
+trading fairies" convert worthless certs to real money. NO! willing executing BD's and MM's like NITE do that.
+Less than a year after filing my Knight TCR with Berger, FINRA (not the SEC) brought the BBH AML complaint.
+This was my information. Swiss banks, foreign/domestic institutions, executing BD's/MM's/ penny stock shells:
+EFTA00069025
+
+$850 mil in proceeds. Did BBH implicate NITE and other entities in my claims? WHY are all of the entities in the
+complaint UN NAMED? In the interest of transparency for the investing public? In 2019, I also filed an award
+application for the UBS x border/AML complaint. This is BLATANTLY my information. SEC/FINRA/ AND the SEC. I
+filed an IRS TCR based on my SEC TCR attached. In April 2016, 2 IRS CI Agents: VIKAS Arora and Nathan Sarnacki
+flew to Denver from Chicago to meet with me. I believe they were blown away. Then came the UBS complaint.
+As a follow up to our meeting, they wanted to know WHO at the SEC I shared my information with. I told them.
+That was the last I heard from them although I continued to send them my information.
+To the SEC IG Carl Hoecker: In 2015 | parted ways with Berger as I was convinced the SEC was using my
+information in an unethical/illegal manner to both bring and obstruct complaints. Berger was not willing to file
+an IG complaint. After parting ways, I almost immediately did just that. Prior to retaining Berger I had filed an
+award application for the UBS Reg Sho complaint. In my submission and my correspondence with
+Mckessy/OWB I made the claim based on OWB permissible rules to "open a new line of inquiry". One that
+would link the trading activity detailed in my ultimate TCR by NITE and UBSS. That link: Abusive naked shorting
+publicly traded shells and money laundering. My application was denied and there was no investigation into
+this link. The SEC had just bailed out a "known criminal enterprise":NITE "glitch" was not a forthcoming
+admission. Neither was the blatantly and knowingly false pretext for the DOJ dropping its UBSS x border DPA
+because "UBSS was in full compliance" in 2010. So, rather than open a new line of inquiry, the SEC chose to
+obstruct.
+I made clear to Hoecker the egregious conflicts by Khuzami,White and Ceresney with clients UBS,JPM, CS, and
+DB. Hoecker claims to have conducted a "thorough" investigation of my very serious allegations and found
+nothing. Despite MJW waivers received to "investigate" her Swiss bank client CS. Then in 2019, Hoecker
+arrogantly told me I could file a FOIA request on his findings. Then, came 2019 and absolutely nothing had
+changed. NITE was still trading billions of shares of OTCM shells like ELTZ. There were still no risk disclosures.
+Cifu refused to publish KCG 202017 financials, Hanover/Magna/AQR/Alpha/IMDS etc etc etc were still up and
+running . I filed ANOTHER complaint with IG Hoecker. Despite the fact that Hoecker himself wroth the IG
+handbook on "thorough investigations" mandating complainant interviews, I have never been interviewed by
+Hoecker. In addition, the IG Hoecker is mandated to inform Congress as to serious allegations like mine. He did
+not. In doing so, obstructed Congress from executing its oversight of the SEC/OWB. And despite hundreds of
+offers to fly to SEC HQ to have the best and brightest at the SEC rip apart my allegations 1 by 1 | have never
+been taken up on my offer. Why is that? The SEC OWB has gone to great lengths in other cases to explain the
+OWB process etc to whistleblowers. I have never been told "no thanks" for my information. In fact, McKessy has
+solicited MORE information from me after submitting my Berger TCR. In Madoff, an intern could have
+verified/shut down in weeks NOT years. No contra parties. Only a well orchestrated obstruction by
+SECNY/McCarthy et al kept it up and running. As I have also repeatedly told the SEC: My claims could be verified
+in weeks also. NITE has a P&L for every stock they trade. These, aggregated, are basis for quarterly trading
+profits. These P&L's, combined with OW data, and balance sheet data will validate ALL of my claims. I've offered
+my service to do exactly that. 2 weeks max. Afterall, proprietary trading strategies are NOT proprietary if they're
+illegal. For the reasons I have listed in this summary, NITE/VIRT is on the SEC "do not investigate list". And yes,
+there most definitely is such a thing. Especially when it comes to illegal activity facilitated by the SEC. So, the
+SEC denial of my OpCo award claim which was 5 years in the making is just another example of my very serious
+allegations: The SEC solicits and uses whistleblower information like mine to both bring and obstruct
+complaints. Unethical. Illegal. To deny my award application because the "investigators" didn't see my
+information is further affirmation of my allegations. They saw it. They used it. They denied my compensation for
+it. Again Ms Norberg, I will forward my 2012 etc emails with Robin Traxler at FINRA as well as McKessy as
+further evidence that my Award application denial should be overturned. Further affirmation from 2 dissenting
+SEC Commissioners and the judge in the Gibraltar case makes this denial both egregious and bizarre. Bizarre
+ONLY if you believe that there is no SEC obstruction that is. BTW, crazy stuff going on with the firing of Mr
+Berman/Clayton nomination to take his place/Rabbitt to DoJ/Carpenito replacing Audrey Strauss/Trump/Barr
+don't you think? The SEC needs some fixers. Wonder why.
+EFTA00069026
+
+I'm cc'ing some our mutual friends on this email Jane. The last overt act of this massive ongoing, SEC facilitated
+conspiracy has not occurred yet.
+Cheers!
+Christopher J Dilorio
+Wistleblower
+From: Chris Dilorio ‹
+Sent: Wednesdav, June 10.2020,2:20 PM
+Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
+Mr Roach,
+The SEC is irrefutably using my information in unethical and illegal manner. My information is being used to
+BOTH Bring complaints AND obstruct/protect investigations into entities detailed in my various TCR's. Denying
+me rightful compensation. This is the latest example......
+Chris
+From: Chris Dilorio <
+Sent: Monday, May 18, 2020 10:36 AM
+Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
+As straightforward as it gets:
+The SEC OWB dragged its feet for 5 years in issuing its preliminary denial notice.
+The SEC knows this is my information. The SEC committed fraud on the court in Gibraltar. The judge corrected
+them. The SEC was omitting information that implicated NITE, UBSS and customers like Sason/Hanover/Magna.
+The SEC was obstructing a thorough investigation of my claims. The naked shorting cited in the CGFIA 10Q in
+2013 PROVES my allegations. The SEC's "targeted investigation" stops short of a full accounting. The SEC
+Gibraltar complaint does NOT explain the totality of the Oppenheimer complaint. The SEC Gibralter complaint
+cites 1 OTCM shell and less than 1 million shares traded by Opco. 2 dissenting Opco waiver SEC Commissioners
+proved that also citing "BILLIONS" of shares in their dissent. The SEC/Opco AML complaint was based on the
+FINRA complaint and my information. The SEC OWB concocted a completely fabricated reason for denying my
+Award: "The SEC investigators involved never saw claimants information". The responsibility to distribute
+Whistleblower information within the SEC is the exclusive and explicit responsibility of the OWB. As a result, the
+massive fraud taking place continued well into 2020. The 1Q2020 10Q, proves this.
+The SEC IG Hoecker is guilty of violating specific IG requirements in keeping Congress informed of serious
+matters like mine. The SEC IG Hoecker has never interviewed me despite my filing 2 separate complaints with
+his office. The SEC IG Hoecker is guilty of criminal obstruction. SEC Chair Clayton and Co Enforcement Peikin
+worked at Sullivan Cromwell with Jared Fishman. Fishman has played a key role in the SEC facilitated criminal
+obstruction. Peikin and Clayton should have recused themselves from ANY pending NITE/VIRT matter before
+EFTA00069027
+
+the SEC: My information. Clayton and Peikin should have recused themselves from the SEC facilitated KCG/VIRT
+merger. My information, including the Opco AML complaint SHOULD have stopped the merger from ever
+happening. 2 former SEC Commissioners agree with that analysis. The SEC is actively facilitating a massive
+, ongoing fraud on the American people they are mandated to protect. NITE/VIRT is a criminal entity. The SEC
+MUST invoke emergency powers and halt trading in VIRT IMMEDIATELY.
+In short Mr Arp, the criminal activity actively perpetrated by the SEC OWB/IG must be referred to law
+enforcement as well as Congress. Separate but related: SEC facilitated criminal activity and my claims. The
+criminality is a matter for law enforcement. My pending matters with the SEC have no bearing on a criminal
+investigation OR a GAO investigation.
+You are incorrect in your analysis.
+1 Urge the IG Integrity Board to have SEC IG Hoecker refute my claims point by point.
+I will be on a plane tomorrow so he can do it in person.
+Cheers!
+Christopher J Dilorio
+Whistleblower
+From: Chris Dilorio <
+Sent: Tuesday, May 12, 2020 8:54 AM
+Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
+Almost immediately I filed a formal appeal to the SEC OWB fabricated denial of my award application. In this
+appeal I show irrefutable proof of my allegations: The SEC OWB used/ is using my information to both bring
+complaints AND obstruct complaints while denying me compensation. In short: My information exposes an
+ongoing, massive in scope, SEC facilitated fraud on the American people. Rather than shut it down, the SEC has
+chosen to cover up so that the illegal activity can continue. It does in 2020
+Chris
+From: Chris Dilorio <
+Sent: Monday, May 11, 2020 7:16 PM
+Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
+From: Chris Dilorio //
+Sent: Wednesday, April 29, 2020 8:03 AM
+Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
+The SMOKING GUN in my allegations:
+EFTA00069028
+
+Naked shorting in CGFIA (My TCR/FINRA complaint) by "un named third party BD" in 2013. Well known to the
+SEC. This is why there was no investigation into the ENTIRETY of the FINRA trading activity. The SEC issued
+waivers to Opco within days of its AML complaint. WHO was the SEC protecting? WHO were the customers and
+executing BD's/MM's in the Opco complaint? ALSO well known to the SEC:
+MY INFORMATION. 5 years to get a preliminary denial: statute of limitations. BUT the last overt act of this
+ongoing conspiracy has not yet occurred.
+Chris
+From: Chris Dilorio <
+Sent: Wednesday, April 29, 2020 7:56 AM
+Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
+Still more evidence of a well orchestrated scheme to cover up and obstruct a FULL SEC investigation into
+Opco/Gibraltar/NITE/UBSS trading activity in billions of shares of OTCM money laundering shells. The SEC used
+my information to bring AND obstruct complaints.
+The 2 SEC Commissioners dissent in granting Oppenheimer waivers after this egregious activity
+https://www.sec.gov/news/statement/dissenting-statement-oppenheimer-inc.html
+SEC.gov | Dissenting Statement In the Matter of Oppenheimer & Co., Inc.
+Dissenting Statement In the Matter of Oppenheimer & Co., Inc., by Commissioner Luis A. Aguilar and
+Commissioner Kara M. Stein, February 4, 2015
+www.sec.gov
+In fact, the SEC waivers came within days of their complaint. Here, these 2 Commissioners cite Oppenheimer
+trading "BILLIONS of shares of penny stocks". Clearly, they were not JUST referencing the SEC Gibraltar
+complaint. WHO was the SEC protecting with its complaint then waivers?
+The smoking gun which I have provided to the SEC on several e mails:
+Which came in an SEC reviewed CGFIA 10Q
+https://www.sec.gov/Archives/edgar/data/1344394/000135448814000425/cgfi_10q.htm
+cgfi_10q.htm - SEC
+Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or
+15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period
+that the registrant was required to file such reports), and (2) has been subject to such filing requirements
+for the past 90 days.
+EFTA00069029
+
+www.sec.gov
+Pg 27
+"Our stock is subject to a "Global Lock" imposed by the Depository Trust and Clearing Corporation (DTCC)"
+"On September 24, 2013, we were notified that the DTCC would be placing a 'Global Lock" on the Company's
+Class A stock as a result of actions by a third-party broker dealer. On November 11 2013, DTCC imposed the
+"Global Lock". Since less than 0.02% of the Company's Class A common stock shares were held within DTCC,
+Management chose to not undertake the expense of challenging the Global Lock. Nevertheless, shares that are
+held in street name (CEDE & CO), will not be able to be withdrawn from DTCC without further action."
+Of Course, I have hard copies if you prefer.
+ex clearing: The illegal SEC/DTCC Obligation Warehouse.
+This is CLEAR, IREEFUTABLE, INCONTROVETIBLE evidence of naked shorting by executing BD's in CGFIA. This
+activity took place per my Knight/UBSS TCR submitted to the SEC. So, WHY did the SEC obstruct an
+investigation into the ENTIRETY of the trading activity in the FINRA (and FINCEN) complaints? WHO were the
+executing BD's/MM's? WHO were the customers?
+The veracity of my information is also irrefutable and incontrovertible.
+Game. Set. Match. The SEC is a grossly corrupt, criminal enterprise facilitating illegal activity detailed by me so
+that this activity can continue. It does in 2020. The SEC solicits then uses Whistleblower information (MINE) to
+bring complaints AND obstruct other illegal activity while denying proper compensation to whistleblowers (ME).
+The SEC KNEW who the "third party BD" was in the CGFIA filing long before it filed its Opco complaint in 2015. It
+had my TCR in its possession in March 2013. So why did it take 5 years for the SEC to issue its preliminary
+denial? I would remind the SEC that this is very much an ONGOING conspiracy on the part of the SEC et al.
+IN FURTHERANCE OF THE CONSPIRACY.....
+Cheers!
+Christopher J Dilorio
+Whistleblower
+From: Chris Dilorio <
+Sent: Tuesday, April 28, 2020 7:24 AM
+Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
+Per my extensive SEC TCR's: Josh Sason/Emanuel/Abitebol/Hanover/Magna extensive overlap with NITE/VIRT
+(and AQR) money laundering shells.
+The SEC Sason/Magna/NewLead Feb 2019 complaint: also my information
+https://www.sec.gov/litigation/complaints/2019/comp24403.pdf
+EFTA00069030
+
+Marc P. Berger SECURITIES AND EXCHANGE COMMISSION Brookfield Place
+200 Vesey Street, Suite 400 New York, NY 10281-1022 SOUTHERN
+DISTRICT OF NEW YORK JOSHUA SASON, MARC MANUEL,
+3 5. In addition, Pallas acted as an underwriter for a primary offering of NewLead stock, which NewLead
+attempted to disguise as an asset sale transaction.
+www.sec.gov
+https://www.sec.gov/Archives/edgar/data/1322587/000114420413065095/v361773_sc13g.htm
+www.sec.gov
+(i) Sole power to vote or to direct the vote. The information required by Item 4(c)(i) is set forth in Row 5 of
+the cover page for each Reporting Person hereto and is incorporated by reference for each such Reporting
+Person.
+www.sec.gov
+MG Partners Ltd: Abitebol
+But not in the complaint: MAGNA GIBRALTAR INVESTMENTS LLC: also Abitebol
+As with Opco/GIBRALTAR, who is the SEC protecting?
+AND, per my extensive correspondence with the SEC re my TCR's: The SEC is ALSO grossly under estimating the
+criminal activity in NITE/Magna/NewLead
+SEC: Criminals bailing out/actively facilitating criminals/criminal activity.
+soliciting/using whistleblower information in unethical/illegal manner to bring complaints/obstruct
+complaints/deny whistleblower rightful compensation.
+Cheers!
+Christopher J Dilorio
+Whistleblower
+From: Chris Dilorio <
+Sent: Tuesday, April 28, 2020 6:43 AM
+Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
+More evidence of SEC fraud on the court in Gibraltar.
+It is CLEAR that the Opco AML Covered Action 2015-016 was NOT ENTIRELY based on the SEC Gibraltar Action.
+The SEC Gibraltar action covered trading activity in just 1 OTCM Money laundering shell: Magnum d'Or where
+Opco traded less than 1 million shares. CLEARLY the SEC Opco complaint was based on the trading activity in the
+FINRA Opco AML complaint: my information. However, the SEC Opco complaint even stops short of a thorough
+EFTA00069031
+
+investigation of the ENTIRETY of the FINRA trading activity. WHY? WHY didn't the SEC Opco/Gibraltar complaint
+go into trading activity in the FINRA AML OTCM shells through 2014 as FINCEN did? WHY did the SEC omit
+MATERIAL information to the court in Gibraltar causing a "significant under estimating" of criminal activity?
+The SEC knows who the accounts were. The SEC knows who the executing BD's/MM's were. The SEC committed
+a fraud on the court in Gibraltar.
+Gibraltar was ROLLING OUT NEW OTCM services into the end of 2011.
+https://www.pr.com/press-release/355246
+Gibraltar Global Securities Now Offering Offshore Brokerage Accounts -
+PR.com
+Nassau, Bahamas, The, September 22, 2011 --0-- Gibraltar Global Securities is now offering offshore
+brokerage accounts in addition to their broad array of financial services. Gibraltar Global ...
+www.pr.com
+https://www.pr.com/press-release/355247
+GGSI Bahamas is Now Offering Pink Sheet Clearance
+Offshore Broker Adds to Buying and Selling Services
+www.pr.com
+https://www.pr.com/press-release/369649
+GGSI Bahamas Provides State-of-the-Art Security for OTC PINK Transactions
+and Communication
+GGSI (Gibraltar Global Securities Inc.) has just announced the release of their latest security measures
+designed to protect their client&rsquo;s personal data, and to secure electronic communication.
+www.pr.com
+The SEC KNEW the Gibraltar/Opco trading activity went well beyond 2011 YET cut off its investigation at "well
+into 2010". Thus, KNOWINGLY omitting material information in Gibraltar: FRAUD ON THE COURT.
+Confirming my allegations of SEC criminal activity in handling my information. WHY? to protect NITE and UBSS.
+2 criminal entities bailed out by the SEC.
+Now, the SEC is using the completely fabricated reason for denying my award claim for covered action 2015-
+016: "The investigators never saw the claimants information".
+WHEN the explicit and exclusive responsibility to distribute whistleblower information within the SEC falls on
+the OWB itself.
+More criminal activity.
+Criminals bailing out criminals while denying Whistleblowers due process and compensation.
+Cheers!
+EFTA00069032
+
+Christopher J Dilorio
+Whistleblower
+From: Chris Dilorio 4
+Sent: Sunday, April 26, 2020 9:36 AM
+Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
+From: Chris Dilorio «
+Sent: Fridav, April 24, 2020 8:18 AM
+Subject: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
+I am in receipt of the SEC preliminary denial of my award claim for the Oppenheimer AML covered action 2015-
+016
+This is my formal appeal of the SEC preliminary determination.
+My award application was based on this very simple FACT:
+The SEC (and FINCEN) Oppenheimer AML actions were based on the FINRA Oppenheimer AML action
+FINRA
+https://www.finra.org/sites/default/files/fda_documents/2009018668801_FDA_KMX39652.pdf
+of - FINRA
+which isFINRA a party, to the entry of findings and violations consistent with the allegations of the
+(as Complaint sanctions amended andby the Offer of Settlement), to the imposition of the set forth
+andbelow, understands fully that this Order will become part ofRespondent's permanent disciplinary
+andrecord may anybe considered in future actions brought by FINRA. BACKGROUND ...
+www.finra.org
+The SEC
+https://www.sec.gov/litigation/admin/2015/33-9711.pdf
+Before the SECURITIES AND EXCHANGE COMMISSION
+Before the . SECURITIES AND EXCHANGE COMMISSION . SECURITIES ACT OF 1933 . Release No. 9711 /
+January 27, 2015 . SECURITIES EXCHANGE ACT O F 1934 . Release No. 74141 / January 27, 2015 .
+ACCOUNTING AND AUDITING ENFORCEMENT . Release No. 3621 / January 27, 2015 . ADMINISTRATIVE
+PROCEEDING . File No. 3 -16361 . In the Matter of
+EFTA00069033
+
+www.sec.gov
+FINCEN
+money-laundering
+https://www.fincen.gov/news/news-releases/fincen-fines-oppenheimer-co-inc-20-million-continued-anti-
+FinCEN Fines Oppenheimer & Co. Inc. $20 Million for Continued Anti-
+Money Laundering Shortfalls | FinCEN.gov
+Washington, D.C. - The Financial Crimes Enforcement Network (FinCEN), working closely with the U.S.
+Securities and Exchange Commission (SEC), assessed a $20 million civil money penalty today against
+Oppenheimer & Co., Inc., for willfully violating the Bank Secrecy Act (BSA). Oppenheimer, a securities
+broker-dealer in New York, admitted that it failed to establish and implement an adequate ....
+www.fincen.gov
+In the summer of 2012, I had extensive correspondence with Robin Traxler at FINRA where I also co'd Sean
+McKessy then SEC OWB Chief. The CURRENT OWB Chief and the SEC IG are in possession of this
+correspondence. My correspondence dealt with 2 penny stock shells cited in my Knight Capital TCR submitted
+by Berger Montague in March 2013 attached here: Colorado Goldfields and AppTech. Both shells were NITE and
+UBSS top traded OTCM shells in 2010-2013. These 2 shells were cited by FINRA in their Oppenheimer AML
+complaint. Again, the SEC and FINCEN Oppenheimer AML complaints were based on this FINRA complaint. In
+fact, per the FINRA Opco complaint above, customer "C" was dumping worthless AppTech (APCX) certificates
+well into mid 2010. DIRECTLY overlapping with the NITE/UBSS APCX trading activity cited in my Berger 2013 TCR
+attached and discussed by me with Robin Traxler at FINRA. HOW is it possible that the SEC OWB didn't share
+my information with SEC investigators? Current SEC OWB Chief Norberg was previously an assistant to then
+OWB Chief McKessy.
+WHO ultimately executed the trades cited in the FINRA Opco complaint?
+Further, the SEC Gibraltar Securities complaint raises more questions than answers as well.
+https://www.sec.gov/litigation/complaints/2013/comp22683.pdf
+UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+SECURITIES AND EXCHANGE COMMISSION, 13 Civ. GffiRALTAR GLOBAL
+SECURITIES, COMPLAINT NATURE OF THE ACTION - SEC.gov
+12. David Della Sciucca, Jr., age 27, is a resident of Fort Lauderdale, Florida. In . the Magnum d'Or
+complaint, the Commission charged Della Sciucca with acting as a nominee
+www.sec.gov
+The SEC Gibraltar Securities complaint references only 1 OTCM money laundering shell: Magnum d'Or. The
+complaint specifically states that Oppenheimer sold just 969,822 shares. Again, no mention of executing
+BD/MM.
+The SEC Oppenheimer AML cites Gibraltar trading activity also.
+The share amounts in the SEC complaint grossly under estimate that in the FINRA complaint. WHY?
+EFTA00069034
+
+The judge in the Gibraltar case said "the SEC's requested amount CLEARLY UNDERESTIMATES the defendants ill-
+gotten gains...."
+http://www.tribune242.com/news/2016/jan/13/bahamian-broker-25m-sanction/
+Bahamian broker in $25m sanction The Tribune
+A former Bahamian broker/dealer and its principal have been hit with a combined $24.484 million in
+financial sanctions by a US court, which found that their "ill gotten gains" were likely ...
+www.tribune242.com
+WHY didn't the SEC go after ALL of the sellers in the FINRA Opco AML complaint? WHY did the SEC "strip out"
+$46 million from the Gibraltar ill gotten gains claiming the customers were "UNKNOWN"? WHO is the SEC
+protecting? WHO were the executing BD's/MM's in the FINRA Opco CGFIA and APCX trades? They certainly
+know who the customers were. Is customer "JK" Justin Keener/JMJ also in my March 2013 TCR attached? While
+the SEC Opco AML was based on the FINRA Opco AML, it stopped short of a thorough investigation of NITE and
+UBSS. In fact, the trading activity of NITE/VIRT and UBSS in the FINRA complaint: my information SHOULD have
+triggered an immediate investigation of NITE and UBSS. It did not. Did the SEC commit fraud on the court in its
+OMISSION of material information?
+The timing of the SEC's preliminary determination and the reasoning for the denial ALSO raises more questions
+than answers.
+My Award application for the Oppenheimer AML SEC complaint was 5 years ago. That's FIVE years ago. So, WHY
+NOW am I so blessed by the SEC with a preliminary judgement?
+The SEC basis for denying my Award claim for covered action 2015-016:
+"Investigative staff responsible for the covered action NEVER RECEIVED ANY INFORMATION FROM THE
+CLAIMANT OR had any communication with the claimant"
+Let's take this whopper in 2 parts:
+First, the SEC OWB denied my Award application because The investigators in the complaint never received my
+information. Has the SEC OWB re written the investigative protocol in this denial? How am I or ANY
+whistleblower supposed to know WHO the investigators are in a particular case WHEN according to the SEC:
+ALL investigations are done in a confidential manner????
+WHAT DOES THE SEC DO WITH WHISTLEBLOWER TIPS EXACTLY? Do they share whistleblower information with
+ENFORCEMENT as is mandated? HOW would ANY whistleblower know WHO to share information with at the
+SEC? Isn't that the job of the SEC OWB?
+Second, the fact that no one at the SEC contacted me DOES NOT mean the SEC didn't use my information. This
+is a completely bogus argument. It certainly would NOT be the first time the SEC used my information now
+would it Jane?
+In fact, it is NOT the responsibility of the whistleblower to get his/her information to the right Enforcement
+personnel. That responsibility EXPLICITLY falls on the SEC OWB. So, is the SEC OWB admitting gross negligence
+in handling my information? After the monumental failure in the Madoff Ponzi/ money laundering SEC
+facilitated scam on the public the then SEC IG made specific recommendations to the SEC with regards to the
+proper handling/vetting of Tips and Complaints.
+https://www.sec.gov/files/468.pdf
+EFTA00069035
+
+Review and Analysis of OCIE Examinations of Bernard L. Madoff Investment
+Securities, LLC
+Review and Analysis of OCIE Examinations of Bernard L. Madoff Investment Securities, LLC Executive
+Summary Background. On June 25, 2009, the Securities and Exchange Commission's
+www.sec.gov
+AGAIN: The responsibility to properly vet Whistleblower information and get the information into the right
+hands at the SEC falls EXPLICITLY and EXCLUSIVELY with the SEC OWB itself and is NOT the responsibility of the
+whistleblower. Further, according to the previous SEC IG in the monumental Madoff failure: the responsibility
+to contact those supplying Tips and Complaints ALSO falls explicitly and exclusively with the SEC OWB and not
+the whistleblower. Using these excuses as the basis of denial of Award is completely contrary to SEC
+MANDATED protocols and procedures.
+Is the SEC OWB admitting it doesn't comply with those recommendations? Recall: the monumental SEC Madoff
+failure was NOT the fault of Whistleblowers either. OR is the SEC OWB scrambling for a 5 years in the waiting
+preliminary determination?
+So, after 5 years of waiting for a preliminary determination for my award claim, this is what the SEC best and
+brightest come up with?
+My Denial of Award for covered action 2015-016 was completely made up on the fly.
+The SEC OWB has applied completely fabricated "rules" to issue this denial. Further affirmation of ALL of my
+allegations.
+Also by SEC admission, the SEC allowed these 2 penny stock shells to remain a clear and present risk to the
+investing public. Were CGFIA and APCX ONLY money laundering shells for Oppenheimer in 2008-2010 and then
+suddenly they were no longer money laundering shells when NITE and UBSS traded billions of shares of both
+shells 2010-2013?
+WHY did it take until September 2018 before the SEC finally revoked the CGFIA registration?
+https://www.sec.gov/cgi-bin/browse-edgar?company=Garpa&owner=exclude&action=getcompany.
+So, WHY was there no SEC investigation of NITE and UBSS trading activity in money laundering shells APCX and
+CGFIA? The SEC et al facilitated NITE "glitch" took place in August 2012. This SEC/Jefferies/JPM/BX/GS/SEC Chair
+Clayton Sullivan Cromwell colleague Jared Fishman et al bailout coincides directly with NITE trading activity in 2
+SEC/FINRA/FINCEN acknowledged money laundering shells. AND the "bailout" penny stock esque reverse
+merger between Getco and Knight didn't close until July 2013. HOW could the SEC conduct a COMPLETE and
+thorough investigation into the FINRA Opco AML complaint WITHOUT implicating NITE when NITE was CLEARLY
+trading billions of shares of OTCM money laundering shells BEFORE and coinciding with the SEC et al facilitated
+"glitch" bailout? For UBSS, the DOJ dropped its cross border AML DPA complaint in 2010. UBSS was trading
+money laundering shells well after the DOJ claimed UBSS was in compliance with the cross border DPA.
+To be clear: BOTH NITE and UBSS knew CGFIA and APCX were money laundering shells when they traded
+billions of shares of each 2010-2013. Is that FACT disputed by the SEC? The SEC OBSTRUCTED a thorough
+investigation into the ENTIRETY of trading activity of NITE and UBSS in CGFIA and APCX: MY CLAIMS. Josh
+Sason/Hanover/ Magna knew CGFIA was a money laundering shell also
+https://www.sec.gov/Archives/edgar/data/1344394/000114420413041432/0001144204-13-041432-index.htm
+ALSO in my claims: Joshua Sason/Hanover Magna. CGFIA. Also my NewLead TCR1426518350699 and FreeSeas
+TCR1440274395191 separate but related TCR's where NITE was a top trader in both and BOTH TCR's were filed
+well in advance (years prior) to the Sason/Hanover/Magna February 2019 complaint. Here's one thing the SEC
+EFTA00069036
+
+has been consistent about: The SEC ignores the role of executing BD's and MM's in these scams. WHY? Because
+NITE is the #1 OTCM shell trader. As far as the SEC is concerned Penny stock trading fairies convert worthless
+certificates into real money. NO! Executing BD's/MM's like NITE do. Did Oppenheimer sell this order flow to
+NITE? Who ultimately converted these worthless certificates to real money? As the number 1 OTCM money
+laundering shell trader it is statistically improbable the NITE has never been the focus of an SEC AML complaint.
+Per my TCR: what does the NITE Compliance Department do exactly? How many SAR's has NITE filed in the last
+10 years? In a 2015 SIFMA speech then SEC Enforcement Director Ceresney was "SHOCKED" by the number of
+BD's filing 1 or ZERO SAR's. That was just 5 years ago. WHEN would NITE file a SAR releted to the billions of
+shares of OTCM money laundering shells it trades like CGFIA and APCX: BEFORE or AFTER it trades those
+BILLIONS of shares?Does NITE pull markets and alert regulators OR continue to trade billions of shares of OTCM
+money laundering shells in the face of GLARING AML red flags? In fact, in December 2019 the top traded
+NITE/VIRT OTCM money laundering shell was ELTZ
+https://www.sec.gov/cgi-bin/browse-edgar?
+action getcompany&CIK=0001607281&owner=exclude&count=40&hidefilings=0
+The SEC knows the people/entities in ELTZ well
+https://www.sec.gov/litigation/admin/34-46993.htm
+Strata Coal Company and Terrence A. Tecco: Admin. Proc. Rel. No. 34-
+46993 / December 13, 2002
+Strata Coal Company ("Strata" or "the company") is a non-reporting Nevada shell corporation based in
+Frisco, Texas. Strata's shares are quoted on the Pink Sheets under the symbol SCOC. Until September
+2002, the company was known as WesPac Technologies, at which time it changed its name to Strata. 2.
+Tecco is the sole officer, director, and ...
+www.sec.gov
+https://www.sec.gov/news/press-release/2019-16
+SEC.gov | SEC Charges Broker-Dealer and Transfer Agent in Microcap Shell
+Factory Fraud
+The Securities and Exchange Commission today announced charges against a broker-dealer, a transfer
+agent, and three individuals for their roles in the creation of over a dozen undisclosed "blank check"
+companies from 2009 to 2014.
+www.sec.gov
+Doesn't the NITE/VIRT compliance Department have internet service in Jersey City? As a DIRECT result of the
+SEC obstructing a complete and thorough investigation into the ENTIRETY of trading activity in APCX and CGFIA,
+the top NITE/VIRT traded OTCM money laundering shell in December 2019 was AML red flags galore ELTZ.
+Illegal activity ACTIVELY facilitated by the SEC. The examples cited in this e mail are not exhaustive.
+And, for it's part AppTech is up and running again/still
+https://www.sec.gov/cgi-bin/browse-edgar?company=Apptech&owner=exclude&action=getcompany
+EFTA00069037
+
+Unfortunately, AppTech is still up and running as a direct result of the aforementioned SEC " CLEARLY under
+estimating" otherwise known as CLEARLY OBSTRUCTING.
+In conclusion, The SEC solicits information from whistleblowers like me. The SEC uses whistleblower information
+to bring actions and then doesn't compensate whistleblowers for their information.
+OR
+The SEC uses whistleblower information to protect criminality perpetrated on the investing public so that this
+criminal activity can continue. BOTH are gross dereliction of the stated and MANDATED SEC Whistleblower
+statutes. To blame a whistleblower for the SEC's EXPLICIT and EXCLUSIVE responsibility to properly vet and
+distribute whistleblower information within the SEC as an excuse to deny Awards is also criminal activity. The
+SEC: criminals using whistleblower information to protect other criminals AND deny whistleblower rightful
+compensation for their information.
+I appeal the SEC preliminary determination and wish to file ANOTHER complaint with the SEC IG.
+Cheers!
+Christopher J Dilorio
+Janey,
+how long have you been in possession of my Knight Capital TCR? Almost 7 years to the day. How many follow up
+e mails have I sent the SEC since then?
+For 7 fucking years, the SEC has known about JMJ/Keener. I told them
+https://www.sec.gov/litigation/complaints/2020/comp-pr2020-72.pdf
+IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT
+OF FLORIDA SECURITIES AND EXCHANGE COMMISSION No. COMPLAINT
+SUMMARY - sec.gov
+5. Justin W. Keener, age 45, resides in San Juan, Puerto Rico.During the Relevant Period, Keener was a
+resident of Miami Beach, Florida. Keener registered the name "JMJ Financial" as a fictitious name in Florida
+in 2008 and used it to conduct the business described
+www.sec.gov
+In February 2019, the SEC brought an action against Joshua Sason/NewLead
+I told the SEC about Magna/ Sason ALSO in my 2013 TCR.
+https://www.sec.gov/litigation/litreleases/2019/lr24403.htm
+Joshua Sason, et al. (Release No. LR-24403; Feb. 15, 2019)
+EFTA00069038
+
+Washington, D.C., February 15, 2019 - The Securities and Exchange Commission today announced charges
+against four individuals and related businesses for their roles in two microcap frauds and unlawful
+securities offerings.
+www.sec.gov
+AND, I filed separate but related NewLead and FreeSeas TCR's in 2015
+Then there's the UBS AML complaint.
+ALSO my claims. For which I sent 10 (TEN) separate Award applications from a commercial fax machine in
+April/May 2019. AND I have YET to receive even a preliminary determination from the OWB/Norberg
+IG, I see your "investigation" into my very very serious accusations of Obstruction related to my information was
+thorough. In short, the SEC has and still is ripping me off.
+Janey, be a hun and update my TCR's/Awards cited in this e mail.
+And Ms Welshhans, a couple of questions for you:
+1) Have you read the FINRA WTFC Keener complaint? Fictitious notes Ring a bell?
+Same MO as Sason/Magna/NewLead/FreeSeas etc etc etc
+2) WHO executed the Keener OTCM trades in your complaint? Penny stock trading fairies?
+YES, NITE was a top trader in BOTH FreeSeas and NewLead
+The core business at NITE/VIRT is and ALWAYS has been: abusive naked shorting OTCM (and other) shells to
+facilitate money laundering.
+In short Ms Welshhans, NITE/VIRT converts these worthless certs into real money. NONE of
+JMJ/Sason/IBC/Ironridge/Asher etc etc etc activity takes place without a willing, corrupt, criminal, executing
+BD/MM like NITE/VIRT, CDEL etc
+Finally, The Keener SEC complaint is FURTHER evidence that FINRA has NO business enforcing US securities
+LAWS. When FINRA "invited" Keener to a disciplinary hearing almost 7 years ago, Keener told them to "fuck
+off". FINRA bar meant nothing the last 7 years. EXCEPT JMJ/Keener/NITE ripping off more investors.
+Obviously the SEC has/is using my information. I expect to be compensated.
+Cheers!
+Christopher Dilorio
+Whistleblower
+Mr Peirce,
+Congratulations on your nomination as SEC Commissioner. I have read your paper on FINRA lack of
+accountability. I believe the SEC has abdicated its responsibility to enforce Broker Dealer compliance with the
+BSA to FINRA BECAUSE it is not accountable. The SEC has not initiated a single stand alone AML complaint.
+The Brown Brothers Harriman AML complaint IS my claim. ALL of the entities in the complaint are un named
+WHY? My SEC and IRS Whistleblower complaints explain why.
+Hello, My name is Chris Dilorio. I have filed extensive SEC and IRS Whistleblower complaints alleging a direct
+link between penny stock money laundering, domestic and foreign entities, Swiss Banks, and executing brokers
+like KCG and UBS. I can provide overwhelming evidence of SEC obstruction. Please read the FINRA Brown
+Brothers Harriman AML complaint. This is my claim. All of the entities in the complaint are un named. Why?
+The SEC is not only obstrueting an investigation, they are aiding and abetting the activity. These are not far flung
+EFTA00069039
+
+theories. The UBS Whistleblower Birkenfeld and his attorney sent 52,000 accounts to the SEC and DOJ. The
+DOJ at the influence of President Obama and Hillary Clinton entered into the UBS DPA based on just 4400.
+What is so egregious is the activity continues un abated today.
+Start with the so calledAugust 2012 Knight/KCG trading "glitch". Initial reports say the NYSE was breaking the
+trades. WHY did they stop. Former KCG CEO Joyce said he had a very frank discussion with then SEC Chair
+Schapiro where the SEC wanted to send a very strong message to market participants. Why not just continue to
+break the trades and hit KCG with a hefty fine? That would not create the conditions to grant KCG exception
+after exception to do their emergency funding which transferred 74% of the company to "glitch" funding
+participants and ultimate reverse merger partner GETCO. AND, despite claiming to having a "highly liquid
+balance sheet" KCG had to raise the entire amount of the loss.
+A very significant and public event was cited in a WSJ article where immediately following the "glitch"KCG
+inadvertently sent 4000 worthless securities to JPM in an attempt to secure a tri party financing where JPM
+guaranteed the loan. This is discussed in my attached TCR's and also the topic in a March 2014 letter I sent to the
+SEC. In the end, the emergency funding was NOT collateral based. The participants knew exactly what a fraud
+the KCG balance sheet was. After the stock was decimated to $3, the deal was a convertible with a conversion
+price at a 50% discount or $1.50/ share.
+There is much more, but this is a good start.
+Recently, KCG did a modified Dutch auction where they "sold" an asset (HotSpot) to an entity both KCG and
+GETCO were a major shareholder (BATS) KCG CEO Coleman called it a "highly competitive process".
+Virtually all of the proceeds went to buy back stock from "glitch" financing participants. The purchase price was
+$14/share. The stock had never traded there and hasn't since. Reports say 82 million shares were tendered at or
+BELOW $14. But they chose to repurchase 23 million shares AT $14?272? I have overwhelming evidence that
+supports my allegations that the SEC is engaging in criminal obstruction to protect KCG.
+1) Current KCG Dan Coleman ran Equities at UBS during the massive REG Sho violations as well as the cross
+border activity detailed by Whistleblower Birkenfeld. White and Ceresney represented UBS prior to joining the
+2) At June 30 2011 KCG/Knight reported just 105 million in working capital with hundreds of millions in
+worthless securities sitting on its balance sheet. KCG was insolvent
+3) The SEC orchestrated the emergency funding for KCG following the so called Aug 2012 trading "glitch"
+4) Read FINRA AML complaints against Brown Brothers Harriman. This is my claim. It links penny stock
+money laundering to executing brokers like KCG, domestic and foreign entities, and Swiss banks. ALL of the
+entities in the complaint are un named. WHY?
+5) The FINRA World Trade Financial AML complaint discusses several entities cited in my claims. The
+customer the complaint focuses on is Justin Keener. Still very much in business. The red flags cited by FINRA
+were cited in my claims as well. Yet still no investigation.
+6) in July 2015 1 contacted Kevin Goodman Dir OCIE for Broker Dealsat the SEC. He had never seen my
+information. The IG OCIE Madoff report mandated the OCIE to vet information. McKessy and Ceresney never
+sent my info to him
+7) I'm sure you are familiar with the Manning v Merrill,KCG,UBS et al litigation. The SEC does not want an
+investigation into my claims while the litigation is pending.
+8) My claims detail ex clearing trading activity by KCG and UBS. despite the glaring red flags in doing so. Ex
+clearing s the Obligation Warehouse. A NON GUARANTEED SERVICE set up by the SEC and DTCC to allow
+firms like KCG to circumvent close out requirements of Rule 204. Clearly contrary to the intent of the SEC
+authorization in Sec 17a of the 1934 Act to create a system of prompt and timely settlement and to remove
+impediments there of.
+In short, I told the SEC KCG was insolvent in 2011. Rather than investigate and prosecute, they chose to
+obstruct. The activity in my TCR's pre dates the "glitch". An investigation would show the SEC bailed out a
+criminal enterprise. Because of the obstruction, the activity continues today unabated in stocks like
+STBV, VELA,NEWL,FREE, and dozens more. The investing public remains at risk
+More to come
+Chris Dilorio
+EFTA00069040
+
+EFTA00069041

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+09/21/2021 11:25 EDT
+Last Name
+EPSTEIN
+Document Number
+Encounter Line Type
+AIRLINE (NOT API)
+Inbound/Outbound
+INBOUND
+Manifest Indicator
+N
+Transmitted By
+First Name
+JEFFREY
+Document Type
+PASSPORT
+Encounter Date
+12/11/1999
+Inspector
+Passenger Status
+U.S. Customs and Border Protection
+U.S. Department of Homeland Security
+Person Encounter Detail
+Generated By:
+Encounter Person Detail
+Middle Initial
+Document Country
+UNITED STATES
+Encounter Person Detail
+Encounter Time (Eastern)
+17:09
+Processing Result
+Manifest Data
+Updated Passenger Status
+Gender
+Class of Admission
+Terminal Lane
+QB02
+Primary Query Result
+Flight/Vessel Number
+1
+Carrier Code
+PV
+Arrival Location
+For Official Use Only / Law Enforcement Sensitive
+Page 1 of 1
+Date of Birth
+Admit Until Date
+Site/Encounter Location
+A511 - CBP-CYRIL E
+KING, INTL AIRPORT
+Referred To Agency
+NOT REFERRED
+Departure Location
+EFTA00075858